Alhambra City Council Agenda 2/27/17

COMMENTS & RESPONSES TO COMMENTS MITIGATED NEGATIVE DECLARATION & INITIAL STUDY
ALHAMBRA COURT COMMERCIAL DEVELOPMENT TENTATIVE TRACT MAP (TTM 74223) AND INDUSTRIAL PLANNED
DEVELOPMENT PERMIT (IP-16-4) 875 SOUTH FREMONT AVENUE AND 1111 SOUTH FREMONT AVENUE
COMPLETE COMPILATION OF COMMENTS AND

RESPONSE TO COMMENTS FOR THE
ALHAMBRA COURT COMMERCIAL
DEVELOPMENT
THIS DOCUMENT IS A COMPLETE COMPILATION OF COMMENTS

AND THE RESPONSE TO COMMENTS FOR THE ALHAMBRA COURT
COMMERCIAL DEVELOPMENT. THIS COMPLETE COMPILATION
CONSISTS OF THREE PARTS.
PART 1 CONSISTS OF COMMENTS THAT WERE RECEIVED

PRIOR TO THE PLANNING COMMISSION MEETING THAT WAS
HELD ON JANUARY 17, 2017.
PART 2 CONSISTS OF COMMENTS THAT WERE RECEIVED TOO

LATE TO BE INCORPORATED INTO PART 1 AND COMMENTS
THAT WERE RECEIVED AFTER THE PLANNING COMMISSION
MEETING.
PART 3 CONSISTS OF THE MAJORITY OF THE COMMENTS

THAT WERE RECEIVED AFTER THE PLANNING COMMISSION
MEETING.
THE ENTIRE PACKAGE IS INCLUDED FOR THE RECORD.
COMMENTS & RESPONSE TO COMMENTS PART I PAGE 1

THIS PAGE HAS BEEN INTENTIONALLY LEFT BLANK.

TABLE OF CONTENTS
Section Page
1. Part 1 ..............................................................................................................................5
2. Part 2 ...........................................................................................................................123
3. Part 3 ...........................................................................................................................179


PART I
COMMENTS & RESPONSES TO COMMENTS
FOR THE
MITIGATED NEGATIVE DECLARATION
& INITIAL STUDY
ALHAMBRA COURT COMMERCIAL DEVELOPMENT

TENTATIVE TRACT MAP (TTM 74223) AND INDUSTRIAL
PLANNED DEVELOPMENT PERMIT IP-16-4
875 & 1111 SOUTH FREMONT AVENUE
ALHAMBRA, CALIFORNIA 91803
LEAD AGENCY:
CITY OF ALHAMBRA
DEVELOPMENT SERVICES DEPARTMENT
111 SOUTH FIRST STREET
REPORT PREPARED BY:
BLODGETT BAYLOSIS ENVIRONMENTAL PLANNING
16388 E. COLIMA ROAD, SUITE 206J
HACIENDA HEIGHTS, CALIFORNIA 91745
JANUARY 11, 2017

ALHM 001


TABLE OF CONTENTS
Section Page
1. Comments and Response to Comments..................................................................................9
2. Community Meeting Comments and Responses.................................................................... 113
3. Comments and Responses to E-mails that were Received ....................................................... 117


1. COMMENTS AND RESPONSES TO COMMENTS

The City of Alhambra oversaw the preparation of an Initial Study that evaluated the environmental impacts
associated with the construction of a 111,257 square-foot Lowes home improvement store and a 23,160
square foot garden center; a six-level parking structure; and two, six-story office buildings (referred to
herein as Building 1 and Building 2) that will have a combined floor area of approximately 245,400 square
feet. The westernmost six-story office building (Building 1) will have a total floor area of 143,400 square
feet. The easternmost six-story office building (Building 2) will have a total floor area of 102,000 square
feet. The six-level above-ground parking structure will be located between the Lowes and Building 1. The
proposed project site has a total land area of 12.66 acres. Access to the project site from Fremont Avenue
will be provided by four driveways located on the west side of Fremont Avenue and four driveways along the
east side of Meridian Avenue.
The City circulated the Mitigated Negative Declaration and Initial Study for a 30-day review period.
Comment letters to date, were received from the following agencies at the conclusion of the review period:
Letter Dated December 22, 2016

Gayle Totton, Associate Governmental Project Analyst
State of California Native American Heritage Commission
Letter Dated December 29, 2016

Lenny Siegel, Executive Director
Center for Public Environmental Oversight
Letter Dated January 3, 2017

Dianna Watson, Branch Chief
State of California Department of Transportation

Mark Licker
Resident of the City of Alhambra

May Jong

Eric Sunada
(two letters are attached)

In addition to the above written comments received following the IS/MNDs circulation, there were
comments made by those in attendance at the Community Meeting that was held on December 13, 2016.
The purpose of this meeting was to provide information to local residents regarding the proposed project
and the environmental review process. This Community Meeting was sponsored by the project Applicant
that was a City requirement. The public comments and the project teams responses are included at the end
of this section.

Comment Letter Dated December 22, 2016

Gayle Totton, Associate Governmental Project Analyst
State of California
Native American Heritage Commission
Comment 1.
The Native American Heritage Commission (NAHC) has reviewed the Mitigated Negative Declaration
prepared for the project referenced above. The review included the Project Description/Introduction, the
Environmental Analysis Section 3.5, Cultural Resources, and the proposed Mitigation Measures prepared
by Blodgett Baylosis Environmental Planning for the City of Alhambra. We have the following concerns:
There is no Tribal Cultural Resources section or subsection in the Environmental Checklist or

Cultural Resources Mitigation as per California Natural Resources Agency (2016) "Final Text for
tribal cultural resources update to Appendix G: Environmental Checklist Form,"
http://resources.ca.gov/ceqa/docs/ab52/Clean-final-AB-52-App-G-text Submitted.pdf.
There are no mitigation measures specifically addressing Tribal Cultural Resources separately.
Mitigation measures must take Tribal Cultural Resources into consideration as required under AB-
52, with or without consultation occurring. Mitigation for archaeological resources is not always
appropriate for, or similar to, measures specifically for cultural resources.
Mitigation for inadvertent finds of human remains is incomplete or inaccurate. The use of a monitor
does not replace the process of finding a Most Likely Descendent (MLD) for the site, as monitors are
not named the MLD for the project.
Response 1.
Formal Native American consultation, provided in accordance with AB-52, did occur. AB-52 consultation
letters were mailed to a total of six tribes, including the different Gabrieleo subsets and the Soboba tribe.
The specific tribal contacts included the following:
Linda Candelaria, Co-Chairperson, Gabrielino-Tongva Tribe;
Anthony Morales, Chairperson, Gabrieleno/Tongva San Gabriel Band of Mission Indians;
Robert F. Dorame, Tribal Chair/Cultural Resources, Gabrielino Tongva Indians of California Tribal
Council;
Joseph Ontiveros, Cultural Resource Director, Soboba Band of Luiseno Indians;
Andrew Salas, Chairman, Gabrieleno Band of Mission Indians Kizh Nation; and,
Sam Dunlap, Cultural Resources Director, Gabrielino/Tongva Nation.
Only one of the aforementioned tribes responded. The tribal representative of the Gabrielino-Kizh
indicated that the project site is situated in an area of high archaeological significance. The following

information was provided by the Gabrieleo-Kizh that responded to the consultation request. The San
Gabriel Valley (and the greater Los Angeles Basin) was previously inhabited by the Gabrieleo-Kizh people,
named after the San Gabriel Mission. The Gabrieleo-Kizh tribe has lived in this region for around 7,000
years. Before European contact, approximately 5,000 Gabrieleo-Kizh people lived in villages throughout
the Los Angeles Basin. Archaeological sites are often located along creek areas, ridgelines, and vistas.
Villages were typically located near major rivers such as the San Gabriel, Rio Hondo, or Los Angeles Rivers.
While no major coastal rivers traverse the City, Alhambras proximity to other known village sites
throughout the San Gabriel Valley make it likely that Native Americans either lived or traveled through the
City. This information was included in Section 3.5.2.B of the IS/MND.
The new requirements cited above came into affect prior to the publication of the new CEQA Guidelines.
On June 3, 2016, the California Natural Resources Agency released a revised proposal to update Appendix G
of the CEQA Guidelines related to tribal cultural resources. The official comment period was June 6, 2016-
to June 21, 2016 on the draft recommendation. Tribal Resource is defined in Public Resources Code section
21074 and includes the following:
Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a
California Native American tribe that are either of the following: included or determined to be
eligible for inclusion in the California Register of Historical Resources or included in a local register
of historical resources as defined in subdivision (k) of Section 5020.1.
A resource determined by the lead agency, in its discretion and supported by substantial evidence,
to be significant pursuant to criteria set forth in subdivision (c) of Section 5024.1. In applying the
criteria set forth in subdivision (c) of Section 5024.1 for the purposes of this paragraph, the lead
agency shall consider the significance of the resource to a California Native American tribe.
A cultural landscape that meets the criteria of subdivision (a) is a tribal cultural resource to the
extent that the landscape is geographically defined in terms of the size and scope of the landscape.
A historical resource described in Section 21084.1, a unique archaeological resource as defined in

subdivision (g) of Section 21083.2, or a non-unique archaeological resource as defined in
subdivision (h) of Section 21083.2 may also be a tribal cultural resource if it conforms with the
criteria of subdivision (a).
The IS/MND indicated the project site does not fall into any of the aforementioned criteria. Nevertheless,
the tribal contact recommended mitigation that should be implemented to address the procedures that must
be adhered to in the event cultural resources are encountered.
Comment 2.
The California Environmental Quality Act (CEQA)1, specifically Public Resources Code section 21084.1,
states that a project that may cause a substantial adverse change in the significance of a historical resource
is a project that may have a significant effect on the environment.2 If there is substantial evidence, in light of
the whole record before a lead agency, that a project may have a significant effect on the environment, an
environmental impact report (EIR) shall be prepared.3 In order to determine whether a project will cause a

substantial adverse change in the significance of a historical resource, a lead agency will need to determine
whether there are historical resources with the area of project effect (APE).
Response 2.
The IS/MND indicates that no significant adverse impacts on cultural resources will result from the
proposed projects implementation. As indicated in Section 3.5.2.A of the IS/MND, the project site was
originally developed between 1925 and 1928 with seven industrial structures used by Reliance Foundry,
Crown Pattern Works, Wintroath Pumping Company, and Cal Tuf Glass as a steel foundry, aluminum
foundry, machine shops, and glass manufacturing/assembly, respectively. These businesses occupied the
property until International Extrusion Corporation (IEC) took occupancy of the facility in 1963. From IECs
initial occupancy in 1963 up until the facilitys closure in July 2009, IEC conducted melting and re-melting,
casting, extruding, and finishing of aluminum alloys. The IECs operations were discontinued in July 2009
and all of the on-site improvements were razed by 2013. The site is largely undeveloped and contains no
historic resources, no impacts will result from the projects implementation.
Comment 3.
CEQA was amended in 2014 by Assembly Bill 52. (AB 52). AB 52 applies to any project for which a
notice of preparation or a notice of negative declaration or mitigated negative declaration is filed on
or after July 1, 2015. AB 52 created a separate category for "tribal cultural resources" that now includes "a
project with an effect that may cause a substantial adverse change in the significance of a tribal cultural
resource is a project that may have a significant effect on the environment.6 Public agencies shall, when
feasible, avoid damaging effects to any tribal cultural resource. Your project may also be subject to
Senate Bill 18 (SB 18) (Burton, Chapter 905, Statutes of 2004), Government Code 65352.3, if it also involves
the adoption of or amendment to a general plan or a specific plan, or the designation or proposed
designation of open space. Both SB 18 and AB 52 have tribal consultation requirements. Additionally, if
your project is also subject to the federal National Environmental Policy Act (42 U.S.C. 4321 et seq.)
(NEPA), the tribal consultation requirements of Section 106 of the National Historic Preservation Act of
1966 may also apply.
Response 3.
Please refer to Response 1. As indicated in the IS/MND (refer to Section 2.6), the proposed projects
implementation will not involve or require a zone change or general plan amendment. As a result, SB 18
will not apply. Finally, the proposed project is not subject to NEPA.
Comment 4.
Consult your legal counsel about compliance with AB 52 and SB 18 as well as compliance with any other
applicable laws.
Response 4.
Please refer to Response 3.

Comment 5.
Agencies should be aware that AB 52 does not preclude agencies from initiating tribal consultation with
tribes that are traditionally and culturally affiliated with their jurisdictions before the timeframes provided in
AB 52. For that reason, we urge you to continue to request Native American Tribal Consultation Lists and
Sacred Lands File searches from the NAHC. The request forms can be found online at:
http://nahc.ca:gov/resources/forms/. Additional information regarding AB 52 can be found online at
http://nahc.ca.gov/wp-content/uploads/2015/10/AB52Tribal Consultationi_CalEPAPDF.pdf, entitled
"Tribal Consultation Under AB 52: Requirements and Best Practices".
Response 5.
Thank you for the above comment. The Lead Agency will continue to cooperate with responsible and
trustee where appropriate.
Comment 6.
The NAHC recommends lead agencies consult with all California Native American tribes that are
traditionally and culturally affiliated with the geographic area of your proposed project as early as
possible in order to avoid inadvertent discoveries of Native American human remains and best protect tribal
cultural resources. A brief summary of portions of AB 52 and SB 18 as well as the NAHC's
recommendations for conducting cultural resources assessments is also attached.
Response 6.
Thank you for the above comment. The Lead Agency will continue to cooperate with responsible and
trustee where appropriate.







Lenny Siegel, Executive Director
Center for Public Environmental Oversight
Comment 1.
I appreciate the opportunity to comment on the draft Mitigated Negative Declaration and Initial Study for
the proposed development at 875 and 1111 South Fremont Avenue, in Alhambra. I have been asked to
review this document by the San Gabriel Valley Oversight Group. This document provides the city with
the opportunity to ensure that new buildings on the property will be safe for future occupants. As a local
elected official myself, it gives me comfort to know that my city (Mountain View, California) has the
authority, will, and knowledge to require "soil-gas safe" construction on our contaminated properties.
Response 1.
The comment is noted for the record.
Comment 2.
I am pleased that the Mitigated Negative Declaration contains the following:
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.
This is a great start, but given the temporal and geospatial heterogeneity of soil gas contamination, it's
important to require that mitigation be designed into any regularly occupyable building on the property.
In the absence of near-continuous sampling, I believe it's important to require actions at 50% of allowable
exposure limits, because otherwise actions might be delayed until months after exceedances occur.
Response 2.
Thank you for your comment regarding the vapor barrier that will be installed to mitigate any potential
exposure of workers to VOCs. The City will work with the Applicant and the Regional Water Quality Control
Board to ensure that the vapor barrier and the sub-slab venting (SSV) system are installed properly. The
Applicant will monitor the SSV system by either measuring VOC concentrations in sub-slab soil gas, or indoor air
testing as required by the Regional Water Quality Control Board. Note that sampling indoor air for vapor intrusion
after occupancy may lead to misleading results given the nature of the goods sold by the retail tenant (e.g., paints,
solvents, etc.). If warranted, the passive system will be converted to an active system to extract vapors. With proper
installation and maintenance of the vapor barrier and SSV system, no exposure pathway should exist for vapor
intrusion.

Comment 3.
[In addition, I recommend the following to reinforce the Water Boards site oversight:] Indoor air
sampling shall be conducted in each building once construction is completed. Sampling shall occur once
before occupancy and at least four times a year for two years, and perhaps more often if sampling shows
significant temporal variation.
Response 3.
Thank you for your comment regarding indoor air sampling; it is duly noted. Please note that the purpose
of the vapor barrier is to prevent any residual vapors in the soil from entering into the buildings by
providing a physical barrier and venting any vapors through the SSV system. The vapor barrier and SSV
system will be reviewed and approved by the Regional Water Quality Control Board and the City prior to
installation. Moreover, the Applicant must ensure that the vapor barrier and SSV system are adequately
maintained. The Applicant will monitor the SSV system by either measuring VOC concentrations in sub-
slab soil gas or indoor air testing, as required by the Regional Water Quality Control Board. Note that
sampling indoor air for vapor intrusion after occupancy may lead to misleading results given the nature of
the goods sold by the retail tenant (e.g., paints, solvents, etc.). If warranted, the passive system will be
converted to an active system to extract vapors. With proper installation and maintenance of the vapor
barrier and SSV system, no exposure pathway should exist for vapor intrusion.
Comment 4.
[In addition, I recommend the following to reinforce the Water Boards site oversight:] There shall be a
contingency plan for reducing indoor air concentrations in each building should any sampling event find
indoor air concentrations above 50% of the target indoor air concentrations. As GSA recommends on page
253 of the draft mitigated negative declaration, this shall include active venting (the addition of fans) and
perhaps off-gas treatment.
Response 4.
Thank you for your comment. Please refer to Response 2.
Comment 5.
[In addition, I recommend the following to reinforce the Water Boards site oversight:] The contingency
plan shall also provide for an urgency response, including temporary relocation of building occupants,
should TCE indoor air concentrations in any building exceed 50% of the Urgent Response Action level, as
defined the U.S. EPA Region 9's June 30, 2014 memo.
Response 5.
Thank you for your comment. Please refer to Response 2. Please also note that the vapor barrier and SSV
system would be located under any elevator shafts.

Comment 6.
[In addition, I recommend the following to reinforce the Water Boards site oversight:] In addition to the
recommended vapor barriers, elevator shafts shall be sealed according to the requirements of California's
Vapor Intrusion Mitigation Advisory.
Response 6.
Thank you for your comment. Please refer to Response 2. Please also note that the vapor barrier and SSV
system would be located under any elevator shafts.
Comment 7.
[In addition, I recommend the following to reinforce the Water Boards site oversight:] All permanent
employees in the buildings shall be notified that the property is subject to an environmental response
overseen by the Regional Water Quality Control Board. We recently required such notice for a hotel
development in Mountain View, where I sit on the City Council. The people in buildings where vapor
intrusion is a potential threat have a right to know about that threat, and notice can be provided in a way
that does not trigger unjustified fear or panic.
Response 7.
The City will work with the Regional Water Quality Control Board, the Applicant, and the tenant to
determine the appropriate notification to be provided to the permanent employees in the buildings. The
City will provide a link to the Geotracker website.
Comment 8.
[In addition, I recommend the following to reinforce the Water Boards site oversight:] All indoor air
sampling results shall be made available to building occupants, as well as the public at large. The City
web site should provide a link to pertinent documents on the Water Board's Geotracker web site.
Response 8.
Please note that the Regional Water Quality Control Board has taken an active oversight role for this site
and the City has been in communication with the Board throughout the cleanup of the site.
Comment 9.
The environmental regulatory agenciesthe LA Water Board, U.S. EPA, and the California Department of
Toxic Substances Controlare doing a good job in Alhambra. But oversight is fragmented and the
agencies are understaffed and underfunded. Vapor intrusion could literally slip through the cracks.
Hence, I believe it is the obligation of city officials to look out for your people by incorporating detailed
protections in your CEQA documents.

Response 9.
Thank you for your comment. Please note that the Regional Water Quality Control Board has taken an
active oversight role for this site and the City has been in communication with the Board throughout the
cleanup of the site.




Comment Letter Dated January 3, 2017

Dianna Watson, Branch Chief
State of California
Department of Transportation
Comment 1.
Thank you for including the California Department of Transportation (Caltrans) in the environmental
review process for the above referenced project. The proposed project will involve the construction of a
new Lowe's Home Improvement store, a six-level parking garage, and two, six-story office buildings.
The nearest State facilities to the proposed project are interstates 10 and 710. The project is estimated to
generate approximately 5,742 daily trips, with 433 trips during the morning peak hour and 467 trips
during the evening peak hour. For the weekend analysis, the project is forecasted to generate
approximately 6,099 daily trips, with 322 trips during the weekend peak hour.
Response 1.
Thank you for the above comment. The above comment correctly summarizes the proposed project.
Comment 2.
Based on a review of the Mitigated Negative Declaration, it is noted that nearby Interstate 10 on/off
ramps including those on South Freemont Avenue were not analyzed in the project vicinity. Caltrans is
particularly interested in potential increased queuing forecasted at the aforementioned location and
would like to see an updated traffic analysis with the requested information using Level of Service (LOS).
Response 2.
The following study intersections were identified based on consultation between City staff and the traffic
engineers. Based on consultation with City of Alhambra staff and study requirements, the following
intersections were analyzed:
1. Fremont Avenue at Main Street (signalized);
2. Fremont Avenue at Poplar Boulevard (signalized);
3. Fremont Avenue at Commonwealth Avenue (signalized);
4. Fremont Avenue at Concord Avenue (signalized);
5. Fremont Avenue at Orange Street (signalized);
6. Fremont Avenue at Lowe's Driveway (Future) (signalized);
7. Fremont Avenue at 1000 Fremont Avenue (signalized);
8. Fremont Avenue at Mission Road (signalized);
9. Fremont Avenue at Valley Boulevard (signalized);
10. Fremont Avenue at Ross Avenue (signalized);
11. Fremont Avenue at Hellman Avenue (signalized);
12. Fremont Avenue at Montezuma Avenue (signalized);

13. Meridian Avenue at Concord Avenue (unsignalized); and,

14. Meridian Avenue at Mission Road (unsignalized).
The proposed project is not anticipated to result in a significant amount of regional traffic that would use
the I-10 Freeway to access the property. The proposed Lowes development will serve the local community
and this traffic will use local streets to access the business. The analysis (refer to Exhibits 3-12 and 3-13)
indicated that approximately four percent of the peak hour weekday traffic generated by the Lowes and
office development would use the I-10 Freeway. This translates into four AM peak hour trips and five PM
peak hour trips for the Lowes and 14 AM peak hour trips and 13 PM peak hour trips for the office
development. A substantial portion of the existing morning and evening peak hour traffic using Fremont
Avenue is regional through traffic that would otherwise use the freeway system if such a system were
available (i.e. the I-710 Freeway extension). The existing and future traffic volumes on Fremont Avenue
would be significantly reduced if the missing segment was available to access the communities located to
the north of Alhambra.
Comment 3.
Decision makers should be aware of cumulative impacts that may occur from related projects in this area
and be prepared to mitigate potential cumulative traffic impacts to the State Highway System. Caltrans
may accept fair share funding contributions towards future improvements of its facilities so long as we
can show that such improvements are expected to be implemented in a reasonable timeframe. Please
contact Caltrans to explore and develop potential reasonable measures and plan.
Response 3.
The IS/MND in Section 3.16.3 considered the related projects in the area that can contribute to the overall
future traffic volumes. The proposed project anticipates a number of mitigation measures that will include
the installation of two traffic signals and other related roadway improvements. The project specific impacts
will be financed by the project Applicant.
Comment 4.
In the spirit of mutual cooperation, Caltrans staff is available to work with your planners and traffic
engineers for this project, if needed. If you have any questions regarding these comments, contact project
coordinator Ms. Miya Edmonson, at (213) 897-6536 and refer to GTS# LA-2016-00336ME.
Response 4.
Thank you for the above comment.



Mark Licker
Comment 1.
Please accept this comment on behalf of the City of Alhambra in response to the traffic study presented by
the developer in support of the projects at the above addresses. I am in principle supportive of the
development of the parcels. Unfortunately, the placement of a large warehouse type of retail center such
as a Lowes is not feasible at this location in light of the already poor traffic flow on Fremont between
Commonwealth and Valley. The developers traffic study acknowledges this, but then suggests that
additional signals and access points on Fremont and Meridian will result in better traffic flow after the
development is complete. This is simply not a plausible outcome.
Response 1.
Thank you for the above comment. The traffic study indicated that the proposed projects impacts would be
fully mitigated with the implementation of the required mitigation. It is important to note that this
determination is based on the traffic analysis that included both the preparers of the study and extensive
peer review by both the Citys traffic engineers and their consultants. The identification of impact uses a
quantifiable methodology that is required by both the City and the County of Los Angeles. The
determination of a potential impact is therefore based on a quantifiable and scientific methodology.
Comment 2.
The traffic study uses a Lowes outlet in Poway, San Diego County, as its data source for predicting the
impact on traffic of the proposed store. It seems more reasonable to use data from the Home Depot store
right here in Alhambra. I suspect doing so will yield less favorable predicted outcomes. Unlike the
proposed development, the Home Depot outlet is the only generator of substantial traffic where it is
located, in a light industrial area away from main traffic arteries.
Response 2.
The traffic generation rates for a Lowes home improvement center are very different compared to the trip
generation rates of other types of home improvement retail stores. In addition, the ITE rates rely on a
generic home improvement store that does not accurately characterize potential traffic generation rates.
Therefore, it was determined during the early project scoping process that the traffic generation rates from
an actual Lowes store would be more appropriate.
As part of this process, it was determined that an accurate trip generation analysis would require the
identification of a Lowes that is stand-alone. The proposed Lowes within the project site would be a
stand-alone retail business. In other words, there would be no shared traffic among other businesses that
would normally be expected where a Lowes store would be an element of a larger retail center. For this
reason, the traffic engineers identified those Lowes in southern California where there are no other retail
uses sharing the property. The 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. In this way, the traffic counts would be generated exclusively by the Lowes and
not from other businesses in a commercial center.
Comment 3.
The proposed office buildings do not present the same traffic issues and I have no objection to them. But
any high volume retail outlet is likely to result in unacceptable increases in traffic volume beyond the
capacity of the surrounding streets.
Response 3.
Thank you for the above comment. In reality, the retail uses peak hour traffic rates will be lower compared
to the proposed office development. This is especially true in the morning peak hours where traffic from the
retail use will be minimal compared to the office when everyone is going to work. In addition, there will be
some pass-by traffic during the evening peak hours that will not result in any net increase in traffic volumes.
For example, a number of patrons will likely stop at the Lowes on their way home from work during
weekday periods.
Comment 4.
The choice appears to be between unacceptable traffic congestion and lower sales tax revenues for the
City. I do not believe it makes sense to sacrifice the quality of life for City residents in order to increase
City sales tax revenues. Tax revenues are a means to the end of improving municipal services and
enhancing quality of life. They are not an end in themselves.
Response 4.
The IS/MND identified mitigation measures that would address the proposed projects traffic impacts.
These measures reduced the level of impact to levels that are less than significant. In addition, the traffic
analysis was very conservative in that no consideration was given to the previous industrial use that was
discontinued in 2013. This previous use included over 400,000 square feet of floor area and the traffic
included not only employees, but numerous trucks.



May Jong
Comment 1.
I am an Alhambra resident and have reviewed the plans and impact studies on the Alhambra City website
regarding the Lowes (134,417 sq feet), 2 office buildings (one @ 143,400 sq. feet and the other @ 102,000
sq feet, both 68 feet tall) and the 1396 parking spots (414 stalls for retail, 982 spaces for office buildings)
on Fremont Ave. I am opposed to the development as it currently stands.
Response 1.
Thank you for the above comment. The above comment correctly summarizes the proposed project.
Comment 2.
My commute takes me on the Alhambra and South Pasadena sides of Fremont Avenue and as we all know
it is a hugely congested area. Even with parking entrances/exits on Mission, the traffic will increase
tremendously on Fremont and in the neighborhood. I am guessing even if not all 1396 parking spots are
utilized at one time, a successful development would want a good percentage of the parking to be utilized
during business hours indicating the Lowes and office buildings were generating business. This could
easily add 500 more vehicles on Fremont during rush hours. If the development were smaller and
included more walkable amenities for the neighborhood (like a park or native plant garden component)
that could help ease some of the potential problems. Additionally, if we just observe the nearby Home
Depot whose parking lot is always full, we can get a sense of what the Lowes will bring to Fremont Ave
(traffic, trash and noise).
Response 2.
The Lowe's and Office project will provide all parking on-site, including a surface lot for Lowe's customers and
employees, and a six-story parking garage for the office buildings. The parking requirements for the project,
as established by City parking standards, are summarized on Table 3-16 included in the IS/MND. The
parking requirement for the Lowe's component of the project is 411 spaces. The number of parking spaces
provided for Lowe's will be 414 spaces in the on-site surface parking lot, including six loading spaces, for a
parking surplus of three parking spaces. The parking requirement for the office component of the project is
982 spaces. The number of parking spaces provided for the office will be 982 spaces, including 947 spaces
in the proposed six-level parking structure and 35 spaces in the on-site surface parking lot. As shown on
Table 3-16 included in the IS/MND, the proposed parking supply will satisfy the Citys off-street parking
requirements.
Comment 3.
Please reconsider the development and make it more human scale in keeping with the neighborhood.
There are plenty of vacant businesses on Main Street and elsewhere that can be utilized instead of building
another large complex that will inevitably have vacancies and cause more problems than solutions.

