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Home My WebLink About2012-01-18 PacketCITY OF UKIAH CITY COUNCIL AGENDA Regular Meeting CIVIC CENTER COUNCIL CHAMBERS 300 Seminary Avenue Ukiah, CA 95482 January 18, 2012 6:00 p.m. 1. ROLL CALL 2. PLEDGE OF ALLEGIANCE 3. PROCLAMATIONS/INTRODUCTIONS/PRESENTATIONS 4. PETITIONS AND COMMUNICATIONS 5. APPROVAL OF MINUTES a. Special Meeting of 1/9/12 b. Regular Meeting of 1/4/12 6. RIGHT TO APPEAL DECISION Persons who are dissatisfied with a decision of the City Council may have the right to a review of that decision by a court. The City has adopted Section 1094.6 of the California Code of Civil Procedure, which generally limits to ninety days (90) the time within which the decision of the City Boards and Agencies may be judicially challenged. 7. CONSENT CALENDAR The following items listed are considered routine and will be enacted by a single motion and roll call vote by the City Council. Items may be removed from the Consent Calendar upon request of a Councilmember or a citizen in which event the item will be considered at the completion of all other items on the agenda. The motion by the City Council on the Consent Calendar will approve and make findings in accordance with Administrative Staff and/or Planning Commission recommendations. a. Disbursements for the Month of December 2011 b. Approve A Resolution Waiving The 60 -Day Notification Requirement For Establishing A County Facility Within The City Limits To Allow The County Of Mendocino To Lease Property At 655 Kings Court, Suites 300 & 400, Ukiah, Ca C. Approval Of A Resolution Of The City Council Of The City Of Ukiah Demanding Repayment Of Outstanding Loan Amount Under The Loan Agreement Between The Ukiah Redevelopment Agency And The City Of Ukiah, Dated April 3, 1996 With An Effective Date Of January 1, 1987 And Approval Of Corresponding Budget Amendment For The Receipt Of Funds. 8. AUDIENCE COMMENTS ON NON -AGENDA ITEMS The City Council welcomes input from the audience. If there is a matter of business on the agenda that you are interested in, you may address the Council when this matter is considered. If you wish to speak on a matter that is not on this agenda, you may do so at this time. In order for everyone to be heard, please limit your comments to three (3) minutes per person and not more than ten (10) minutes per subject. The Brown Act regulations do not allow action to be taken on audience comments in which the subject is not listed on the agenda. 9. COUNCIL REPORTS 10. CITY MANAGER/CITY CLERK REPORTS 11. PUBLIC HEARINGS (6:15 PM) a. Appeal Of The Planning Commission's Certification Of The Walmart Expansion Project Environmental Impact Report (EIR) 12. UNFINISHED BUSINESS a. Discussion And Possible Introduction Of Public Nuisance Abatement Ordinance b. Receive Status Report On Observatory Park Development Project. 13. NEW BUSINESS 14. CLOSED SESSION — Closed Session may be held at any time during the meeting a. Conference with Labor Negotiator (§ 54957.6) Agency Representative: Jane Chambers, City Manager Employee Organizations: Police, Fire, Electric, Miscellaneous, Management, and Department Head Units b. Conference with Legal Counsel —Existing Litigation (Subdivision (a) of Gov't Code Section 54956.9) Name of case: (Ukiah Valley Sanitation District v. City of Ukiah, dispute resolution under Participation Agreement) 15. ADJOURNMENT Please be advised that the City needs to be notified 72 hours in advance of a meeting if any specific accommodations or interpreter services are needed in order for you to attend. The City complies with ADA requirements and will attempt to reasonably accommodate individuals with disabilities upon request. Materials related to an item on this Agenda submitted to the City Council after distribution of the agenda packet are available for public inspection at the front counter at the Ukiah Civic Center, 300 Seminary Avenue, Ukiah, CA 95482, during normal business hours, Monday through Friday, 8:00 am to 5:00 pm. I hereby certify under penalty of perjury under the laws of the State of California that the foregoing agenda was posted on the bulletin board at the main entrance of the City of Ukiah City Hall, located at 300 Seminary Avenue, Ukiah, California, not less than 72 hours prior to the meeting set forth on this agenda. Dated this 12th day of January, 2012. JoAnne Currie, City Clerk CITY OF UKIAH CITY COUNCIL MINUTES Special Meeting CIVIC CENTER COUNCIL CHAMBERS 300 Seminary Avenue Ukiah, CA 95482 1/9/2012 1. ROLL CALL Ukiah City Council met at a Special Meeting on Januaiy19 being legally noticed on January 5, 2012. Mayor.Landi,c 6:00 pm. Roll was taken with the following Coubclimemb Rodin, Baldwin, and Mayor Landis. Councilr»embers abs Manager Chambers, Assistant City Manager�Sangiacomo Clerk Currie, and Project and Grant Ad, 101strator Mills. 2. NEW BUSINESS a. Status report on rede Supreme Court decisl6n the City Council of the"""; successor agency to the Ukiah, pursuant to Part 1. Code; and Co» Ukiah, ;Ga1i€orni previou{y :,perfc pursuant to Part Grant Ad a resoluti Item 5a 2012, the notice for which tilled the meeting to order at ers present: Thomas, Crane, ent: None. Staff Present: City City Attorney Rapport, City lopment issues resulting from the California t AB 1X 26 & 27 Consideration of a Resolution of tyofUkiah, Caifornia, electing to serve as the ,y the Divisio rn`unity RedeVetopment Agency of the City of Diw§f-n 24 of the�California Health and Safety Reso{utido, of the City Council of the City of retain the ihousing assets and functions Redeirelopment Agency of the City of Ukiah n 24. of the California Health and Safety Code. fibers, Assistant City Manager Sangiacomo, and Project and dills preserfted-the item. Recommended Action(s): 1. Approve ,it Iy Council of the City of Ukiah, California, electing to serve as cy to fhe Redevelopment Agency of the City of Ukiah, pursuant ion 24 6f the California Health and Safety Code. 2. Approve a y Council'of the City of Ukiah, California, electing to retain the function previously performed by the Redevelopment Agency of rsant to Part 1.85 of Division 24 of the California Health and Public CommeftOpened 6:20 pm Public Speaking to the item: Judy Hatch Public Comment Closed 6:23 pm MIS Crane/Rodin to approve Recommended Action One (Approve a resolution of the City Council of the City of Ukiah, California, electing to serve as the successor agency to the Redevelopment Agency of the City of Ukiah). Motion carried by the following roll call votes: AYES: Thomas, Crane, Rodin, Baldwin, and Mayor Landis. NOES: None. ABSENT: None. ABSTAIN: None Page 1 of 2 1/9/2012 M/S Crane/Thomas to approve resolution electing to retain the housing assets and function previously performed by the Redevelopment Agency of the City of Ukiah. Motion carried by the following roll call votes: AYES: Thomas, Crane, Rodin, Baldwin, and Mayor Landis. NOES: None. ABSENT: None. ABSTAIN: None 3. PUBLIC COMMENT 4. ADJOURNMENT There being no further business, the meeting adjourned at 6:48 pm. JoAnne M. Currie, City Clerk Page 2 of 2 1/9/2012 CITY OF UKIAH CITY COUNCIL MINUTES Regular Meeting CIVIC CENTER COUNCIL CHAMBERS 300 Seminary Avenue Ukiah, CA 95482 114/2012 1. ROLL CALL Ukiah City Council met at a Regular Meeting on January 4, 2012, the notice for which being legally noticed on December 29, 2011. Mayor Landis called the meeting to order at 6:00 pm. Roll was taken with the following Couhdilmembers present: Thomas, Crane, Rodin, Baldwin, and Mayor Landis. CouncilmOmbers absent:. None. Staff Present: City Manager Chambers, Assistant City Manager Sangiacomo, City Attorney Rapport, City Clerk Currie, Assistant Finance Director R©th, City Treasurer Carter, Director of Public Safety Dewey, Fire Division Chief Thomsen,, Director of Community Development and Planning Stump, Community Services Administrator M;0rsolan, Purchasing Supervisor Horger, and Museum Director Smith -Ferri. 2. PLEDGE OF ALLEGIANCE 3. 4. 5. APPROVAL OF```MtNUTES a. Regular Meeting of 1 b. Recuiar.Meetinq & 1'. MIS,; Crane/Couhdilrnember Rodin to Approve the Regular Minutes of 12/7/11 and 11/15/11 as submitteel.,:Motion`carried by the following roll call votes: AYES: Thomas, Crane, Rodin, Baldwin; and Landis. NOES: None. ABSENT: None. ABSTAIN: None 6. RIGHT TO APPEAL DECISION 7. CONSENT CALENDAR a. Approval Of NoticeOf Completion For Waugh Lane Bridge, Specification No. 11- 08 b. Adoption of Resolution Approving City of Ukiah Qualified Contractors' List for 2012 C. Approval Of Notice Of Completion For The Orchard Substation Project, Specification No. 10-08 And Approval Of Final Payment Of The 10% Retention To Cal Electro, Inc. (EUD) d. Authorize The Information Technology Department To Renew The ESRI Geographical Information System Software Licensing Agreement For A Term Of 3 Years In The Amount $26,937.50 Annually For A Total Of $80,812.50 Page 1 of 5 1/4/2012 M/S Crane/Thomas to approve Consent Item 7a -7d. Motion carried by the following roll call votes: AYES: Thomas, Crane, Rodin, Baldwin, and Landis. NOES: None. ABSENT: None. ABSTAIN: None 8. AUDIENCE COMMENTS ON NON -AGENDA ITEMS James Connerton spoke regarding the possible removal of a Valley Oak tree at the Sun House Museum. From what he understands, the tree needs care for a long life and it is possible to provide public safety and keep the tree. He does not support removal of the tree. Pinky Kushner spoke regarding saving the Valley Oak tree at the Sun House Museum and provided a handout regarding the tree to the City>,106- cil. Mary Anne Miller spoke regarding saving the and requests that procedures be in place re< not be a staff decision. Linda Sanders opposes removal of the supports protection of the tree during pa 9. COUNCIL REP, Councilmember Imember of have a a /alley Oak tree at the Sun House Museum �rding removal of heritage trees and that it Oak tree at the Sun; House Museum and the Live Oak free at the Sun Council sent to Mendocino County in 2009 ned and expressed concern the Walmart [rnpact of tax sharing with the County. He iar from the League of California Cities na tomorrow. sported the Public, Safety subcommittee (Thomas and Baldwin) report and encouraged the public to forward comments. Councilrr, tuber Baldwin requested"the City Council agendize green and food waste and Cold Creek,bompost's proposal in February or March. Baldwin reported he is working for a congressioh kcandida4r Norman Solomon; Phil Donahue will be in Ukiah Tuesday 5 pm representrn" trim. Irnterdsted persons should contact Baldwin. Mayor Landis reported she would like to see the following accomplished this year: plastic bag ban, local preference purchasing policy, and examination of the building permit process with the goal of improved customer service. 10. CITY MANAGER/CITY CLERK REPORTS Assistant City Manager Sangiacomo reported on the Live Oak Tree in Carpenter Hudson Park. It has been determined the tree is in the final phase of its life cycle. City staff is concerned for public safety because of falling limbs and the cables do not appear to be strong enough to hold the limbs. Multiple tree experts and arbors have been solicited to evaluate the tree. The fall zone area is blocked off during the evaluation period to ensure Page 2 of 5 1/4/2012 the safety of the public. The conceptual design and grant work has always included the tree as part of the park renovation. The City has tree guidelines, which the City Council has adopted and City staff is following those guidelines. Information will be forthcoming and staff will update the Tree Advisory Committee. 