Response 3.
Thank you for the aforementioned comment.



Eric Sunada
(Two letters are attached.)
Letter #1.
Comment 1.
I appreciate the opportunity to comment on the proposed development at 875 and 1111 South
Fremont Avenue, Alhambra, California. The issue being raised in this written input is being
submitted in accordance with the public review period of said project.
Response 1.
Comment 2.
The land use for the proposed project is currently dictated by the city's Zoning Ordinance, which
shows it to be in the Industrial Planned Development (IPD) zone. Specifically, Chapter 23.32 of the
city's municipal code details the permitted uses and is enclosed here for reference as Enclosure #1.
Response 2.
The statement is correct in that the propertys zoning designation is Industrial Planned Development (IPD).
The above reference is included at the end of Mr. Sunadas letter.
Comment 3.
The Zoning Ordinance leaves little room for interpretation. Per 23.32.020, permitted uses are
limited to the following:
"The following uses shall be permitted in the IPD zone, conducted wholly within a building;
(A) Uses involving the manufacture, processing or treatment of products which are not
obnoxious or offensive by reason of omission of odor, dust, smoke, noxious gases, noise,
vibration, glare, heat or other impacts, nor hazardous by way of materials, process,
product, waste or other methods;
(B) Professional, medical, financial, public service and general business offices, and similar office
uses;
(C) Warehousing and distribution facilities;
(D) Wholesale trade;
(E) Research, development and testing facilities which involve laboratories or large-scale

electronic data processing systems;
(F) Outdoor storage of fleet vehicles;
(G) Lumberyards, with accessory hardware sales;
(H) Contractor's storage yards;
(I) Plant nurseries;
(J) Adult businesses;
(K) Fitness centers, health clubs and gymnasiums."
Response 4.
According to Table 3-6 included in the IS/MND, the project conforms to all of the development standards
identified for IPD zoned properties. As indicated previously, the project will require the approval of an
Industrial Planned Development permit. The IPD permit application will permit the construction of the
three new buildings. The IPD permit will also place standards on the project to ensure the projects
conformity with the applicable zoning designation. The project in its current state meets the findings that
are required for the approval of an IPD. These findings are described as follows:
The project is permitted under the Citys zoning code.
The project will comply with the Citys General Plan land use designations and polices with the
appropriate conditioning. The project complies with the sites development standards refer to Table
3-6).
The project is physically suitable for the proposed site. The project complies with the Citys zoning
and building standards (refer to Table 3-6).
The project is compatible with the surrounding uses. The site is abutted by retail and office uses.
The project will have adequate fire flows and the local utility lines will have sufficient capacity to
serve the project. In addition, the local utility providers will have adequate supplies to
accommodate the increase in demand following the occupation of the project (refer to Section 3.17).
The project will be provided with adequate public access. The project will include the installation of
four driveways along the west side of Fremont Avenue and four driveways along the east side of
Meridian Avenue.
Comment 5.
On a conditional basis, some retail is permitted per 23.32.020 "Conditionally Permitted Uses":
"The following uses may be permitted subject to the approval of a conditional use permit pursuant
to the provisions of Chapter 23.66 of this title:

(A) Commercial uses, such as restaurants, which are intended primarily to serve employees
within the industrial district;
(B) Self-storage facilities, which may include one dwelling unit for a resident manager or caretaker;
(C) Service stations and motor vehicle repair facilities when conducted wholly within an enclosed
building;
(D) Public service and utility structures and facilities;
(E) Uses involving the manufacture, processing or treatment, of products which, by virtue of size,
number of employees or the nature of the operation, have the potential to be obnoxious or
offensive by reason of emission of odor, dust, smoke, noxious gases, noise, vibration, glare, heat or
other impacts, or hazardous by way of materials, process, product, wastes or other methods;
(F) Retail sales of goods manufactured on the premises, provided that the floor space devoted to
such use does not exceed 25% of the gross floor area of the primary permitted use;
(G) Retail sales as an accessory use to warehousing and/or wholesale sales provided that the floor
space devoted to such use does not exceed 25% of the gross floor area of the primary permitted
use;
(H) Kennels and animal hospitals;
(I) Commercial antennae and broadcast production facilities;
(J) Professional, technical and vocational schools;
(K) Educational, instructional and tutoring services."
Response 5.
Comment noted for the record. Also, please see Response 4.
Comment 6.
This project for a big-box retail store, Lowe's home improvement, is being allowed contrary to the above
regulations, and as a result cannot be allowed to move forward. It clearly does not fall within any of the
permitted nor conditionally permitted uses. Moreover, it is being proposed without any application for
any sort of waiver.
Response 6.
Comment 7.
In response to inquiries made with the city, it was revealed that former Development Services Director,

James Funk, proposed an interpretation of this Zoning Code in June 2010 that permits Home
Improvement Retail. This interpretation has no basis and is clearly in violation of the Code, which leaves
no room for such an interpretation. Yet it was put before the city council on June 28, 2010 and was
unanimously approved without discussion. Documentation on this action is enclosed (Enclosure #2). A
group of us met with city management and staff on January 6, 2017 to ask if there was any other
supporting reason for how this interpretation was made and approved. We received no additional
information. Consequently, the interpretation allowing big-box retail in the IPD zone is not valid because
it does not provide adequate justification and violates the Zoning Code.
Response 7.
Comment 8.
The zoning of a city is done with careful planning for the benefit of those who live and work in the city
while also promoting economic development. Zoning must weigh many factors, and among the most
important are incompatible uses. The site of the proposed project is in one of the most heavily congested
zones of the city along Fremont Avenue. One of the reasons why large retail is not permitted is due to the
traffic generated. Big-box home improvement retail generates on the order of 4,000 trips per day and
nearly doubles on weekends.1 At peak times, the problem is even more dire.
Response 8.
Policies included in the General Plans Land Use Element that are applicable to commercial land uses such
as those envisioned for the project and the projects conformity with each are outlined below:
Principle for Land Use Selection 2.3.3. Where appropriate, commercial land uses shall be
intensified or expanded when proper land is available. The proposed project will involve the
redevelopment of an underutilized and largely vacant property.
Policy 4.1.1. Promote growth, development, and redevelopment that recognize the costs, benefits,
and trade-offs, both social and economic, of the capacities of the natural and man-made
environmental of the City. The proposed project will provide additional employment opportunities
and sales tax revenue for the City.
Policy 4.1.3. Encourage land use patterns that minimize incompatibility between uses. The
proposed projects commercial land uses are consistent with the other land uses along the Fremont
Avenue Corridor.
Policy 4.1.4. Promote better mitigation of conflicting uses through known techniques for
eliminating conflicts for industrial and commercial areas adjacent to residential areas. The
proposed project will include a number of design features (architecture, setback, building
placement, and landscaping) that will effectively mitigate potential land use compatibility impacts
to residential development in the area.

Policy 4.1.10. Encourage the development of commercial land uses that enhance the Citys share of
the regional retail sales market. The Lowes home improvement store will serve as the
developments retail anchor.
As demonstrated above, the proposed project will not be in conflict with the Citys land use policy governing
commercial development. As a result, the potential impacts are considered to be less than significant.
Comment 9.
In terms of economic development, a city must have a mix of available jobs. The type of jobs associated
with permitted industrial uses are higher paying and can generate more jobs with less traffic. Giving
away a major portion of the city's IPD zone to retail uses, which are notorious for unlivable wages, would
perpetuate a city practice that is clearly not working for its people (Figure 1 below).
Response 9.










Letter #2 from Eric Sunada.
Comment 1.
I appreciate the opportunity to comment on the proposed development at 875 and 1111 South Fremont
Avenue, Alhambra, California. The issue being raised in this written input is being submitted in
accordance with the public review period of said project.
Response 1.
The above comment is noted for the record.
Comment 2.
The public comment period, which opened on December 2, 2016, is based on project-related documents
provided by the city at http://www.cityofalhambra.org/page/614/environmental documents/ . But these
documents and others available on the city's website are insufficient to properly inform the public,
commissioners, and elected officials to make decisions affecting the proposed project's area.
Response 2.
The comment period was extended from January 3, 2017 to January 17, 2017.
Comment 3.
"Planning" is to think of the future and to make decisions in the best interest of the city. The residents of
Alhambra rely on their planning commissioners to exercise proper judgment. In turn, commissioners rely
on city staff to provide the necessary background information and context. The documents made available
provide minimal information for the specific site and fails to consider relevant cumulative impacts from
nearby allowable land use. In summary, insufficient information has been provided to allow discretionary
actions to be carried out by Alhambra Planning Commissioners.
Response 3.
The comment is noted for the record. All of the various documents related to the preparation of the
IS/MND, traffic studies, and the supporting technical studies have been made available on the Citys
website.
Comment 4.
Specifically, the proposed project is located in a zone called Industrial Planned Development (IPD). If one
were to refer to the city's Zoning Code to determine the types of developments allowed in the IPD zone (see
Enclosure #1), one would find a discrepancy in that the Code clearly prohibits large-scale retail projects
such as the proposed big-box home improvement store. Yet nowhere in the project documents is there
mention of the need for a waiver or variance. This discrepancy requires disclosure of a highly questionable
interpretation that was made by a former Development Services Director (see Enclosure #2).

Response 4.
According to Table 3-6 included in the IS/MND, the project conforms to all of the development standards
identified for IPD zoned properties. As indicated previously, the project will require the approval of an
Industrial Planned Development permit. The IPD permit application will permit the construction of the
three new buildings. The IPD permit will also place standards on the project to ensure the projects
conformity with the applicable zoning designation. The project in its current state meets the findings that
are required for the approval of an IPD. These findings are described as follows:
3-6).
Meridian Avenue.
Comment 5.
Likewise, a large site to the immediate east is currently zoned as Professional Office (P0) as shown in the
enclosed zoning map (Enclosure #3). This is the site of The Alhambra that presently includes a set of for-
profit colleges, LA county offices, and others and is the former C.F. Braun site. Again, if one were to refer
to the city's Zoning Code, PO zones are restricted to the uses listed in Enclosure #4, which are offices and
educational institutions. But it needs to be disclosed that a Conditionally Permitted Use is listed as "Urban
residential if included on a site with a minimum size of 30 acres." Furthermore, Urban Residential is
defined in 23.04.757 of our Code as "high density residential ranging in density from 15 to 75 units per
acre...". It needs to be disclosed that this ruling was done specifically for this site, as it is the only one in the
PO zone of 30+ acres. Also, this ruling was made at the July 10, 2006 City Council meeting as a Zoning
Text Amendment. See Enclosures #5 and #6 for the city council information package and meeting minutes,
respectively.

Response 5.
The comment is noted for the record. The enclosures are provided at the end of this letter.
Comment 6.
This information is directly relevant to assess cumulative impacts and, hence, toward Planning
Commissioner's discretionary decisions. In addition to the fact that the current property owner of The
Alhambra is now able to build thousands of high density residential units with no requirement for an
affordable housing set-aside, it needs to be disclosed that indeed a developer, The Ratkovich Company,
submitted an application in January of 2016 for more than 1,100 units at this site. The application was
later withdrawn, reportedly only because the developer lost their financing. But the project, possibly even
larger, will undoubtedly be back.
Response 6.
As indicated in the comment, the application was withdrawn.
Comment 7.
In summary, it is insufficient to supply the public and Planning Commissioners with only the information
listed at the above website. The city's Zoning Map does not provide proper insight without the enclosed
context. The thousands of car trips generated by the proposed project and the potential for thousands
more from the special PO Zone across the street has serious implications on traffic and the environment.
The future of the city depends on properly informed decisions.
Response 7.














Eric Sunada Enclosure #5.







































Enclosure #6 from Eric Sunada.








2. COMMUNITY MEETING COMMENTS AND RESPONSES
comments made by those in attendance at the Community Meeting that was held on December 13, 2016.
The purpose of this meeting was to provide information to local residents regarding the project Applicant
that was a City requirement. The public comments and the project teams responses are included in this
section.
Comment 1.
The City did not consider the northern communities when analyzing traffic. The community is overrun
with traffic looking for an alternative route to Fremont Avenue. In addition, it appears as though the City
has an agenda.
Response 1.
A complete traffic report along with the technical worksheets was circulated concurrently with the IS/MND.
In addition, the traffic study text was incorporated directly into the IS/MND. The traffic engineer worked
closely with City staff as well as with the Citys traffic engineers to identity the study intersections that
included 14 intersections. The northernmost intersection included Fremont Avenue and Main Street. The
southernmost intersection located in the study area was Montezuma Avenue and Fremont Avenue, located
south of the I-10 freeway. Nearly half of the intersections analyzed are located to the north of the project.
As indicated in the traffic studys projected distribution analysis, the residential neighborhoods located to
the north of the project site were considered in the analysis.
Comment 2 Mike Okomodo
There is a mistake on the aerial exhibit. The document identifies the entire office building as medical
office when only portions of the building are. I am also opposed to the 20 foot wall that will be
erected between the property line and the parking garage. There will be a lot of traffic coming in and
out.
Response 2.
The mistake has been corrected and will be reflected in all future exhibits and presentations. Please refer to
Exhibits 2-4 and 3-2 in the IS/MND.
Comment 3.
How long will it take to construct? Once the project is completed, how many people will be on-site?
Response 3.
The estimated construction duration was included in the IS/MND (please refer to Section 2.4.3, page 37).
The estimated length of construction would take approximately 31 months total and will consist of six
phases. This duration was considered to be the maximum scenario so as to obtain a conservative estimate

of construction air emissions. For the Lowes project, the Applicant has indicated that the construction
period would be approximately eight months. The exact construction period for the two office buildings
cannot be precisely defined since there is no current application being considered by the City. The
maximum occupancy of the new Lowes retail store will depend on the maximum permitted occupancy that
will be determined by the Citys Fire Department. In addition, the maximum parking capacity for the
Lowes is 414 parking stalls, which is another occupancy limit. Based on these two variables (parking and
permitted occupancy), the maximum permitted occupancy at any single time will not likely exceed 500
persons including patrons and employees for the Lowes.
Comment 4
Extend the comment period.
Response 4.
The City is now accepting public comments through January 17, 2017.
Comment 5 John Davis
There will be traffic on Meridian.
Response 5.
We concur that the proposed project will add traffic to Meridian Avenue between Emery Park and Mission
Road. The traffic study (Section 3.16, page 125) indicates the anticipated traffic volumes along Meridian
Avenue that will be associated with the proposed project.
Comment 6.
I live south of Valley and Fremont. People are going to exit the I-10 to go to Lowes. The City did not
notify the neighbors either. What will the City do differently next time and what does the traffic engineer
have to say about traffic south of Fremont and Valley.
Response 6.
The traffic analysis considered the project traffic that would continue south of Valley Boulevard. Three
intersections in this geographic area were analyzed including Fremont Avenue and Ross Avenue, Fremont
Avenue and Hellman Avenue, and Fremont Avenue and Montezuma Avenue. The traffic study anticipates
the projected distribution through this area.
Comment 7.
How will this project affect future groundwater remediation? In addition, how do they remediate
groundwater?

Response 7.
The proposed project will not impact ongoing efforts to remediate the aquifer that extends through this
portion of the City. The San Gabriel Valley National Priorities List (NPL) indicates this area is part of a
plume that extends under the site at a depth of between 250 to 300 feet. This contamination is related to
chlorinated Volatile Organic Compounds (VOCs). Groundwater levels under the site extend from 90 to 115
feet below ground surface. As a result, grading and construction activities will not extend to this depth. The
remediation of the groundwater basin is the responsibility of the Environmental Protection Agency (EPA),
the Regional Water Quality Control Board (RWQCB), and others. The former use of the site did not result
in the contamination of this deep layer of groundwater.
Comment 8 Eric Sonata
Industrial Planned Development zone, how is it that we can have retail in an industrial zone (recites the
list of permitted uses within the IPD zone). Retail is notorious for traffic.
Response 8.
The City made a formal determination as to the conformity between the proposed project and the Citys IPD
zone designation. The proposed project retail and office use is consistent with the land uses that currently
extend along the Fremont Avenue corridor. In addition, this type of land use is more compatible with the
residential development found in the vicinity of the project site.
Comment 9
Can we have the references for the traffic? What year was the 9th edition for the ITE?
Response 9.
A bibliography page will be included in the IS/MND that will be considered by the Planning Commission.
The latest 9th edition was published in 2012.
Comment 10
What are you going to do about day laborers? Where will trucks stage and queue? What is going to
prevent trucks from going northbound on Meridian?
Response 10.
Lowes managers will monitor the parking area to ensure that day laborers do not congregate on the
property. The Lowes management does not permit the congregation of day laborers for safety reasons.
During construction, truck and construction staging areas will be located in the southerly portion of the
property. No parking or staging will be permitted within the Meridian Avenue right-of-way. Truck parking
associated with the Lowes will not be permitted on Meridian Avenue once the store is operational. The
larger trucks will be limited to those delivering goods for the Lowes. The Lowes representative indicated
that a maximum of two to three five axle trucks will travel to the Lowes. There is more than adequate room

to accommodate this truck traffic.
Comment 11.
On the site plan it indicates future development. Will there be future (additional) developments on-site?
Response 11.
The map that is being referred to was an error (refer to Exhibit 2-11). This notation will be removed by the
project architect.
Comment 12
Extend the comment period.
Response 12
The comment period will be extended.
Comment 13
What is the difference between Lowes and Home Depot? How many full time and part time employees
will be hired? Adding an extra signal is going to extend traffic to the north and south.
Response 13.
The Lowes home improvement store generally caters to individuals that are do-it-yourself (DIY) rather than
general contractors that typically patronize Home Depot. The Lowes indoor lighting, displays, and
inventory are all designed to cater to the individual as opposed to building contractors. At any given time,
an estimated 35 employees will work in the Lowes with the total maximum employment being 125
employees. Both signals are designed to both improve traffic flow and safety.
Comment 14.
I have been a resident for 30 years. Thank you Tonya for the noticing, though it needs to be expanded.
Can the engineer give me a clarification of LOS and what it means.
Response 14.
The Level of Service (LOS) definitions are described in detail on pages 126 and 127 of the IS/MND.

3. COMMENTS AND RESPONSES TO E-MAILS THE WERE RECEIVED
comments made by individuals in emails to the City. The e-mails and the project teams responses are
included in this section.
Email from May Jong, email dated January 3, 2017.
Comment 1.
I am an Alhambra resident and have reviewed the plans and impact studies on the Alhambra City website
regarding the Lowes (134,417 sq feet), 2 office buildings (one @ 143,400 sq. feet and the other @ 102,000
sq feet, both 68 feet tall) and the 1396 parking spots (414 stalls for retail, 982 spaces for office buildings)
on Fremont Ave. I am opposed to the development as it currently stands.
Response 1.
Comment 2.
My commute takes me on the Alhambra and South Pasadena sides of Fremont Avenue and as we all know it
is a hugely congested area. Even with parking entrances/exits on Mission, the traffic will increase
tremendously on Fremont and in the neighborhood. I am guessing even if not all 1396 parking spots are
utilized at one time, a successful development would want a good percentage of the parking to be utilized
during business hours indicating the Lowes and office buildings were generating business. This could easily
add 500 more vehicles on Fremont during rush hours. If the development were smaller and included more
walkable amenities for the neighborhood (like a park or native plant garden component) that could help
ease some of the potential problems. Additionally, if we just observe the nearby Home Depot whose parking
lot is always full, we can get a sense of what the Lowes will bring to Fremont Avenue (traffic, trash and
noise).
Response 2.
The comment is noted for the record. The projects traffic impacts were analyzed in the IS/MND as well as
in the traffic study that was prepared for the project. The analysis identified both the projects impact and
the mitigation that would be effective in reducing the impacts to the established levels of significance.
Comment 3.
Please reconsider the development and make it more human scale in keeping with the neighborhood. There
are plenty of vacant businesses on Main Street and elsewhere that can be utilized instead of building
another large complex that will inevitably have vacancies and cause more problems than solutions.

Response 3.
The comment is noted for the record. The Planning Commission will consider not only the proposed project
but the findings of the environmental study prepared for the project.
Email from rdmclain10, email dated December 26, 2016.
Comment 4.
Bad idea!!! There's already too much traffic on Fremont Ave. The city already has Home Depot. Focus on
traffic reduction.
Response 4.
Comment is noted for the record.
Email from Manny Hernandez, email dated December 15, 2016.
Comment 5.
Just build the project please don't wait like the 710 freeway. to much time has been waisted. people in
general are tired like my self in driving to other cities to shop at Lowes.
Response 5.
Email from Masao "Mike" Okamoto, AIA, email dated December 14, 2016.
Comment 6.
Thank you for the last night's informative meeting. As one of the property owners of adjacent Fremont
Business Center, I would like to state my concerns. As I will be explaining below, giving MND to Phase 2
portion of the project should be denied. Too many unknowns! The developer and their consultants
(hereafter referred as "Proponent") do not know when they are building, what they will be building, how
they solve the traffic issues and how environmental issues can be mitigated to protect the neighboring
community.
Response 6.
The comment is correct in that the precise timing of the office development is not known at this time.
However, CEQA requires that an environmental analysis consider an entire potential project so that
piecemealing of the analysis does not occur.

Comment 7.
There are still inconsistency in MND attachments, i.e. several plans are still showing our building (919 S.
Fremont Ave,) as if integral part of the proposed project. I want Proponent to correct immediately.
(Proponent commented such that "it's just MND documents and has no effect to the project.." This kind of
approach is not acceptable and I would hope the city to reject any submittal if such materials are
presented as "knowingly" incorrect.
Response 7.
The cartography was incorrect in the delineation of the project site on two aerial photographs. These will be
corrected in the Final IS/MND. The other exhibits included in the IS/MND correctly identify the project
site boundaries.
Comment 8.
Certainly "aesthetics" is one of the critical items for the mitigation. However, certain elements of the
current design does not depict clearly the aesthetic impact to the neighbors. The provided site layout is
unclear about the distance between the 6 floor parking structure to the Easterly property line. Verbally,
Proponent explained (in front of the panel) "the distance is at least 20 feet between the parking exterior
wall and the East property line. However, I could only see the distance equivalent to one parking width
between the parking exterior and the East property. Proponent has an East exterior elevation of the
parking structure building which can only be fulfilled with more than 20 foot clearance. Again, this is
another sign of disrespect for the accuracy of the document. City should request Proponent to correct such
inaccuracy which are critical to the mitigation.
Response 8.
The distance between the parking structure and the adjacent buildings as well as any setbacks conform to
the Citys zoning ordinance. The difficulty sited in the above comment has to do with the scale of the
drawings provided in the IS/MND. Large sized drawings of the site plan and other project elements are
available at City Hall for review by the public.
Comment 9.
There was some indication of office being "medical office," which Proponent denied. As you are aware,
parking requirement will be different for Medical offices and can affect the basis of the traffic impact.
Especially, if the project is contemplated for unknown future but medical office needs are strong in this
area due to USC's medical facilities nearby. City should request Proponent to dictate clearly what are the
intended use now and future, so there is no future surprise!
Response 9.
The office component is a general office and will not be a medical office. The comment is correct in that the
parking requirements for medical office are very different a general office. The project being considered is

for general office space. A medical office would require the entire project to be redesigned and new
environmental analysis to be undertaken.
Comment 10.
Does Proponent have the right to sell this "phase 2" part of the project to some other developer? How can
City enforce the adherence to development conditions as agreed with the community. Will the terms be
bound in the development agreement holding the new buyer responsible? Will terms be filed as the
covenants to the property?
Response 10.
The proposed development is privately owned and a resale and not be precluded. However, any conditions
required by the City will still be conditions for any new property owner. The conditions and mitigation are
applicable to the project regardless of its ownership.
Comment 11.
The added signal in between Orange and Mission has to be studied further. Lowe's Customer traffic has
been explained last night but what about office traffic (even if the construction is unknown)? Dumping
cars from 6 floor parking at commuting time has not been addressed. Also 60 ft trailers exiting onto
Fremont would have to block at lease two lanes making turns. Please address such issues in the study.
Response 11.
The traffic study did include an analysis of the offices traffic impacts during the peak traffic periods (the
office would utilize the parking structure exclusively.)
Comment 12.
Because the construction timings of the office buildings and parking structure are "totally" unknown, the
rest of the property may be fully used by Lowe's. City should mandate the construction of parking
structure to take place first as a condition of office building entitlement. Since Fremont Business Center is
adjacent, people will start parking in our property. Or otherwise Meridian will be filled with construction
workers' cars and such temporary blockage to through traffic will be a big problem to the residents. Thus,
the construction of the parking structure should take place first as the condition of approval.
Response 12.
All parking for both the office and the proposed Lowes must be accommodated within the designated
parking areas for the project. Both project components meet the Citys parking standards and sufficient
parking as defined by those standards.
Comment 13.
Environmental "sign-off" was not clearly addressed last night. For single story warehouse, passive
venting with vapor barrier may be an acceptable compromise, but 6 story office buildings and the

parking structure may not be applicable as their foundation structures are likely to penetrate through the
vapor barrier. If active venting is mandated, we will have big issues with adjacent buildings including
Youth Center and Children's Park. If land fill is required to create a buffer, then the building height will be
inconsistent with the MND documents. Thank you for your consideration.
Response 13.
Please note that the purpose of the vapor barrier is to prevent any residual vapors in the soil from entering
into the buildings by providing a physical barrier and venting any vapors through the SSV system. The
vapor barrier and SSV system will be reviewed and approved by the Regional Water Quality Control Board
and the City prior to installation. Moreover, the Applicant must ensure that the vapor barrier and SSV
system are adequately maintained. The Applicant will monitor the SSV system by either measuring VOC
concentrations in sub-slab soil gas or indoor air testing, as required by the Regional Water Quality Control
Board. Note that sampling indoor air for vapor intrusion after occupancy may lead to misleading results
given the nature of the goods sold by the retail tenant (e.g., paints, solvents, etc.). If warranted, the passive
system will be converted to an active system to extract vapors. With proper installation and maintenance of
the vapor barrier and SSV system, no exposure pathway should exist for vapor intrusion.
Email from Masao "Mike" Okamoto, AIA, email dated December 8, 2016.
Comment 14
Please convey my following concern to the developer of the above project. The exhibit pages 2-4, 2-11, 3-1
and 3-2 include 919 S. Fremont Ave. As one of the property owners of the building, we have not been
approached nor explained of such inclusion. Now that such information is out in public disposition, our
leasing and/or sales effort is negatively impacted by such erroneous disclosure.
Response 14.
Two aerial maps depicted the projects boundaries incorrectly. The remaining exhibits included in the
IS/MND were correct including the site plan and other thematic maps included in the report. The corrected
maps will be included in the presentation at the community meeting and will be included in the Final
IS/MND.
Email from Jeanmarie Zimmerman, email dated December 7, 2016.
Comment 15.
Requesting a reschedule of Hearing due to holiday. I am an immediate neighbor and the first I heard of
this project was on NextDoor this week. Fremont is a congestion point to get to 710 and vice-a-versa.
What I read about proposed quantity of cars to be accommodated in development seems excessive. The
adjacent residential neighborhood Emery Park will likely get a huge increase in through traffic of non-
residents to deter from Fremont.

Response 15.
The comment is noted for the record. The IS/MND included mitigation measures that would prevent right
turns at key exit points along Meridian. These measures would be effective in significantly reducing
through traffic into the Emery Park neighborhood.
Email from D. Agopian, email dated December 5, 2016.
Comment 15.
Are people complete idiots. Or maybe you just want to create total gridlock on fremont. Probably both.
Not to mention the increase in illegal aliens hanging around increase crime... but you idiots know all that.
Response 15
The comment is noted.