11. PUBLIC HEARINGS (6:15 PM) a. Authorize Updated Ambulance Rates And Approve Resolution Adopting Fees For Ambulance Services Provided By The Ukiah Fire Department Public Hearing Opened 6:33 pm Director of Public Safety Dewey and Fire Division Recommended Action(s): Conduct a public hearit fees for ambulance services provided by the UkiaEi Public speaking to the item: none. Public hearing closed 6:57 pm M/S Crane/Rodin to Approve adoption of a carried by the following roll -,,scall votes: AYE Landis. NOES: None. ABSENT; None. ABSTAI 12. UNFINISHED BUSINESS a. Sign Enforcement Discuss, on,(no fThomsen presented the item. nd approve Resolution adopting Department. ion approving the rates. Motion as, Crane, Ronin; Baldwin, and Directof of Community Development and Planning Stump responded that the issue T- is not so simple that ire' a couple of hours it is resolved. Stump provided some ideas such as, streamlining the process and change where the money from collected fines goes (currentlyfnes go to court not the program), and shutting down the planning counter to allow`fhe associate planner to perform some enforcement duties. City Manager Chambers is curious as to what drives the businesses to put up the signs. Getting that information might be helpful to finding a solution. It appears a disconnect exists between the community's desire for a certain look and the Council's desire for a certain look. City Council thought talking with the community would be helpful, if council is concerned with how the community looks and what drives the businesses to put up the signs. Page 3 of 5 1/4/2012 13. Consensus is to have this item be taken up by City Council, but make it part of the strategic planning process. Public speaking to the item: John Johns, John Johns Sign Company. b. Authorize City Manager To Negotiate And Execute A Contract With Alchemy Of Design For Interpretive Design Services In An Amount Not To Exceed $103,465 To Be Reimbursed By Grant Funds For The Grace Hudson Cultural Center Project Community Services Administrator Marsolan, Pur Museum Director Smith -Ferri presented the item: Paige Poulos and John Moon were available to".a Action(s): Authorize the City Manager to negotiaf Alchemy of Design for Interpretive Design Servic( $103,465 to be reimbursed by grant forYcts for the Project. Public Comment Opened 7:55 pm Public speaking to the item: Bruni Public comment closed 8'08,pm ing Supervisor Horger, and mittee Review members r questions. Recommended execute a contract with an amount not to exceed ;& ,Hudson Cultural Center , and Paige Poulos. Assistant Finance Director Roth and City Treasurer Carter presented the item. Recommended Action(s): Adopt resolution calling for a Special Election on June 5, 2012 and consolidating the special election with the Presidential Primary Election. M/S Crane/Baldwin to approve the Recommended Actions. Public Comment Opened 8:32 pm Public speaking to the item: JR Rose. Public Comment Closed 8:35 pm Page 4 of 5 1/4/2012 Motion carried by the following roll call votes: AYES: Thomas, Crane, Rodin, Baldwin, and Landis. NOES: None. ABSENT: None. ABSTAIN: None b. Ukiah Redevelopment Agency Annual Report For Fiscal Year 2010-2011 Assistant City Manager Sangiacomo and Assistant Finance Director Roth presented the item. Recommended Action(s): Receive, review, and file the Ukiah Redevelopment Agency Annual Report. M/S Rodin/Crane to approve Recommended Actions including a correction on page 5 of the Ukiah Redevelopment Agency Financial Statements, Table 1, Total assets should be -6.6% not -63%. Motion carried by the following roll cal( 'votes: AYES: Thomas, Crane, Rodin, Baldwin, and Landis. NOES: None. ABSENT: None.;/ B,STAIN: None Agency at 8:45 meetin laneous, Management, and of Ukiah, dispute resolution Reconvened r v:Ooen SessM6 4t x:50 Sin with no reportable action. 15.ADJOURNMENT Thei`e, being no further business-; ;the meeting adjourned at 9:50 pm JoAnne M. Currie, Page 5 of 5 1/4/2012 ITEM NO.: 7a MEETING DATE: January 18, 2012 AGENDA SUMMARY REPORT SUBJECT: REPORT OF DISBURSEMENTS FOR THE MONTH OF DECEMBER 2011 Payments made during the month of December 2011, are summarized on the attached Report of Disbursements. Further detail is supplied on the attached Schedule of Bills, representing the five (5) individual payment cycles within the month. Accounts Payable check numbers: 110943-111113, 111150-111261, 111263-111360 Accounts Payable Manual check numbers: none Payroll check numbers: 110906-110942, 111114-111149, 111361-111400 Payroll Manual check numbers: none Void check numbers: 111262 This report is submitted in accordance with Ukiah City Code Division 1, Chapter 7, Article 1. Fiscal Impact: I Budgeted FY 11/12 F-1 New Appropriation Not Applicable Budget Amendment Required Amount Budgeted Source of Funds (title and #) Account Number Addit. Appropriation Requested Continued on Page 2 Recommended Action(s): Approve the Report of Disbursements for the month of December 2011 Alternative Council Option(s): N/A Citizens advised: N/A Requested by: City Manager Prepared by: Accounts Payable Specialist II Coordinated with: Finance Director and City Manager Attachments: Reports of Disbursements Approved // , t 4: — J e Chambers, City Manager CITY OF UKIAH REPORT OF DISBURSEMENTS REGISTER OF PAYROLL AND DEMAND PAYMENTS FOR THE MONTH OF DECEMBER 2011 Demand Payments approved: Check No. 110943-111027, 111028-111113, 111150-111261, 111263-111360 FUNDS: 100 General Fund $157,669.60 600 Airport $32,741.48 105 Measure S General Fund $41,990.72 610 Sewer Service Fund 110 Special General Fund 611 Sewer Construction Fund $3,250.00 140 Park Development $72,770.41 612 City/District Sewer $146,386.68 141 Museum Grants 614 Sewer Capital Projects Fund 143 N.E.H.1. Museum Grant 615 City/District Sewer Replace 150 Civic Center Fund 620 Special Sewer Fund (Cap Imp) 200 Asset Seizure Fund $9,386.55 640 San Dist Revolving Fund 201 Asset Seizure (Drug/Alcohol) 641 Sanitation District Special $12,975.15 203 H&S Education 11489 (B)(2)(A1) $506.40 650 Spec San Dist Fund (Camp Imp) 204 Federal Asset Seizure Grants 652 REDIP Sewer Enterprise Fund 205 Sup Law Enforce. Srv. Fund (SLESF $2,500.00 660 Sanitary Disposal Site Fund $25,742.57 206 Community Oriented Policing 661 Landfill Corrective Fund 207 Local Law Enforce. Blk Grant 664 Disposal Closure Reserve 208 Asset Forfeiture 11470.2 H&S _ 670 U.S.W. Bill & Collect $26,910.47 220 Parking Dist. #1 Oper & Maint $483.41 678 Public Safety Dispatch $932.47 230 Parking Dist. 91 Revenue Fund 695 Golf $29,313.34 250 Special Revenue Fund $18,434.08 696 Warehouse/Stores $1,618.12 255 ARC General Operating Fund $2,123.49 697 Billing Enterprise Fund $7,520.89 260 _ Downtown Business Improvement 698 Fixed Asset Fund $111,497.05 270 Signalizaton Fund 699 Special Projects Reserve $476.00 290 Bridge Fund _ 765 City RDA Projects $15,542.30 300 2106 Gas Tax Fund 800 Electric $1,007,325.44 301 2107 Gas Tax Fund 805 Street Lighting Fund $8,859.18 303 2105 Gas Tax Fund 806 Public Benefits Charges $6,223.98 310 Special Aviation Fund 820 Water $53,526.66 315 Airport Capital Improvement 840 Special Water Fund (Cap Imp) 330 Revenue Sharing Fund 900 Special Deposit Trust $28,050.57 332 Federal Emerg. Shelter Grant 910 Worker's Comp. Fund $7,978.90 333 Comm. Development Block Grant _ 920 Liability Fund $177,143.00 334 EDBG 94-333 Revolving Loan 940 Payroll Posting Fund $192,226.73 335 Community Dev. Comm. Fund $20,000.00 950 General Service (Accts Recv) $705.03 336 08 -HOME -4688 960 Community Redev. Agency $1,847.44 337 CDBG Grant 09-STBG-6417 961 RDA Housing Pass -Through 340 SB325 Reimbursement Fund 962 Redevelopment Housing Fund $131.45 341 S.T.P. 963 Housing Debt 342 Trans -Traffic Congest Relief 964 RDA Capital Pass -Through 345 Off -System Roads Fund 965 Redevelopment Cap Imprv. Fund $13,112.30 410 Conference Center Fund $5,785.98 966 Redevelopment Debt Svc. 550 Lake Mendocino Bond-Int/Red 967 Housing Bond Proceeds $153.00 555 Lake Mendocino Bond -Reserve 968 Non -Housing Bond Proceeds $153.00 575 Garage $2,429.67 975 Russian River Watershed Assoc 976 Mixing Zone Policy JPA PAYROLL CHECK NUMBERS 110906-110942 DIRECT DEPOSIT NUMBERS 54240-54445 PAYROLL PERIOD 11/13/11-11/26/11 PAYROLL CHECK NUMBERS: 111114-111149 DIRECT DEPOSIT NUMBERS 54446-54638 PAYROLL PERIOD 11/27/11-12/10/11 PAYROLL CHECK NUMBERS: 111361-111400 DIRECT DEPOSIT NUMBERS 54639-54826 PAYROLL PERIOD: 12/11/11-12/24/11 VOID CHECK NUMBERS: none TOTAL DEMAND PAYMENTS- A/P CHECKS $2,246,423.51 TOTAL DEMAND PAYMENTS -WIRE TRANSFERS' $75.00 TOTAL PAYROLL CHECKS & DIRECT DEPOSIT! $1,044,348.99 TOTAL PAYROLL EFT's (TAXES, PERS, VENDORS) $797,149.54 TOTALPAYMENTS CERTIFICATION OF CITY CLERK This register of Payroll and Demand Payments was duly approved by the City Council on APPROVAL OF CITY MANAGER I have examined this Register and approve same. City Manager City Clerk $4,087,997.04 CERTIFICATION OF DIRECTOR OF FINANCE I have audited this Register and approve for accuracy and available funds. Director of Finance xw xw xa fs, U OW P: H rl U O 00 w d, O Ln as UU rn U) Q EI 01610010010L -'j, MONO Ln MLOh MOO N E -I 00 OD z H M O H M N O O M r 00 h 001"0 M M N 00 Ll z L- r- . . . . . . . . . . .. . . 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(S �D H Ri �D O H rsa ZI xH a U cna4U a W I QO U �w U w r 4 � I r0i GaN W Q I �Q, U] a' W Z I o-- x rx a E I Ino o N Z x l U Z I O HN I 000 O aC FC I OM U -- [ f=a I li w (3)N M fel I �D H Q a w Q Q oz w w o U m cn Ga zW Hp H H Z 0 w •• as ,n x �H zw H O � H O Csa N O\ H >1N Ems\ H N UH 4city (7�_ •zfki"fi ITEM NO.: 7b MEETING DATE: AGENDA SUMMARY REPORT January 18, 2012 SUBJECT: APPROVE A RESOLUTION WAIVING THE 60 -DAY NOTIFICATION REQUIREMENT FOR ESTABLISHING A COUNTY FACILITY WITHIN THE CITY LIMITS TO ALLOW THE COUNTY OF MENDOCINO TO LEASE PROPERTY AT 655 KINGS COURT, SUITES 300 & 400. UKIAH. CA Discussion: The City has received a request from the County of Mendocino to waive the 60 -day notice requirement to lease a property within City Limits. Government Code §25351 requires that the County notify the City in advance of its intent to locate a County facility in the incorporated area. Government Code §25351 further requires that said advance notification occur at least 60 days prior to use and occupancy of the County facility, unless the City Council waives the notification requirement by Resolution. The General Services Department of Mendocino County has requested a waiver of the 60 -day notification requirement to lease property at 655 Kings Court, Suites 300 & 400, Ukiah. This is not a new use at this location. The County is simply continuing its use at this location under a new lease term. The granting of the waiver will enable the County to lease the property by January 2012, thereby avoiding loss of the property to another prospective tenant. Fiscal Impact: Budgeted FY 11/12 F-1New Appropriation � Not Applicable Budget Amendment Required Recommended Action(s): Approve Resolution waiving the 60 -day notification requirement. Alternative Council Option(s): Remand to staff with alternate direction. Citizens advised: Requested by: Kristin McMenomey, General Services Director, County of Mendocino Prepared by: Sage Sangiacomo, Assistant City Manager Coordinated with: Attachments: 1) Resolution Waiving Notice Approved: Jane Chambers, City Manager if ATTACHMENT --! RESOLU T ION NO. 2012 - RESOLUTION OF THE CITY COUNCIL OF THE CITY OF UKIAH WAIVING THE 60 -DAY NOTIFICATION REQUIREMENT FOR ESTABLISHING A COUNTY FACILITY WITHIN THE CITY LIMITS, AS REQUIRED BY GOVERNMENT CODE §25351 WHEREAS, 1. Government Code §25351 requires that a County notify a City in advance of its intent to locate a County facility in the incorporated area; and 2. Government Code §25351 further requires that said advance notification occur at least 60 days prior to use and occupancy of the County facility, unless the City Council waives the notification requirement by Resolution; and 3. The General Services Department of Mendocino County has requested a waiver of the 60 -day notification requirement to lease property at 655 Kings Court, Suites 300 & 400, Ukiah. 4. The granting of the waiver will enable the County to lease the property by January 2012, thereby avoiding loss of the property to another prospective tenant. NOW, THEREFORE, BE IT RESOLVED that the City of Ukiah grants the County of Mendocino a waiver of the 60 -day notification requirement so as to lease the property at 655 Kings Court, Suites 300 & 400, Ukiah. PASSED AND ADOPTED on vote: AYES: NOES: ABSTAIN: ABSENT: ATTEST: JoAnne M. Currie, City Clerk by the following roll call Mary Anne Landis, Mayor ,city a_J 4-fkiah ITEM NO.: 7c MEETING DATE: AGENDA SUMMARY REPORT January 18, 2012 SUBJECT: Approval Of A Resolution Of The City Council Of The City Of Ukiah Demanding Repayment Of Outstanding Loan Amount Under The Loan Agreement Between The Ukiah Redevelopment Agency And The City Of Ukiah, Dated April 3, 1996 With An Effective Date Of January 1, 1987 And Approval Of Corresponding Budget Amendment For The Receipt Of Funds. Background: The Community Redevelopment Agency of the City of Ukiah ("Agency") was created by the City Council for the purposes of implementing redevelopment activities in the City. The City Council adopted the Redevelopment Plan for the Ukiah Redevelopment Project in accordance with the Community Redevelopment Law (Health and Safety Code § 33000 et seq.) ("CRL"). The Ukiah Redevelopment Project Area was found to have a significant number of physical and economic blighting conditions that necessitated adoption of the Redevelopment Plan. The Redevelopment Plan authorizes the Agency to receive tax increment revenue to pay for programs and projects that address these conditions consistent with the CRL. The City of Ukiah and the Ukiah Redevelopment Agency entered into a loan agreement dated April 3, 1996 with an effective date of January 1, 1987 by which the City loaned the Agency funds for programs and activities. The agreement is included as Attachment #1 for review. Such agreements are common given that redevelopment agencies have limited tax increment revenue in the early years after inception and an agency is being formed. The Agency has continued to make annual payments on the loan since the funds were disbursed. Discussion: Per the terms of the loan agreement, the City has the right to demand repayment at anytime. Given the recent California Supreme Court ruling upholding AB 1X 26 and the impending dissolution of the Ukiah Redevelopment Agency, City staff recommends that the City Council exercise the demand provision of the loan agreement for full payment of all loaned funds. A resolution for the repayment is included as Attachment #2. The total amount of funds due to the City of Ukiah is $1,197,702.01. Fiscal Impact: 0 Budgeted FY 11/12 F7New Appropriation Not Applicable 0 Budget Amendment Required Revenue Amount Title of Account Revenue Account # $1,197,702.01 TBD by Finance Dept. TBD by Finance Dept. Recommended Action(s): Approve a Resolution (Attachment #2) of the City Council of the City of Ukiah demanding repayment of outstanding loan amount under the loan agreement between the Ukiah Redevelopment Agency and the City of Ukiah, dated April 3, 1996 with an effective date of January 1, 1987 and approve the corresponding budget amendment for the receipt of funds. Alternative