PART II
SUPPLEMENTAL COMMENTS &
RESPONSES TO COMMENTS FOR THE
& INITIAL STUDY

LEAD AGENCY:
CITY OF ALHAMBRA
REPORT PREPARED BY:
JANUARY 17, 2017ALHM 001
COMMENTS & RESPONSE TO COMMENTS PART II PAGE 123


TABLE OF CONTENTS
Section Page
1. Additional Comments & Response to Comments...................................................................127
2. Comments & Responses to E-mails that were Received ....................................................................... 155
3. Comments & Responses to Comments Received through a Phone Call ...............................................170
4. Most Recent Comments Received by Email .......................................................................................... 171


1. ADDITIONAL COMMENTS AND RESPONSES TO COMMENTS

Additional comment letters to date, were received from the following:

G Valladodid, Resident of Alhambra

State of California
Governors Office of Planning and Research
State Clearinghouse and Planning Unit

State of California

Ranajit (Ron) Sahu

Michael Lawrence

Sonia McIntosh, Emery Park Resident
The City received comments via email from the following:
Email Letter Dated December 5, 2016

Mariana Martinez, Emery Park Resident

Melanie Ulloa, Emery Park Resident

Carlos Barron, Emery Park Resident
Email Letter Dated January 10, 2017

Eric Sunada, Resident of Alhambra


Joe Cano, El Sereno Resident


Zoe Wu, Emery Park Resident

Mrs. Khan, Resident of Alhambra

Rita Ramirez

Laura Telles, Emery Park Resident

Daniel Solorzano, Emery Park Resident

Ckool63
The City received comments via a phone call from the following:
Phone Call Received on January 12, 2017

Shirley Mollen


G Valladodid
Comment 1.
I am opposed to the development on Fremont that includes Lowes and office buildings. Please follow the
zoning for the area. While lumber yards may be considered industrial, a big box Lowe's is not; it is a retail
establishment. It is an unjust stretching of a horse of a different color to the detriment of residents' quality
of life. All the traffic to be brought in by retail cannot be handled by Fremont without completely affecting
residents of Alhambra. Even those of us who may not live immediately adjacent to the space, often use
Fremont to reach our frequent destinations. Stop. Do not continue on this unfair to residents path.
Response 1.
Comment has been noted for the record. The environmental impacts of the proposed project including
traffic and land use accountability were analyzed in the IS/MND.
Comment 2.
The additional traffic will detrimentally affect the air quality for the southern CA region. We have already
surpassed the permitted levels of ozone and particle production. We do not want nor do we deserve your
money deals that will raise the percentages of heart disease and cancers. Stop it.
Response 2.
The proposed project will result in additional traffic impacts and air emissions from traffic and energy
sources. The IS/MND did identify mitigation that would be effective in reducing these impacts to levels that
are less than significant.



State of California
Comment 1.
The State Clearinghouse submitted the above named Mitigated Negative Declaration to selected state
agencies for review. On the enclosed Document Details Report please note that the Clearinghouse has
listed the state agencies that reviewed your document. The review period closed on January 3, 2017, and
the comments from the responding agency (ies) is (are) enclosed. If this comment-package is not in order,
please notify the State Clearinghouse immediately. Please refer to the project's ten-digit State
Clearinghouse number in future correspondence so that we may respond promptly.
Response 1.
The comment has been noted for the record.
Comment 2.
Please note that Section 21104(c) of the California Public Resources Code states that:
"A responsible or other public agency shall only make substantive comments regarding those activities
involved in a project which are within an area of expertise of the agency or which are required to be
carried out or approved by the agency. Those comments shall be supported by specific documentation."
Response 2.
Comment 3.
These comments are forwarded for use in preparing your final environmental document. Should you need
more information or clarification of the enclosed comments, we recommend that you contact the
commenting agency directly.
Response 3.




State of California
Comment 1.
The enclosed comment (s) on your Mitigated Negative Declaration was (were) received by the State
Clearinghouse after the end of the state review period, which closed on January 3,2017. We are
forwarding these comments to you because they provide information or raise issues that should be
addressed in, your final environmental document.
Response 1.
The comment has been noted for the record. Responses have already been provided to the California
Department of Transportation.
Comment 2.
The California Environmental Quality Act does not require Lead Agencies to respond to late comments.
However, we encourage you to incorporate these additional comments into your final environmental
document and to consider them prior to taking final action on the proposed project.
Response 2.




Ranajit (Ron) Sahu
Comment 1.
I appreciate the opportunity to comment on the Traffic Study prepared to support the proposed Lowes
and Office Development (hereafter proposed project) at 875 and 1111 South Fremont Avenue, Alhambra,
California. I understand that the City of Alhambra Planning Commission will be asked to approve this
matter on January 17, 2016 at a public hearing. I am requesting that a copy of this comment letter be
provided to each member of the Planning Commission, the City Manager, and to each member of the City
Council.
Response 1.
The comment is noted for the record. The Planning Commission hearing is scheduled for January 17, 2017.
Comment 2.
Among other obligations, the extant Traffic Study has been provided by the project proponent as part of
the required environmental impact assessment for the proposed project in order to satisfy the
requirements of the California Environmental Quality Act (CEQA). It is my understanding that the
project proponent has proposed and that the City of Alhambra has accepted that the CEQA obligation of
the proposed project can be discharged via a Mitigated Negative Declaration (MND) as opposed to a full
Environmental Impact Report (EIR) the latter being a more thorough assessment of the potential
environmental impacts that may result from the proposed project.
Response 2.
The environmental analysis prepared in support of the IS/MND determined that an EIR was not required
given that no significant unmitigable impacts would result. For this reason, the City of Alhambra, in its
capacity as Lead Agency, determined that an EIR was not required.
Comment 3.
Based on my review of the Traffic Study alone (i.e., setting aside other potentially problematic
environmental concerns such as Air Quality and potential risk of harm via Vapor Intrusion of
contaminants known to be present in groundwater under the proposed development site, etc.), it is my
opinion that the MND is not the appropriate CEQA document for a project of this size and scope at its
proposed location namely along Fremont Avenue, currently one of the most heavily impacted traffic
corridors in the City, with unacceptable traffic even without the proposed project.
Response 3.
The comment is noted for the record. The traffic analysis acknowledged the proposed projects impact on
the Fremont Avenue Corridor. Mitigation was included in the IS/MND that would be effective in reducing
the impact to levels that are less than significant.

Comment 4.
I provide this opinion not just because I am a resident of the City of Alhambra (since 1988) but also as a
professional consultant competent to provide such opinions on environmental assessments. If staff or
members of the Planning Commission or City Council would like to discuss my qualifications, I will be
very happy to provide additional details.
Response 4.
Comment 5.
The Traffic Study is fatally compromised and, as a result, its conclusions are flawed and cannot and
should not be relied upon. Due to improper and unsupported assumptions made regarding nature of the
proposed project, the Traffic Study consciously significantly underestimates the number of additional
trips that will be generated as a result of the proposed project. It does so by improperly deviating from
standard practices in how such traffic impact analyses are conducted for such developments throughout
the country. As in any traffic analysis, once the project trip estimate is erroneous, the conclusions of the
study are consequently also erroneous.
Response 5.
The above comment, while citing limitations in the traffic analysis, does not provide specifics that can be
directly responded to. The traffic analysis clearly indicates the number of additional trips that would be
generated by the proposed project and the attendant impacts.
Comment 6.
The additional trips from the proposed project will incrementally burden the already poor traffic
conditions in and around the area, which even the Traffic Study acknowledges. Thus, underestimating the
number of additional trips artificially lessens the impact of the proposed project. This defeats the purpose
of the assessment and moots the CEQA analysis. And, it makes mockery of the types of mitigations that
can and should be considered to lessen the incremental traffic impacts once they are properly estimated.
Response 6.
The traffic analysis was prepared and peer-reviewed by three different traffic engineering companies. In
addition, the City conducted their own peer review prior to circulation. The traffic studys preparation
adhered to the standard engineering protocols required under the Los Angeles County Congestion
Management Program (CMP).
Comment 7.
I wish to make it clear that I am not against development in the City. I acknowledge that it is unrealistic
to expect that the land proposed for development will not undergo some type of future development. But,

that is simply not an excuse to use poor technical analyses as support for the proposed development and to
ram it through the process. Doing so is harmful on many levels: it defeats the happy talk of sustainable or
smart growth that is supposedly the planning goal in the City; it invites equally poor analyses on future
projects; and it exposes the City to potential legal risks. I would urge the Planning Commission to send the
environmental analysis back to the drawing board to be reworked and to make sure it properly conforms
to CEQA.
Response 7.
Comment 8.
Based on a meeting I (and others) had with City staff, I have put together a list of questions (provided in
Attachment A) relating to the Traffic Study. This has been provided to staff and it is my understanding
that staff will obtain responses from the authors of the Traffic Study. Regardless of whether or not
responses are obtained, as a fellow resident of the City, I urge members of the Planning Commission to
fully satisfy themselves as to the Traffic Study before voting on this matter. I urge Commissioners to
become familiar with what can often be technical aspects of the various CEQA analyses, including the
Traffic Study, and to ask pointed questions and clarifications before considering approval for the project
as currently conceived. And, I urge City Council members to support their appointed Planning
Commissioners in this task.
Response 8.
The traffic engineers responses were provided in a separate email.
Comment 9.
It is my opinion, based on review of numerous documents and many discussions with City staff over the
years, that CEQA compliance for many projects proposed in the City over the years has been an after-
thought a check-the-box exercise that leaves much to be desired. I have heretofore refrained from
commenting publicly on the record on this issue. But, the quality of the analysis in the present Traffic
Study warrants a public response.
Response 9.
Comment 10.
While I understand staffs desire (and that of the Planning Commission and City Council members) to be
helpful to folks intending to invest in the City, this desire must be properly balanced against the regulatory
obligations of staff, Commissioners, and Council members and their obligations to the citizens of
Alhambra. Without a proper balance between the regulatory and facilitation functions, the desired goal
of sustainable development in the City is simply not possible. This is even more important when

considering projects, such as the proposed project, in an area of the City along Fremont Avenue that is
already subject to significant congestion and which sits on land above contaminated groundwater.
Response 10.
The comment is noted for the record. The site, as well as the entire City, overlies a contaminated ground
water basin as noted in the IS/MND. The proposed project will not affect this groundwater basin nor its
ongoing remediation.







Michael Lawrence
Comment 1.
I will address the main argument presented in the traffic study prepared by Kimley-Horn and Associates,
Inc., October 2016. The justification for bypassing the normal use of the IT manual and using the Lowe's
Poway data is that the IT manual does not reflect the type of home improvement audience that is part of
the Lowe's model for business. Below I have included their justification (see Attachment A). In it they
state the difference is that they cater to the homeowner and not the small contractors. This is not factual
and is a disingenuous argument.
Response 1.
A detailed traffic study was prepared for the proposed project. In addition to this stand-alone traffic study,
the report was incorporated directly into the IS/MND. The traffic study included a detailed description of
the existing traffic conditions and the study area. The traffic analysis then projected future traffic that
would be generated by the proposed project. This net increase in traffic was then added to both the existing
traffic volumes as well as the future traffic volumes without the project that would be expected in the near
term. As part of this analysis, the traffic engineer worked closely with the City to identify the location and
extent of the study intersections and how this future traffic would be distributed onto the local streets.
Mitigation was proposed that would facilitate traffic flow on Fremont and Meridian, as well as eliminating
truck traffic from going northbound from Meridian into the residential neighborhood.
Comment 2.
Lowe's website has several pages devoted to small contractors offering in store delivery and discounts for
contractors. The service is called Lowe's ProServices. A banner advertising bulk rates for contractors is
prominent on their www.lowesforpros.com home page for the services.
Response 2.
Comment 3.
A cursory view of the documents on the web show that Lowe's is directly competing with Home Depot
for contractor business and in fact their stock ratings are dependent on it. In a Fortune financial analysis
This is the Best Home - Improvement Stock to Own by Ryan Derousseau dated April 20th, 2016 the
article compares Home Depot and Lowe's and an Oppenheimer analyst Brian Nagel, states "The two
companies are "about 90% identical". The report does say they are behind Home Depot in contractor
sales but are making significant moves to correct this.

Response 3.
Comment 4.
Some analysts think Lowe's can gain ground by capturing more of the $120 billion professional home-
improvement market. The average pro contractor customer at Home Depot spends $6,500 a year, while
Lowe's garners about $2,000 per pro. To narrow that gap, Lowe's recently launched an e-commerce
platform for contractors and began partnering with brands preferred by professionals, like Sherwin-
Williams paints. Piper Jaffray analyst Peter Keith says those initiatives could enable Lowe's to boost its
overall growth.
Response 4.
Comment 5.
I urge the commissioners to review all of the letters and documents that have been presented. There is
more than enough material to merit sending this back for a new traffic study that uses standard
methodology and the IT manual. The IT trip generation manual was used in all of the Lowe's stores in the
Los Angeles area and also with the two office buildings so it is disturbing that an exception was made just
for Lowe's Alhambra. Undoubtedly the figures produced by using the IT manual would trigger an EIR
and would require the developer to truly mitigate the increase in traffic.
Response 5.
The information from the ITE manual was referred to in the IS/MND. However, the nature of the ITE
manual is that it is based off of nationwide surveys that typically have a very small sample size. Therefore, it
was deemed that actual driveway counts from a stand-alone Lowes store would provide a more accurate
characterization of potential traffic impacts.
Comment 6.
The current conclusion that the Lowe's development including two 6 story office buildings does not
significantly impact the environment with traffic is a disservice to our City and residents. The City of
Alhambra can encourage development without harming our quality of life by having this project examined
under and EIR. This can only be done with good data and not by circumventing the process with bad
traffic analysis.
Response 6.





Sonia McIntosh
Ms. McIntosh submitted a hand-written letter in regards to a number of issues, mainly concerning traffic.
Response
The issues that were legible in the letter included the projects traffic impacts, the fact that the site overlies a
superfund site which is a groundwater basin and underlies a major of the San Gabriel Valley, vibration and
noise during construction, and impacts to the Emery Park. These issues were addressed in the IS/MND.




2. COMMENTS & RESPONSES TO E-MAILS THAT WERE RECEIVED
additional comments made by individuals in emails to the City. The e-mails and the project teams
responses are included in this section.
Email from Mariana Martinez, dated December 5, 2016.
Comment 1.
I reside in the Emery Park neighborhood. I have been living here for a number of years.
Response 1.
Comment 2.
I appreciate the improvement and development projects in our city. I do have to say though that I don't'
understand why we need a Lowe's. We already have Home Depot in the city which is more affordable.
Even with a Lowe's close by I still only plan on going to Home Depot. I would much prefer bringing in a
merchant that we don't have yet like say Wal Mart or a Trader Joes.
Thanks for your time.
Response 2.
Email from Melanie Ulloa, dated December 8, 2016.
Comment 3.
I am a resident of Alhambra and I am requesting an extension of the public comment period for the above
stated project be moved from 01/03/17 to 01/17/17 for the following reasons: The meeting is held on the
first day of business for the new year. It is unreasonable to expect that many residents will be able to
attend on this evening; people may still be traveling back from their holiday.
Response 3.
The comment is noted for the record. The comment period was extended as requested.
Comment 4.
I have asked and not all of my neighbors received notice of this meeting in the mail; is this posted online?
is notice being given to all residents, per Robert's Rules of Parliamentary Procedure?

Response 4.
The City sent the meeting notices to surrounding property owners within a specified distance from the
project site as required by the Municipal Code.
Comment 5.
Will the agenda be available 72 hours prior to the meeting? That would mean it would need to be posted
on January 1st. Will city hall open for residents who do not have Internet access to view the agenda? You
attention and consideration to this matter is greatly appreciated.
Response 5.
The comment is noted for the record. The agendas were pursuant to the Citys Municipal Code
requirements.
Email from Carlos Barron, dated December 22, 2016.
Comment 6.
This is where you can send the document you mentioned and I requested once you have it electronically.
The contact information below is the best way to get in touch with me. I respond in a more timely manner
via text and email.
Response 6.
Comment 7.
I'm sorry you brought it up in our ad hoc conversation so I'm not privy to it's title. It's interesting to note
how long it took for you to get back to me since you insisted I give you my contact information post haste.
Response 7.
Email from Eric Sunada, dated January 10, 2017.
Comment 8.
At our meeting on Friday, January 6, you offered to seek answers to our questions from the developer's
traffic engineer(s), either by meeting or email. In the interest of time and a quicker turnaround, we'd like
to take you up on your offer to obtain answers via email.
Response 8.

Comment 9.
Questions: On Table 2, page 17, why did the traffic analysis not use the trip generation rates from ITE
Trip Generation Manual, 9th Edition, code 862 in order to calculate the rates for the Lowes store for AM
Peak Hour, PM Peak Hour, and Weekend Peak Hour?
Response 9.
The Traffic Study explains that Lowes home improvement superstores are considered different than other
typical home improvement superstores, e.g., Home Depot, in terms of peak hour trip generation from the
site; and that the trip generation rates that are available for use in analyzing traffic impact from typical
home improvement superstores do not necessarily reflect the proposed project.
Comment 10.
Were the trip generation values for Lowes ever calculated using the ITE 9th Edition code 862 rates?
Response 10.
Refer to Response 9.
Comment 11.
Regardless of the answer to Q2. above, what would the Lowes' trip generation values for AM Peak
Hour/PM Peak Hour/Weekend Peak Hour be if ITE 9th Edition code 862 rates were used instead of the
Lowes/Poway rates?
Response 11.
Please refer to Table A provided below.

Comment 12.
Did Kimley/Horn request 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 details (such as approval letter, etc.).
Response 12.
The City agreed with the use of the site-specific empirical data collected at an existing Lowes store. No
formal letter of approval was issued.
Comment 13.
Please provide 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.
Response 13.
Kimley-Horn has conducted site driveway, drive-through queuing, and parking data collection for use in
traffic and parking studies on a number of occasions, such as for distribution centers, office complexes,
warehouse uses, drive-through restaurants, shopping centers, gas stations, etc. (not specifically for a Home
Improvement Store). This is a common practice for all traffic consultants. It is not uncommon to collect
site-specific empirical data for a particular use. In fact, the following is a direct quote taken from the
Institute of Transportation Engineers (ITE) Trip Generation Manual (9th Edition): When practical, the
user is encouraged to supplement the data in this document with local data that have been collected at
similar sites. In addition, it should be noted that the trip generation data provided in the ITE Trip
Generation Manual is based on site-specific empirical data collected at local sites, just like the Lowes data
collected and used in this study. Without local driveway data like the Lowes data, the Trip Generation
Manual would not exist.
Comment 14.
How were the trip distribution assignments shown on Figures 5, 6, and 7 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.
Response 14.
As is typical of all traffic studies, the traffic consultant prepares preliminary trip generation and trip
distribution assumptions, discusses with staff, and works with City staff to finalize the assumptions based
on staffs knowledge and familiarity with the City. This does not involve a formal written process.

Comment 15.
How would the conclusions of the traffic analyses as shown on Tables 3, 4, 5, 6, 7, and 8 change if the trip
generation values for the Lowes store used the ITE Manual 9th Edition Code 862 rates in Table 2 instead
of the Lowes/Poway rates, along with the assumed trip distributions shown in Figures 5-7?
Response 15.
To answer this question, a separate full analysis of the project would be required.
Comment 16.
Does Kimley/Horn typically address accidents and other safety metrics at the potentially affected
intersections within the assumed area of study in its traffic analyses? The current analysis does not seem
to contain this type of information.
Response 16.
This is not a typical component of a traffic impact study.
Comment 17.
Appendix C contains a report prepared by Crown City Engineers. The following questions pertain to
Appendix C. Not sure if they should be addressed by Kimley/Horn or Crown City. General response: the
Crown City driveway count study provides answers to many of these questions not to the very specific
questions, such as information about the customers of the store, or the effect of other uses near the site
where the counts were being collected. Even ITE does not request or require information of this level of
detail or specificity for trip studies that are used in the Trip Generation Manual.
Response 17.
Comment 18.
Please provide support for the statement that "Lowes home improvement superstores are considered
different than other typical home improvement superstores...." (unnumbered page 1 of the report in
Appendix C). What is the basis of this statement? Please provide references as appropriate.
Please provide support for the statement "Lowes stores sell home improvement items geared more to the
homeowners whereas Home Depot stores sell these items geared more to small contractors."
(unnumbered page 2 of the report in Appendix C) Was this statement based on observations (please
provide documentation), company statements (please provide documentation), or other sources (please
provide documentation)?
Please provide information on the customers (i.e., home owners, small contractors, large contractors,
MRO, etc.) that Lowes intends to target to its Alhambra store - if known.

Please clarify the statement "....Alhambra Lowes will not share any driveways form other businesses." It
is apparent from the traffic analysis that traffic to and from the two proposed office complexes also
planned as part of the development (which will presumably house "other businesses") will be able to
enter/leave the development via the Lowes driveways.
Response 18.
Changes to the project site plan and the site access and circulation were made after the Crown City report
was prepared.
Comment 19.
On what basis was the Lowes in Poway deemed "similar" to the proposed Lowes in Alhambra?
Using the support for "similar" as used in Appendix C, are there any other Lowes stores located closer to
the proposed Alhambra Lowes than the Poway store, which could also be considered "similar" to the
Alhambra Lowes?
Were there any other Lowes stores other than the one in Poway considered for traffic count data
gathering described in Appendix C?
Were any actual traffic counts collected at any other Lowes, other than the one in Poway. If the answer is
yes, please provide this data.
The Lowes store in Poway is located across a Walmart Superstore. Please comment on the effect this
could have on traffic counts observed at the Poway Lowes in contrast to, for example, the Lowes being all
by itself - i.e., could it have depressed the observed traffic counts? If not, why not?
Please comment on whether the ITE Manual or other applicable ITE guidance and methodology was
followed in gathering this additional data from Lowes/Poway, when the intent was to use this data as
opposed to the Code 862 data from the Manual in the subsequent traffic analysis. If the answer is yes,
please provide cross references to ITE documents.
Was the City of Alhambra consulted prior to the collection of the data from Lowes/Poway - i.e., was the
need for this data and the collection methodology discussed and/or approved prior to the data collection.
Were any drafts of the traffic analysis provided to the City of Alhambra prior to its finalization? If yes,
did Kimley/Horn receive any written comments from City of Alhambra? Please provide these comments
and responses by Kimley/Horn.
Response 19.
As is typical of all traffic studies, the traffic consultant submits a preliminary (draft) study and makes
revisions as needed to finalize the report. In this particular case, changes to the project, including changes
to square footage and site access and circulation, were made after the initial draft, which necessitated
revisions to the report prior to its final submittal.

Email from Joe Cano, dated January 12, 2017.
Comment 20.
Please see the attached materials. By way of this email I am submitting my opposition to the proposed
development project on Fremont Ave. As of this day the public is not aware if the soil at this location has
been cleaned up let alone tested for contaminates from the former Alhambra Foundry. An Environmental
Impact Report has not been initiated as required by state law. Moving forward without any
Environmental study or final report is irresponsible just short of criminality. If this project is pushed
through for the sake of profit over safety then the City Of Alhambra, specifically the City Council, can be
found guilty of depraved indifference.
Response 20.
A detailed analysis was completed as part of the preparation of the IS/MND. Under CEQA, the only
circumstances where an EIR is required is if a Statement of Over-riding Considerations is required. This
finding is only required if there is a significant unmitigable environmental impact. The mitigation
measures that are included in the IS/MND is able to reduce the impacts to levels that are less than
significant.
Comment 21.
I will also be sending this to the State Of California CEQA board and the Federal Nation Environmental
Protection Agency. Hopefully these agencies will find the actions of the City of Alhambra in violation of
established pollution laws and exact sanctions & heavy fines against it and this planning commission.
(Mr. Canos attachments include a photo (attached below) and a video clip).
Response 21.
Email from Melanie Ulloa, dated January 12, 2017.
Comment 22.
I am reaching out to you today with concerns and question relating to the Alhambra Court Development.
As a resident of the Emery Park neighborhood with two children this is very alarming. I am concerned
about the safety and health of our children.
Response 22.
Thank you for the above comment. The IS/MND evaluates a number of issues related to health and safety.
The analysis included mitigation measures that would be implemented as a means to address hazardous
materials, air quality, traffic, and public services.

Comment 23.
One of my concerns is that there will be more traffic at the Fremont and Mission intersection and the
Emery Park neighborhood in general. Drivers already speed up La Paloma Avenue (the street I reside
on), which runs parallel to Fremont and is one block east of Meridian, to avoid the already congested
traffic on Fremont. Drivers already speed through Commonwealth. When we asked the representatives at
Lowes about traffic enforcement, their response was that their only concern was the immediate area of
the development traffic safety concerns in the neighborhood is not their responsibility. Also, at
the December 13th Informational Meeting, we were told there would be only one entrance on Meridian, but
now Ive seen the parking plan and there will be TWO driveways on Meridian? One for the trucks
delivering goods and another for the employees of the two office buildings. DID YOU FORGET THAT YOU
HAVE RESIDENTS HOW NEED TO LEAVE THE NEIGHBORHOOD TO GET TO WORK? The employees
of these office buildings will use the street I live on to cut through to get to work. How unsafe for the
children walking to school. Since Lowes or the Charles Company will not do anything to help with the
extra traffic that their development will bring, what will the City of Alhambra do to protect my children
from cars that speed down our streets to avoid traffic on Fremont? The City should put in speed bumps on
Meridian, Orange Grove and La Paloma streets between Poplar and Concord to reduce the speed of traffic
and to discourage cars from traveling through the neighborhood.
Response 23.
Comment 24.
Retailers like Lowes and Home Depot are known to have day laborers camped out on their premises. A
neighbor asked their representatives about their plans on handling the loitering and they responded by
saying once they loiterers are off their property, it is no longer a concern. Well, what concerns me is
where will these people go? Will they loiter the Emery Park Recreation center where they hold Mommy
and Me classes? Children who walk home from school will be prey to these new habitants. Will the
homeless population in our neighborhood increase? Will crime rates go up? What will the City do to
protect my family from a potential break-in? Will there be more officers patrolling the area?

Response 24.
The Lowes management indicated they do not anticipate that day labors will be located within the Lowes
development once the store is operation. The Lowes business model is directed more to individuals than
commercial contractors that would typically utilize day laborers. In addition, management at the Lowes
generally discourage loitering within their property.
Comment 25.
I checked the City of Alhambra Zoning Map and this parcel is zoned industrial. Has the parcel been
rezoned to accommodate a retail and office buildings? I believe that if it is to be rezoned, it needs to be put
to a vote. Is this correct?
Response 25.
The City Council made a previous determination that the proposed use is permitted within the IPD zone.
Comment 26.
The soil at the site is contaminated; there is a concern from neighbors about the effect on the air quality in
our neighborhood. Construction is expected to last three to five years for the entire project. There will be
loud construction sounds disrupting teaching at Emery Park elementary school, which is located less than
one half mile from this building. The loud sounds will disrupt the learning that is taking place. It seems as
if there is no concern for our young residents in the Emery Park neighborhood. Does the City have plans
to limit the noise and air pollution while construction is taking place?
Response 26.
The environmental analysis included in the IS/MND included a description of the potential noise and air
quality impacts related to both the projects construction and subsequent operation. In addition, the
IS/MND included mitigation that will be effective in reducing potential environmental impacts.
Comment 27.
Lowes promises to build jobs; however, let us not be fooled. These will be part time, minimum wage
paying jobs. We need to bring employers who will provide full time jobs with benefits. That will help
raise the quality of life for our citizens.
Response 27.
Comment 28.
How can the City of Alhambra vote on a project that will have such a huge impact on our community,
when it doesnt even have all the facts? Lowes was unable to give the residents a clear idea of how many
shoppers could potentially come into this store. Shouldnt the City have this information in order to vote?

If not, seems to me like you are voting with all of the pertinent information. If the parking lot is to be able
to accommodate the 1,396 cars, it seems that there would be that much more traffic on our streets. It is
irresponsible for Lowes and the City of Alhambra to think that this development will not impact the traffic
at Fremont and Mission.
Response 28.
The IS/MND included a detailed traffic analysis that identified new traffic that would be generated by the
proposed project. The ultimate number of shoppers that would potentially be inside the new building would
be limited to the occupancy load of the new building. Finally, the proposed project will adhere to the Citys
off-street parking requirements.
Comment 29.
It is a shame that none of the City Council members nor the Mayor of Alhambra were at the Informational
Meeting held on December 13th. Their absence speaks volumes. Please let them know.
Response 29.
Comment 30.
Lastly, this project effects ALL the residents of the Emery Park area; why hasnt more outreach been
done? Statistics show that 48% of Alhambra residents are of Asian descent, but the Information letters
were sent in only one language? There are several of my neighbors who received both letters but could
not read them because it was in English only. What is the city doing to reach out to its non-English
readers? Thank you for your attention to this matter.
Response 31.
The comment is noted for the record. The City, as part of this CEQA review process exceeded the State
requirements. For example, the staff required the Applicant to conduct an informational meeting and
extended the comment period.
Email from Zoe Wu, dated January 12, 2017.
Comment 32.
My name is Zoe Wu, a resident in the Emery Park neighborhood. I am really concerned about the gigantic
Lowe's project on Fremont. 3 6-story buildings and the Lowe's Store would seem to create a lot of traffic
on the already crowded 2-lane Fremont. All the traffic will pour into West of Fremont in order to get
into/out of the plaza from Meridian. That is to say, the traffic in the residential streets of Emery Park will
be greatly impacted, and the streets will no longer be safe for the kids who are going to the Emery Park
School. This project is way too big for these small streets.

Response 32.
The comment is noted for the record. A traffic study was prepared for the proposed project that
documented the traffic impacts.
Comment 33.
The city does not seem to have done a reliable study on the impacts of the traffic. We need this done.
Please hear us. Thanks.
Response 33.
The comment is noted for the record. As stated previously, a traffic study was prepared for the proposed
project that documented the traffic impacts. The comment does not cite any specific short-comings will the
traffic analysis.
Email from Mrs. Khan, dated January 13, 2017.
Comment 34.
In regards to the proposed commercial development including the addition of Lowe's to Fremont, please
answer a few questions of mine:
What exactly is the plan to reduce the traffic jam on Fremont Ave during rush hour? What are the
alternate routes and how many people are anticipated to travel on each? What is the estimated increase in
commute time during rush hour? Has there been any analysis done on this matte? Please remember that
we already have a traffic jam problem, so I'm not only asking about future traffic jam created by the new
development, but also the current massive traffic jam.
Response 34.
Comment 35.
What exactly is the impact of this commercial development? Please provide a 5-yr and 10-yr projected
income to the city of Alhambra.

Response 35.
The comment is not a CEQA issue. The economic impacts/benefits of a project is not a specific CEQA issue.
As part of the preliminary analysis, it was determined that the proposed commercial development would not
lead to urban decay elsewhere in the City.
Comment 36.
What is the impact on the residential property values? Please provide a solid analysis report based on
Alhambra, not a "similar to this city" report.
Response 36.
The projects adverse impacts/benefits on property value is not a CEQA issue and was not considered in the
IS/MND.
Comment 37.
How does the timeline of this potential construction clash/match up with the potential construction of 710?
How much more traffic can we anticipate as a result of these two construction going on concurrently?
Response 37.
It is our understanding that Caltrans has eliminated the I-710 extension project from near-term freeway
construction plans.
Comment 38.
What is the environmental impact (i.e. pollution) to the residents of Alhambra with these constructions? I
would greatly appreciate your detailed response to my questions.
Response 38.
A detailed analysis of the projects short-term construction related impacts is provided in Section 3.3.D,
beginning on page 54 of the IS/MND.
Email from Rita Ramirez, dated January 13, 2017.
Comment 39.
I am AGAINST having Lowe's built on Fremont. There is so much traffic on Fremont Ave already. I love
Home Depot and they carry plenty of goods there. We also have Costco which also has appliances. Easy
access going into Home Depot without any congested traffic!! Keep LOWE'S out of Alhambra!!!
Response 39.
Comment noted for the record. The traffic analysis analyzed the proposed projects traffic impacts to
Fremont Avenue.

Email from Daniel Solorzano, dated January 13, 2017.
Comment 40.
Dear Ms. Pace, I am a 30-year resident of Alhambra and live with my family on 501 Westminster Avenue
in the Emery Park Community. I attended the Information Meeting on December 2, 2016 regarding the
Lowes Development in the area between Fremont and Meridian Avenues. I have two major concerns.
First, at the Meeting a number of important concerns of our neighbors were expressed regarding the
increased traffic in the streets to the north of the Lowes Development along Concord, Commonwealth, and
Popular. Also, my worry is the increased traffic also along the following streets: La Paloma, Meridian,
Orange Grove, Westminster, Westboro, Winthrop, and Westmont. Traffic is already a problem in our
neighborhood and I would hate to see us petition the City of Alhambra for more stop signs and speed
bumps to slow and discourage traffic in the area. Those issues werent adequately addressed at the Dec.
2nd Information Meeting.
Response 40.
truck traffic from going northbound from Meridian into the residential neighborhood. The IS/MND
included a detailed traffic analysis and a stand-alone traffic study.
Comment 41.
My second major concern was not addressed at the Information Meeting. As you drive north on Meridian
Avenue off Mission Road there are more than 30 trees that line the east side of the street from the end of
the Alhambra Foundry property line to Emory Park (where we held the Information Meeting). The Kohls
Property seemed to keep the trees at the back of their parcel and the Alhambra Foundry has kept the trees
in the front of their storage yard. I trust that the Lowes Development will do the same and preserve those
magnificent trees along Meridian Avenue. I thank you in advance for sharing this with those who will
make the final decisions regarding our concerns on the Lowes Development.
Response 41.
The proposed project will require the removal of eight street trees located along the sites western property
line along Meridian Avenue and approximately 30 trees in the westerly portion of the project site. Title 14
(Parks and Public Grounds) Chapter 14.08 Trees and Shrubs of the City of Alhambra municipal code
serves as the Citys Tree Ordinance. None of the affected trees are heritage trees.

Email from Laura Telles, dated January 13, 2017.
Comment 42.
I attended the meeting on December 13, 2016. I am a 30 year plus resident of Alhambra. I have lived at
my property in Emery Park since 1991. One of the reasons we bought in Emery Park was because of the
single family homes and the quiet tree lined streets.
Response 42.
Comment 43.
With this new proposed project (Lowes, etc) I have a concerns it will bring much traffic to streets that are
already congested. It is critical that the community be involved in the planning. The answer to only
notify the immediate surrounding community members is inconsiderate and can only make a community
feel as though this project is being imposed rather than the community members are active participants in
the planning process.
Response 43.
The comment is noted for the record. The City has required the Applicant to conduct to the workshop cited
in the above comment to maximize community input. In addition, the IS/MND in Section 3.16 included a
comprehensive traffic analysis.
Comment 44.
The neighboring community also needs to be notified, El Sereno residents as traffic will also increase for
them.
Response 44.
Comment 45.
One last major concern are the 30 plus trees either on property and the walk-way of Meridian. It is
critical that the very large trees be saved!
Response 45.

Comment 46.
I thank you in advance for sharing my concerns with those individuals who are making the decisions. I
also recognize you are new to your job and those who asked you to attend the meeting alone as a new
employee were not invested in really answering the communitys questions.
Response 46.
Email from ckool63, dated January 15, 2017.
Comment 47.
I live on la Paloma and concord, which is 1 block east of emery park school, I block west of Fremont. I have
been here over 10 years and the traffic as it is now is terrible during morning and evening hrs. they use la
Paloma to bypass traffic on Fremont and use Concord to go west. many speed down and make rolling
stop or in some cases run the stop. Im waiting to see when a fatal accident is going to occur. I'm surprised
it hasn't yet. La Paloma asphalt is in need of repair. this is going to create more traffic around the school
and surrounding area. the city needs to do a traffic study and the police dept need to do a little traffic
patrol. thank you
Response 47.

3. COMMENTS & RESPONSES TO COMMENTS RECEIVED THROUGH A PHONE CALL

Comments Received Via Phone Call from Shirley Mollen, dated January 12, 2017.
Comment 1.
Traffic is horrible.
Response 1.
Comment is noted for the record. A detailed traffic study was prepared for the proposed project. In
addition to this stand-alone traffic study, the report was incorporated directly into the IS/MND. The traffic
study included a detailed description of the existing traffic conditions and the study area. The traffic
analysis then projected future traffic that would be generated by the proposed project. This net increase in
traffic was then added to both the existing traffic volumes as well as the future traffic volumes without the
project that would be expected in the near term. As part of this analysis, the traffic engineer worked closely
with the City to identify the location and extent of the study intersections and how this future traffic would
be distributed onto the local streets. Mitigation was proposed that would facilitate traffic flow on Fremont
and Meridian, as well as eliminating truck traffic from going northbound from Meridian into the residential
neighborhood.
Comment 2.
Additional traffic on Meridian will impact the safety of the children at Emery Park School.
Response 2.
Comment 3.
The project is not a good thing and opposes it.
Response 3.

4. MOST RECENT COMMENTS RECEIVED BY EMAIL
Email received from John Rodriguez and Christine Rodriguez, dated January 16, 2017
I am a resident of Alhambra, the Emery Park area since 1976. Despite the traffic I am for the Lowes store.
I attended the last meeting held on Dec.13,2016. A majority of the local residents were concerned about the
traffic. My suggestion is to build back the railroad overcross that Alhambra once had on Westminister to
alleviate the traffic grid lock on Valley Blvd and Fremont Ave..
I am opposed to building the two office buildings #1 and #2 because that would just add even more traffic.
On the information sheet provided by the City of Alhambra it specifies that the parking structure will
accommodate 982 car spaces thats more than double the Lowes car space which is 414. That only adds to
more traffic and does not serve the community well.
Our community does not need two six story buildings that will cover our beautiful mountain view.
Alhambra already has enough high rise buildings which I thought should have never been built. The City
of Alhambra has failed to make significant improvements concerning our traffic conjestions.
I and other residents are for the extension of the 710 freeway to continue up to Huntington Dr. to alleviate
our taffic on Valley Blvd.and Fremont Ave.
I am opposed to the ridiculous 710 freeway tunnel for many reasons.One of the main reasons is the cost to
build the tunnel.It will be a straight away thoroughfare with no exits. Other serious considerations for my
opposition to the tunnel is the possibility of an earthquake or a terrorist threat, a possible bomb in the
tunnel. How will emergency units come to assist if there are no accessible entries or exists. The tunnel will
be a toll tunnel. Once again the local citizen will have to dish out the money for the ridiculous tunnel idea
costing us not the government.
Email received from Mona Anolik, dated January 16, 2017
I live on Meridian at Popular streets. I really oppose this development number one reason is Emery Park
school and the traffic. Already people drive too fast and is used as an access to other streets. Are they
going to fix the existing potholes that are pretty bad and will only get worse with more traffic. Probably
not. Safety is number one for the children. Thank you for your support.
Email received from Helen Padilla, dated January 16, 2017
We have lived on Meridian Avenue near Main Street for almost 20 years. In that time we have seen the
traffic increase tremendously. Because it is a two way street that goes straight through to Mission, we
have experienced first hand the dangerous speeds at which cars zoom by. Our car has been side swiped
twice taking off the mirror because people insist on squeezing by without slowing down or even granting
each other the right of way.
We are not opposed to the Lowe's development but certainly are concerned about how it will impact an
already dangerous situation especially since we do have the elementary school just down the block.

Perhaps Meridian Avenue can be changed to a ONE WAY street either north or south depending on your
studies.
Also, we have observed over the last year that the grass meridians on Main Street (from Fremont to
Meridian Ave) are consistently trashed by what appears to be a recycling truck. There are magazine,
newspaper pieces strewn all along the street and grass. This happens almost every week or two. We see
the city workers clean it up and again it happens. This creates an eyesore and makes the community look
trashy.
If you are planning to bring in more customers that will most likely be using Meridian Ave to get to this
complex then this also is a concern for your study. Alhambra has experienced much growth over these
many years. We hope that it will continue to be done in a manner that maintains what is a safe and clean
community.
Email received from Joe Potts, dated January 16, 2017
Although many cities assume that the development of shopping centers and big-box stores will yield a
financial windfall, the tax benefits often prove to be a mirage. When evaluating a retail development
proposal, developers and municipal officials often focus on only one side of the equation: the amount of
new tax revenue that the project will generate. It's easy to overlook the fact that retail development also
creates new costs and often leads to a decline in tax revenue from existing commercial districts. In the case
of big-box stores and strip malls, these costs and revenue losses can be so high that they reduce the overall
tax benefit of the development to a negligible trickle or even result in a net loss for the city. In California,
cities are constrained in their ability to raise property taxes and therefore depend more heavily on local
sales taxes and various fees.
In general, there are three main costs that cities commonly overlook:
First, because consumers have only so much money to spend, sales at a new shopping center are
invariably mirrored by sales losses at other businesses in the region. An equivalent drop in sales tax
revenue from other retail areas in turn matches the sales taxes generated by the new development.
Second, in California, strict caps on property tax rates have forced cities to rely primarily on a local sales
tax, sparking fierce competition to attract big-box stores and shopping Malls. But despite extensive retail
development over the last twenty years, the amount of sales tax revenue that California cities are raising
per capita has remained the same. Some cities can become tax winners by playing host to a new shopping
center that draws customers from nearby cities, but these gains are usually fleeting. It's only a matter of
time before that new shopping center is eclipsed by an even newer retail development that pulls shoppers
to another town. Some evidence suggests big-box stores may not even produce a temporary revenue gain.
One study of 116 cities in California found that, in all but two cases, the presence of Wal-Mart, Target,
Costco, Kmart, or Sam's Club stores did not correspond to increased sales tax revenue.
Third, neighborhood and downtown business districts, as well as older strip malls and even big-box
stores, are often harmed by new retail development. As these areas lose sales and experience growing
vacancies, the value of the property declines and, with it, the tax revenue. Allowing older commercial

districts to deteriorate, while fostering retail development elsewhere, also wastes public resources. Public
investment in the roads, water lines, and utilities that serve older retail areas end up sitting idle or
underutilized, while taxpayers foot the bill for new infrastructure to serve the new big-box store or
shopping center.
Big-box development also creates substantial direct costs. Every time an older development succumbs to a
new shopping center, the local government incurs new expenses for maintaining roads, water and sewer
lines, and police and fire services. Traditional main-street business districts, because of their density and
compactness, are very efficient users of public infrastructure and services. Sprawling big-box stores are
not. They require more road maintenance, additional utilities, and more fire and police time. One case
study found that the annual cost of providing city services to traditional downtown and neighborhood
business districts was $786 per 1,000 square feet of retail space. Big-box stores were 30% more costly,
requiring $1,023 in services per 1,000 sq. ft., while strip malls where even more expensive at $1,248. Most
of this difference is due to additional costs for road maintenance and police services. Because big-box
stores generate substantial car traffic and typically increase the number of road miles that residents
travel for shopping, cities end up having to spend more on road maintenance. Although developers may
offer to pay for new traffic infrastructure (turn lanes, signals, etc.), the real issue is ongoing operational
costs. Big-box stores also require substantial police services. This is partly because the added traffic
generates more accidents and necessitates more policing. It's also due to the fact that big-box stores
generate large numbers of police service calls far more on average than local retailers do on a per
square foot basis. Many of these calls are for shoplifting.
The Bottom Line for Cities Once the full range of costs are factored in, retail development can end up being
a net drain on city finances. Not only does main-street retail produce lower services costs, it also
generates more property tax revenue per square foot, because these retailers occupied higher-value, often
historic, buildings. In one study, the net result was that the main-street retail produced an annual tax
surplus of $326 per 1,000 square feet, while big-box stores cost the city $468 more per 1000 sq. ft. than
they contributed in tax revenue.
Studies also find that big-box flunks the definition of economic developmentand therefore should not
get subsidiesbecause it packs such a lousy bang for the buck compared to almost any other economic
activity. To measure the ripple effects of a new business, you look upstream to see how many supplier
jobs the region would gain, and then you look downstream to see how many jobs would be created by
the buying power of the people who work at the business. The upstream of a big-box store creates very few
jobs for the local economy (i.e., Made in China), and the downstream ripple effects are terrible because
retail jobs are overwhelmingly part-time and minimum wage.
That means most retail workers have very small disposable incomes: after paying for bare necessities,
they have little left with which to stimulate the local economy. Building new retail space just moves sales
and lousy jobs around. It doesn't grow the economy.
There is only one justifiable time to subsidize retail: to help revitalize a truly depressed neighborhood that
lacks basic retail needs such as food, prescriptions and clothing. In all other situations, subsidizing retail
is a waste of money that could be better deployed creating better jobs and stronger ripple effects.

As Alhambra contemplates another big-box store moving in, lets do all that we can to make very sure that
Lowes is not subsidized by the taxpayers as they will do long term damage to Alhambras financial
stability.
Email received from valvarez, dated January 16, 2017
As a resident of the Emery Park area, we request that the planning commission conduct a comprehensive
study on the hazards and traffic.
Email received from Anson Gong, dated January 16, 2017
My wife and I live with with our 3 children in the Emery Park neighborhood of Alhambra. I am opposed to
the Lowes and office building development on Fremont due to the increased traffic (on fremont and
meridian), with corresponding noise and air pollution.
I ask that a comprehensive environmental impact study be done for this proposed project and shared with
the public BEFORE any review be made by the city planning commission. Thank you
Email received from Efren Moreno, Jr., dated January 16, 2017
I am submitting my concerns regarding the above development. As much as having a Lowe's will benefit
the residents of Alhambra and bring revenue to the city, the location is worst possible location it could be
built.
First, is the additional traffic this development will bring to an already heavily impacted thoroughfare.
The traffic will be so bad it will force cars to find other routes to get past the area and cause more
pollution and increase the danger to pedestrians and cyclist in the surrounding areas of the project.
Second, from reading the article in the Alhambra Source, the development is not allowed because of the
zoning, and the interpretation by city staff is wrong and not substantiated.
Lastly, since the Lowes development does not fall under the zoned land use, please consider using some to
the land for to create more open green space, such as a dog park, a city youth center, or a performing arts
center.
Email received from Sean McMorris, dated January 16, 2017
Please see attached my public comments regarding the proposed development on 875 and 1111 South
Freemont Ave. that goes before the Planning Commission for a vote on Tuesday.
The proposed development on 875 and 1111 South Fremont Ave. appears to violate the city's zoning laws
regarding that area of the city. The parcel of land on which the proposed development on 875 and 1111
South Fremont resides is designated for Industrial Planned Developments (IPD). A Lowes home
improvement store does not fall within the IPD category according to Chapter 23.32 of Alhambra's Zoning
Code.
I understand that a former Alhambra Development Services Director and Assistant City Attorney

interpreted IPD zones to be retail inclusive, specifically noting the inclusivity of home improvement supply
stores even though such stores are not specifically identified in Alhambra's IPD zoning code. The
interpretation was then passed by the City Council in 2010 as consistent with the City's Redevelopment
Plan.
Yet, the Development Services Department's IPD Zoning Interpretation submitted to the City Council on
June 28, 2010, supplies no evidence to back its claim that "Building material sales and/or home
improvement supplies sales are likely to be less intensive in terms of potential omission of odor, dust,
smoke, noxious gases, and hazardous materials and waste materials than many of the specifically
identified permitted uses in the IPD zone," nor does such a justification address the legality of permitting a
facility in an IPD zone that the city's zoning code clearly disallows. On the contrary, point 2 of the
Background, Facts, and Analysis of the Development Services Department's IPD Zoning Interpretation
provided to the City Council in 2010 submits that "the permitted uses in IDP Zones are fairly restrictive to
industrial and commercial uses."
Thus, I and others in the community find this interpretation to have no legal or scientific merit since its
conclusions are based solely on conjecture. What is more, it appears that the interpretation was made out
of convenience to City Hall's economic and development goals at the time rather than sound reasoning,
independent study, legal analysis, precedent, and careful consideration for the long-term impacts on
traffic, the environment, health and safety, and the effects on sustainable living in Alhambra. Point 8 of
the Background, Facts, and Analysis of the Development Services Department's IPD Zoning Interpretation
appears to concede this point when stating:
In the event owners, investors, developers, and building material sales

businesses and/or home improvement supplies businesses are aware of the
uses being permitted in the IPD Zone, the more likely such a building business
would move towards acquisition and development in the district and
redevelopment project area.
In short, such an interpretation appears not to be legally and scientifically grounded, but economically
and politically motivated. Thus, it would likely not stand up in a court of law.
In addition, and perhaps more importantly, politically and economically motivated interpretations of
ordinances and zoning codes null the purpose of legislation, which disenfranchises the community at
large, diminishes residents' faith in their local government, and ultimately weakens the democratic
process.
I hope the Planning Commission will call on the city to thoroughly address these concerns before voting on
this development project.
It is extremely concerning that a Mitigated Negative Declaration (MND) has been accepted by the City in
lieu of an Environmental Impact Report (EIR) as fulfillment of California Environmental Quality Act
(CEQA) requirements. The CEQA website outlines when it is appropriate to use a NMD in place of an EIR
as follows:

A Negative Declaration can be prepared only when there is no substantial evidence in light of the
whole record before the lead agency that the project may have a significant effect on the
environment. (PRC 21080(c)), (14 C.C.R. 15070)
An EIR must be prepared when there is substantial evidence in the record that supports a fair
argument that significant effects may occur. (PRC 21080(d))
Given that the proposed development on 874 and 1111 South Fremont is a designated Super Fund site and
sits adjacent to one of the busiest streets in the region, I fail to see how the City can justify the acceptance
of an MND over an EIR based on their conclusion that "substantial evidence" does not exist that such a
large retail project will have a significant effect on the environment, not to mention residents' livelihoods.
I have not seen any evidence supplied by the City or its lead agency to substantiate such a conclusion. On
the contrary, I have spoken to several experts and looked over numerous documents that indicate there is
substantial evidence that the type of development being proposed on 874 and 1111 South Fremont will
result in negative impacts on the environment and health and well-being of the community.
Furthermore, the data and analysis in the MND appears to be extremely flawed and its conclusions
spurious. For instance, the traffic study portion of the MND breaks with standard protocol by not using
the Institute of Transportation Engineers Trip Generation Manual (TGM) to calculate ALL of the trip
rates for home supply stores like Lowes. The study's authors utilize the TGM trip rate calculations only for
non-peak hours on weekdays and weekends and rely on trip calculation data from a Lowes in Poway to
calculate peak trip hours on weekdays and weekends. Why? This is extremely suspect and the study's
justification, or lack thereof, does not hold water. Poway is a much smaller, less urban city than
Alhambra. It is troubling that the study would rely solely on the data collected by one Lowes in Poway to
calculate peak hour trip rates as opposed the average calculated peak hour trip rate from data collected at
multiple Lowes stores in cities similar in size and layout to Alhambra. It is also troubling that the study
would use two different data sets for different hours of the day.
The study also contradicts itself when claiming, without evidence or precedent, that the same standards
that apply to a Home Depot do not apply to a Lowes because a Lowes "sells home improvement items
geared more to homeowners whereas Home Depot stores sell items geared more to small contractors." If
this statement were true, and there is no evidence supplied to prove that it is, then how do the study's
authors justify using TGM trip generation rates that are associated with Home Improvement Store land
use, which includes Home Depots, to calculate non-peak hour trip rates on weekdays and weekends for the
proposed Lowes development on Freemont? Regardless, the data used is inconsistent and suspect, which
negates the study's conclusions.
I urge the planning commission to require the city to adequately address these concerns before voting on
It is unreasonable and undesirable to leave the land on 874 and 1111 South Fremont undeveloped. I and
others are not asking the city to do this. What we are asking the city to do is to develop the land in a way

that is most beneficial to Alhambra residents, which takes into account livability, necessity, and economic
and social sustainability in both the short and long-term. I and others feel that another large home
improvement store that is literally blocks away from a pre-existing large home improvement store is not
only unnecessary, but detrimental to the Alhambra way of life.
The planning commission is the primary check and balance to the City Council regarding development in
Alhambra. Even though planning commissioners are appointed by City Council members, they are less
influenced by moneyed interests because they do not receive campaign contributions from developers.
This should allow Alhambra's Planning Commissioners to make uncompromised decisions about
development and its net-affects on Alhambra residents.
To this end, I urge the Planning Commission to disregard any politically motivating factors when voting
on this matter, and instead rely solely on the evidence and facts, Alhambra's zoning code as written in the
City's charter, and the environmental and social impact of such a development in an already overly
congested area of the city.
Thank you for the opportunity to comment on this important city matter.
Email received from Eric Sunada, dated January 16, 2017
Over the weekend, I noticed that the posted agenda and information package for tonight's hearing on the
Alhambra Court Development acknowledged receipt of Ron Sahu's letter, but the letter itself was not
included in the package. Was this an oversight or was there a specific reason?
Email received from Jim Rodriguez, dated January 16, 2017
As an Alhambra resident and homeowner on Meridian ave for over 48 years, I am very concerned about
the impact the proposed building project for a Lowes store, and two office buildings will have on our
community. These proposed new business will increase the traffic on our street significantly, and with the
Emery Park School, will increase the potential for major safety issues.
The Alhambra planning commission needs and must conduct a comprehensive study on the traffic, noise,
air pollution, and various other hazards before they approve this project.
In researching the traffic activity at various other Lowes locations, traffic was about 5,000 to 8,000 cars
per day. We are a residential community, not a commercial business area, and this project would have a
severe detrimental impact on our community. We already have a Home Depot just a few blocks way,
which meets the needs of our community.


PART III
& INITIAL STUDY

LEAD AGENCY:
CITY OF ALHAMBRA
REPORT PREPARED BY:
FEBRUARY 16, 2017

ALHM 001
COMMENTS & RESPONSE TO COMMENTS PART III PAGE 179


TABLE OF CONTENTS
Section Page
1. Additional Comments & Response to Comments.................................................................. 182
2. Comments & Responses to E-mails that were Received ...................................................................... 207
3. Most Recent Comments Received by Email ..........................................................................................210



Melissa Michelson, Resident of the City of Alhambra

Carily and Stephen Mesi, Residents of the City of Alhambra

Bryan Moscardini and Teena Santiago, Residents of the City of Alhambra

Peggy Toney, Resident of the City of Alhambra

Melissa Michelson, Resident of the City of Alhambra

Pablo Saucillo, Resident of the City of Alhambra

Stephen and Carily Mesi, Residents of the City of Alhambra

Tom Williams, Resident of the City of Alhambra

Jeramy Gerami, Resident of the City of Alhambra

Ray Gonzalez, Resident of the City of Alhambra

Bryan Moscardini and Teena Santiago, Residents of the City of Alhambra

Robert Franco, Jr., Residents of the City of Alhambra


Mona Anolik, Resident of the City of Alhambra

Helen Padilla, Resident of the City of Alhambra

Joe Potts, Resident of the City of Alhambra

valvarez, Resident of the City of Alhambra

Anson, Resident of the City of Alhambra

Efren Moreno, Jr., Resident of the City of Alhambra

Sean McMorris, Resident of the City of Alhambra

Eric Sunada, Resident of the City of Alhambra

Jim Rodriguez, Resident of the City of Alhambra


Melissa Michelson
Comment 1.
I have questions and concerns (see #A-Z and "Specific Questions about Traffic Study" below) about the
proposed project at 875 and 111 South Fremont, which I would like addressed at the upcoming Planning
Commission hearing. The project has been separated in to smaller project components over the years,
from demolition, hazardous materials studies, remediation, grading/filling, and now proposed
construction. I am concerned that each is being separately considered and exempted from CEQA process.
Response 1.
The current project in its entirety is described fully in Section 2 of the IS/MND. The demolition and the
subsequent remediation and clean-up activities were required by the various responsible and trustee
agencies. The proposed projects implementation will not be permitted to interfere with this clean up effort.
Comment 2.
If my questions and concerns cannot be addressed, I respectfully request that the Planning Commission
reject the agenda item until any and all issues with the project can be researched thoroughly in the form of
an Environmental Impact Report and when the General Plan for Alhambra is finalized, which should be
any month now. Should the Planning Commission rubber-stamp this project with only the Initial Study
done, Alhambrans are poised appeal your decision.
Response 2.
Comment 3.
Please provide the article number of Industrial Zoning Ordinance Chapter 23.32.020 that the Lowes falls
under. B) Please share what other projects have been put forward for this lot, that would satisfy the
ordinance.
Response 3.
The project conforms to all of the development standards identified for IPD zoned properties. As indicated
previously, the project will require the approval of an Industrial Planned Development permit. The IPD
permit application will permit the construction of the three new buildings. The IPD permit will also place
standards on the project to ensure the projects conformity with the applicable zoning designation. The
project in its current state meets the findings that are required for the approval of an IPD. These findings
are described as follows:

3-6).
Meridian Avenue.
Comment 4.
Please provide the number of full-time jobs with benefits and part-time hourly jobs Lowes will offer, D) as
well as a list of companies offering those jobs in the two office buildings.
Response 4.
The Lowes is projected to employ between 125 to 150 persons. Of this total, approximately 70% will be full-
time. The potential tenants for the office buildings are not known at this time.
Comment 5.
Vehicular traffic on major streets (Fremont, Mission, Valley) and Emery Park. Please provide a more
recent traffic and traffic signal study of the nearby major intersections. The one in your report is from 2
years ago, before the developments on Main Street. The only mitigation measure on Fremont would be a
traffic signal. Please provide a comparison of the number of cars estimated on Fremont with and without
the new Fremont traffic signal at peak and off-peak times. Also:
What is the estimated number cars using the 5 driveways on Meridian on a daily basis?
What is the estimated number of trucks using the 5 driveways on Meridian on a daily basis?
Please provide a comparison of # of cars currently on Fremont during peak rush hour times
between Poplar and Valley, and J) how many that will be if a Lowes and the 2 office buildings are
operating at full capacity. K) How much time will it add to commuter's trip when travelling south
from Poplar to Valley.