Council Option(s): Do not approve resolution and provide direction to Staff. Citizens advised: N/A Requested by: N/A Prepared by: Sage Sangiacomo, Assistant City Manager and Guy Mills, Project and Grant Administrator Coordinated with: Jane Chambers, City Manager; David Rapport, City Attorney; Gordon Elton, Director of Finance; Ian Roth, Assistant Director of Finance; and Iris Yang, RDA Legal Specialist Attachments: 1. Loan Agreement between the City of Ukiah & Ukiah Redevelopment Agency 2. Resolution for Repayment of Loan r Approved: Ch Jan ambers, City Manager ATTACHMENT-J. RESOLUTION NO, 96-8 RESOLUTION OF THE UKIAH REDEVELOPMENT AGENCY APPROVING LOAN AGREEMENT BETWEEN THE UKIAH REDEVELOPMENT AGENCY AND THE CITY OF UKIAH WHEREAS, the Ukiah Redevelopment Agency (Agency) was established by the Ukiah City Council (City) In 1974, and adopted a Redevelopment Plan in 1989; and WHEREAS, the Ukiah Redevelopment Agency performs duties and carries out plans and programs beneficial to the City and Its environs, and WHEREAS, the Agency, like all Redevelopment Agencies, must operate In a debt situation, precluding unencumbered fund balances; and WHEREAS, both the Agency and the City wish to formalize the loan procedures between the two parties. NOW, THEREFORE, BE IT RESOLVED, by the Ukiah Redevelopment Agency that the Loan Agreement between the City of Ukiah and the Ukiah Redevelopment Agency, attached hereto as Exhibit 'A,' is approved, and the Chairman is authorized to execute some, PASSED AND ADOPTED this 3rd day of April, 1996, by the following roll call vote: AYES: Commissioners Mastin, Malone, Shoemaker, and Chairman Schnelter NOES: Commissioner Wattenburger ABSENT: None ABSTAIN: None ATTES � - - Karen Yoast, Red v lopment Secretary 4/Res:Loan.URA Fred Schnelter, Chairman LOAN AGREEMENT BETWEEN THE UKIAH REDEVELOPMENT AGENCY AND THE CITY OF UKIAH This Agreement is made and entered in Ukiah, California, on Apr;1 3 , 1996, by and between the City of Ukiah ("City") and the Ukiah Redevelopment Agency ("Agency"), effective as of January 1, 1987. RECITALS: 1. City first formed the Agency in 1974. 2. In 1983 the City began to consider adopting a Redevelop-ment Plan. 3. Beginning in 1987 the Agency retained professional consultants to advise and assist it in the development of a redevelopment plan and associated documents, including environmental documents. These consultants included the law firm of McDonough, Holland and Allen, the planning firms of Wurster, Bernardi & Emmons, Inc., and John B. Dykstra & Associates as well as financial consultants. 4. In addition, the Agency incurred additional legal and administrative expenses in the course of developing and implementing its redevelopment plan. 5. The City has advanced funds to the Agency for all of these purposes periodically since February, 1983. 6. Not later than October 1 of each year, the Agency has filed annual statements of indebtedness with the County Auditor pursuant to the Health & Safety Code §33675. 7. Periodically, the City will be required to advance funds to the Agency in the future for administrative and other expenses of the Agency. 8. All of these advances to the Agency were made as loans which the Agency is required to repay pursuant to resolutions of the City and the Agency. 9. The purpose of this Agreement is to memorialize the terms under which the City has and will loan funds to the Agency for costs of developing, implementing, revising and administering the redevelopment plan. AGREEMENT: In consideration of the above -recited facts and on the terms and conditions as further stated herein, the parties hereby agree as follows: 1. REPAYMENT OF PAST LOANS. To and including June 30, 1996, the City has or will have loaned the Agency for the development, implementation and administration of the Ukiah Redevelopment Plan, amounts as set forth in the attached Exhibit A which is incorporated herein by reference. The total amount of said loan equals $1,577,205.52 ("Loan Amount"). The Loan Amount is comprised of the following: Date of Advance 2/2/83 - 1/3/87 Fy 91/92 - 3/29/96 3/5/96 - 6/30/96 TABLE I Amount Interest Rate $ 152,110.001 10% $1,379,331.522 Adjust .3 $ 45,764.009 Adjust. Designation "Audited Loan" "Budget Deficit Loan" "Projected Deficit Loan" Agency agrees to repay the Loan Amount as further provided in this paragraph. 1.1 Upon demand of the City, Agency shall repay all or part of the outstanding balance of the Loan Amount; provided, however, that the Agency shall only be obligated to repay the Loan Amount from unencumbered tax increment revenues actually available to the Agency and not required by the Agency to satisfy legally binding financial commitments arising prior to a demand for repayment by the City. 1.2 From the date of advance through June 30, 1996, the Agency shall pay annual interest on the Audited Loan, Budget Deficit Loan and Projected Deficit Loan at the interest rates stated in Table I, compounded annually. The Loan Amount already includes accrued interest at these rates to the dates stated in footnotes 1-2 and 4 of paragraph 1. After June 30, 1996, the 1 Includes interest through 6/30/96 2 Includes accrued interest through March 5, 1996 3 Adjustable rate equal to the average interest rate earned by City on all its invested funds. 9 Includes accrued interest through June 30, 1996 s:\u\a9=ts96\rda.1n March 29, 1996 2 Agency shall pay annual interest on the entire unpaid balance of the Loan Amount, including accrued but unpaid interest at the rate of 6%, compounded annually. 1.3 The Agency shall continue to make payments on demand as provided in this paragraph until the total outstanding balance of the Loan Amount and accrued interest is paid in full. 2. REPAYMENT OF FUTURE BUDGETED LOANS. On and after June 30, 1996, the Agency may request the City to budget additional amounts to loan the Agency pursuant to the terms of this paragraph. 2.1 On or before May 15 of each year, the Agency may submit a request to the City to budget an amount of funds to loan the Agency for costs of revising, implementing and administering the redevelopment plan or performing a public function of the community. These purposes can include costs of City supplied personnel, equipment, overhead and supplies, costs associated with the officers and employees of the Agency, costs of outside contractors and consultants, and costs associated with the purchase of real or personal property. All amounts budgeted shall be a loan from the City to the Agency ("Budgeted Loan") which the Agency shall repay pursuant to the terms of this paragraph. 2.2 In addition to Budgeted Loans requested pursuant to paragraph 2.1, the Agency make request the City to budget additional amounts at any time for the purposes stated in paragraph 2.1. Any additional amounts so budgeted by the City shall also be considered Budgeted Loans subject to the terms of this paragraph 2. 2.3 Upon demand of the City, Agency shall repay all or part of the outstanding balance of the Budgeted Loan; provided, however, that the Agency shall only be obligated to repay the Budgeted Loan from unencumbered tax increment revenues actually available to the Agency and not required by the Agency to satisfy legally binding financial commitments arising prior to a demand for repayment by the City. 2.4 From the date of each advance of a Budgeted Loan to the Agency, the Agency shall pay annual interest on the entire unpaid balance of the Budgeted Loan, including accrued but unpaid interest, at the rate of 6%, compounded annually. 2.5 The Agency shall continue to make payments on demand as provided in this paragraph until the total outstanding balance of the Budgeted Loan and accrued interest are paid in full. 3. FINANCIAL REPORTS REQUIRED. As long as a Loan Amount, Budgeted Loan or accrued interest remain unpaid, Agency shall file annual financial statements with the City of all revenues and expenditures. 9:\u\a9rmts96\rda.1n 3 March 29, 1996 4• AGENCY ADMINISTRATIVE FUND. All money loaned to Agency under this Agreement shall be kept by the treasury of the City in a special fund to be known as the "Ukiah Community Redevelopment Agency Administrative Fund" and money shall be drawn from the fund to meet the administrative and other approved expenses of the Agency in substantially the same manner as money is drawn by other departments and agencies of the City subject to budgetary control. 5. SUBORDINATION. The Agency's pledge of tax increment revenues and its obligation to repay the Loan Amount, a Budgeted Loan or accrued interest under the terms of this Agreement is subordinate to its pledge of tax increments for tax allocation bonds or other long-term indebtedness the Agency incurs to carry out a project. 6. SEVERABILITY. If any provision of the Agreement is held by a court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in full force and effect without being impaired or invalidated in any way. 7. INTEGRATION. This Agreement contains the entire agreement among the parties and supersedes all prior and contemporaneous oral and written agreements, understandings, and representations among the parties. No amendments to this Agreement shall be binding unless executed in writing by all of the parties. 8. WAIVER. No waiver of any of the provisions of this Agreement shall be deemed, or shall constitute a waiver of any other provision, nor shall any waiver constitute a continuing waiver. No waiver shall be binding unless executed in writing by the party making the waiver. 9. NOTICES. Whenever notice, payment or other communication is required or permitted under this Agreement it shall be deemed to have been given when personally delivered or when deposited in the United Sates mail with proper first class postage affixed thereto and addressed as follows: AGENCY Executive Director Ukiah Civic Center 300 Seminary Ave. Ukiah, CA. 95482 CITY City Manager Ukiah Civic Center 300 Seminary Ave. Ukiah, CA. 95482 10. PARAGRAPH HEADINGS. The paragraph headings contained herein are for convenience and reference only and are not intended to define or limit the scope of thit agreement. s:\u\agrmts96\r8a.ln 4 March 29, 1996 ii. BUPLiCA71E ORIGINALS. This Agreement may be executed in one or more duplicate originals bearing the original signature of both parties and when so executed any such duplicate original shall be admissible as proof of the existence and terms of the Agreement between the parties. WHEREFORE, the parties have entered this Agreement on the date first written above. CITY OF UKIAH By: 1(lalltlweqtlel Fred S neiter, Mayor ATTEST: Cathy McKa , Cit Jerk a:\u\agrmts96\rda.1n March 29, 1996 5 UKIAH REDEVELOPMENT AGENCY B W4, �Wal� Y Fred Schneiter, Chairman ATTEST: Karen Yoast, S retary EXHIBIT A RDA BORROWING interest 7/1/96-6/30/97 7,500.00 1597610.00 DEBT SUMMARY CASH FLOW DEFICIT Accumulated Balance Operating Cap. Project Principal Interest to 6/30/95 Due 2/2/83 10,000.00 12,333.00 22,333.00 5/15/85 15,000.00 15,193.00 30,193.00 1/3/87 50,000.00 42,084.00 92,084.00 Audited balance 6/30/95 75,000.00 69,610.00 144,610.00 Interest 7/1/95 - 3/31/96 FY 1995/96 YTD 5,625.00 150,235.00 Interest 4/1/96 - 6/30/96 (593,042.46) (399,930.20) 1,875.00 152,110.00 interest 7/1/96-6/30/97 7,500.00 1597610.00 DEBT SUMMARY CASH FLOW DEFICIT Original Combined Operating Cap. Project Prior to FY 91/92 Fund 960 (34,060.73) Fund 965 Loans * (114,610.00) Total (148,670.73) FY 1991/92 (176,211.84) (7,500.00) (183,711.84) FY 1992/93 FY 1993/94 (21,696.99) (7,500.00) (29,196.99) FY 1994/95 (167,514.30) (585,542.46) (7,500.00) (175,014.30) FY 1995/96 YTD (204,178.29) (190,126.91) (7,500.00) (5,625.00) (593,042.46) (399,930.20) FY 1996 Projected to Apr - Jun 140,800.00 186,564.00 1,875.00 47,639.00 TOTAL at June 30, 1996 1,048,404.61 (376,690.91)1 M52,110.00 1,577,205.52 FY 1996/97 Projected 20,595.39 (70,309.09 9,126.60 100,031.08 TOTAL (2,117,404.61) 823,690.91 313,34fi.60 1,677,236.60 Total debt, pre-existing loan (Principal & accrued interest), as of June 30, 1996 ** Total debt (Budget Deficit) incurred to March 29, 1996 Projected debt to be incurred to June 30, 1996 TOTAL Projected debt to be incurred in FY 1996/97 TOTAL * Includes accrued interest ** Includes $77,110 of accrued interest. (152,110.00) (1,379,331.52) _ (45,764.00) (1,577,205.52) (100,031.08) (1,677,236.60) DEBTSUM.XLS 3/29/96 Page 1 April 3, 1996 Agenda ATTACf-IMENT RESOLUTION NO. RESOLUTION OF THE CITY COUNCIL OF THE CITY OF UKIAH DEMANDING REPAYMENT OF OUTSTANDING LOAN AMOUNT UNDER THE LOAN AGREEMENT BETWEEN THE UKIAH REDEVELOPMENT AGENCY AND THE CITY OF UKIAH, DATED APRIL 3, 1996 WITH AN EFFECTIVE DATE OF JANUARY 1, 1987 WHEREAS, 1. Under the Loan Agreement between the Ukiah Redevelopment Agency and the City of Ukiah, dated April 3, 1996, with an effective date of January 1, 1987 ("Loan Agreement"), the Ukiah Redevelopment Agency ("Agency") acknowledged loans from the City of Ukiah ("City") to the Agency beginning in February 1983, which were reflected in annual statements of indebtedness filed not later than October 1 each year with the County Auditor;' and 2. The Loan Agreement memorialized that the amount of the indebtedness as of April 3, 1996, including principal and interest, totaled $1,577,205.52; and 3. Under the terms of the Loan Agreement the Agency has a mandatory duty to repay all or any portion of the indebtedness upon demand of the City, provided that the Agency is only required to repay the loan from unencumbered tax increment revenues actually available to the Agency and not required by the Agency to satisfy legally binding financial commitments arising prior to the demand for repayment; and 4. Prior to January 18, 2012, the Agency has repaid the City interest and $417,654.42 in principal on the outstanding balance of the funds loaned to the Agency by the City under the Loan Agreement; and 5. The outstanding indebtedness under the Loan Agreement as of January 18, 2012, is $1,197,702.01, including unpaid principal and accrued interest ("Loan Balance"); and 6. The Agency currently has available to it unencumbered tax increment revenue not required by the Agency to satisfy legally binding financial commitments arising prior to January 18, 2012, in Fund 966 sufficient to repay the Loan Balance; NOW, THEREFORE, BE IT RESOLVED that 1. The City Council of the City of Ukiah hereby makes demand on the Agency to repay $1,197,702.01 of the Loan Balance, by no later than January 30, 2012. 