Response 5.
The number of peak hour vehicles traveling along Fremont adjacent to the project site during the peak
hours is currently 3,827 in the morning peak hour and 2,727 in the evening peak hour. The traffic study
estimates that the project would add 75 AM peak hour and 84 PM peak hour trips to this segment of
Fremont. The project site plan shows 4 project driveways on Meridian and 4 on Fremont. Varying amounts
of project traffic will enter and exit the site to and from each of the driveways. The traffic study estimates
that the project would add 40 AM peak hour and 43 PM peak hour trips to Meridian to the north of the
project site, and 98 AM peak hour and 90 PM peak hour trips to Meridian to the south of the project site.
The potential for the closure of Meridian at the northwest corner of the project site was not contemplated
and therefore not studied in the traffic study. The applicant has been conditioned to evaluate the feasibility
of this closure.
There will be between 3 to 6 trucks a week from January to March first and from August to December.
From March to July which is the busy season for Home Improvement stores, the truck traffic increases from
6 to 10 trucks a week. The site plan and site driveways are designed so that trucks approach the site on
Meridian from the south, and exit onto Fremont, to minimize the number of project-related trips on
Meridian to the north of the site.
Comment 6.
Other than that it is a stand-alone home improvement store, L) please provide the criteria used to
compare a Lowes in Poway, CA https://goosilimaps/pifC6FGbG9m (half the population of Alhambra, in
a rural part of San Diego county) to a Lowes in Alhambra. The Trip Generation Rates report by Crown
City Engineers claims the Poway Lowes is "comparable in size and location". How is the 'location' of
Poway comparable to the location of Alhambra?
Response 6.
Being a stand-alone site is a key criteria for conducting site driveway counts for a particular use. In
addition, the Poway Lowes is a 153,000-square-foot store, compared to the proposed 134,417-square-foot
store. Both have a garden center. Both are located along a commercial corridor, with residential
development nearby. A Home Depot store is located near the Poway Lowes store - just over a mile away.
Comment 7.
Driveways on Meridian + use of Emery Park side streets, right past elementary school. I'm very
concerned about the traffic that will avoid Fremont (either southbound or northbound) and head into
Emery Park neighborhood to access the 5 driveways behind Lowes. An elementary school with 435
students is on Meridian and Commonwealth, one of three entry points into Emery Park from Fremont.
Employees and Lowes consumers coming from Pasadena or north, will use Fremont and turn left on
Poplar, Commonwealth or Concord in Emery Park, and head right down Meridian, right past the
Elementary school (if coming from Poplar or Commonwealth).

According to Page 4-5 of the Traffic Study:
Driveway F- 2-lane, 28 foot-wide driveway, for shoppers at Lowes AND employees in office
buildings. That's enterable by Lowes trucks from Meridian, but N) How will it be designed so that
TRUCKS are forced to go south and not north, but CARS can go north AND south?
Driveway G- a 2-lane 46 ft-wide driveway- for the two 6-story office buildings and Lowes
employees and when coming to work or leaving for the day, they will come from or drive into
Emery Park, onto Meridian.
Driveway H- for the office buildings only. They will come from or drive into Emery Park, onto
Meridian
Response 7.
The project site plan shows 4 driveways on Meridian 2 primarily serving the office portion of the site and
2 primarily for Lowes. It is acknowledged that some project traffic may enter the site via the Meridian
driveways. Project design features have been included in the project to minimize project trips on Meridian
north of the project. The primary entrances for the project, including the signalized entrance, are designed
to be the driveways located on Fremont.
The truck entrance (Driveway F) will be angled to only allow arriving trucks to enter via a right turn
from the south on Meridian, and to prohibit trucks from turning right out of the site. A raised
median feature will be added to the center of Meridian to restrict left turns in or out of the driveway.
Trucks will be required to exit the site via Fremont.
Likewise, Driveway H will be angled to allow traffic to enter and exit only via Meridian to and from
the south.
As shown on the site plan, Driveway E and Driveway G will be standard driveways, which will allow
all turning movements.
As mentioned at the Planning Commission meeting on January 17, 2017, the applicant has been
conditioned to evaluate the feasibility of closing Meridian to through traffic near the northwest
corner of the site. If determined to be feasible, closing Meridian would have the dual effect of
eliminating not only project traffic on Meridian north of the project site, but also eliminating
existing cut-through traffic that uses Meridian through the Emery Park area.
Comment 8.
Provide a list of mitigation measures to reduce traffic into the Emery Park neighborhood from the north
and from the west of the project, not just a median or signage on Meridian at the driveway entry points.

ALHAMBRA COURT COMMERCIAL DEVELOPMENT TENTATIVE TRACT MAP (TTM 74223) AND INDUSTRIAL PLANNED Page 3
Response 8.
The site driveway design features, along with the median that are discussed above are the measures that
have been incorporated into the project design to reduce project traffic on Meridian north of the project.
These were assumed in the technical studies in the MND. The potential for the closure of Meridian is an
additional potential measure that will be evaluated by the applicant, as a condition of the project approval.
Comment 9.
At the Dec. 13 Informational Meeting, your department told the public that your study doesn't mitigate for
future or unforeseen impacts. Why, then, is the chart included from CalTrans' website projecting possible
traffic reduction on Fremont 15 years from now, should the 710 be connected, when you are not
considering the more immediate plans for development of 1,100 residential units across the street from the
site, which will add significantly to the traffic on Fremont?
Response 9.
The IS/MND considered those related projects for which applications had been received. Any extension
of the I-710 Freeway would have a beneficial impact associated with the diversion of through traffic on local
arterials. However, given the time frame and the uncertainty associated with the potential extension, it was
not considered in the traffic analysis.
Comment 10.
Lowes considers itself a competitor of Home Depot, as noted by its increased contractor services
competition with Home Depot. Please provide an actual daily trip comparison to the Home Depot on
Marengo, less than a mile away from the proposed site.
Response 10.
Actual daily trip data for the Home Depot on Marengo is not available.
Comment 11.
What other possible projects for this zone would better benefit Alhambran residents? For home
improvement, the closest Home Depot is less than 1 mile away in Alhambra, and there is an Orchard
Supply Hardware store in South Pasadena 3 miles away. There is a Lowes in Pico Rivera 11 miles away.
For other items that Lowes sells, there's a Target and Costco less than a mile away. I like Lowes, but
Alhmabran residents, the ones you are to represent as planning commissioners, do not need yet another
home improvement store in the area especially not in THAT location, the main thoroughfare for
Pasadena, South Pasadena and Alhambra, to get to the 710 and 10 freeways. Given that Pasadena has
ruled out connecting the 710 freeway and are looking into options to develop the 210 freeway stub, the
future looks bleak for 'closing the gap', so we cannot rely on a toll underground tunnel to save US.

Response 11.
The comment is noted for the record. The current application for the project involves the construction and
operation of a Lowes. The CEQA analysis is not permitted to analyze the economic feasibility of the
application.
Comment 12.
What is the annual revenue for the City that would be generated by this project. T) What % does that make
up for Alhambra's total revenue. What tax breaks are being given to Lowes Corporation?
Response 12.
The direct economic benefit to the City from the proposed is not a CEQA issue.
Comment 13.
On the traffic study, page 43, mention is made of a potential 710 freeway extension. If that is being
included in this study for the year 2030--14 years from now-- then future building plans and other local
projects in Alhambra need to be included, like the General Plan.
Response 13.
Any extension of the I-710 Freeway would have a beneficial impact associated with the diversion of through
traffic on local arterials. However, given the time frame and the uncertainty associated with the potential
extension, it was not considered in the traffic analysis.
Comment 14.
How is the Planning Commission mitigating future growth in the area?
Response 14.
Larger projects that are CEQA project are required to undergo environmental similar to that being
undertaken by this proposed project. When warranted, these other project will be required to mitigate their
project-specific impacts.
Comment 15.
Please provide a list of development projects that are in progress and around Alhambra. (e.g. the
Ratkovich Company that owns The Alhambran across the street plans to build 1100 residential units on its
property across the street; also the project on Commonwealth across from Costco...). How does this
project fit in with the General Plan of Alhambra for the future 10 years?
Response 15.
The list of projects that had submitted applications to the City at the time the IS/MND were included in the
analysis. The proposed project is consistent with the City of Alhambras General Plans Land Use Element

in that no General Plan Amendment will be required.
Comment 16.
What projects are expected to be completed between 2015-2020 and why only 5 years? Are those projects
in all of LA County, as are listed in the Congestion Management Plan? Why isn't the CMP plan also
included in this study?
Response 16.
The Los Angeles County Congestion Management Program (CMP) is a state-mandated program that is
administered by the Los Angeles County Metropolitan Transportation Authority (LACMTA). Compliance
with the CMP requirements ensures a citys eligibility to compete for State gas tax funds for local
transportation projects. The CMP sets forth reporting and compliance requirements for participating cities,
in order for them to remain eligible for gas tax funds; it does not address or name specific projects.
Comment 17.
Specific questions about your Traffic Study:
When was the last traffic study done by our own Traffic Commission, which between 2014-2016
has only met a handful of times? Please conduct a regularly updated Traffic Impact Study and use
that to study this project. Since May 2014, it had been revised every few months, but between Sep.
2015- Nov. 2016, it's not been updated. The traffic counters study used was from 2015. (It is also
being referred to for the plaza on Commonwealth across from Costco.)
Why is there a 20% pass-by reduction to that # (4132/day becomes 3306/day for example) for
hardware/ lumber stores, when elsewhere in the mitigation study and what Lowes itself told the
community on 12/13/16, Lowes is being considered a RETAIL store? (p. 17)
On page 23 of Traffic Study, Table 3, it says the same intersections will continue to "operate at
unacceptable levels of service." So why would the Planning Commission make that worse?
On page 29, it says that in year 1, the three main intersections will operate deficiently. What will
be used to mitigate that?
One of the Turning Movement study was taken from 2014, another from 2015 ! The population of
the area has increased then! If the commission is truly serious about mitigating traffic, it would
use up to date studies that reflect current traffic trends, not outdated studies.
How will Mitigation Measure #27 be done to prohibit construction vehicles from traveling north
on Meridian?

Response 17.
Specific responses to the above comments are listed below.
The Traffic Commission is an advisory body that addresses traffic conditions and recommendations
in the City; it does not conduct traffic studies.
The pass-by reduction of 20% is consistent with the standards used by the Los Angeles Department
of Transportation for home improvement stores. The pass-by rate in the Institute of Transportation
Engineers (ITE) Trip Generation Manual (9th Edition) is actually much higher at 48%. The use of
the Los Angeles standard of 20% was a very conservative assumption.
In addition to reporting the Existing and Projected intersection Level of Service, the Traffic Study
also reported the projects projected impact, and whether or not that impact would meet the
threshold for significance. The project is required to provide mitigation where its impact is
determined to be significant. A project cannot be required to remedy existing congested conditions.
The traffic count data was current (taken within a one-year period) at the time the study was
undertaken. Although it was not required, because of the time that had passed during the course of
the study, an annual growth rate was applied to the counts for the Existing conditions analysis.
Haul routes and travel paths for construction traffic will be identified in the Construction Traffic
Management Plan that will be required of the project, and will be enforced.
Comment 18.
This site is too large and encompassing to treat it like a small site that doesn't need further study, and it
should be thoroughly studied with an EIR and taking Alhambra's soon-to-be finalized General Plan for
sensible and responsible city planning.
Response 18.
The comment is noted for the record. The initial study that was prepared for the proposed project indicated
that an EIR was not required.






Carily and Stephen Mesi
Residents of the City of Alhambra
Comment 1.
We are 37 year residents of Emery Park and are writing to voice our deep concern over the planned
development of two parcels on the western side of Fremont Avenue, north of Mission. We are informed
that the site (which was previously occupied by several industrial facilities) will be used for a Lowes
Home Center, several smaller shops and a large residential development.
Response 1.
No specific response is required.
Comment 2.
Leaving aside that the new development may enhance the City treasury and possibly bring additional
jobs, there are presently numerous drawbacks that must be considered. Significant Additional Traffic on
Fremont Ave: Fremont Avenue is already extremely congested, especially during rush hours and is only
two lanes in each direction. Our neighborhood has already experienced an unpleasantly large increase in
through traffic since Costco opened several years ago and more traffic is not wanted.Streets such as
Poplar Boulevard are overtaxed and not being properly maintained. Moreover, claiming that public
transportation will ameliorate the traffic situation is disingenuous. Who goes to a Home Depot to shop in
anything but a car or truck, in order to bring bulky building supplies purchased back home??
Response 2.
The traffic study has reported the existing intersection Level of Service, and has acknowledged that some
locations are operating with congested peak hour conditions. The project will provide mitigation where its
impact is determined to be significant, but cannot be expected to remedy all existing congestion. The Traffic
Study did not claim that public transportation will ameliorate the traffic situation. A 10% mode shift
reduction in trips was assumed for the office portion of the project, for employees who use alternative travel
modes to and from the site, such as public transit, ridesharing, biking, or walking. No mode shift reduction
was assumed for the Lowes traffic.
Comment 3.
Does Alhambra really need a Lowes at this location? The planned location is less than a mile from
another large building supply center (Home Depot) that has served the area for many years.
Response 3.
The Lowes is an application that was submitted to the City and it was this application that initiated the
CEQA review.

Comment 4.
Does Alhambra need more low-paying jobs? Like Walmart, Lowes does not employ a significant full-time
work force. C. F. Braun and Sears provided full-time jobs for many Alhambrans for many, many years
but are no longer operating. Rather than adding another part-time work force, we need to look for more
full-time employers for our citizens.
Response 4.
The comment is noted for the record. The comment is not specifically related to the CEQA analysis
Comment 5.
There are a number of unaddressed environmental concerns. We have not seen a comprehensive
Environmental Impact Study for this project. The site has numerous toxic issues because of the chemicals
that were being used there for years. More investigation is needed and we need to know that the area will
be decontaminated/remediated.
Response 5.
The comment is noted for the record. The sites contamination was analyzed in Section 3.8 of the IS/MND.
Comment 6.
We were very disturbed to learn that two sitting councilmembers (Mejia and Maloney) accepted
campaign contributions of $5,000 from the developer of this project. The appearance of favoritism is
obvious. These two council members should be required to recuse themselves from any decision involving
this project.
Response 6.
Comment 7.
Please respond to these points at the January 17 meeting. We are concerned for the future and want to
ensure that our tax dollars are not being spent to compromise the quality of life in Alhambra, and that
uberdevelopments such as this one are not rubber-stamped or rushed into. Such a mind set only serves to
erode citizens trust in City Hall and our elected officials. Thank you for your consideration.
Response 7.



ALHAMBRA COURT COMMERCIAL DEVELOPMENT TENTATIVE TRACT MAP (TTM 74223) AND INDUSTRIAL PLANNED DEVELOPMENT
PERMIT (IP-16-4) 875 SOUTH FREMONT AVENUE AND 1111 SOUTH FREMONT AVENUE

Bryan Moscardini and Teena Santiago
Residents of the City of Alhambra
Comment 1.
Thank you for the opportunity to comment on the proposed project. We received notice of the December 13, 2016
Courtesy Informational Meeting at the Emery Park Youth Center and are very interested in the development of the
site, not only as eight-year Emery Park Tract residents and parents of two young children, but also as design
(architecture) and government (County Parks and Recreation) professionals.
Response 1.
Comment 2.
We are thrilled that the site is the focus of any type of development. We welcome the addition of a Lowe's to our
neighborhood, understanding the applicant's position that Lowe's offers a different business model and site
operation to the big-box home-improvement retail center (similar to OSH). However, as previous iterations of the
applicant's project proposals have included housing and mixed retail opportunities, the current iteration of an
office tower and associated parking seems misguided.
Response 2.
The City did not support the concept plan that included housing.
Comment 3.
We have read the Planning Commission Staff Report and Mitigated Neg Dec (MND) and understand that zoning
allows for the elements proposed by the applicant. However, the scale and siting of the office tower and parking
elements are out of proportion and inconsiderate of the surrounding uses. While alternatives aren't mandatory
for an MND under CEQA, the scale and siting of the office towers and parking lot should be appropriately
designed to a four-story maximum. Office tower #1 and parking lot could also be located further south on the
property as to not tower over the undersized Emery Park and Eugene Colletta Memorial Youth Center. This
alternative could further be realized by shifting the Lowe's main building south on the property, accommodated
by moving the garden center to the southern-most proposed parking area, having its own garden center and
seasonal operation (like some Targets). Another alternative to a reduced six-story to four-story parking structure
would be sharing parking with Lowe's. At the Courtesy Informational Meeting, Lowe's representatives stated
that most of their customers are there on the weekends, leaving a surplus of surface parking available during the
week for office tenants, therefore reducing the need for the larger parking structure.
Response 3.
The current plan reflects a balance that considered fire access requirements, development standards (building
height, setbacks, etc.), and parking requirements.

Comment 4.
Other than the County Department of Public Works building at 900 South Fremont, there are no other buildings
over four stories high in the area, let alone one's adjacent to a community park whose primary use is for toddlers,
pre-teens and senior citizens. The Edwards Theater at Garfield and Main as well as any new residential mixed
use along the Main Mosaic are capped at four or five stories.
Response 4.
The current plan reflects a balance that considered fire access requirements, development standards (building
height, setbacks, etc.), and parking requirements. The height of the two office buildings conform to the Citys
maximum height requirements.
Comment 5.
The MND only briefly mentions that adjacent parkland would not be affected by the adjacent development
and that parkland is adequate in the area. Local parkland in the City is inadequate. In the MND (3.15.2, page
123) the City's standard for calculating open space, not local parkland, is inadequate. The "Less than
Significant Impact" determination is misleading as it's based on a total of 442 acres of open space (including
parks, trails, public school sites, landscaped street medians, and a golf course).
Response 5.
The proposed project will not physically impact any existing park facilities, including Emory Park. The less
than significant impact determination recognized that some future employees may visit the park from time to
time (lunch, etc.).
Comment 6.
While this ratio equates to 5.9 acres of open space per 1,000 people, excellent by most municipal standards, public
school sites, landscaped street medians and golf courses do not provide recreational activities and should not be
used to "pad" the ratio (Emery Park Elementary is closed off to the general public for recreation at all times). The
MND further adds that: "However, employees at the office complex would likely visit the nearest parks (such as
Emery Park) during lunch or rest breaks." This is an excellent opportunity to expand the undersized city park as
well as provide parkland/vegetative buffering to potentially sensitive receptors that may be affected by
temporary construction and on-going off-site (office park) operations.
Response 6.
The open space standard referenced to in the comment was taken from the City of Alhambra General Plan.
Comment 7.
While the traffic study seems adequate for the project, the City should be using the project (or any future
projects) to improve the traffic LOS in the Fremont Ave Corridor.

Response 7.
The project will provide improvements to mitigate the impacts that are determined to meet the thresholds of
significance. These improvements will also provide some relief for existing traffic, but the project cannot be
expected to remedy all existing congestion.
Comment 8.
Again, thank you for the opportunity to provide comments on this very important project in a very important
corridor. We hope the City will respond to the community's concerns and guide the applicant toward a more
appropriate project.
Response 8.




Peggy Toney
Comment 1.
I cannot attend the meeting scheduled for January 17 regarding the hearing on the above mentioned
development on Fremont Avenue. I am the owner of a residential duplex on Fremont Avenue and am
already greatly concerned about the traffic on Fremont. My tenants have difficulty getting in and out of
the driveway due to heavy traffic and usually have to ask a person to stand on the sidewalk and give them
a signal as to when they can back into the street in order to merge onto Fremont Ave. In addition to this
there is an increasing amount of traffic noise both day and at night making it more and more difficult to
rent these units.
Response 1.
The traffic study has reported the existing intersection Level of Service, and has acknowledged that some
locations are currently operating with congested peak hour conditions. The project will provide mitigation
where its impact is determined to be significant, but cannot be expected to remedy all existing congestion.
Comment 2.
The proposed development will only add more traffic to Fremont, particularly since the driveways are
proposed to be located on the Fremont side of the project. Not only will the traffic into and out of Lowes
put more traffic onto Fremont but also the increased traffic from the two proposed office buildings.
Response 2.
The statement is correct. Any new development on the site will generate additional traffic, compared to a
vacant site. The additional traffic estimated to be added to Fremont is shown on Figure 8 of the Traffic
Study.
Comment 3.
I am greatly concerned that soon Fremont will not have any residential areas that are accessible to
tenants. The commercial areas have monopolized the neighborhood and I would like to see more focus on
increasing residential spaces for those residents that want to live and work in Alhambra. I am adamantly
opposed to this large commercial enterprise and do not feel it is in the best interests of the citizens. Thank
you for your attention to this concern. I will look forward to hearing from you.
Response 3.


Email received from Melissa Michelson, dated January 16, 2017. Ms. Michelsons letter is
found in the previous section.
Comment 1.
Please find attached my letter to the Planning Commission for Tuesdays meeting. Thank you.
Response 1.
The letter referenced in the comment was responded to.
Email from Pablo Saucillo, dated January 16, 2017.
Comment 2.
I will attend on Jan 17 @ 7 p.m.
Response 2.
Email from Stephen and Carily Mesi, dated January 16, 2017. Their letter is found in the
previous section.
Comment 3.
Please see attached correspondence. Thank you.
Response 3.
The letter referenced in the comment was responded to.
Email from Tom Williams, dated January 15, 2017.
Comment 4.
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.
Response 4.

Email from Jeremy Gerami, dated January 17, 2017.
Comment 5.
With this email Im requesting an Environmental Impact Report for the Lowes project. Thank you
Response 5.
The Initial Study that was prepared for the project determined that an EIR was not required.
Email from Ray Gonzalez, dated January 17, 2017.
Comment 6.
My name is Ray Gonzales and I live at 2925 Poplar Blvd in Alhambra. I won't be able to attend tonight's
meeting but I would like register my position on the issue. I would like to request that the Alhambra
Planning Commission pay to have an analysis conducted on the project.
Response 6.
Comment is noted for the record. Numerous environmental studies were completed for the project and
these studies are referenced in the IS/MND.
Comment 7.
My concern is primarily related to traffic--I'm especially concerned about the intersection of Mission and
Fremont-it's really bad at certain parts of the day and I can imagine that having a new business there will
only make things worse.
Response 7.
The existing congested conditions during the peak hours has been reported and acknowledged in the Traffic
Study, and the additional traffic from the project is shown on Figure 8 of the Traffic Study. Where the
project impact has been determined to be significant, the project will provide improvements to mitigate
those impacts.
Emails from Bryan Moscardini and Teena Santiago, dated January 17, 2017. Bryan
Moscardini and Teena Santiago sent the City two letters, both of which are exactly the same.
The letter is noted in the previous section.
Comment 8.
Please see attached comment letter for the above project. Sorry so late. Thank you!
Response 8.
Comment is noted for the record. The letter referenced in the comment was responded to.

Comment 9.
Can you confirm that you received my timely comment letter yesterday? Thanks!
Response 9.
The comment was received.
Email from Robert Franco, Jr., dated January 17, 2017.
Comment 10.
Hello Tonya, Im writing to you in lieu of my attendance at tonights meeting. I wanted to put in my 2
cents worth also. My family lives in this immediate area and definitely would not like this to happen. This
proposed Lowes would add to the already extremely busy streets, and congestion in the area. Freemont
traffic is a joke, and the fact that the 710 freeway is not happening, only makes this idea worse. We do not
need a parking structure, or more trucks on these really narrow streets. There is an elementary school up
the block, this will only make it more dangerous for the children. Thank you for your time.
Response 10.
The letter referenced in the comment was responded to. The lack of the I-710 Freeway is beyond the scope
of this project. The IS/MND and the traffic study analyzed the amount of traffic that would result from the
proposed project and the attendant traffic impacts.

Comment 1.
school and the traffic. Already people drive too fast and is used as an access to other streets. Are they
going to fix the existing potholes that are pretty bad and will only get worse with more traffic. Probably
not. Safety is number one for the children. Thank you for your support.
Response 1.
It is acknowledged that some project traffic may use Meridian to get to and from the site. Project design
features have been included in the project to minimize project trips on Meridian north of the project, and to
prohibit trucks from using Meridian north of the project to get to and from the project site. The primary
entrances for the project, including the signalized entrance, are designed to be the driveways located on
Fremont. As mentioned at the Planning Commission meeting on January 17, 2017, the applicant has been
conditioned to evaluate the feasibility of closing Meridian to through traffic near the northwest corner of the
site. If determined to be feasible, closing Meridian would have the dual effect of eliminating not only project
traffic on Meridian north of the project site, but also eliminating existing cut-through traffic that uses
Meridian through the Emery Park area.
Comment 2.
traffic increase tremendously. Because it is a two way street that goes straight through to Mission, we
have experienced first hand the dangerous speeds at which cars zoom by. Our car has been side swiped
twice taking off the mirror because people insist on squeezing by without slowing down or even granting
each other the right of way.
Response 2.
The IS/MND analyzed the existing traffic conditions on Meridian Avenue and the potential impacts the
proposed project would have on thus roadway.
Comment 3.
already dangerous situation especially since we do have the elementary school just down the block.
Perhaps Meridian Avenue can be changed to a ONE WAY street either north or south depending on your
studies. Also, we have observed over the last year that the grass meridians on Main Street (from Fremont
to Meridian Ave) are consistently trashed by what appears to be a recycling truck. There are magazine,
newspaper pieces strewn all along the street and grass. This happens almost every week or two. We see

the city workers clean it up and again it happens. This creates an eyesore and makes the community look
trashy.
Response 3.
There has been no discussion associated with the Lowes project regarding converting Meridian to a one-
way street. As mentioned at the Planning Commission meeting on January 17, 2017, the applicant has been
conditioned to evaluate the feasibility of closing Meridian to through traffic near the northwest corner of the
site. If determined to be feasible, closing Meridian would have the dual effect of eliminating not only project
traffic on Meridian north of the project site, but also eliminating existing cut-through traffic that uses
Meridian through the Emery Park area.
Comment 4.
complex then this also is a concern for your study. Alhambra has experienced much growth over these
many years. We hope that it will continue to be done in a manner that maintains what is a safe and clean
community.
Response 4.
As indicated in the traffic analysis, the majority of the Lowes traffic would use Fremont Avenue to access
the site.
Comment 5.
proposal, developers and municipal officials often focus on only one side of the equation: the amount of
new tax revenue that the project will generate. It's easy to overlook the fact that retail development also
creates new costs and often leads to a decline in tax revenue from existing commercial districts. In the case
of big-box stores and strip malls, these costs and revenue losses can be so high that they reduce the overall
tax benefit of the development to a negligible trickle or even result in a net loss for the city. In California,
cities are constrained in their ability to raise property taxes and therefore depend more heavily on local
sales taxes and various fees.
Response 5.
The comment has been noted for the record. No specific CEQA issue was raised in the comment.
Comment 6.
In general, there are three main costs that cities commonly overlook: First, because consumers have only
so much money to spend, sales at a new shopping center are invariably mirrored by sales losses at other

businesses in the region. An equivalent drop in sales tax revenue from other retail areas in turn matches
the sales taxes generated by the new development.
Response 6.
Comment 7.
Second, in California, strict caps on property tax rates have forced cities to rely primarily on a local sales
tax, sparking fierce competition to attract big-box stores and shopping Malls. But despite extensive retail
development over the last twenty years, the amount of sales tax revenue that California cities are raising
per capita has remained the same. Some cities can become tax winners by playing host to a new shopping
center that draws customers from nearby cities, but these gains are usually fleeting. It's only a matter of
time before that new shopping center is eclipsed by an even newer retail development that pulls shoppers
to another town. Some evidence suggests big-box stores may not even produce a temporary revenue gain.
One study of 116 cities in California found that, in all but two cases, the presence of Wal-Mart, Target,
Costco, Kmart, or Sam's Club stores did not correspond to increased sales tax revenue.
Response 7.
Comment 8.
Third, neighborhood and downtown business districts, as well as older strip malls and even big-box
stores, are often harmed by new retail development. As these areas lose sales and experience growing
vacancies, the value of the property declines and, with it, the tax revenue. Allowing older commercial
districts to deteriorate, while fostering retail development elsewhere, also wastes public resources. Public
investment in the roads, water lines, and utilities that serve older retail areas end up sitting idle or
underutilized, while taxpayers foot the bill for new infrastructure to serve the new big-box store or
shopping center.
Response 8.
Comment 9.
compactness, are very efficient users of public infrastructure and services. Sprawling big-box stores are
not. They require more road maintenance, additional utilities, and more fire and police time. One case
study found that the annual cost of providing city services to traditional downtown and neighborhood
business districts was $786 per 1,000 square feet of retail space. Big-box stores were 30% more costly,

requiring $1,023 in services per 1,000 sq. ft., while strip malls where even more expensive at $1,248. Most
of this difference is due to additional costs for road maintenance and police services. Because big-box
stores generate substantial car traffic and typically increase the number of road miles that residents
travel for shopping, cities end up having to spend more on road maintenance. Although developers may
offer to pay for new traffic infrastructure (turn lanes, signals, etc.), the real issue is ongoing operational
costs. Big-box stores also require substantial police services. This is partly because the added traffic
generates more accidents and necessitates more policing. It's also due to the fact that big-box stores
generate large numbers of police service calls far more on average than local retailers do on a per
square foot basis. Many of these calls are for shoplifting.
Response 9.
Comment 10.
a net drain on city finances. Not only does main-street retail produce lower services costs, it also
generates more property tax revenue per square foot, because these retailers occupied higher-value, often
historic, buildings. In one study, the net result was that the main-street retail produced an annual tax
surplus of $326 per 1,000 square feet, while big-box stores cost the city $468 more per 1000 sq. ft. than
they contributed in tax revenue.
Response 10.
Comment 11.
activity. To measure the ripple effects of a new business, you look upstream to see how many supplier
jobs the region would gain, and then you look downstream to see how many jobs would be created by
the buying power of the people who work at the business. The upstream of a big-box store creates very few
jobs for the local economy (i.e., Made in China), and the downstream ripple effects are terrible because
retail jobs are overwhelmingly part-time and minimum wage.
Response 11.
Comment 12.
That means most retail workers have very small disposable incomes: after paying for bare necessities,
they have little left with which to stimulate the local economy. Building new retail space just moves sales
and lousy jobs around. It doesn't grow the economy. There is only one justifiable time to subsidize retail:

to help revitalize a truly depressed neighborhood that lacks basic retail needs such as food, prescriptions
and clothing. In all other situations, subsidizing retail is a waste of money that could be better deployed
creating better jobs and stronger ripple effects. As Alhambra contemplates another big-box store moving
in, lets do all that we can to make very sure that Lowes is not subsidized by the taxpayers as they will do
long term damage to Alhambras financial stability.
Response 12.
Email received from Valvarez, dated January 16, 2017
Comment 13.
Response 13.
The IS/ND considered both these issues: hazards in Section 3.8 and traffic in Section 3.16.
Comment 14.
the Lowes and office building development on Fremont due to the increased traffic (on Fremont and
Meridian), with corresponding noise and air pollution. I ask that a comprehensive environmental impact
study be done for this proposed project and shared with the public BEFORE any review be made by the
city planning commission. Thank you.
Response 14.
All of the issues identified in the comment were considered in the IS/MND: traffic (Section 3.16); noise
(Section 3.12); and air quality (Section 3.3). The IS/MND determined that a mitigated negative declaration
(MND) is the most appropriate CEQA document.
Comment 15.
I am submitting my concerns regarding the above development. As much as having a Lowe's will benefit the
residents of Alhambra and bring revenue to the city, the location is worst possible location it could be built.
Response 15.