2. The City Clerk is directed to transmit this demand for payment to the Agency Executive Director. 1 A true and correct copy of the Loan Agreement is attached to this Resolution. 3. The City Council confirms the authority of the City's Finance Director to make demands on the Agency for repayment under the Loan Agreement and reaffirms all demands for repayment by the Finance Director prior to or after the adoption of this resolution. DULY AND REGULARLY ADOPTED by the City Council of the City of Ukiah on January 18, 2012 by the following roll call vote: AYES: NOES: ABSENT: ABSTAIN: ATTEST: Joanne Curry, City Clerk 2 8266 1.0000 1\5861861.1 APPROVED: Mary Ann Landis, Mayor City of TJriafi ITEM NO.: 12a MEETING DATE: UKIAH CITY COUNCIL AGENDA SUMMARY REPORT January 18, 2012 SUBJECT: DISCUSSION AND POSSIBLE INTRODUCTION OF PUBLIC NUISANCE ABATEMENT ORDINANCE SUMMARY: The City Council considered a proposed nuisance abatement ordinance at its meeting on April 6, 2011. A majority of the Council expressed the opinion that a nuisance abatement ordinance would be a useful tool in abating public nuisance conditions throughout the City. However, concerns were expressed that the proposed ordinance included conditions that did not arise to the level of a public nuisance and could potentially apply to conditions, particularly on residential property, that do not warrant enforcement actions by the City. Particular concerns were expressed about including as public nuisance conditions parking vehicles on unpaved surfaces, weeds or overgrown vegetation on private property, furniture stored or used on private property that was not designed for outdoor use, peeling paint, or water stored in cisterns or tanks used as part of a rainwater catchment or grey water reuse system. Attached is a revised ordinance to address the concerns expressed at the April 6, 2011, meeting and making some additional corrections identified by the City Attorney. The ordinance is attached as clean revised ordinance and in redlined format to show the changes from the prior version considered by the City Council. City staff recommends the introduction of the revised ordinance. As a reminder the ordinance authorizes a "Code Compliance Manager"' to abate various conditions on private or public property that create a public nuisance. The ordinance adds Sections 3450-3468 to the Ukiah City Code and will provide the City with an additional tool to remedy conditions on residential property that are not currently addressed in the City Code. It also provides additional administrative procedures to remedy public nuisances throughout the City. "'Code Compliance Manager" means the person or persons designated by the City Council or the City Manager to enforce the provisions of the ordinance. (§3451.) This could be current City employee such as a planner or the Building Official. Recommended Action(s): Introduce ordinance by title only. Alternative Council Option(s): Modify and introduce ordinance; instruct staff to bring back changes. Decline to introduce ordinance Citizens advised: N/A Requested by: N/A Prepared by: David J. Rapport, City Attorney Coordinated with: Jane Chambers, City Manager and Trent Taylor, Police Captain Attachments: 1. Ordinance of the City Council of the City of Ukiah Adding a New Chapter 12, Entitled: "Abatement of Public Nuisances," To Division 3 of the Ukiah City Code (Clean version). 2. Redlined version of ordinance Approved: z.L�. Jan ambers, City Manager DETAILED DISCUSSION: The ordinance covers a variety of conditions on private and public property visible or affecting neighboring property and public property, including, attractive nuisances (conditions which are unsafe and unprotected that could attract and endanger small children, such as broken equipment, improperly maintained swimming pools, ponds culverts or excavations), conditions which produce foul or noxious odor offensive to persons of ordinary sensitivity and affecting an entire neighborhood or a substantial number of persons, or any other condition which is contrary to the public peace, health and safety. Some of these conditions are already addressed in the City Code, such as accumulations of garbage (Art. 2, Ch 5, Div 4 of the City Code), abandoned, wrecked or inoperable vehicles (Ch 9, Div 8 of the Code), prohibited parking of vehicles (City Code §7154), buildings which are maintained in violation of the Building, Fire and Abatement of Dangerous Building Codes, and the City's Commercial Property Maintenance Ordinance (City Code §§3400 et seq.). The attached ordinance addresses many conditions on residentially zoned property not currently addressed in the City Code and provides additional administrative remedies to abate public nuisances that are not currently available to the City. These remedies are declared to be in addition to all other remedies available to the City under the City Code and state law. The additional remedies include: 1. The authority to summarily abate a public nuisance without providing prior notice or an opportunity for a hearing, where a public nuisance poses a serious and imminent threat to public health or safety, such that during the time required to provide prior notice and an opportunity for a hearing, a significant risk of serious personal injury or substantial property damage exists. If the property owner does not consent to the summary abatement, Section 3455 requires the Code Compliance Manager or Building Official to obtain an inspection and abatement warrant pursuant to Code of Civil Procedure Sections 1822.50 et seq. 2. An administrative procedure to abate the nuisance which starts with an order to abate the public nuisance from the Code Compliance Manager to the property owner or other person in possession of property and which requires the violator to file an appeal within 10 days after service of the notice. If no appeal is filed, the order becomes final and enforceable. If a timely appeal is filed, a Hearing Officer, appointed by the City, conducts a hearing and makes a final decision. If he or she determines that a nuisance exists, the Hearing Officer can issue an order requiring abatement within 10 days, or, for good cause found, a longer period. (§3456. D.) 3. If the property owner fails to abate the nuisance within the time allowed, the City can abate or contract for the abatement of the nuisance and recover the cost from the owner. (§3458.) 4. The Code Enforcement Manager files a report and accounting with the City Clerk accompanied by a notice to the property owner of the cost of abatement, which the owner can protest by filing a request for a hearing within 10 days after service of the notice. (§§ 3459.B; 3462.) A Hearing Officer hears and decides the appeal which is a final decision for the City. If the owner fails to pay the costs within 30 days, the City Council can adopt a resolution assessing the costs as special assessment and a lien on the property, which the City Clerk can file with the County Auditor. The lien is collected and enforced in the same way as the property tax. (§3464.) 5. The ordinance also allows the City to recover from the property owner its attorneys' fees incurred in administrative or judicial proceedings to abate a public nuisance. (§3460.) 6. Finally, if the City is required to file a court action to abate a public nuisance more than once in a two year period, the ordinance allows the court to require the property owner to pay three times the cost to abate the nuisance. (§3461.) The Code Compliance Manager could be the Building Official, the Planning and Community Development Director, another City employee, or provided for on a contractual basis. The City staff have encountered situations where conditions on private property have created significant public nuisance impacts which the attached ordinance would assist them with abating more quickly and at less cost than is currently possible. For this reason, they recommend introduction of the ordinance. Fiscal Impact: Budgeted FY 10/11 1-1IxAppropriation Not Applicable Budget Amendment Required ATTACHMENT --i ORDINANCE NO. ORDINANCE OF THE CITY COUNCIL OF THE CITY OF UKIAH ADDING A NEW CHAPTER 12, ENTITLED: "ABATEMENT OF PUBLIC NUISANCES," TO DIVISION 3 OF THE UKIAH CITY CODE. SECTION ONE. The City Council of the City of Ukiah hereby ordains that a new Chapter 12, entitled "Abatement of Public Nuisances" is hereby added to Division 3 of the Ukiah City Code to read as follows. DIVISION 3 BUILDING CHAPTER 12 ABATEMENT OF PUBLIC NUISANCES Sections: 3450 Purpose. 3451 Definitions. 3452 Declaration of nuisances. 3453 Summary Abatement. 3454 Method of giving notice. 3455 Determination of nuisance. 3456 Appeal. 3457 Time limit for compliance. 3458 Abatement by City. 3459 Report of abatement costs. 3460 Recovery of attorneys' fees and report of attorneys' fees. 3461 Treble damages. 3462 Protest of abatement costs. 3463 Council action. 3464 Imposition of special assessment lien and notice. 3465 Recording of nuisance abatement lien. 3466 Collection of costs and attorney's fees prior to hearing. 3467 Alternative remedies. 3450: PURPOSE. It is hereby declared to be in the public interest to promote the health, safety and welfare of the residents of the City of Ukiah by providing procedures for the abatement of nuisances as declared by the City Council of the City of Ukiah, which abatement procedures shall be in addition to all other proceedings authorized by this Code or otherwise -by-law. 3451: DEFINITIONS. For the nurnose of this Chanter the fnllnwinn wnrcis and nhra-,P-, -,hall have the meanings: "Abandoned vehicle" means an unlicensed or physically inoperable vehicle "Abatement" means the demolition, removal, repair, maintenance, construction, reconstruction, replacement, or reconditioning of structures, appliances or equipment; or the removal, transportation, disposal and treatment of waste and abandoned materials and equipment capable of harboring, breeding, or attracting rodents or insects or producing odors or blight. "Agricultural groves" means any grove of ten or more trees on a parcel or lot. "Attractive nuisance" means any condition, instrumentality, or machine which is unsafe and unprotected and thereby dangerous to young children by reason of their inability to appreciate the peril which exists, and which may reasonably be expected to attract young children to the premises and risk injury by playing with, in, or on it. Attractive nuisances may include, but shall not be limited to: 1. Abandoned and/or broken equipment; 2. Swimming pools being used as fish ponds or other uses contrary to permitted swimming or other pool uses, subject to state or local regulations requiring, without limitation, that drains be visible from the water's surface and that the water be filtered: 3. Hazardous and/or unmaintained pools, ponds, culverts, excavations; and 4. Neglected machinery. "Building" means any structure including, but not limited to, any house, garage, duplex, apartment, condominium, stock cooperative, mobile home, or other residential structure or any portion thereof, which is designed, built, rented or leased to be occupied or otherwise is intended for supporting or sheltering any use or occupancy, and any commercial, industrial, or other establishment, warehouse, kiosk, or other structures affixed to or upon real property, used for the purpose of conducting a business, storage or other activity. "Construction Waste " means any discarded material from the building or destruction of structures, road and bridges including concrete, rocks, asphalt, plasterboard, wood and other related material. "Code Compliance Manager" shall mean the person or persons designated by the City Council or the City Manager to enforce the provisions of this Chapter. "Excavation" means any wells, shafts, basements, cesspools, septic tanks, fish ponds, and other like or similar conditions more than six inches in diameter and three feet in depth. "Foul" means very offensive to the senses. "Garbage" means any putrescible animal, fish, fowl, food, fruit, or vegetable matter 2 resulting from the cultivation, preparation, storage, handling, decay or consumption of the substance. "Hazardous materials and waste" means any chemical, compound, mixture, substance or article which is identified or listed by the United States Environmental Protection Agency or appropriate agency of the State of California as a "hazardous waste" as defined in 40 C.F.R. §§ 261.1 through 261.33, except that for purposes of this Chapter, hazardous waste also shall include household waste as defined in 40 C.F.R. § 261.4(B)(1). "Hearing Officer" means the individual appointed by the City Manager of the City of Ukiah to hear the appeal on a determination of the existence of a nuisance. "Noxious" means hurtful or unwholesome "Odor" means any smell, scent, or fragrance "Owner" means any person, agent, firm or corporation having legal or equitable interest in the property, as disclosed by a current title search from any accredited title company, and shall include any person in possession of the property. "Premises" means any lot or parcel of land upon which a building is situated, including any portion thereof improved or unimproved, and adjacent streets, sidewalks, parkways and parking areas. "Property" means any lot or parcel of land, including any alley, sidewalk, parkway or unimproved public easement. "Refuse" means any putrescible and nonputrescible solid waste, except sewerage, whether combustible or noncombustible and includes garbage and rubbish. "Stagnant water" means water which is allowed to become stagnant contained in ditches, pools, excavations, holes, depressions, open cesspools, privy vaults, fountains open cisterns, open tanks, shallow wells, barrels, troughs, urns, cans, tires, boxes, bottles, tubs, buckets, vessels, receptacles of any kind or other containers or devices which may hold water. "Unmerchantable" means unsalable. "Vehicle" means any device by which any person or property may be propelled, moved or drawn upon a highway, or upon water, excepting a device moved exclusively by human power, or used exclusively upon stationary rails or tracks. "Violator" means any responsible party, including the landowner, or lessee, tenant, or any other person who had possession or custody of the property. "Waste matter" means any rubbish or construction waste. "Weeds" means useless and troublesome plants generally accepted as having no value and frequently of uncontrolled growth. 3452: DECLARATION OF NUISANCES. It is unlawful and is hereby declared a nuisance for any person owning, leasing, occupying or having charge or possession of any Property and any vehicles thereon, in the City to maintain the Property in such a manner that any of the following conditions are present: A. The existence of any garbage, rubbish, refuse or waste matter upon the premises contrary to the provisions of Article 2, Chapter 5, Division 4 of the Ukiah City Code. B. Any abandoned or discarded furniture, stove, refrigerator, freezer, sink, toilet, cabinet, or other household fixture or equipment visible from a public right-of-way. C. The existence of any abandoned, wrecked, dismantled or inoperative motor vehicle upon the premises contrary to the provisions of Chapter 9, Division 8 of the Ukiah City Code. D. The outdoor storage of personal property on private property visible from the public right of way or adjacent property as follows: 1. Any furniture, whether designed for indoor or outdoor use, which is in dilapidated condition and would be offensive to the senses of a person of ordinary sensitivity or a significant percentage of owners or residents in the neighborhood; upholstered furniture where the original or replacement upholstery is torn, tattered, or soiled to the degree that it substantially detracts from the aesthetic and property values of neighboring properties; mattresses and box springs; any other personal property not designed for outdoor use that is not in good working order or is stored or maintained in such a way that it substantially detracts from the aesthetic and property values of neighboring properties; and 2. The existence of any junk, trash, refuse, construction waste or household appliances including washers, dryers, water heaters, commercial/industrial machinery and/or equipment (whether operable or inoperable); and 3. Any items or conditions, including those visible from neighboring properties, which provide a harborage for rats and/or other vermin, or create any other potential health hazard or nuisance. E. The outdoor storage of personal property on public property, including any public street, sidewalk, parking lot, public park, parkway, median or greenbelt or other public area, whether improved or unimproved, except with the consent and approval of the City. Any personal property stored, maintained, placed or abandoned in violation of this section may be removed and discarded at the discretion of the Public Works Director or his designee. F. Any dangerous or substandard building, whether or not occupied, abandoned, boarded -up or partially destroyed, contrary to the provisions of the California Fire Code, California Building Code, California Housing Code, and/or California Code for Abatement of Dangerous vus uuiiuinyJ. 11 G. The existence of loud or unusual noises, or foul or noxious odors which offend the peace and quiet enjoyment of persons of ordinary sensibilities and which interferes with the comfortable enjoyment of life or property and affect the entire neighborhood or any considerable number of persons. H. The existence of hazardous substances and waste unlawfully released, discharged, or deposited upon any premises or onto any City property. I. The existence of any stagnant water that poses a health risk or water contained in hazardous and/or unmaintained swimming or other pools on private property which obscure required visibility and proper filtering. J. Any attractive nuisance. K. Any other condition which is contrary to the public peace, health and safety. 3453: SUMMARY ABATEMENT. In cases where a public nuisance poses a serious and imminent threat to public health or safety, such that during the time required to provide prior notice and an opportunity for a hearing, a significant risk of serious personal injury or substantial property damage exists, the Building Official or the Code Compliance Manager, or their designees, shall have the authority to immediately abate or call a contractor to abate such public nuisance. Any such abatement activity may be conducted without observance of any notice requirements described in this Chapter; provided, however, that in the absence of consent from the owner, the City shall obtain an inspection and/or abatement warrant' prior to entering upon the property and abating the nuisance. The City may recover all abatement costs as set forth in this Chapter. 3454: METHOD OF GIVING NOTICE. A. Any notice required by this Chapter may be served in any one of the following methods: (1) by personal service on the owner, occupant, or person in charge or control of the property; or (2) if the owner cannot be located in the exercise of reasonable diligence the notice may be served by posting a copy thereof in a conspicuous place upon the property for a period of 10 days and publication thereof in a newspaper of general circulation published in the City pursuant to Government Code Section 6062.; or (3) by mailing the notice by first class U.S. Mail to the address shown on the last available assessment roll, or as otherwise known; or (4) publication of—a-le-g-a-l-adveftisement at once a week for the period of two weeks in a newspaper of general circulation in the City of Ukiah. I See, e.g., Cal. Code Civ. v. Proc. §1822.50 et seq. B. Notice deemed served as follows: (1) if served pursuant to A(1), upon receipt; (2) if served pursuant to A(2), at the expiration of the time required for posting and publication; (3) if served pursuant to A(3), 48 hours after deposit in the U.S. Mail; or (4) if served pursuant to A(4), 24 hours after publication of the second weekly notice. 3455: DETERMINATION OF NUISANCE. A. The Code Enforcement Manager may determine that any premises within the City may constitute a public nuisance pursuant to any provisions of Section 3452 and may initiate abatement proceedings pursuant to this Chapter. The Code Compliance Manager or the authorized representative thereof shall set forth such determination in a notice to abate which shall identify the premises and state the conditions which may constitute the nuisance and shall require that such conditions be corrected within such time periods set forth in the notice to abate. B. The notice to abate to the owner or person in control or charge of the property shall include (1) the condition or conditions on the premises creating the nuisance; (2) a description of the actions required to abate the nuisance; (2) a reasonable time limit to abate the nuisance; and (4) notice of the right to appeal, if filed within ten (10) calendar days of the date the notice is served. The notice shall direct the abatement of the nuisance and refer to this Chapter for particulars. C. Failure of the owner to accept or otherwise receive such notice shall not affect the validity of any proceeding pursuant to this Chapter, except as otherwise required by law. 3456: APPEAL. A. Within ten days from the date of giving notice to abate, the violator may file a appeal of the determination of the nuisance with the Code Compliance Manager. Such appeal shall be in writing and shall identify the property subject to the Notice to Abate. The Code Compliance Manager shall then cause the matter to be set for hearing before a Hearing Officer appointed by the City to hear such matters. The Hearing Officer shall be qualified by training, education and/or experience to conduct the hearing and shall be impartial. Except in his or her capacity as a Hearing Officer, he or she shall have no personal or business relationship to the property owner or the City. B. Notice of the date of hearing shall be given in writing. The date of the hearing shall be no sooner than fifteen days from the date when notice of the hearing is given to the appellant and -to the Code Compliance Manager. C. At the time fixed in the notice, the Hearing Officer shall receive evidence, including the testimony of all competent persons desiring to testify respecting the nnnrJi+inn nnnc+i+i i+in' +ho n, iic.nna VVI 1-1- 1 VVI IJUIUUI ly U 1 J I IUIOUl IIiG. D. At the conclusion of the hearing, the Hearing Officer shall determine whether or not a nuisance exists, and if the Hearing Officer so concludes, he or she may declare the conditions existing to be a nuisance and direct the person owning the property upon which the nuisance exists to abate it within ten days after the date of posting on the premises a notice of the Hearing Officer's order. The Hearing Officer may grant additional time to abate the nuisance, if in his or her opinion, good cause for additional time exists. E. The decision of the Hearing Officer on the determination of nuisance is final. Any appeal of the Hearing Officer's decision shall be governed by California Code of Civil Procedure Section 1094.6 as such section may be amended from time to time. 3457: TIME LIMIT FOR COMPLIANCE. The violator must abate the nuisance within the period of time set forth in the Notice to Abate, or, in case of an appeal, within ten days from the finding of the Hearing Officer or such longer period as may be determined by the Hearing Officer. Unless an emergency situation exists, the violator shall be given at least ten days to abate the nuisance. 3458: ABATEMENT BY CITY. A. If the nuisance is not abated by the violator within the time limits set forth above in Section 3457, the City, by its employees or any hired contractor, may cause the nuisance to be abated. 3459: REPORT OF ABATEMENT COSTS. A. The Code Compliance Manager shall thereafter cause a report of the action and an accurate account of the costs to be filed with the City Clerk of the City of Ukiah. B. The statement shall be accompanied by a notice to the owner that the cost of abatement may be protested as set forth in Section 3462. If the cost is not protested within ten calendar days after service, it shall be deemed final. 3460: RECOVERY OF ATTORNEYS' FEES AND REPORT OF ATTORNEYS' FEES. In any action, administrative proceeding, or special proceeding to abate a nuisance, the prevailing party shall be entitled to recovery of attorneys' fees. The recovery of attorneys' fees by the prevailing party shall be limited to those individual actions or proceedings in which the City elects, at the initiation of that individual action or proceeding, to seek recovery of its own attorneys' fees. In no action, administrative proceeding, or special proceeding shall an award of attorneys' fees to a prevailing party exceed the amount of reasonable attorneys' fees incurred by the City in the action or proceeding. The City Attorney's Office shall thereafter cause a report of the action and an accurate account of costs to be filed with the City Clerk of the City of Ukiah. 3461: TREBLE DAMAGES. Upon entry of a second or subsequent civil or criminal judgment within a two-year period finding that an owner oT property is responsible Tor a condition that may be abated in 7 accordance with this Chapter, except for conditions abated pursuant to Section 17980 of the Health and Safety Code, related to substandard buildings, the court may order the owner to pay treble the costs of the abatement. 