Comment 16.
First, is the additional traffic this development will bring to an already heavily impacted thoroughfare.
The traffic will be so bad it will force cars to find other routes to get past the area and cause more
pollution and increase the danger to pedestrians and cyclist in the surrounding areas of the project.
Response 16.
The Traffic Study provides estimates of how much traffic will be added to the surrounding street system,
identified the project impacts, and identified traffic improvements to mitigate the project impacts. It is
acknowledged that individual drivers may choose alternative travel paths, which is typical in an urban street
environment, where drivers have multiple route options available to them to reach their destination. Any
chosen path or route may or may not be a path with more pedestrians or cyclists.
Comment 17.
Response 17.
The proposed project will not require a zone change or a general plan amendment.
Comment 18.
center.
Response 18.
Comment 19.
Response 19.
Comment has been noted for the record.
Comment 20.
Invalid Zoning. The proposed development on 875 and 1111 South Fremont Ave. appears to violate the
city's zoning laws regarding that area of the city. The parcel of land on which the proposed development

on 875 and 1111 South Fremont resides is designated for Industrial Planned Developments (IPD). A Lowes
home improvement store does not fall within the IPD category according to Chapter 23.32 of Alhambra's
Zoning Code.
Response 20.
Comment 21.
Plan.
Response 21.
The comment is noted for the record. The proposed project will not require a zone change or a general plan
amendment.
Comment 22.
smoke, noxious gases, and hazardous materials and waste materials than many of the specifically
identified permitted uses in the IPD zone," nor does such a justification address the legality of permitting a
facility in an IPD zone that the city's zoning code clearly disallows. On the contrary, point 2 of the
provided to the City Council in 2010 submits that "the permitted uses in IDP Zones are fairly restrictive to
industrial and commercial uses."
Response 22.
The comment is noted for the record. The proposed project will not require a zone change or a general plan
amendment.
Comment 23.
conclusions are based solely on conjecture. What is more, it appears that the interpretation was made out
of convenience to City Hall's economic and development goals at the time rather than sound reasoning,
independent study, legal analysis, precedent, and careful consideration for the long-term impacts on
traffic, the environment, health and safety, and the effects on sustainable living in Alhambra. Point 8 of
the Background, Facts, and Analysis of the Development Services Department's IPD Zoning Interpretation

In the event owners, investors, developers, and building material sales businesses and/or home
improvement supplies businesses are aware of the uses being permitted in the IPD Zone, the more
likely such a building business would move towards acquisition and development in the district and
In short, such an interpretation appears not to be legally and scientifically grounded, but economically
and politically motivated. Thus, it would likely not stand up in a court of law. In addition, and perhaps
more importantly, politically and economically motivated interpretations of ordinances and zoning codes
null the purpose of legislation, which disenfranchises the community at large, diminishes residents' faith
in their local government, and ultimately weakens the democratic process. I hope the Planning
Commission will call on the city to thoroughly address these concerns before voting on this development
project.
Response 23.
Comment 24.
Dubious Negative Mitigated Declaration. It is extremely concerning that a Mitigated Negative

Declaration (MND) has been accepted by the City in lieu of an Environmental Impact Report (EIR) as
fulfillment of California Environmental Quality Act (CEQA) requirements. The CEQA website outlines
when it is appropriate to use a NMD in place of an EIR as follows:
environment (PRC 21080(c)) (14 C.C.R. 15070).
argument that significant effects may occur (PRC 21080(d)).
Response 24.
The IS/MND determined that an EIR was not required for the proposed project. All of the potentially
significant impacts were mitigated.
Comment 25.
sits adjacent to one of the busiest streets in the region, I fail to see how the City can justify the acceptance
of an MND over an EIR based on their conclusion that "substantial evidence" does not exist that such a
large retail project will have a significant effect on the environment, not to mention residents' livelihoods.
I have not seen any evidence supplied by the City or its lead agency to substantiate such a conclusion. On
the contrary, I have spoken to several experts and looked over numerous documents that indicate there is

substantial evidence that the type of development being proposed on 874 and 1111 South Fremont will
result in negative impacts on the environment and health and well-being of the community.
Response 25.
The Superfund site referred to in the comment is the groundwater basin which underlies the majority of the
City. The project will not affect the ongoing remediation of this groundwater basin.
Comment 26.
spurious. For instance, the traffic study portion of the MND breaks with standard protocol by not using
the Institute of Transportation Engineers Trip Generation Manual (TGM) to calculate ALL of the trip
rates for home supply stores like Lowes. The study's authors utilize the TGM trip rate calculations only for
non-peak hours on weekdays and weekends and rely on trip calculation data from a Lowes in Poway to
calculate peak trip hours on weekdays and weekends. Why? This is extremely suspect and the study's
justification, or lack thereof, does not hold water. Poway is a much smaller, less urban city than
Alhambra. It is troubling that the study would rely solely on the data collected by one Lowes in Poway to
calculate peak hour trip rates as opposed the average calculated peak hour trip rate from data collected at
multiple Lowes stores in cities similar in size and layout to Alhambra. It is also troubling that the study
would use two different data sets for different hours of the day.
Response 26.
The traffic generation rates for a Lowes home improvement center are very different compared to the trip
generation rates of other types of home improvement retail stores. In addition, the ITE rates rely on a
generic home improvement store that does not accurately characterize potential traffic generation rates.
Therefore, it was determined during the early project scoping process that the traffic generation rates from
an actual Lowes store would be more appropriate. As part of this process, it was determined that an
accurate trip generation analysis would require the identification of a Lowes that is stand-alone. The
proposed Lowes within the project site would be a stand-alone retail business. In other words, there would
be no shared traffic among other businesses that would normally be expected where a Lowes store would be
an element of a larger retail center. For this reason, the traffic engineers identified those Lowes in southern
California where there are no other retail uses sharing the property. The 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. In this way, the traffic counts would be
generated exclusively by the Lowes and not from other businesses in a commercial center.
Comment 27.
The study also contradicts itself when claiming, without evidence or precedent, that the same standards
that apply to a Home Depot do not apply to a Lowes because a Lowes "sells home improvement items
geared more to homeowners whereas Home Depot stores sell items geared more to small contractors." If
this statement were true, and there is no evidence supplied to prove that it is, then how do the study's
authors justify using TGM trip generation rates that are associated with Home Improvement Store land

use, which includes Home Depots, to calculate non-peak hour trip rates on weekdays and weekends for the
proposed Lowes development on Freemont? Regardless, the data used is inconsistent and suspect, which
negates the study's conclusions. I urge the planning commission to require the city to adequately address
these concerns before voting on this development project.
Response 27.
Please refer to Response 26.
Comment 28.
others are not asking the city to do this. What we are asking the city to do is to develop the land in a way
that is most beneficial to Alhambra residents, which takes into account livability, necessity, and economic
and social sustainability in both the short and long-term. I and others feel that another large home
improvement store that is literally blocks away from a pre-existing large home improvement store is not
only unnecessary, but detrimental to the Alhambra way of life. The planning commission is the primary
check and balance to the City Council regarding development in Alhambra. Even though planning
commissioners are appointed by City Council members, they are less influenced by moneyed interests
because they do not receive campaign contributions from developers. This should allow Alhambra's
Planning Commissioners to make uncompromised decisions about development and its net-affects on
Alhambra residents.
Response 28.
Comment 29.
To this end, I urge the Planning Commission to disregard any politically motivating factors when voting
on this matter, and instead rely solely on the evidence and facts, Alhambra's zoning code as written in the
City's charter, and the environmental and social impact of such a development in an already overly
congested area of the city. Thank you for the opportunity to comment on this important city matter.
Response 29.
Comment 30.

Response 30.
The letters that were referred to in the comment have been addressed in Parts II and Paerts III of this
Response to Comments document.
Comment 31.
As an Alhambra resident and homeowner on Meridian Ave for over 48 years, I am very concerned about
the impact the proposed building project for a Lowes store, and two office buildings will have on our
Response 31.
It is acknowledged that the project will add traffic to the streets that provide access to the site. Any new
development on the site will generate additional traffic, compared to a vacant site. The project and its site
driveways have been designed to minimize the number of project trips on Meridian to the north of the
project site.
Comment 32.
Response 32.
The Traffic Study was comprehensive, providing an evaluation of 14 intersections, for 18 different condition
scenarios. The study provided existing and projected peak hour Level of Service, project impacts, and traffic
improvements needed to mitigate the projects significant impacts. The study was prepared in accordance
with the standards and requirements of the City of Alhambra, which follows Traffic Study Guidelines
established by Los Angeles County Public Works. These guidelines are followed by many Cities within LA
County as well as for projects located within Los Angeles County borders and is an accepted traffic
engineering practice.
Comment 33.
In researching the traffic activity at various other Lowes locations, traffic was about 5,000 to 8,000 cars
per day. We are a residential community, not a commercial business area, and this project would have a
severe detrimental impact on our community. We already have a Home Depot just a few blocks way,
which meets the needs of our community.
Response 33.
It is unclear what traffic activity was researched, and what the 5,000 to 8,000 estimates are based on. The
proposed project is an application for a Lowes.

SUPPLEMENTAL COMMENTS & RESPONSES TO COMMENTS MITIGATED NEGATIVE DECLARATION & INITIAL STUDY

& INITIAL STUDY

LEAD AGENCY:
CITY OF ALHAMBRA
REPORT PREPARED BY:
JANUARY 17, 2017ALHM 001
SUPPLEMENTAL COMMENTS & RESPONSE TO COMMENTS PAGE 1

TABLE OF CONTENTS
Section Page
1. Comments & Response to Comments ....................................................................................3
2. Comments & Responses to E-mails that were Received .........................................................................31
3. Comments & Responses to Comments Received through a Phone Call ................................................ 46
4. Most Recent Comments Received by Email ........................................................................................... 47



G Valladodid, Resident of Alhambra

State of California

State of California

Ranajit (Ron) Sahu

Michael Lawrence

Sonia McIntosh, Emery Park Resident

Mariana Martinez, Emery Park Resident


Carlos Barron, Emery Park Resident

Eric Sunada, Resident of Alhambra


Joe Cano, El Sereno Resident


Zoe Wu, Emery Park Resident

Mrs. Khan, Resident of Alhambra

Rita Ramirez

Laura Telles, Emery Park Resident

Daniel Solorzano, Emery Park Resident

Ckool63
The City received comments via a phone call from the following:
Phone Call Received on January 12, 2017

Shirley Mollen


G Valladodid
Comment 1.
I am opposed to the development on Fremont that includes Lowes and office buildings. Please follow the
zoning for the area. While lumber yards may be considered industrial, a big box Lowe's is not; it is a retail
establishment. It is an unjust stretching of a horse of a different color to the detriment of residents' quality
of life. All the traffic to be brought in by retail cannot be handled by Fremont without completely affecting
residents of Alhambra. Even those of us who may not live immediately adjacent to the space, often use
Fremont to reach our frequent destinations. Stop. Do not continue on this unfair to residents path.
Response 1.
Comment has been noted for the record. The environmental impacts of the proposed project including
traffic and land use accountability were analyzed in the IS/MND.
Comment 2.
The additional traffic will detrimentally affect the air quality for the southern CA region. We have already
surpassed the permitted levels of ozone and particle production. We do not want nor do we deserve your
money deals that will raise the percentages of heart disease and cancers. Stop it.
Response 2.
The proposed project will result in additional traffic impacts and air emissions from traffic and energy
sources. The IS/MND did identify mitigation that would be effective in reducing these impacts to levels that
are less than significant.



State of California
Comment 1.
The State Clearinghouse submitted the above named Mitigated Negative Declaration to selected state
agencies for review. On the enclosed Document Details Report please note that the Clearinghouse has listed
the state agencies that reviewed your document. The review period closed on January 3, 2017, and the
comments from the responding agency (ies) is (are) enclosed. If this comment-package is not in order,
please notify the State Clearinghouse immediately. Please refer to the project's ten-digit State Clearinghouse
number in future correspondence so that we may respond promptly.
Response 1.
Comment 2.
Please note that Section 21104(c) of the California Public Resources Code states that:
"A responsible or other public agency shall only make substantive comments regarding those activities
involved in a project which are within an area of expertise of the agency or which are required to be carried
out or approved by the agency. Those comments shall be supported by specific documentation."
Response 2.
Comment 3.
These comments are forwarded for use in preparing your final environmental document. Should you need
more information or clarification of the enclosed comments, we recommend that you contact the
commenting agency directly.
Response 3.




State of California
Comment 1.
The enclosed comment (s) on your Mitigated Negative Declaration was (were) received by the State
Clearinghouse after the end of the state review period, which closed on January 3,2017. We are forwarding
these comments to you because they provide information or raise issues that should be addressed in, your
final environmental document.
Response 1.
Comment 2.
The California Environmental Quality Act does not require Lead Agencies to respond to late comments.
However, we encourage you to incorporate these additional comments into your final environmental
document and to consider them prior to taking final action on the proposed project.
Response 2.




Ranajit (Ron) Sahu
Comment 1.
I appreciate the opportunity to comment on the Traffic Study prepared to support the proposed Lowes and
Office Development (hereafter proposed project) at 875 and 1111 South Fremont Avenue, Alhambra,
California. I understand that the City of Alhambra Planning Commission will be asked to approve this
matter on January 17, 2016 at a public hearing. I am requesting that a copy of this comment letter be
provided to each member of the Planning Commission, the City Manager, and to each member of the City
Council.
Response 1.
The comment is noted for the record. The Planning Commission hearing is scheduled for January 17, 2017.
Comment 2.
Among other obligations, the extant Traffic Study has been provided by the project proponent as part of the
required environmental impact assessment for the proposed project in order to satisfy the requirements of
the California Environmental Quality Act (CEQA). It is my understanding that the project proponent has
proposed and that the City of Alhambra has accepted that the CEQA obligation of the proposed project can
be discharged via a Mitigated Negative Declaration (MND) as opposed to a full Environmental Impact
Report (EIR) the latter being a more thorough assessment of the potential environmental impacts that
may result from the proposed project.
Response 2.
The environmental analysis prepared in support of the IS/MND determined that an EIR was not required
given that no significant unmitigable impacts would result. For this reason, the City of Alhambra, in its
capacity as Lead Agency, determined that an EIR was not required.
Comment 3.
Based on my review of the Traffic Study alone (i.e., setting aside other potentially problematic
environmental concerns such as Air Quality and potential risk of harm via Vapor Intrusion of contaminants
known to be present in groundwater under the proposed development site, etc.), it is my opinion that the
MND is not the appropriate CEQA document for a project of this size and scope at its proposed location
namely along Fremont Avenue, currently one of the most heavily impacted traffic corridors in the City, with
unacceptable traffic even without the proposed project.
Response 3.
The comment is noted for the record. The traffic analysis acknowledged the proposed projects impact on
the Fremont Avenue Corridor. Mitigation was included in the IS/MND that would be effective in reducing
the impact to levels that are less than significant.

Comment 4.
I provide this opinion not just because I am a resident of the City of Alhambra (since 1988) but also as a
professional consultant competent to provide such opinions on environmental assessments. If staff or
members of the Planning Commission or City Council would like to discuss my qualifications, I will be very
happy to provide additional details.
Response 4.
Comment 5.
The Traffic Study is fatally compromised and, as a result, its conclusions are flawed and cannot and should
not be relied upon. Due to improper and unsupported assumptions made regarding nature of the proposed
project, the Traffic Study consciously significantly underestimates the number of additional trips that will
be generated as a result of the proposed project. It does so by improperly deviating from standard practices
in how such traffic impact analyses are conducted for such developments throughout the country. As in any
traffic analysis, once the project trip estimate is erroneous, the conclusions of the study are consequently
also erroneous.
Response 5.
The above comment, while citing limitations in the traffic analysis, does not provide specifics that can be
directly responded to. The traffic analysis clearly indicates the number of additional trips that would be
generated by the proposed project and the attendant impacts.
Comment 6.
The additional trips from the proposed project will incrementally burden the already poor traffic conditions
in and around the area, which even the Traffic Study acknowledges. Thus, underestimating the number of
additional trips artificially lessens the impact of the proposed project. This defeats the purpose of the
assessment and moots the CEQA analysis. And, it makes mockery of the types of mitigations that can and
should be considered to lessen the incremental traffic impacts once they are properly estimated.
Response 6.
The traffic analysis was prepared and peer-reviewed by three different traffic engineering companies. In
addition, the City conducted their own peer review prior to circulation. The traffic studys preparation
adhered to the standard engineering protocols required under the Los Angeles County Congestion
Management Program (CMP).
Comment 7.
I wish to make it clear that I am not against development in the City. I acknowledge that it is unrealistic to
expect that the land proposed for development will not undergo some type of future development. But, that

is simply not an excuse to use poor technical analyses as support for the proposed development and to ram
it through the process. Doing so is harmful on many levels: it defeats the happy talk of sustainable or smart
growth that is supposedly the planning goal in the City; it invites equally poor analyses on future projects;
and it exposes the City to potential legal risks. I would urge the Planning Commission to send the
environmental analysis back to the drawing board to be reworked and to make sure it properly conforms to
CEQA.
Response 7.
Comment 8.
Based on a meeting I (and others) had with City staff, I have put together a list of questions (provided in
Attachment A) relating to the Traffic Study. This has been provided to staff and it is my understanding that
staff will obtain responses from the authors of the Traffic Study. Regardless of whether or not responses are
obtained, as a fellow resident of the City, I urge members of the Planning Commission to fully satisfy
themselves as to the Traffic Study before voting on this matter. I urge Commissioners to become familiar
with what can often be technical aspects of the various CEQA analyses, including the Traffic Study, and to
ask pointed questions and clarifications before considering approval for the project as currently conceived.
And, I urge City Council members to support their appointed Planning Commissioners in this task.
Response 8.
The traffic engineers responses were provided in a separate email.
Comment 9.
It is my opinion, based on review of numerous documents and many discussions with City staff over the
years, that CEQA compliance for many projects proposed in the City over the years has been an after-
thought a check-the-box exercise that leaves much to be desired. I have heretofore refrained from
commenting publicly on the record on this issue. But, the quality of the analysis in the present Traffic Study
warrants a public response.
Response 9.
Comment 10.
While I understand staffs desire (and that of the Planning Commission and City Council members) to be
helpful to folks intending to invest in the City, this desire must be properly balanced against the regulatory
obligations of staff, Commissioners, and Council members and their obligations to the citizens of Alhambra.
Without a proper balance between the regulatory and facilitation functions, the desired goal of sustainable
development in the City is simply not possible. This is even more important when considering projects,
such as the proposed project, in an area of the City along Fremont Avenue that is already subject to

significant congestion and which sits on land above contaminated groundwater.
Response 10.
The comment is noted for the record. The site, as well as the entire City, overlies a contaminated ground
water basin as noted in the IS/MND. The proposed project will not affect this groundwater basin nor its
ongoing remediation.







Michael Lawrence
Comment 1.
I will address the main argument presented in the traffic study prepared by Kimley-Horn and Associates,
Inc., October 2016. The justification for bypassing the normal use of the IT manual and using the Lowe's
Poway data is that the IT manual does not reflect the type of home improvement audience that is part of the
Lowe's model for business. Below I have included their justification (see Attachment A). In it they state the
difference is that they cater to the homeowner and not the small contractors. This is not factual and is a
disingenuous argument.
Response 1.
Comment 2.
Lowe's website has several pages devoted to small contractors offering in store delivery and discounts for
contractors. The service is called Lowe's ProServices. A banner advertising bulk rates for contractors is
prominent on their www.lowesforpros.com home page for the services.
Response 2.
Comment 3.
A cursory view of the documents on the web show that Lowe's is directly competing with Home Depot for
contractor business and in fact their stock ratings are dependent on it. In a Fortune financial analysis This
is the Best Home - Improvement Stock to Own by Ryan Derousseau dated April 20th , 2016 the
article compares Home Depot and Lowe's and an Oppenheimer analyst Brian Nagel, states "The two
companies are "about 90% identical". The report does say they are behind Home Depot in contractor sales
but are making significant moves to correct this.

Response 3.
Comment 4.
Some analysts think Lowe's can gain ground by capturing more of the $120 billion professional home-
improvement market. The average pro contractor customer at Home Depot spends $6,500 a year, while
Lowe's garners about $2,000 per pro. To narrow that gap, Lowe's recently launched an e-commerce
platform for contractors and began partnering with brands preferred by professionals, like Sherwin-Williams
paints. Piper Jaffray analyst Peter Keith says those initiatives could enable Lowe's to boost its overall
growth.
Response 4.
Comment 5.
I urge the commissioners to review all of the letters and documents that have been presented. There is
more than enough material to merit sending this back for a new traffic study that uses standard
methodology and the IT manual. The IT trip generation manual was used in all of the Lowe's stores in the
Los Angeles area and also with the two office buildings so it is disturbing that an exception was made just for
Lowe's Alhambra. Undoubtedly the figures produced by using the IT manual would trigger an EIR and
would require the developer to truly mitigate the increase in traffic.
Response 5.
The information from the ITE manual was referred to in the IS/MND. However, the nature of the ITE
manual is that it is based off of nationwide surveys that typically have a very small sample size. Therefore, it
was deemed that actual driveway counts from a stand-alone Lowes store would provide a more accurate
characterization of potential traffic impacts.
Comment 6.
The current conclusion that the Lowe's development including two 6 story office buildings does not
significantly impact the environment with traffic is a disservice to our City and residents. The City of
Alhambra can encourage development without harming our quality of life by having this project examined
under and EIR. This can only be done with good data and not by circumventing the process with bad traffic
analysis.
Response 6.





Sonia McIntosh
Ms. McIntosh submitted a hand-written letter in regards to a number of issues, mainly concerning traffic.
Response
The issues that were legible in the letter included the projects traffic impacts, the fact that the site overlies a
superfund site which is a groundwater basin and underlies a major of the San Gabriel Valley, vibration and
noise during construction, and impacts to the Emery Park. These issues were addressed in the IS/MND.




Email from Mariana Martinez, dated December 5, 2016.
Comment 1.
I reside in the Emery Park neighborhood. I have been living here for a number of years.
Response 1.
Comment 2.
I appreciate the improvement and development projects in our city. I do have to say though that I don't'
understand why we need a Lowe's. We already have Home Depot in the city which is more affordable. Even
with a Lowe's close by I still only plan on going to Home Depot. I would much prefer bringing in a
merchant that we don't have yet like say Wal Mart or a Trader Joes.
Thanks for your time.
Response 2.
Email from Melanie Ulloa, dated December 8, 2016.
Comment 3.
I am a resident of Alhambra and I am requesting an extension of the public comment period for the above
stated project be moved from 01/03/17 to 01/17/17 for the following reasons: The meeting is held on the
first day of business for the new year. It is unreasonable to expect that many residents will be able to attend
on this evening; people may still be traveling back from their holiday.
Response 3.
The comment is noted for the record. The comment period was extended as requested.
Comment 4.
I have asked and not all of my neighbors received notice of this meeting in the mail; is this posted online? is
notice being given to all residents, per Robert's Rules of Parliamentary Procedure?

Response 4.
The City sent the meeting notices to surrounding property owners within a specified distance from the
project site as required by the Municipal Code.
Comment 5.
Will the agenda be available 72 hours prior to the meeting? that would mean it would need to be posted on
January 1st. Will city hall open for residents who do not have Internet access to view the agenda? You
attention and consideration to this matter is greatly appreciated.
Response 5.
The comment is noted for the record. The agendas were pursuant to the Citys Municipal Code
requirements.
Email from Carlos Barron, dated December 22, 2016.
Comment 6.
This is where you can send the document you mentioned and I requested once you have it electronically.
The contact information below is the best way to get in touch with me. I respond in a more timely manner
via text and email.
Response 6.
Comment 7.
I'm sorry you brought it up in our ad hoc conversation so I'm not privy to it's title. It's interesting to note
how long it took for you to get back to me since you insisted I give you my contact information post haste.
Response 7.
Email from Eric Sunada, dated January 10, 2017.
Comment 8.
At our meeting on Friday, January 6, you offered to seek answers to our questions from the developer's
traffic engineer(s), either by meeting or email. In the interest of time and a quicker turnaround, we'd like to
take you up on your offer to obtain answers via email.
Response 8.

Comment 9.
Questions: On Table 2, page 17, why did the traffic analysis not use the trip generation rates from ITE Trip
Generation Manual, 9th Edition, code 862 in order to calculate the rates for the Lowes store for AM Peak
Hour, PM Peak Hour, and Weekend Peak Hour?
Response 9.
The Traffic Study explains that Lowes home improvement superstores are considered different than other
typical home improvement superstores, e.g., Home Depot, in terms of peak hour trip generation from the
site; and that the trip generation rates that are available for use in analyzing traffic impact from typical
home improvement superstores do not necessarily reflect the proposed project.
Comment 10.
Were the trip generation values for Lowes ever calculated using the ITE 9th Edition code 862 rates?
Response 10.
Comment 11.
Regardless of the answer to Q2. above, what would the Lowes' trip generation values for AM Peak Hour/PM
Peak Hour/Weekend Peak Hour be if ITE 9th Edition code 862 rates were used instead of the Lowes/Poway
rates?
Response 11.
Please refer to Table A provided below.