3462: PROTEST OF ABATEMENT COSTS. A. The property owner may protest the cost of abatement by filing a written request for a hearing on the abatement costs with the Code Compliance Manager, and the Code Compliance Manager shall cause a Hearing Officer to be appointed to hear the protest. At the time fixed for the hearing on the statement of abatement costs, the Hearing Officer shall consider the statement and protests or objections raised by the person liable to be assessed for the cost of the abatement. B. The Hearing Officer may revise, correct or modify the statement as the Hearing Officer considers just and thereafter shall confirm the cost. C. The decision of the Hearing Officer shall be in writing and shall be served by mail. The decision of the Hearing Officer on the abatement costs shall be final. D. Any appeal of the Hearing Officer's decision shall be governed by California Code of Civil Procedure Section 1094.6 or such section as it may be amended from time to time. 3463: COUNCIL ACTION. A. If the property owner does not pay the cost of abating the nuisance within thirty calendar days after the cost becomes final or the hearing officer confirms the costs of abatement, the cost shall become a special assessment against the real property upon which the nuisance was abated. The assessment shall continue until it is paid, together with interest at the legal maximum rate computed from the date of confirmation of the statement until payment. The assessment may be collected at the same time and in the same manner as ad valorem property taxes are collected and shall be subject to the same penalties and the same procedure and sale in case of delinquency as provided for property taxes. B. The City Council shall adopt a resolution assessing such unpaid costs of abatement as liens upon the respective parcels of land as they are shown upon the last available assessment roll. 3464: IMPOSITION OF SPECIAL ASSESSMENT LIEN AND NOTICE. A. The City Clerk shall prepare and file with the County Auditor a certified copy of the resolution of the City Council assessing the costs of abatement as a lien on the land, adopted pursuant to the preceding section. B. Notice of lien shall be mailed by certified mail to the property owner, if the property owner's identity can be determined from the County Assessor's or County Recorder's records. The notice shall be given at the time of imposing the assessment and shall specify that the property may be sold after three years by the Tax Collector for unpaid delinquent assessments. The Tax Collector's power of sale shall not be affected Uy the failure of the property owner to receive notice. C. The County Auditor shall enter each assessment on the County tax roll upon the parcel of land. The assessment shall be collected at the same time and in the same manner as ad valorem real property taxes are collected, and shall be subject to the same penalties and procedure and sale in case of delinquency as is provided for such taxes. All laws applicable to the levy, collection and enforcement of municipal taxes shall be applicable to the special assessment. However, if any real property to which the cost of abatement relates has been transferred or conveyed to a bona fide purchaser for value, or if a lien of a bona fide encumbrancer for value has been created and attaches thereon, prior to the date on which the first installment of the taxes would become delinquent, then the cost of abatement shall not result in a lien against the real property but instead shall be transferred to the unsecured roll for collection. The tax collector's power of sale shall not be affected by the failure of the property owner to receive notice. 3465: RECORDING OF NUISANCE ABATEMENT LIEN. As an additional remedy, the Code Compliance Manager may cause a nuisance abatement lien for costs related to abatements, other than dangerous building abatements, to be recorded with the Mendocino County Recorder's Office, in accordance with the procedures specified in Government Code Section 38773.1. As required by Section 37773. 1, prior to recording the lien, notice of the proposed lien shall be given to the property owner as provided in Section 3454(a)(1) or (2). 3466: COLLECTION OF COSTS AND ATTORNEY'S FEES PRIOR TO HEARING. The Finance Department of the City may accept payment of any amount due at any time prior to the filing of a certified copy of the City Council resolution assessing the abatement costs with the County Auditor. 3467: ALTERNATIVE REMEDIES. The procedures established in this Chapter shall be in addition to criminal, civil or other legal or equitable remedies established by law which may be pursued to address violations of this Code or applicable state codes and the use of this Chapter shall be at the sole discretion of the City. SECTION TWO 1. COMPLIANCE WITH CEQA. The City Council finds that this ordinance is not subject to the California Environmental Quality Act ("CEQA") pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment), 15061(b)(3) (there is no possibility the activity in question may have a significant effect on the environment.) 2. SEVERABILITY. If any provision of this ordinance or the application thereof to any person or circumstance is held invalid, the remainder of the ordinance and the application of such provision to other persons or circumstances shall not be affected thereby. The City Council hereby declares that it would have adopted this Ordinance and any section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared unconstitutional or otherwise invalid. 3. EFFECTIVE DATE. This Ordinance shall be published as required by law in a newspaper of general circulation in the City of Ukiah, and shall become effective thirty (30) days after its adoption. Introduced by title only on , 2012, by the following roll call vote: AYES: NOES: ABSENT: ABSTAIN: Adopted on , 2012, by the following roll call vote: AYES: NOES: ABSENT: ABSTAIN: Mary Anne Landis, Mayor ATTEST: JoAnne Currie, City Clerk 10 ATTACHMENT ORDINANCE NO.2011 ORDINANCE OF THE CITY COUNCIL OF THE CITY OF UKIAH ADDING A NEW CHAPTER 12, ENTITLED: "ABATEMENT OF PUBLIC NUISANCES," TO DIVISION 3 OF THE UKIAH CITY CODE. --- Formatted: Centered, Indent: Left: 0", Right: 0" SECTION ONE. The City Council of the City of Ukiah hereby ordains that a new Chapter 12, entitled "Abatement of Public Nuisances" is hereby added to Division 3 of the Ukiah City Code to read as follows. DIVISION 3 BUILDING CHAPTER 12 ABATEMENT OF PUBLIC NUISANCES Sections: 3450 Purpose. 3451 Definitions. 3452 Declaration of nuisances. 3453 Summary Abatement. 3454 Method of giving notice. 3455 Determination of nuisance. 3456 Appeal. 3457 Time limit for compliance. 3458 Abatement by City. 3459 Report of abatement costs. 3460 Recovery of attorneys' fees and report of attorneys' fees. 3461 Treble damages. 3462 Protest of abatement costs. 3463 Council action. 3464 Imposition of special assessment lien and notice. 3465 Recording of nuisance abatement lien. 3466 Collection of costs and attorney's fees prior to hearing. 3467 Alternative remedies. 3450: PURPOSE. It is hereby declared to be in the public interest to promote the health, safety and welfare of the residents of the City of Ukiah by providing procedures for the abatement of nuisances as declared by the City Council of the City of Ukiah, which abatement procedures shall be in addition to all other proceedings authorized by this Code or otherwise by law. 3451: DEFINITIONS. For the purpose of this Chapter the following words and phrases shall have the meanings: "Abandoned vehicle" means an unlicensed or physically inoperable vehicle "Abatement" means the demolition, removal, repair, maintenance, construction, reconstruction, replacement, or reconditioning of structures, appliances or equipment; or the removal, transportation, disposal and treatment of waste and abandoned materials and equipment capable of harboring, breeding, or attracting rodents or insects or producing odors or blight. "Agricultural groves" means any grove of ten or more trees on a parcel or lot "Attractive nuisance" means any condition, instrumentality, or machine which is unsafe and unprotected and thereby dangerous to young children by reason of their inability to appreciate the peril which exists, and which may reasonably be expected to attract young children to the premises and risk injury by playing with, in, or on it. Attractive nuisances may include, but shall not be limited to: 1. Abandoned and/or broken equipment; 2. Swimming pools being used as fish ponds or other uses contrary to permitted swimming or other pool uses, subject to state or local regulations requiring, without imotatienlimitation, that drains be visible from the water's surface and that the water be filtered; 3. Hazardous and/or unmaintained pools, ponds, culverts, excavations; and 4. Neglected machinery. "Building" means any structure including, but not limited to, any house, garage, duplex, apartment, condominium, stock cooperative, mobile home, or other residential structure or any portion thereof, which is designed, built, rented or leased to be occupied or otherwise is intended for supporting or sheltering any use or occupancy, and any commercial, industrial, or other establishment, warehouse, kiosk, or other structures affixed to or upon real property, used for the purpose of conducting a business, storage or other activity. "Construction m te4alWaste " means any discarded material from the building or destruction of structures, road and bridges including concrete, rocks, asphalt, plasterboard, wood and other related material. "Code Compliance Manager" shall mean the person or persons designated by the City Council or the City Manager to enforce the provisions of this Chapter. "Excavation" means any wells, shafts, basements, cesspools, septic tanks, fish ponds, and other like or similar conditions more than six inches in diameter and three feet in depth. "Foul" means very offensive to the senses. "Garbage" means any putrescible animal, fish, fowl, food, fruit, or vegetable matter resulting from the cultivation, preparation, storage, handling, decay or consumption of the substance. "Hazardous materials and waste" means any chemical, compound, mixture, substance or article which is identified or listed by the United States Environmental Protection Agency or appropriate agency of the State of California as a "hazardous waste" as defined in 40 C.F.R. §§ 261.1 through 261.33, except that for purposes of this Chapter, hazardous waste also shall include household waste as defined in 40 C.F.R. § 261.4(6)(1). "Hearing Officer" means the individual appointed by the City Manager of the City of Ukiah to hear the appeal on a determination of the existence of a nuisance. "Noxious" means hurtful or unwholesome. "Odor" means any smell, scent, or fragrance. "Owner" means any person, agent, firm or corporation having legal or equitable interest in the property, as disclosed by a current title search from any accredited title company, and shall include any person in possession of the property. "Premises" means any lot or parcel of land upon which a building is situated, including any portion thereof improved or unimproved, and adjacent streets, sidewalks, parkways and parking areas. "Property" means any lot or parcel of land, including any alley, sidewalk, parkway or unimproved public easement. "Refuse" means any putrescible and non pUtFeSGiblenomutrescible solid waste, except sewerage, whether combustible or noncombustible and includes garbage and rubbish. "Stagnant water" means water which is allowed to become stagnant contained in ditches, pools, ponds 6fream6, excavations, holes, depressions, open cesspools, privy vaults, fountains, open cisterns, open tanks, shallow wells, barrels, troughs, urns, cans, tires, boxes, bottles, tubs, buckets, roof gutters, taRks of flush GIGSef6 reseNeirs vessels, receptacles of any kind or other containers or devices which may hold water. "Unmerchantable" means unsalable "Vehicle" means any device by which any person or property may be propelled, moved, or drawn upon a highway, or upon water, excepting a device moved exclusively by human power, or used exclusively upon stationary rails or tracks. "Violator" means any responsible party, including the landowner, or lessee, tenant, or any other person who had possession or custody of the property. 'Waste matter" means any rubbish or construction P3,a�alwaste . "Weeds" means useless and troublesome plants generally accepted as having no value and frequently of uncontrolled growth. 3452: DECLARATION OF NUISANCES. It is unlawful and is hereby declared a nuisance for any person owning, leasing, occupying or having charge or possession of any Property and any vehicles thereon, in the City to maintain the Property in such a manner that any of the following conditions are present: A. The existence of any garbage, rubbish, refuse or waste matter upon the premises contrary to the provisions of Article 2, Chapter 5, Division 4 of the Ukiah City Code. B. OF alleys hehueen said pre.m.isesand the r.eRterline of any p blip 6tree+ or allevAnny abandoned or discarded furniture, stove, refrigerator, freezer, sink, toilet, cabinet, or other household fixture or equipment visible from a public right-of-way. G he ex'SteRGe of eveFgFeWR,dead, desayed, diseased or hazardoustrees, neinhhnrinn properties. F. ARy-abaadGRed O d ssa Qed f ,rte+ ,re, stove, efrigera+�freezer, Ginl,toilet, nahine+ er other hn, icehnld fivfi ire or on. do on+ . i vicihle f1.rom a nhlin right _nf_�aa�i F. C. The existence of any abandoned, wrecked, dismantled or inoperative motor vehicle upon the premises contrary to the provisions of Chapter 9, Division 8 of the Ukiah City Code. G The storage or arkinn of neFtain ac fnlln_ws, 1 The c+prone or narking of +r6nLc o eerl'nn +ho man, +. fanirer'6 gross . ieh'nle Weight ra+'n of 11,000 n R& OR all _Are.as of all r sides+'al Z nrl the storage or papk'Rg of other vehir_,les; on the landSGaped front and- street side yard setbaGk (a) is likely to disrupt traffin flew the City; (b) 6tir up dust from D. The outdoor storage of personal property on private property visible ------- Formatted: Indent: First line: 0.5" from the public right of way or adjacent propertVas follows: 1. Any furniture , whether designed for t ------ Formatted: Indent: Left: 0.5", First line: 0.5" indoor or outdoor use), , which is in dilapidated condition and/or FearyaFd&, would be offensive to the senses of a person of ordinary sensitivity or a significant percentage of owners or residents in the neighborhood; upholstered furniture where the original or replacement upholstery is torn, tattered, or soiled to the degree that it substantially detracts from the aesthetic and property values of neighboring properties; mattresses and box springs; any other personal property not designed for outdoor use aadthat is not in good working order; or is stored or maintained in such a way that it substantially detracts from the aesthetic and property values of neighboring properties; and 2. The existence of any hay, stFa , i, ,mher paper or ether e6ib6ta Geo r------ Formatted: Indent: Left: 0.5", First line: 0.5" junk,trash, refuse, construction materiel6 a eRt; RleSS r erily Leet or stored under validly permitted, GUFrent ;waste or household appliances including washers, dryers, water heaters, commercial/industrial machinery and/or equipment (whether operable or inoperable); and 3. Any item Gau6in^ an "^6'nhtly appeerer,Ge WhiGh .------- Formatted: Indent: Left: 0.5", First line: 0.5" p6ibliG Fight of way or sites of neighbering items or conditions, including those visible from neighboring properties, which provides rovide a harborage for rats and/or other vermin, or sreatescreate any other potential health hazard or nuisance. IE. The outdoor storage of personal property on public property as ellews including any 1 The use of public pmpeFty te steFe, maiRtain, street, sidewalk, ary-parking lot-G�r public park, parkway, median or greenbelt; or other public area, whether improved or unimproved, except with the consent and approval of the City. Any personal property stored, maintained, placed or abandoned in violation of this section may be removed and discarded at the discretion of the Public Works Director or his designee. JF. Any dangerous or substandard building, whether or not occupied, abandoned, boarded -up or partially destroyed contrary to the provisions of the California Fire Code, California Building Code, California Housing Code, and/or California Code for Abatement of Dangerous Buildings. L. G. The existence of loud or UReasaalunusual noises, or foul or noxious odors which offend the peace and quiet enjoyment of persons of ordinary sensibilities and which interferes with the comfortable enjoyment of life or property and affect the entire neighborhood or any considerable number of persons. MH. The existence of hazardous substances and waste unlawfully released, discharged, or deposited upon any premises or onto any City property. NI. The existence of any stagnant water that poses a health risk or water contained in hazardous and/or unmaintained swimming or other pools on private property which obscure required visibility and proper filtering. 9J. Any attractive nuisance. PK. Any other condition which is contrary to the public peace, health and safety. 3453: SUMMARY ABATEMENT. ' Formatted: Font: Not Bold In cases where a public nuisance poses a serious and imminent threat to public health or safety, such that during the time required to provide prior notice and an opportunity for a hearing, a significant risk of serious personal injury or substantial property damage exists, the Building Official or the Code E�entCompliance Manager, or their designees, shall have the authority to immediately abate or call a contractor to abate such public nuisance. Any such abatement activity may be conducted without observance of any notice requirements described in this Chapter; provided, however, that in the absence of consent from the owner, the City shall obtain an inspection and/or abatement warrant' prior to entering upon the property and abating the nuisance. The City may recover all abatement costs as set forth in this Chapter. 3454: METHOD OF GIVING NOTICE. A. Any notice required by this Chapter may be served in any one of the following methods: (1) by personal service on the owner, occupant, or person in charge or control of the property; or (2) if the owner cannot be located in the exercise of reasonable diligence, the notice maV be served by posting a copy thereof in a conspicuous place eRupon the db tti^^ p he^ ri^h+-property for a period of -way 10 dans and mailing a sept' publication thereof in a newspaper of general circulation published in the CitV pursuant to the address shE)WR ^n the last available assessment r^II, or as ^th^n.do^ kROWn,GOyernment Code Section 6062.; or (3) by mailing the notice by first class U.S. Mail to the address shown on the last available assessment roll, or as otherwise known; or ' See, e.g., Cal. Code Civ. Proc. §1822.50 et seq. (4) publication of a legal advertisement at least once a week for the period of two weeks in a newspaper of general circulation in the City of Ukiah. B. Notice deemed served as follows: (1) if served pursuant to A(1), upon receipt; (2) if served pursuant to A(2), upeR d 14as#at the expiration of the +wailed AC_)t0r_,e OA thp- 'J.S. Mail with prGper fiFSt Glass postage time required for posting and publication; (3) if served pursuant to A(3), 48 hours after deposit in the U.S. Mail; or (4) #if served pursuant to A(4), 24 hours after publication of the second weekly notice 3455: DETERMINATION OF NUISANCE. A. The Code Enforcement Manager may determine that any premises within the City may constitute a public nuisance pursuant to any provisions of Section 3452 and may initiate abatement proceedings pursuant to this Chapter. The Code ERfGFGeme tCompliance Manager or the authorized representative thereof shall set forth such determination in a notice to abate which shall identify the premises and state the conditions which may constitute the nuisance and shall require that such conditions be corrected within such time periods set forth in the notice to abate. B. The notice to abate to the owner or person in control or charge of the property shall include (1) the condition or conditions on the premises creating the nuisance; (2) a description of the actions required to abate the nuisance; (2) a reasonable time limit to abate the nuisance; and (4) notice of the right to appeal, if filed within ten (10) calendar days of the date the notice is served. The notice shall direct the abatement of the nuisance and refer to this Chapter for particulars. C. Failure of the owner to accept or otherwise receive such notice shall not affect the validity of any proceeding pursuant to this Chapter.-, except as otherwise required by law. KL4•iii_1;12=F,1X A. Within ten days from the date of giving notice to abate, the violator may file aaa appeal teof the determination of the nuisance with the Code ERfGFGeFReR Compliance Manager. Such appeal shall be in writing and shall identify the property subject to the Notice to Abate. The Code EntCompliance Manager shall then cause the matter to be set for hearing before a Hearing Officer appointed by the City to hear such matters. The Hearing Officer shall be qualified by training, education and/or experience to conduct the hearing and shall be impartial. Except in his or her capacity as a Hearing Officer, he or she shall have no personal or business relationship to the property owner or the City. B. Notice of the date of hearing shall be given in writing. The date of the hearing shall be no sooner than fifteen days from the date when notice of the hearing is given to the appellant and to the Code F=RfGFGeM RtCompliance Manager. C. At the time fixed in the notice, the Hearing Officer shall receive evidence, including the testimony of all competent persons desiring to testify respecting the condition constituting the nuisance. D. At the conclusion of the hearing, the Hearing Officer shall determine whether or not a nuisance exists, and if the Hearing Officer so concludes, he or she may declare the conditions existing to be a nuisance and direct the person owning the property upon which the nuisance exists to abate it within ten days after the date of posting on the premises a notice of the Hearing Officer's order. The Hearing Officer may grant additional time to abate the nuisance, if in his or her opinion, good cause for additional time exists. E. The decision of the Hearing Officer on the determination of nuisance is final. Any appeal of the Hearing Officer's decision shall be governed by California Code of Civil Procedure Section 1094.6 as such section may be amended from time to time. 3457: TIME LIMIT FOR COMPLIANCE. The violator must abate the nuisance within the period of time set forth in the Notice to Abate, or, in case of an appeal, within ten days from the finding of the Hearing Officer or such longer period as may be determined by the Hearing Officer. Unless an emergency situation exists, the violator shall be given at least ten days to abate the nuisance. 3458: ABATEMENT BY CITY. A. If the nuisance is not abated by the violator within the time limits set forth above in Section 3457, the City, by its employees or any hired contractor, may cause the nuisance to be abated. 3459: REPORT OF ABATEMENT COSTS. A. The Code Enf^eme^++Compliance Manager shall thereafter cause a report of the action and an accurate account of the costs to be filed with the City Clerk of the City of Ukiah. B. The statement shall be accompanied by a notice to the owner that the cost of abatement may be protested as set forth in Section 3462. If the cost is not protested within ten calendar days after service, it shall be deemed final. 3460: RECOVERY OF ATTORNEYS' FEES AND REPORT OF ATTORNEYS' FEES. In any action, administrative proceeding, or special proceeding to abate a nuisance, the prevailing party shall be entitled to recovery of attorneys' fees. The recovery of attorneys' fees by the prevailing party shall be limited to those individual actions or proceedings in which the City elects, at the initiation of that individual action or proceeding, to seek recovery of its own attorneys' fees. In no action, administrative proceeding, or special proceeding shall an award of attorneys' fees to a prevailing party exceed the amount of reasonable attorneys' fees incurred by the City in the action or proceeding. The City Attorney's Office shall thereafter cause a report of the action and an accurate account of costs to be filed with the City Clerk of the City of Ukiah. 3461: TREBLE DAMAGES. Upon entry of a second or subsequent civil or criminal judgment within a two-year period finding that an owner of property is responsible for a condition that may be abated in accordance with this Chapter, except for conditions abated pursuant to Section 17980 of the Health and Safety Code, related to substandard buildings, the court may order the owner to pay treble the costs of the abatement. 3462: PROTEST OF ABATEMENT COSTS. A. The property owner may protest the cost of abatement by filing a written request for a hearing on the abatement costs with the Code infer e nentCompliance Manager, and the Code FaRfGFeementCompliance Manager shall cause a Hearing Officer to be appointed to hear the protest. At the time fixed for the hearing on the statement of abatement costs, the Hearing Officer shall consider the statement and protests or objections raised by the person liable to be assessed for the cost of the abatement. B. The Hearing Officer may revise, correct or modify the statement as the Hearing Officer considers just and thereafter shall confirm the cost. C. The decision of the Hearing Officer shall be in writing and shall be served by mail. The decision of the Hearing Officer on the abatement costs shall be final. D. Any appeal of the Hearing Officer's decision shall be governed by California Code of Civil Procedure Section 1094.6 or such section as it may be amended from time to time. 3463: COUNCIL ACTION. A. If the property owner does not pay the cost of abating the nuisance within thirty calendar days after the cost becomes final or the hearing officer confirms the costs of abatement, the cost shall become a special assessment against the real property upon which the nuisance was abated. The assessment shall continue until it is paid, together with interest at the legal maximum rate computed from the date of confirmation of the statement until payment. The assessment may be collected at the same time and in the same manner as ad valorem property taxes are collected and shall be subject to the same penalties and the same procedure and sale in case of delinquency as provided for property taxes. B. The City Council shall adopt a resolution assessing such unpaid costs of abatement as liens upon the respective parcels of land as they are shown upon the last available assessment roll. 3464: IMPOSITION OF SPECIAL ASSESSMENT LIEN AND NOTICE. A. The City Clerk shall prepare and file with the County Auditor a certified copy of the resolution of the City Council assessing the costs of abatement as a lien on the land, adopted pursuant to the preceding section. B. Notice of lien shall be mailed by certified mail to the property owner, if the property owner's identity can be determined from the County Assessor's or County Recorder's records. The notice shall be given at the time of imposing the assessment and shall specify that the property may be sold after three years by the Tax Collector for unpaid delinquent assessments. The Tax Collector's power of sale shall not be affected by the failure of the property owner to receive notice. C. The County Auditor shall enter each assessment on the County tax roll upon the parcel of land. The assessment shall be collected at the same time and in the same manner as ad valorem real property taxes are collected, and shall be subject to the same penalties and procedure and sale in case of delinquency as is provided for such taxes. All laws applicable to the levy, collection and enforcement of municipal taxes shall be applicable to the special assessment. However, if any real property to which the cost of abatement relates has been transferred or conveyed to a bona fide purchaser for value, or if a lien of a bona fide encumbrancer for value has been created and attaches thereon, prior to the date on which the first installment of the taxes would become delinquent, then the cost of abatement shall not result in a lien against the real property but instead shall be transferred to the unsecured roll for collection. The tax collector's power of sale shall not be affected by the failure of the property owner to receive notice. 