Comment 12.
Did Kimley/Horn request 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 details (such as approval letter, etc.).
Response 12.
The City agreed with the use of the site-specific empirical data collected at an existing Lowes store. No
formal letter of approval was issued.
Comment 13.
Please provide 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.
Response 13.
Kimley-Horn has conducted site driveway, drive-through queuing, and parking data collection for use in
traffic and parking studies on a number of occasions, such as for distribution centers, office complexes,
warehouse uses, drive-through restaurants, shopping centers, gas stations, etc. (not specifically for a Home
Improvement Store). This is a common practice for all traffic consultants. It is not uncommon to collect
site-specific empirical data for a particular use. In fact, the following is a direct quote taken from the
Institute of Transportation Engineers (ITE) Trip Generation Manual (9th Edition): When practical, the
user is encouraged to supplement the data in this document with local data that have been collected at
similar sites. In addition, it should be noted that the trip generation data provided in the ITE Trip
Generation Manual is based on site-specific empirical data collected at local sites, just like the Lowes data
collected and used in this study. Without local driveway data like the Lowes data, the Trip Generation
Manual would not exist.
Comment 14.
How were the trip distribution assignments shown on Figures 5, 6, and 7 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.
Response 14.
As is typical of all traffic studies, the traffic consultant prepares preliminary trip generation and trip
distribution assumptions, discusses with staff, and works with City staff to finalize the assumptions based
on staffs knowledge and familiarity with the City. This does not involve a formal written process.

Comment 15.
How would the conclusions of the traffic analyses as shown on Tables 3, 4, 5, 6, 7, and 8 change if the trip
generation values for the Lowes store used the ITE Manual 9th Edition Code 862 rates in Table 2 instead of
the Lowes/Poway rates, along with the assumed trip distributions shown in Figures 5-7?
Response 15.
To answer this question, a separate full analysis of the project would be required.
Comment 16.
Does Kimley/Horn typically address accidents and other safety metrics at the potentially affected
intersections within the assumed area of study in its traffic analyses? The current analysis does not seem to
contain this type of information.
Response 16.
This is not a typical component of a traffic impact study.
Comment 17.
Appendix C contains a report prepared by Crown City Engineers. The following questions pertain to
Appendix C. Not sure if they should be addressed by Kimley/Horn or Crown City. General response: the
Crown City driveway count study provides answers to many of these questions not to the very specific
questions, such as information about the customers of the store, or the effect of other uses near the site
where the counts were being collected. Even ITE does not request or require information of this level of
detail or specificity for trip studies that are used in the Trip Generation Manual.
Response 17.
Comment 18.
(i) Please provide support for the statement that "Lowes home improvement superstores are considered
different than other typical home improvement superstores...." (unnumbered page 1 of the report in
Appendix C). What is the basis of this statement? Please provide references as appropriate.
(ii) Please provide support for the statement "Lowes stores sell home improvement items geared more to
the homeowners whereas Home Depot stores sell these items geared more to small contractors."
(unnumbered page 2 of the report in Appendix C) Was this statement based on observations (please
provide documentation), company statements (please provide documentation), or other sources (please
provide documentation)?
(iii) Please provide information on the customers (i.e., home owners, small contractors, large contractors,
MRO, etc.) that Lowes intends to target to its Alhambra store - if known.

(iv) Please clarify the statement "....Alhambra Lowes will not share any driveways form other businesses."
It is apparent from the traffic analysis that traffic to and from the two proposed office complexes also
planned as part of the development (which will presumably house "other businesses") will be able to
enter/leave the development via the Lowes driveways.
Response 18.
Changes to the project site plan and the site access and circulation were made after the Crown City report
was prepared.
Comment 19.
(v) On what basis was the Lowes in Poway deemed "similar" to the proposed Lowes in Alhambra?
(vi) Using the support for "similar" as used in Appendix C, are there any other Lowes stores located closer to
the proposed Alhambra Lowes than the Poway store, which could also be considered "similar" to the
Alhambra Lowes?
(vii) Were there any other Lowes stores other than the one in Poway considered for traffic count data
gathering described in Appendix C?
(viii) Were any actual traffic counts collected at any other Lowes, other than the one in Poway. If the answer
is yes, please provide this data.
(ix) The Lowes store in Poway is located across a Walmart Superstore. Please comment on the effect this
could have on traffic counts observed at the Poway Lowes in contrast to, for example, the Lowes being all by
itself - i.e., could it have depressed the observed traffic counts? If not, why not?
(x) Please comment on whether the ITE Manual or other applicable ITE guidance and methodology was
followed in gathering this additional data from Lowes/Poway, when the intent was to use this data as
opposed to the Code 862 data from the Manual in the subsequent traffic analysis. If the answer is yes,
please provide cross references to ITE documents.
(xi) Was the City of Alhambra consulted prior to the collection of the data from Lowes/Poway - i.e., was the
need for this data and the collection methodology discussed and/or approved prior to the data collection.
Were any drafts of the traffic analysis provided to the City of Alhambra prior to its finalization? If yes, did
Kimley/Horn receive any written comments from City of Alhambra? Please provide these comments and
responses by Kimley/Horn.
Response 19.
As is typical of all traffic studies, the traffic consultant submits a preliminary (draft) study and makes
revisions as needed to finalize the report. In this particular case, changes to the project, including changes
to square footage and site access and circulation, were made after the initial draft, which necessitated
revisions to the report prior to its final submittal.

Email from Joe Cano, dated January 12, 2017.
Comment 20.
Please see the attached materials. By way of this email I am submitting my opposition to the proposed
development project on Fremont Ave. As of this day the public is not aware if the soil at this location has
been cleaned up let alone tested for contaminates from the former Alhambra Foundry. An Environmental
Impact Report has not been initiated as required by state law. Moving forward without any Environmental
study or final report is irresponsible just short of criminality. If this project is pushed through for the sake
of profit over safety then the City Of Alhambra, specifically the City Council, can be found guilty of depraved
indifference.
Response 20.
A detailed analysis was completed as part of the preparation of the IS/MND. Under CEQA, the only
circumstances where an EIR is required is if a Statement of Over-riding Considerations is required. This
finding is only required if there is a significant unmitigable environmental impact. The mitigation
measures that are included in the IS/MND is able to reduce the impacts to levels that are less than
significant.
Comment 21.
I will also be sending this to the State Of California CEQA board and the Federal Nation Environmental
Protection Agency. Hopefully these agencies will find the actions of the City of Alhambra in violation of
established pollution laws and exact sanctions & heavy fines against it and this planning commission. (Mr.
Canos attachments include a photo (attached below) and a video clip).
Response 21.
Email from Melanie Ulloa, dated January 12, 2017.
Comment 22.
I am reaching out to you today with concerns and question relating to the Alhambra Court Development. As
a resident of the Emery Park neighborhood with two children this is very alarming. I am concerned about
the safety and health of our children.
Response 22.
Thank you for the above comment. The IS/MND evaluates a number of issues related to health and safety.
The analysis included mitigation measures that would be implemented as a means to address hazardous
materials, air quality, traffic, and public services.

Comment 23.
One of my concerns is that there will be more traffic at the Fremont and Mission intersection and the Emery
Park neighborhood in general. Drivers already speed up La Paloma Avenue (the street I reside on), which
runs parallel to Fremont and is one block east of Meridian, to avoid the already congested traffic on
Fremont. Drivers already speed through Commonwealth. When we asked the representatives at Lowes
about traffic enforcement, their response was that their only concern was the immediate area of the
development traffic safety concerns in the neighborhood is not their responsibility. Also, at the December
13th Informational Meeting, we were told there would be only one entrance on Meridian, but now Ive seen
the parking plan and there will be TWO driveways on Meridian? One for the trucks delivering goods and
another for the employees of the two office buildings. DID YOU FORGET THAT YOU HAVE RESIDENTS
HOW NEED TO LEAVE THE NEIGHBORHOOD TO GET TO WORK? The employees of these office
buildings will use the street I live on to cut through to get to work. How unsafe for the children walking to
school. Since Lowes or the Charles Company will not do anything to help with the extra traffic that their
development will bring, what will the City of Alhambra do to protect my children from cars that speed down
our streets to avoid traffic on Fremont? The City should put in speed bumps on Meridian, Orange Grove
and La Paloma streets between Poplar and Concord to reduce the speed of traffic and to discourage cars
from traveling through the neighborhood.
Response 23.
Comment 24.
Retailers like Lowes and Home Depot are known to have day laborers camped out on their premises. A
neighbor asked their representatives about their plans on handling the loitering and they responded by
saying once they loiterers are off their property, it is no longer a concern. Well, what concerns me is where
will these people go? Will they loiter the Emery Park Recreation center where they hold Mommy and Me
classes? Children who walk home from school will be prey to these new habitants. Will the homeless
population in our neighborhood increase? Will crime rates go up? What will the City do to protect my
family from a potential break-in? Will there be more officers patrolling the area?

Response 24.
The Lowes management indicated they do not anticipate that day labors will be located within the Lowes
development once the store is operation. The Lowes business model is directed more to individuals than
commercial contractors that would typically utilize day laborers. In addition, management at the Lowes
generally discourage loitering within their property.
Comment 25.
I checked the City of Alhambra Zoning Map and this parcel is zoned industrial. Has the parcel been rezoned
to accommodate a retail and office buildings? I believe that if it is to be rezoned, it needs to be put to a vote.
Is this correct?
Response 25.
The City Council made a previous determination that the proposed use is permitted within the IPD zone.
Comment 26.
The soil at the site is contaminated; there is a concern from neighbors about the effect on the air quality in
our neighborhood. Construction is expected to last three to five years for the entire project. There will be
loud construction sounds disrupting teaching at Emery Park elementary school, which is located less than
one half mile from this building. The loud sounds will disrupt the learning that is taking place. It seems as
if there is no concern for our young residents in the Emery Park neighborhood. Does the City have plans to
limit the noise and air pollution while construction is taking place?
Response 26.
The environmental analysis included in the IS/MND included a description of the potential noise and air
quality impacts related to both the projects construction and subsequent operation. In addition, the
IS/MND included mitigation that will be effective in reducing potential environmental impacts.
Comment 27.
Lowes promises to build jobs; however, let us not be fooled. These will be part time, minimum wage paying
jobs. We need to bring employers who will provide full time jobs with benefits. That will help raise the
quality of life for our citizens.
Response 27.
Comment 28.
How can the City of Alhambra vote on a project that will have such a huge impact on our community, when
it doesnt even have all the facts? Lowes was unable to give the residents a clear idea of how many shoppers
could potentially come into this store. Shouldnt the City have this information in order to vote? If not,

seems to me like you are voting with all of the pertinent information. If the parking lot is to be able to
accommodate the 1,396 cars, it seems that there would be that much more traffic on our streets. It is
irresponsible for Lowes and the City of Alhambra to think that this development will not impact the traffic
at Fremont and Mission.
Response 28.
The IS/MND included a detailed traffic analysis that identified new traffic that would be generated by the
proposed project. The ultimate number of shoppers that would potentially be inside the new building would
be limited to the occupancy load of the new building. Finally, the proposed project will adhere to the Citys
off-street parking requirements.
Comment 29.
It is a shame that none of the City Council members nor the Mayor of Alhambra were at the Informational
Meeting held on December 13th. Their absence speaks volumes. Please let them know.
Response 29.
Comment 30.
Lastly, this project effects ALL the residents of the Emery Park area; why hasnt more outreach been done?
Statistics show that 48% of Alhambra residents are of Asian descent, but the Information letters were sent
in only one language? There are several of my neighbors who received both letters but could not read them
because it was in English only. What is the city doing to reach out to its non-English readers? Thank you
for your attention to this matter.
Response 31.
The comment is noted for the record. The City, as part of this CEQA review process exceeded the State
requirements. For example, the staff required the Applicant to conduct an informational meeting and
extended the comment period.
Email from Zoe Wu, dated January 12, 2017.
Comment 32.
My name is Zoe Wu, a resident in the Emery Park neighborhood. I am really concerned about the gigantic
Lowe's project on Fremont. 3 6-story buildings and the Lowe's Store would seem to create a lot of traffic on
the already crowded 2-lane Fremont. All the traffic will pour into West of Fremont in order to get into/out
of the plaza from Meridian. That is to say, the traffic in the residential streets of Emery Park will be greatly
impacted, and the streets will no longer be safe for the kids who are going to the Emery Park School. This
project is way too big for these small streets.

Response 32.
The comment is noted for the record. A traffic study was prepared for the proposed project that
documented the traffic impacts.
Comment 33.
The city does not seem to have done a reliable study on the impacts of the traffic. We need this done. Please
hear us. Thanks.
Response 33.
The comment is noted for the record. As stated previously, a traffic study was prepared for the proposed
project that documented the traffic impacts. The comment does not cite any specific short-comings will the
traffic analysis.
Email from Mrs. Khan, dated January 13, 2017.
Comment 34.
In regards to the proposed commercial development including the addition of Lowe's to Fremont, please
answer a few questions of mine:
What exactly is the plan to reduce the traffic jam on Fremont Ave during rush hour? What are the alternate
routes and how many people are anticipated to travel on each? What is the estimated increase in commute
time during rush hour? Has there been any analysis done on this matte? Please remember that we already
have a traffic jam problem, so I'm not only asking about future traffic jam created by the new development,
but also the current massive traffic jam.
Response 34.
Comment 35.
What exactly is the impact of this commercial development? Please provide a 5-yr and 10-yr projected
income to the city of Alhambra.

Response 35.
The comment is not a CEQA issue. The economic impacts/benefits of a project is not a specific CEQA issue.
As part of the preliminary analysis, it was determined that the proposed commercial development would not
lead to urban decay elsewhere in the City.
Comment 36.
What is the impact on the residential property values? Please provide a solid analysis report based on
Alhambra, not a "similar to this city" report.
Response 36.
The projects adverse impacts/benefits on property value is not a CEQA issue and was not considered in the
IS/MND.
Comment 37.
How does the timeline of this potential construction clash/match up with the potential construction of 710?
How much more traffic can we anticipate as a result of these two construction going on concurrently?
Response 37.
It is our understanding that Caltrans has eliminated the I-710 extension project from near-term freeway
construction plans.
Comment 38.
What is the environmental impact (i.e. pollution) to the residents of Alhambra with these constructions? I
would greatly appreciate your detailed response to my questions.
Response 38.
A detailed analysis of the projects short-term construction related impacts is provided in Section 3.3.D,
beginning on page 54 of the IS/MND.
Email from Rita Ramirez, dated January 13, 2017.
Comment 39.
I am AGAINST having Lowe's built on Fremont. There is so much traffic on Fremont Ave already. I love
Home Depot and they carry plenty of goods there. We also have Costco which also has appliances. Easy
access going into Home Depot without any congested traffic!! Keep LOWE'S out of Alhambra!!!
Response 39.
Comment noted for the record. The traffic analysis analyzed the proposed projects traffic impacts to
Fremont Avenue.

Email from Daniel Solorzano, dated January 13, 2017.
Comment 40.
Dear Ms. Pace, I am a 30-year resident of Alhambra and live with my family on 501 Westminster Avenue in
the Emery Park Community. I attended the Information Meeting on December 2, 2016 regarding the Lowes
Development in the area between Fremont and Meridian Avenues. I have two major concerns.
First, at the Meeting a number of important concerns of our neighbors were expressed regarding the
increased traffic in the streets to the north of the Lowes Development along Concord, Commonwealth, and
Popular. Also, my worry is the increased traffic also along the following streets: La Paloma, Meridian,
Orange Grove, Westminster, Westboro, Winthrop, and Westmont. Traffic is already a problem in our
neighborhood and I would hate to see us petition the City of Alhambra for more stop signs and speed bumps
to slow and discourage traffic in the area. Those issues werent adequately addressed at the Dec. 2nd
Information Meeting.
Response 40.
truck traffic from going northbound from Meridian into the residential neighborhood. The IS/MND
included a detailed traffic analysis and a stand-alone traffic study.
Comment 41.
My second major concern was not addressed at the Information Meeting. As you drive north on Meridian
Avenue off Mission Road there are more than 30 trees that line the east side of the street from the end of the
Alhambra Foundry property line to Emory Park (where we held the Information Meeting). The Kohls
Property seemed to keep the trees at the back of their parcel and the Alhambra Foundry has kept the trees
in the front of their storage yard. I trust that the Lowes Development will do the same and preserve those
magnificent trees along Meridian Avenue. I thank you in advance for sharing this with those who will make
the final decisions regarding our concerns on the Lowes Development.
Response 41.

Email from Laura Telles, dated January 13, 2017.
Comment 42.
I attended the meeting on December 13, 2016. I am a 30 year plus resident of Alhambra. I have lived at my
property in Emery Park since 1991. One of the reasons we bought in Emery Park was because of the single
family homes and the quiet tree lined streets.
Response 42.
Comment 43.
With this new proposed project (Lowes, etc) I have a concerns it will bring much traffic to streets that are
already congested. It is critical that the community be involved in the planning. The answer to only notify
the immediate surrounding community members is inconsiderate and can only make a community feel as
though this project is being imposed rather than the community members are active participants in the
planning process.
Response 43.
The comment is noted for the record. The City has required the Applicant to conduct to the workshop cited
in the above comment to maximize community input. In addition, the IS/MND in Section 3.16 included a
comprehensive traffic analysis.
Comment 44.
The neighboring community also needs to be notified, El Sereno residents as traffic will also increase for
them.
Response 44.
Comment 45.
One last major concern are the 30 plus trees either on property and the walk-way of Meridian. It is critical
that the very large trees be saved!
Response 45.

Comment 46.
I thank you in advance for sharing my concerns with those individuals who are making the decisions. I also
recognize you are new to your job and those who asked you to attend the meeting alone as a new employee
were not invested in really answering the communitys questions.
Response 46.
Email from ckool63, dated January 15, 2017.
Comment 47.
I live on la Paloma and concord, which is 1 block east of emery park school, I block west of Fremont. I have
been here over 10 years and the traffic as it is now is terrible during morning and evening hrs. they use la
Paloma to bypass traffic on Fremont and use Concord to go west. many speed down and make rolling stop
or in some cases run the stop. Im waiting to see when a fatal accident is going to occur. I'm surprised it
hasn't yet. La Paloma asphalt is in need of repair. this is going to create more traffic around the school and
surrounding area. the city needs to do a traffic study and the police dept need to do a little traffic patrol.
thank you
Response 47.

3. COMMENTS & RESPONSES TO COMMENTS RECEIVED THROUGH A PHONE CALL

Comments Received Via Phone Call from Shirley Mollen, dated January 12, 2017.
Comment 1.
Traffic is horrible.
Response 1.
Comment is noted for the record. A detailed traffic study was prepared for the proposed project. In
addition to this stand-alone traffic study, the report was incorporated directly into the IS/MND. The traffic
study included a detailed description of the existing traffic conditions and the study area. The traffic
analysis then projected future traffic that would be generated by the proposed project. This net increase in
traffic was then added to both the existing traffic volumes as well as the future traffic volumes without the
project that would be expected in the near term. As part of this analysis, the traffic engineer worked closely
with the City to identify the location and extent of the study intersections and how this future traffic would
be distributed onto the local streets. Mitigation was proposed that would facilitate traffic flow on Fremont
and Meridian, as well as eliminating truck traffic from going northbound from Meridian into the residential
neighborhood.
Comment 2.
Additional traffic on Meridian will impact the safety of the children at Emery Park School.
Response 2.
Comment 3.
The project is not a good thing and opposes it.
Response 3.

Email received from John Rodriguez and Christine Rodriguez, dated January 16, 2017
I am a resident of Alhambra, the Emery Park area since 1976. Despite the traffic I am for the Lowes store. I
attended the last meeting held on Dec.13,2016. A majority of the local residents were concerned about the
traffic. My suggestion is to build back the railroad overcross that Alhambra once had on Westminister to
alleviate the traffic grid lock on Valley Blvd and Fremont Ave..
I am opposed to building the two office buildings #1 and #2 because that would just add even more traffic.
On the information sheet provided by the City of Alhambra it specifies that the parking structure will
accommodate 982 car spaces thats more than double the Lowes car space which is 414. That only adds to
more traffic and does not serve the community well.
Our community does not need two six story buildings that will cover our beautiful mountain view. Alhambra
already has enough high rise buildings which I thought should have never been built. The City of Alhambra
has failed to make significant improvements concerning our traffic conjestions.
I and other residents are for the extension of the 710 freeway to continue up to Huntington Dr. to alleviate
our taffic on Valley Blvd.and Fremont Ave.
I am opposed to the ridiculous 710 freeway tunnel for many reasons.One of the main reasons is the cost to
build the tunnel.It will be a straight away thoroughfare with no exits. Other serious considerations for my
opposition to the tunnel is the possibility of an earthquake or a terrorist threat, a possible bomb in the
tunnel. How will emergency units come to assist if there are no accessible entries or exists. The tunnel will
be a toll tunnel. Once again the local citizen will have to dish out the money for the ridiculous tunnel idea
costing us not the government.
school and the traffic. Already people drive too fast and is used as an access to other streets. Are they going
to fix the existing potholes that are pretty bad and will only get worse with more traffic. Probably not.
Safety is number one for the children. Thank you for your support.
traffic increase tremendously. Because it is a two way street that goes straight through to Mission, we have
experienced first hand the dangerous speeds at which cars zoom by. Our car has been side swiped twice
taking off the mirror because people insist on squeezing by without slowing down or even granting each
other the right of way.
already dangerous situation especially since we do have the elementary school just down the block. Perhaps
Meridian Avenue can be changed to a ONE WAY street either north or south depending on your studies.

Also, we have observed over the last year that the grass meridians on Main Street (from Fremont to
Meridian Ave) are consistently trashed by what appears to be a recycling truck. There are magazine,
newspaper pieces strewn all along the street and grass. This happens almost every week or two. We see the
city workers clean it up and again it happens. This creates an eyesore and makes the community look trashy.
complex then this also is a concern for your study. Alhambra has experienced much growth over these many
years. We hope that it will continue to be done in a manner that maintains what is a safe and clean
community.
proposal, developers and municipal officials often focus on only one side of the equation: the amount of new
tax revenue that the project will generate. It's easy to overlook the fact that retail development also creates
new costs and often leads to a decline in tax revenue from existing commercial districts. In the case of big-
box stores and strip malls, these costs and revenue losses can be so high that they reduce the overall tax
benefit of the development to a negligible trickle or even result in a net loss for the city. In California, cities
are constrained in their ability to raise property taxes and therefore depend more heavily on local sales taxes
and various fees.
In general, there are three main costs that cities commonly overlook:
First, because consumers have only so much money to spend, sales at a new shopping center are invariably
mirrored by sales losses at other businesses in the region. An equivalent drop in sales tax revenue from
other retail areas in turn matches the sales taxes generated by the new development.
Second, in California, strict caps on property tax rates have forced cities to rely primarily on a local sales tax,
sparking fierce competition to attract big-box stores and shopping Malls. But despite extensive retail
development over the last twenty years, the amount of sales tax revenue that California cities are raising per
capita has remained the same. Some cities can become tax winners by playing host to a new shopping center
that draws customers from nearby cities, but these gains are usually fleeting. It's only a matter of time
before that new shopping center is eclipsed by an even newer retail development that pulls shoppers to
another town. Some evidence suggests big-box stores may not even produce a temporary revenue gain. One
study of 116 cities in California found that, in all but two cases, the presence of Wal-Mart, Target, Costco,
Kmart, or Sam's Club stores did not correspond to increased sales tax revenue.
Third, neighborhood and downtown business districts, as well as older strip malls and even big-box stores,
are often harmed by new retail development. As these areas lose sales and experience growing vacancies,
the value of the property declines and, with it, the tax revenue. Allowing older commercial districts to
deteriorate, while fostering retail development elsewhere, also wastes public resources. Public investment in
the roads, water lines, and utilities that serve older retail areas end up sitting idle or underutilized, while
taxpayers foot the bill for new infrastructure to serve the new big-box store or shopping center.

compactness, are very efficient users of public infrastructure and services. Sprawling big-box stores are not.
They require more road maintenance, additional utilities, and more fire and police time. One case study
found that the annual cost of providing city services to traditional downtown and neighborhood business
districts was $786 per 1,000 square feet of retail space. Big-box stores were 30% more costly, requiring
$1,023 in services per 1,000 sq. ft., while strip malls where even more expensive at $1,248. Most of this
difference is due to additional costs for road maintenance and police services. Because big-box stores
generate substantial car traffic and typically increase the number of road miles that residents travel for
shopping, cities end up having to spend more on road maintenance. Although developers may offer to pay
for new traffic infrastructure (turn lanes, signals, etc.), the real issue is ongoing operational costs. Big-box
stores also require substantial police services. This is partly because the added traffic generates more
accidents and necessitates more policing. It's also due to the fact that big-box stores generate large numbers
of police service calls far more on average than local retailers do on a per square foot basis. Many of these
calls are for shoplifting.
a net drain on city finances. Not only does main-street retail produce lower services costs, it also generates
more property tax revenue per square foot, because these retailers occupied higher-value, often historic,
buildings. In one study, the net result was that the main-street retail produced an annual tax surplus of
$326 per 1,000 square feet, while big-box stores cost the city $468 more per 1000 sq. ft. than they
contributed in tax revenue.
activity. To measure the ripple effects of a new business, you look upstream to see how many supplier jobs
the region would gain, and then you look downstream to see how many jobs would be created by the
buying power of the people who work at the business. The upstream of a big-box store creates very few jobs
for the local economy (i.e., Made in China), and the downstream ripple effects are terrible because retail
jobs are overwhelmingly part-time and minimum wage.
That means most retail workers have very small disposable incomes: after paying for bare necessities, they
have little left with which to stimulate the local economy. Building new retail space just moves sales and
lousy jobs around. It doesn't grow the economy.
There is only one justifiable time to subsidize retail: to help revitalize a truly depressed neighborhood that
lacks basic retail needs such as food, prescriptions and clothing. In all other situations, subsidizing retail is a
waste of money that could be better deployed creating better jobs and stronger ripple effects.
As Alhambra contemplates another big-box store moving in, lets do all that we can to make very sure that
Lowes is not subsidized by the taxpayers as they will do long term damage to Alhambras financial stability.

Email received from valvarez, dated January 16, 2017
the Lowes and office building development on Fremont due to the increased traffic (on fremont and
meridian), with corresponding noise and air pollution.
I ask that a comprehensive environmental impact study be done for this proposed project and shared with
the public BEFORE any review be made by the city planning commission. Thank you
I am submitting my concerns regarding the above development. As much as having a Lowe's will benefit the
residents of Alhambra and bring revenue to the city, the location is worst possible location it could be built.
First, is the additional traffic this development will bring to an already heavily impacted thoroughfare. The
traffic will be so bad it will force cars to find other routes to get past the area and cause more pollution and
increase the danger to pedestrians and cyclist in the surrounding areas of the project.
center.
Invalid Zoning
The proposed development on 875 and 1111 South Fremont Ave. appears to violate the city's zoning laws
regarding that area of the city. The parcel of land on which the proposed development on 875 and 1111 South
Fremont resides is designated for Industrial Planned Developments (IPD). A Lowes home improvement
store does not fall within the IPD category according to Chapter 23.32 of Alhambra's Zoning Code.
Plan.

smoke, noxious gases, and hazardous materials and waste materials than many of the specifically identified
permitted uses in the IPD zone," nor does such a justification address the legality of permitting a facility in
an IPD zone that the city's zoning code clearly disallows. On the contrary, point 2 of the Background, Facts,
and Analysis of the Development Services Department's IPD Zoning Interpretation provided to the City
Council in 2010 submits that "the permitted uses in IDP Zones are fairly restrictive to industrial and
commercial uses."
conclusions are based solely on conjecture. What is more, it appears that the interpretation was made out of
convenience to City Hall's economic and development goals at the time rather than sound reasoning,
independent study, legal analysis, precedent, and careful consideration for the long-term impacts on traffic,
the environment, health and safety, and the effects on sustainable living in Alhambra. Point 8 of the
In the event owners, investors, developers, and building material sales

businesses and/or home improvement supplies businesses are aware of the
uses being permitted in the IPD Zone, the more likely such a building business
would move towards acquisition and development in the district and
In short, such an interpretation appears not to be legally and scientifically grounded, but economically and
politically motivated. Thus, it would likely not stand up in a court of law.
In addition, and perhaps more importantly, politically and economically motivated interpretations of
ordinances and zoning codes null the purpose of legislation, which disenfranchises the community at large,
diminishes residents' faith in their local government, and ultimately weakens the democratic process.
I hope the Planning Commission will call on the city to thoroughly address these concerns before voting on
Dubious Negative Mitigated Declaration
It is extremely concerning that a Mitigated Negative Declaration (MND) has been accepted by the City in
lieu of an Environmental Impact Report (EIR) as fulfillment of California Environmental Quality Act
(CEQA) requirements. The CEQA website outlines when it is appropriate to use a NMD in place of an EIR as
follows:

environment. (PRC 21080(c)), (14 C.C.R. 15070)
argument that significant effects may occur. (PRC 21080(d))
sits adjacent to one of the busiest streets in the region, I fail to see how the City can justify the acceptance of
an MND over an EIR based on their conclusion that "substantial evidence" does not exist that such a large
retail project will have a significant effect on the environment, not to mention residents' livelihoods. I have
not seen any evidence supplied by the City or its lead agency to substantiate such a conclusion. On the
contrary, I have spoken to several experts and looked over numerous documents that indicate there is
substantial evidence that the type of development being proposed on 874 and 1111 South Fremont will result
in negative impacts on the environment and health and well-being of the community.
spurious. For instance, the traffic study portion of the MND breaks with standard protocol by not using the
Institute of Transportation Engineers Trip Generation Manual (TGM) to calculate ALL of the trip rates for
home supply stores like Lowes. The study's authors utilize the TGM trip rate calculations only for non-peak
hours on weekdays and weekends and rely on trip calculation data from a Lowes in Poway to calculate peak
trip hours on weekdays and weekends. Why? This is extremely suspect and the study's justification, or lack
thereof, does not hold water. Poway is a much smaller, less urban city than Alhambra. It is troubling that
the study would rely solely on the data collected by one Lowes in Poway to calculate peak hour trip rates as
opposed the average calculated peak hour trip rate from data collected at multiple Lowes stores in cities
similar in size and layout to Alhambra. It is also troubling that the study would use two different data sets
for different hours of the day.
The study also contradicts itself when claiming, without evidence or precedent, that the same standards that
apply to a Home Depot do not apply to a Lowes because a Lowes "sells home improvement items geared
more to homeowners whereas Home Depot stores sell items geared more to small contractors." If this
statement were true, and there is no evidence supplied to prove that it is, then how do the study's authors
justify using TGM trip generation rates that are associated with Home Improvement Store land use, which
includes Home Depots, to calculate non-peak hour trip rates on weekdays and weekends for the proposed
Lowes development on Freemont? Regardless, the data used is inconsistent and suspect, which negates the
study's conclusions.
I urge the planning commission to require the city to adequately address these concerns before voting on
Closing
others are not asking the city to do this. What we are asking the city to do is to develop the land in a way that

is most beneficial to Alhambra residents, which takes into account livability, necessity, and economic and
social sustainability in both the short and long-term. I and others feel that another large home improvement
store that is literally blocks away from a pre-existing large home improvement store is not only unnecessary,
but detrimental to the Alhambra way of life.
The planning commission is the primary check and balance to the City Council regarding development in
Alhambra. Even though planning commissioners are appointed by City Council members, they are less
influenced by moneyed interests because they do not receive campaign contributions from developers. This
should allow Alhambra's Planning Commissioners to make uncompromised decisions about development
and its net-affects on Alhambra residents.
To this end, I urge the Planning Commission to disregard any politically motivating factors when voting on
this matter, and instead rely solely on the evidence and facts, Alhambra's zoning code as written in the City's
charter, and the environmental and social impact of such a development in an already overly congested area
of the city.
Thank you for the opportunity to comment on this important city matter.
As an Alhambra resident and homeowner on Meridian ave for over 48 years, I am very concerned about the
impact the proposed building project for a Lowes store, and two office buildings will have on our
In researching the traffic activity at various other Lowes locations, traffic was about 5,000 to 8,000 cars per
day. We are a residential community, not a commercial business area, and this project would have a severe
detrimental impact on our community. We already have a Home Depot just a few blocks way, which meets
the needs of our community.

RESOLUTION NO. R2M17-9
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

ALHAMBRA DENYING APPELLANTS PETITION OF AN APPEAL
AND UPHOLDING PLANNING COMMISSION RESOLUTION (17 -
4) APPROVING THE PROJECT MITIGATION MONITORING AND
REPORTING PROGRAM, MITIGATED NEGATIVE
DECLARATION, TENTATIVE TRACT MAP TT74223 AND
INDUSTRIAL PLANNED DEVELOPMENT PERMIT IP-16-4; AND,
UPHOLDING THE JUNE 28, 2010 CITY COUNCIL
DETERMINATION THAT BUILDING MATERIAL SALES, RETAIL
AND WHOLESALE, INCLUDING HOME IMPROVEMENT
SUPPLIES IS A PERMITTED USE IN THE INDUSTRIAL
PLANNED DEVELOPMENT (IPD) ZONE.
SECTION 1. FINDINGS OF FACT. The City Council does hereby make the
following findings of fact:
A. The applicant Vasilis Papadatos, National Engineering & Consulting on behalf

of Charles Co. (South Meridian, LLC a Delaware Limited Liability Company) has filed
with the Alhambra City Planning Commission an application for an Industrial Planned
Development Permit and Tentative Tract Map for the development of a 111,257 square
foot Lowes home improvement store and a 23,160 square foot garden center; a six level
parking structure; and two six-story office buildings designated to have a combined floor
area of approximately 245,400 square feet;
B. The City Council has previously determined, per Minute Order No. M2M10-
1006 that Building Material Sales, Retail and Wholesale, including Home Improvement
Supplies is a permitted use in the IPD Zone;
C. The Applicant conducted a public outreach meeting concerning the Project on

December 13, 2016. Nine hundred and eight (980) mailed notices were sent out
concerning the outreach meeting. Based upon comments received, the date of the
Alhambra Planning Commission meeting to consider the project was rescheduled from
January 3, 2017 to January 17, 201.;
D. Notice of the January 17, 2017 Alhambra Planning Commission public hearing
was published in the Pasadena Star News and posted in front of the Property.
Additionally, rather than send out the approximately 74 mailed notices required by the
Alhambra Municipal Code, an expanded notice area was mailed, which included 994
mailed notices.;
E. On January 17, 2017, a public hearing was duly held upon said application by the
City of Alhambra Planning Commission and at the conclusion of such hearing, the
Planning Commission voted 6-2 Approving Resolution 17-4 approving the project
Mitigation Monitoring and Reporting Program, Mitigated Negative Declaration,
Tentative Tract Map TT74223 and Industrial Planned Development Permit IP-16-4,
Page 1 of 10
including a determination that the proposed use was consistent with the IPD zone;
D. On January 24, 2017, the decision of the Planning Commission contained in

Resolution 17-4 was appealed to the City Council by appellant Eric Sunada; and
E. Notice of a public hearing to consider the appeal was published in the Pasadena
Star News on February 17, 2017 and mailed notice was sent to an expanded noticing area
on February 17, 2017, resulting in 995 mailed notices being sent out for the February 27,
2017 City Council hearing; and.
F. After conducting a duly noticed public hearing on February 27, 2017, and having
considered the arguments raised in the Appeal, as well as the written materials provided
to the Planning Commission and City Council, including, but not limited to the staff
reports, attachments, comment letters and responses; as well as the public testimony
provided at the Planning Commission and City Council, the City Council does not grant
the Appeal of the Project, and instead affirms the Planning Commission determination
and approves the Project as more fully set forth in this Resolution.
SECTION 2. CALIFORNIA ENVIRONMENTAL QUALITY ACT FINDINGS.

Based upon the Negative Declaration prepared for the project, as well as written
comments and testimony provided by the Appellant and the general public, the City
Council further finds and determines as follows:
A. The Initial Study and Mitigated Negative Declaration for this project have been
prepared in compliance with the California Environmental Quality Act;
B. The Mitigated Negative Declaration was posted on December 2, 2016, in

accordance with CEQA. The review period was open from December 2, 2016
through January 3, 2017, however, public comments were continually accepted
until January 17, 2017, at 5:00 P.M.;
C. There is no substantial evidence that the project with mitigation incorporation will
have a significant effect on the environment as proposed. The Mitigated Negative
Declaration reflects the independent judgment of the City of Alhambra;
D. The documents and other materials which constitute the record of proceedings for
Industrial Planned Development Permit IP-16-4 and Tentative Tract Map TT
74223 upon which the decision of the City Council is made is located within the
Development Services Department; and
E. The City Council, based upon the findings set forth above, hereby determines that
the Mitigated Negative Declaration for this project has been prepared in
compliance with CEQA, and adopts same, along with the associated mitigation,
monitoring and reporting program.
SECTION 3. INDUSTRIAL PLANNED DEVELOPMENT PERMIT FINDINGS.

Based upon the foregoing facts and findings (Section 23.62.070 of the Alhambra
Municipal Code) for Industrial Planned Development Permit IP-16-4, as well as written
Page 2 of 10
comments and testimony provided by the Appellant and the general public, the City
Council hereby determines as follows:
A. That the proposed use is permitted within the subject zone:
The proposed project consists of a one-story, 134,417 square foot Lowes home
improvement center which includes a 23,160 square foot garden center, a six-
story, 143,400 square foot office building, a six-story, 102,000 square foot office
building, and a six-level above-ground parking structure on a 12.66 acre site. The
permitted uses within the Industrial Planned Development zone are contained in
Section 23.32.020 of the Alhambra Municipal Code. The permitted uses within
the Industrial Planned Development zone include, but are not limited to, offices,
wholesale trade, lumberyards with accessory hardware sales, and plant nurseries.
On June 28, 2010, consistent with his authority in the Alhambra Municipal Code
the Director of Development Services interpreted the permitted uses in the IPD
zone to include building material sales, retail, and wholesale, including home
improvement supplies, based upon similarity to certain uses within the IPD zone
and a determination that such a use is not more objectionable than other permitted
uses within the zone. Furthermore this interpretation was presented to the
Alhambra City Council, and was confirmed unanimously. Per Minute Order No.
M2M10-1006, Building Material Sales, Retail and Wholesale, including Home
Improvement Supplies are a permitted use in the IPD zone. That zoning code
interpretation was included as part of the noticed Planning Commission hearing
for the project and was affirmed by the Planning Commissions determination of
zoning consistency, as set forth in the Planning Commissions resolution.
Additionally, the notice for this appeal hearing indicated that the determination of
zoning consistency was based upon similarity of use and the fact that such use is
not more objectionable than those uses otherwise permitted within the zone. In
that regard, the Project has as its components: office, sale of lumber, hardware,
and a plant nursery. These uses would be permitted independently in the IPD
without any limitation on retail square footage. Therefore it is reasonable to
interpret that when these uses are combined as one use, that use should similarly
be permissible under the IPD zone. With regard to whether such a use is not more
objectionable than those otherwise permitted in the zone, other manufacturing
uses could have noise, odor, exhaust, and possible soil contamination impacts
(such as the prior use) that would not be associated with the proposed Project.
Adult businesses (which are not part of the Project) are also a permitted use in the
zone and could have more objectionable impacts (as documented in the studies
that accompanied the Citys adoption of its adult use ordinance) than those
proposed in the Project.
B. The proposed use complies with the purpose and intent of the Zoning Ordinance
and the citys General Plan:
The purpose of the City of Alhambras Zoning Ordinance is to manage land uses
Page 3 of 10
and development in the City to insure compatibility with adjacent land uses
through regulations pertaining to, but not limited to, land uses, development
standards, design standards, and off-street parking. The proposed development
complies with all applicable regulations of the City of Alhambra Zoning
Ordinance and therefore is complaint with the intent and purpose of the Zoning
Ordinance.
The goal of the General Plan is to manage the use of land so growth,
development, and redevelopment occur in an orderly and beneficial manner which
recognizes and is sensitive to opportunities and constraints imposed by the Citys
infrastructure, and environmental and social resources. The Land Use Element of
the General Plan defines land use policy for the City through the Element text and
General Plan Land Use Policy Map. The Land Use Map describes the general
pattern of land uses and designates the project site as Industrial. The policies
included in the General Plan Land Use Element that are applicable to the land
uses proposed, and the projects conformity with each are as follows:
- Principle for Land Use Selection 2.3.3. Where appropriate, commercial

land uses shall be intensified or expanded when proper land is available.
The proposed project will involve the redevelopment of an underutilized
and vacant property.
- Policy 4.1.1. Promote growth, development, and redevelopment that

recognizes the costs, benefits, and trade-offs, both social and economic, of
the capacities of the natural and man-made environment of the City. The
proposed project will provide additional employment opportunities and
sales tax revenue for the City.
- Policy 4.1.3. Encourage land use patterns that minimize incompatibility

between uses. The proposed projects commercial land uses are consistent
with the other land uses along the Fremont Avenue corridor.
- Policy 4.1.4. Promote better migration of conflicting uses through known

techniques for eliminating conflicts for industrial and commercial areas
adjacent to residential areas. The proposed project will include a number
of design features (architecture, setback, building placement, and
landscaping) that will effectively mitigate potential land use compatibility
impacts to residential development in the area.
- Policy 4.1.10. Encourage the development of commercial land uses that

enhance the Citys share of the regional retail sales market. The Lowes
home improvement store will serve as the developments retail anchor.
C. The subject site is physically suitable for the type of land use being proposed:
The subject site measures 12.66 acres. As proposed, the subject site will be
Page 4 of 10
subdivided into two parcels of 8.84 acres and 3.82 acres. The 8.84 acre parcel
will be developed with a one-story, 134,417 square foot home improvement
center with a 23,160 square foot garden center. The 3.82 acre parcel will be
developed with two six-story office buildings of 143,000 square feet and 102,000
square feet, and a six-level above-ground parking structure. The proposed
developments for both parcels comply with all applicable property development
standards and does not required and deviations from code.
The Site is located in an US Environmental Protection Agency (EPA) Superfund

area Area 3 of the San Gabriel Valley Superfund. Area 3 covers the west end of
the San Gabriel Valley. More specifically, the Site is located at the western-most
edge of Area 3. The chemicals of concern (COCs) associated with the Site
included volatile organic compounds (VOCs) and petroleum hydrocarbons. As
reported in the Supplemental Remedial Action Report and Feasibility Study -
Shallow Unsaturated Zone (GSA, 2016a), shallow impacts of VOCs and
petroleum hydrocarbons have been mitigated through soil vapor extraction and
remedial excavation, under the oversight of the Los Angeles Regional Water
Quality Control Board (LARWQCB). The site is currently in the process of being
evaluated by the Regional Water Quality Control Board for a soils-only closure
with a deed restriction. Groundwater monitoring is anticipated to continue. The
Mitigated Negative Declaration contains Mitigation Measures No. 14 which
requires that 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. Mitigation
Measure No. 15 requires the applicant to 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). Implementation of these two Mitigation Measures will
ensure that the subject site is suitable for the proposed development.
D. The proposed use would be compatible with existing and future land uses within
the zone and general area in which the proposed use is to be located:
The proposed project will be restricted to the 12.66 acre project site and will not
divide or disrupt any residential neighborhood. The nearest such residential
development includes the residential units located along the north side of Mimosa
Street opposite of Emery Park. In addition, the proposed project will not result in
incompatible land uses since the project will consist of retail and office uses that
are consistent with the surrounding development, including the Kohls department
store and The Shops at Alhambra retail center to the south of the project site, and
LA Fitness gym, the Los Angeles County Public Works Department offices, The
Alhambra offices, and the Fremont Plaza shopping center to the east and north
east of the project site.
Page 5 of 10
E. With appropriate conditioning, there will be adequate provisions for water,
sanitation and public utilities and services to ensure that the proposed use would
not be detrimental to public health and safety.
The proposed project has been evaluated by the Citys Police, Fire, Public Works,
and Utilities Departments, and the Building Division, which have each submitted
conditions of approval to ensure that there will be adequate provisions for water,
sanitation and public utilities and services not only for the occupants of the
proposed use, but adequate provisions for all persons in the City. Surveillance
cameras with recording and retention capabilities will be provided for the two
office buildings as well as the Lowes building. There will also be adequate
lighting throughout the property as required by the Alhambra Police Department.
The proposed project will undergo further review by the Police Department as
part of the Plan Check process to ensure that the Police Department requirements
are met. The proposed project would not place additional demands on fire
services since the project will involve the construction of modern structures that
will be subject to all pertinent fire and building codes. Additionally, the proposed
project will undergo further review by the Fire Department as part of the plan
check process to ensure that sprinklers, hydrants, fire flow, fire access, etc., are
adequate in meeting the Fire Departments requirements. The project site is
located within the Los Angeles County Sanitation District Area 16 which is
served by the Joint Outfall System. Sewage generated within the City, including
the project site, is conveyed to the Joint Water Pollution Control Plant1. Future
wastewater generation will be within the treatment capacity of the Joint Water
Pollution Control Plant, therefore no new water and wastewater treatment
facilities will be needed to accommodate the excess effluent generated by the
proposed project.2 The project will be required to comply with the Citys
stormwater management guidelines as well as all applicable Federal Clean Water
Act requirements. The project proposes new impervious surfaces that will be
subject to the National Pollutant Discharge Elimination System permit from the
Regional Water Quality Control Board. The project will include various design
measures implemented to control and prevent the pollution of storm water runoff.
The addition of the runoff controls will ease the potential strain placed on the
existing system by excess runoff.3 The proposed project will not exceed City
water supplies.4 The proposed project will incorporate features aimed to reduce
water consumption, including landscaping with drought tolerant plants, and
installing high-efficiency WaterSense toilets and faucets in all restrooms.
F. With appropriate conditioning, there will be adequate provisions for public

access to serve the subject proposal.
The proposed off-street parking will be provided in the form of surface parking
for the home improvement parcel and a combination of surface parking and
structured parking in a six-level above ground parking structure for the office
parcel. The home improvement parcel will have a total of 414 parking spaces,
one more than the 413 parking spaces that are required for the Home
Page 6 of 10
Improvement Store. The office parcel will have a total of 982 parking spaces (35
surface spaces, 947 structured spaces), the minimum number of parking space
required for office uses. Direct access to the project site will be provided by a
total of eight driveways: four driveways located on the west side of Fremont
Avenue and four driveways located on the east side of Meridian Avenue. The
main driveway for Lowe's on Fremont Avenue is proposed to be signalized.
Cross access between the two parcels will allow all users of the site (both Lowe's
and the offices) to enter and exit the site via any of the driveways, although, two
driveways on Meridian Avenue will have physical design features that will limit
right-turn only ingress and left-turn only egress. In particular, all users will have
the option to enter and exit the site via the new signal on Fremont Avenue. This
means that office traffic will be able to head northbound from the site on Fremont
Avenue via the signal, thereby reducing the project dependence on Meridian
Avenue.
A traffic study was prepared by the project traffic consultant, Kimley Horn, in
accordance with standards established by the Los Angeles Congestion
Management Program (CMP), the County of Los Angeles, and the City of
Alhambra. Morning and evening weekday and weekend peak hour operating
conditions were evaluated at 12 signalized intersections and two unsignalized
intersections. The traffic study analyzed the Intersection Capacity Utilization
(ICU) for signalized intersections using Traffix software, and conducted a delay-
based analysis for unsignalized intersections using the Highway Capacity Manual
(HCM). The traffic study concluded that the project will generate traffic at a level
of significance which can be mitigated to pre-project levels with the addition of a
right-turn overlap for the westbound approach at the Fremont Avenue and Valley
Boulevard intersection, as well as traffic signals at Driveway C and Fremont
Avenue, and at the intersection of Mission Road and Meridian Avenue.
Implementation of the mitigation measures will ensure that there will be adequate
provisions for public access to serve the proposed development.
SECTION 4. TENTATIVE TRACT MAP FINDINGS. Based upon the foregoing

facts and findings (Title 22 of the Alhambra Municipal Code) for Tentative Tract Map
TT 74223, as well as written comments and testimony provided by the Appellant and the
general public, the City Council hereby determines as follows:
A. That the proposed Tentative Tract Map meets and performs all the applicable
requirements and conditions imposed by the State Subdivision Map Act and Title
22 (Subdivisions) of the Alhambra Municipal Code.
The proposed Tentative Tract map has been reviewed for compliance with the
State Subdivision Map Act and Title 22 (Subdivisions) of the Alhambra
Municipal Code. It has been determined that the proposed subdivision which will
reduce the number of parcels from 16 parcels to two parcels of 8.84 acres and
3.82 acres land meets and performs all the applicable requirements and conditions
imposed by the State Subdivision Map Act and Title 22 of the Alhambra
Page 7 of 10
Municipal Code.
B. That the proposed map is consistent with applicable General Plan and specific
plans.
There are no specific plans approved for or applicable to the project site. The
proposed subdivision is permitted under the Industrial land use designation of the
General Plan and the IPD (Industrial Planned Development) zoning designation.
The resulting two parcels will have sizes of 8.84 acres and 3.82 acres. The size of
each parcel exceeds the minimum lot size standards for new industrial projects,
which require a minimum 20,000 square feet of lot area.
C. That the design or improvement of the proposed subdivision is consistent with

applicable general and specific plans;
The proposed subdivision of the subject property into two parcels of 8.84 acres
and 3.82 acres is consistent with the Industrial land use classification of the
General Plan. The project meets all property development standards, including
setbacks, building height, floor area ratio and number of parking spaces. The
proposed project is in compliance with City regulations. There are no specific
plans approved or applicable to the project site.
D. That the site is physically suitable for the type of development.
The proposed subdivision of the subject property will result in two parcels of 8.84
acres and 3.82 acres. The 8.84 acre parcel will be developed with a one-story,
134,417 square foot home improvement center with a 23,160 square foot garden
center. The 3.82 acre parcel will be developed with two six-story office buildings
of 143,000 square feet and 102,000 square feet, and a six-level above-ground
parking structure. The proposed developments for both parcels comply with all
applicable property development standards and does not required and deviations
from code.
E. That the site is physically suitable for the proposed density of development.
IPD (Industrial Planned Development) zoned parcels larger than one acre in size
are permitted a maximum floor area ratio (FAR) of 2.0. The proposed home
improvement store parcel will have a FAR of 0.29 and the proposed office parcel
will have a FAR of 1.47. This proposed development will fit within the site and
will comply with all setback, building height, floor area ratio and parking
requirements, as well as all other applicable zoning requirements.
F. That the design of the subdivision or the proposed improvements is not likely to
cause substantial environmental damage or substantially and avoidably injure fish
or wildlife, or their habitat.
Page 8 of 10
A review of the California Department of Fish and Wildlife California Natural
Biodiversity Database (CNDDB) Bios Viewer for the Los Angeles Quadrangle
(the City of Alhambra is located within the aforementioned quadrangle) indicated
that out of the 33 native plant and animal species, five are either threatened or
endangered.5 The proposed project will not have an impact upon any of these
species because there is not suitable riparian or native habitat located within, or in
the vicinity of, the project site.6
G. That the design of the subdivision or the type of improvements is not likely to
cause serious public health problems.
The proposed subdivision will allow for the development of a home improvement
store and office uses. The Mitigated Negative Declaration (MND) contains
extensive environmental analysis that examined many factors including air quality
impacts, geology and soils impacts, greenhouse gas emission impacts, hazards &
hazardous waste impacts, noise impacts, population and housing impacts, public
services impacts, recreation impacts, and utilities impacts; all impacts that could
be related to public health problems. The lot consolidation and design for a
commercial center provides adequate light, air and circulation and will comply
with the current codes for health and safety and will not cause health problems.
The MND has analyzed all of these impacts pursuant to the requirements of the
California Environmental Quality Act (CEQA) and where there are potentially
any impacts arising from the project, those impacts will be mitigated through
mitigation measures to less than significant levels.
H. That the design of the subdivision or the type of improvements will not conflict
with easements, acquired by the public at large, for access through or use of
property within the proposed subdivision.
There are no easements currently existing across the property which were
acquired by the public at large, for access through or use of property within the
proposed subdivision.
5 Mitigated Negative Declaration Page 60

6 Mitigated Negative Declaration Page 61
SECTION 5. DETERMINATION ON APPEAL AND APPROVAL OF

PROJECT, based upon the foregoing determinations and findings, the City Council of
the City of Alhambra, California, does hereby:
A. Deny Appellants petition of Appeal and uphold Planning Commission Resolution

(17-4) Approving Industrial Planned Development Permit IP-16-4 and Tentative
Tract Map TT 74223, subject to the Conditions of Approval (Exhibit A), the
Mitigation Monitoring and Reporting Program (Exhibit B) and the Mitigated
Negative Declaration (Exhibit C) of Attachment C, for the development of a
Page 9 of 10
111,257 square foot home improvement center with a 23,160 square foot garden
center, a 143,000 square foot six-story office building, a 102,000 square foot six-
story office building, and a six-level above-ground parking structure on a 12.66
acre site located in the Industrial Planned Development zone at 875 and 1111
South Fremont Avenue (Assessor parcel numbers 5342-030-009, 5342-030-010,
5342-031-001, 5342-031-004, 5342-031-038, 5342-031-039, 5342-031-040,
5342,-31-041, 5342-031-42, 5342-032-007, 5342-032-008) in the City of
Alhambra;
B. Reaffirm the prior City Council determination that "Building Material Sales,
Retail and Wholesale, including Home Improvement Supplies" is a permitted use
in the Industrial Planned Development (IPD) Zone.
SECTION 6. The City Clerk shall certify to the adoption of this Resolution. The City
Clerk shall cause a certified copy of this Resolution to be mailed via certified mail to the
Appellant within five days of its adoption.
Signed and approved this ____ day of February, 2017.
_______________________
David Mejia, Mayor
ATTEST:
_____________________________
Lauren Myles, City Clerk
Page 10 of 10

Alhambra City Council Agenda 2/27/17

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Alhambra City Council Agenda 2/27/17

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COMMENTS & RESPONSES TO COMMENTS MITIGATED NEGATIVE DECLARATION & INITIAL STUDY

COMPLETE COMPILATION OF COMMENTS AND

THIS DOCUMENT IS A COMPLETE COMPILATION OF COMMENTS

PART 1 CONSISTS OF COMMENTS THAT WERE RECEIVED

PART 2 CONSISTS OF COMMENTS THAT WERE RECEIVED TOO

PART 3 CONSISTS OF THE MAJORITY OF THE COMMENTS

THE ENTIRE PACKAGE IS INCLUDED FOR THE RECORD.

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 1

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COMMENTS & RESPONSE TO COMMENTS PART I PAGE 2

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 3

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COMMENTS & RESPONSE TO COMMENTS PART I PAGE 4

ALHAMBRA COURT COMMERCIAL DEVELOPMENT

JANUARY 11, 2017

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 5

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COMMENTS & RESPONSE TO COMMENTS PART I PAGE 6

1. Comments and Response to Comments..................................................................................9

2. Community Meeting Comments and Responses.................................................................... 113

3. Comments and Responses to E-mails that were Received ....................................................... 117

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 7

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COMMENTS & RESPONSE TO COMMENTS PART I PAGE 8

1. COMMENTS AND RESPONSES TO COMMENTS

Letter Dated December 22, 2016

Letter Dated December 29, 2016

Letter Dated January 3, 2017

Letter Dated January 3, 2017

Letter Dated January 4, 2017

Letter Dated January 7, 2017

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 9

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 10

Comment Letter Dated December 22, 2016

There is no Tribal Cultural Resources section or subsection in the Environmental Checklist or

Linda Candelaria, Co-Chairperson, Gabrielino-Tongva Tribe;

Anthony Morales, Chairperson, Gabrieleno/Tongva San Gabriel Band of Mission Indians;

Joseph Ontiveros, Cultural Resource Director, Soboba Band of Luiseno Indians;

Sam Dunlap, Cultural Resources Director, Gabrielino/Tongva Nation.

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 11

A historical resource described in Section 21084.1, a unique archaeological resource as defined in

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 12

Please refer to Response 3.

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 13

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 14

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 15

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 16

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 17

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 18

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 19

Comment Letter Dated December 29, 2016

The comment is noted for the record.

I am pleased that the Mitigated Negative Declaration contains the following:

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 20

Thank you for your comment. Please refer to Response 2.

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 21

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 22

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 23

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 24

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 25

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 26

Comment Letter Dated January 3, 2017

COMMENTS & RESPONSE TO COMMENTS PART I PAGE 27

13. Meridian Avenue at Concord Avenue (unsignalized); and,