3465: RECORDING OF NUISANCE ABATEMENT LIEN. As an additional remedy, the Code F;tCompliance Manager may cause a nuisance abatement lien for costs related to abatements, other than dangerous building abatements, to be recorded with the Mendocino County Recorder's Office, persuant-te the pFevisiens of Government S. in accordance with the procedures specified in Government Code Section 38773.1. As required by Section 37773.1, prior to recording the lien, notice of the proposed lien shall be given to the property owner as provided in Section 3454(a)(1) or (2). 3466: COLLECTION OF COSTS AND ATTORNEY'S FEES PRIOR TO HEARING. The Finance Department of the City may accept payment of any amount due at any time prior to the filing of a certified copy of the City Council resolution assessing the abatement costs with the County Auditor. 3467: ALTERNATIVE REMEDIES. The procedures established in this Chapter shall be in addition to criminal, civil or other legal or equitable remedies established by law which may be pursued to address violations of this Code or applicable state codes and the use of this Chapter shall be at the sole discretion of the City. SECTION TWO 10 1. COMPLIANCE WITH CEQA. The City Council finds that this ordinance is not subject to the California Environmental Quality Act ("CEQA") pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment), 15061(b)(3) (there is no possibility the activity in question may have a significant effect on the environment.) 2. SEVERABILITY. If any provision of this ordinance or the application thereof to any person or circumstance is held invalid, the remainder of the ordinance and the application of such provision to other persons or circumstances shall not be affected thereby. The City Council hereby declares that it would have adopted this Ordinance and any section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared unconstitutional or otherwise invalid. 3. EFFECTIVE DATE. This Ordinance shall be published as required by law in a newspaper of general circulation in the City of Ukiah, and shall become effective thirty (30) days after its adoption. Introduced by title only on , 2-9442012, by the following roll call vote. AYES: NOES: ABSENT: ABSTAIN: Adopted on , 22012, by the following roll call vote: AYES: NOES: ABSENT: ABSTAIN: AAau Rnd'n Mary Anne Landis, Mayor ATTEST.- JoAnne TTEST: JoAnne Currie, City Clerk a�� E'' ,d! �?' �r 1 :� , 1, J� I: 6�.. v y; - - ------ - ------------- Ad Haw" ♦I �l � '��' �4 gill 1 J 1 �Yrl �i� Y f I r I MAW J7! l _ ku�)/,tlI- ..o ?�"! - -- MV* -J, I -mow .o m Li 0;1 /1 V IM I®, 1 �� OP Y: "V i Y1 J �.II ITEM NO.: 12b MEETING DATE: January 18, 2012 AGENDA SUMMARY REPORT SUBJECT: RECEIVE STATUS REPORT ON OBSERVATORY PARK DEVELOPMENT PROJECT. Summary: In February 2009, the Community Services Department received direction from the City Council to pursue grant funding with the Land and Water Conservation Fund (LWCF) for the completion of Observatory Park. The City was successful in securing a grant award of $58,850 with a match of $58,850 from the Park Development Fund for a total project cost of $117,700. During 2010 and 2011, staff worked with the Office of Grants and Local Services on the grant requirements for the park project. This agenda summary report is an update on the park project, the progress, and the next steps for the work. Background: Observatory Park is approximately four acres with frontages facing Luce Street and Observatory Avenue. The property is both historic and special in that only six such International Latitude Observatory sites exist around the world. The other five sites are located in Ohio, Maryland, Italy, Japan, and Russia. Ukiah's original Observatory was built on this site in 1899 with the existing buildings constructed in 1948. The historical residence and three small outbuildings, comprising approximately one acre, are concentrated on the south side of the property facing Observatory Avenue. The remaining property extends north to Luce Street and is marked by a large specimen Oak tree with substantial open space extending back to the structures. The Department of Interior granted the property to the City of Ukiah for the purpose of developing a public park. The property's extensive size has provided an excellent opportunity to create an expansive green space in a developed residential area that is surrounded by single family dwellings and a number of high density apartment complexes. The park currently includes a turf area with irrigation, a labyrinth, a number of established trees along with the historic buildings. The pathways are graded but left without any curbing or finishing material. The site plan with the structures is included as Attachment #1. Photographs of the park site are included as Attachment #2. Recommended Action(s): Receive status report on Observatory Park Development Project. Alternative Council Option(s): Remand to staff with direction. Citizens advised: n/a Requested by: n/a Prepared by: Katie Marsolan, Community Services Administrator Coordinated with: Sage Sangiacomo, Assistant City Manager, Tom Hamblet, Parks -Golf Superintendant, Jarrod Meyer, Parks Leadworker Attachments: 1. Site Diagram with Structures 2. Site Photographs 3. Original Landscape Concept Plan 4. Observatory Planting Diagram and Plant Photos � J Approved: Jan�Ehambers, City Manager City staff have worked in collaboration with community members through the Friends of Observatory Park in the design and planning of the park space. More than 10 years ago the City and community members went about crafting a landscaping plan which is included as Attachment #3. The City then took steps to partner with the CCC to install irrigation. Additionally, the City partnered with local Boy Scouts on the labyrinth. Due to limited City funding, the goal has been to seek out grant funding and complete the project in stages. Over the years staff continued to look for funding sources to support the ongoing development of the park. The funding through the LWCF grant and the overall completion plan for the park includes finishing the main pathway, the perimeter landscaping and the primary entry point to the park at Luce Street. The goal for the grant funds is to create a park space that encourages a healthy community. One of the features of the park completion includes native drought tolerant plants that will be used for educational purposes. The pathway will encourage walking, and the history of the Observatory will be highlighted to educate our community about the natural sciences. By installing the final materials for the pathway, improving areas such as the deteriorating fencing and filling the empty planter beds, the location will truly become a safe and welcoming park. In addition to the LWCF grant, Community Services staff were also successful in securing grant funding through the Community Foundation in the amount of $4,000 for signage at the park facility. The signage will be part of a self -guided tour to educate visitors about the history of the Observatory structures. The signs will explain the unique buildings and markers that are part of the park space. Updates: Upon receiving the Land and Water Conservation Fund (LWCF) grant award in September 2009, staff began correspondence with the California Office of Grants and Local Services (OGALS) for the grant contract and work plan. The LWCF is a federal program, however, the grant management is conducted at the state level by OGALS. Staff took the appropriate steps to prepare the requested documents per the grant guidelines. In April 2010, staff was contacted by the OGALS regarding the historic structures at the park site. Specifically, the City was mandated to comply with the LWCF post -selection requirements which include compliance with the National Historic Preservation Act. Staff was directed to contact the California Historical Resources Information System (CHRIS). To summarize, in receiving federal funds, the City must comply with the policies of the National Environmental Policy Act and the subsequent protection of historic structures and artifacts. Staff spent months in correspondence with OGALS and CHRIS to work with the appropriate archeologists and meet the requirements of the LWCF. We were fortunate to receive support from the Northwest Information Center at Sonoma State University and locate a 2009 Cultural Resources Study which included the historically significant recorded information for the site. Upon obtaining these documents, the City was able to satisfy the requirements and receive approval from OGALS and LWCF for the project work -plan. This tedious process involved lengthy correspondence and documentation and took several months which caused some unanticipated delays for the overall park development project. While the correspondence with the OGALS was underway, staff made an effort to keep the park development process moving forward. Staff conducted an RFP procurement process to engage landscape architect services. The City Council then awarded a contract to Ann Baker Landscape Architecture to -prepare the plans and -specifications for construction and installation -of -the pathways, planting, and entry areas. Due to the City's purchasing guidelines in relation to the total project cost, and the California contractor licensing requirements, it is necessary that the landscape design services be conducted separately from the landscape installation services. Ann Baker Landscape Architecture is performing the park design work in collaboration with Nick Thayer of Late Afternoon Garden Design. Ann Baker has subcontracted design components for Observatory Park to Nick Thayer who is based here in Ukiah. The outcome has been a comprehensive process which includes the experience from both professionals who represent the Northern California Region as well as local Ukiah and Mendocino County. This has been a benefit to the project in meeting the goals specific to native plants and has allowed for incorporating a variety of native plants which are sourced locally. Attachment #4 includes a planting diagram and photos of plant species. Staff has been working closely with the Landscape Architect in the preparation of the plans and the City has now received authorization from the OGALS to move forward with the grant work plan. Next Steps: The next steps for this project will be to advertise the plans and specifications for bid and then to award the contract for the construction/installation services. The Landscape Architect is nearing completion of the final plans and specifications for bid. The landscape architects estimate for the planned construction/installation work is approximately $85,000. Based upon the Cities purchasing policies, and the project budget, the plans and specifications will be advertised and then return to Council for award. While it has been unfortunate that there were some previous delays related to the grant requirements, staff has made tremendous progress and the next stage of the park development should commence without further delay. Staff will return to Council in March 2012 for an award for construction services and construction will occur during the spring months. A park planting diagram and plant photos are included as Attachment #4. During the presentation of this agenda item, staff will provide additional detail about the park plans and highlight some of the features within the park. Fiscal Impact: F Budgeted FY 11/12 1-1 New Appropriation X❑ Not Applicable Budget Amendment Required Amount Budgeted Source of Funds (title and #) Account Number Addtl. Appropriation Requested $130,000* Park Development: Observatory 140.6050.930.000 $0 "amount budgeted represents grant funds and park development funds for Observatory Park as budgeted in FY 11/12 AffaCh.-nont # I gqM y =w J• 1t• � 1a�� .,� Sk � r � VI ra f�i + •Y '' •FY� .� c4 /.. � ,' vim. �{ ! x'r, .>r :�i t 'i.�ti• .�, tom,: „mac -'_•`s" •..1 * . •w i bL r •t,yG, e S .r i� r .. ago �V'9•-�K.� 'W ��p{ �Jti iy!'c � rq�L�6�..;ll•,�r'R� I sh 1'- •�-y,�r r'� { J Z �RL A' ; �Of..4 tJ�+l �kr{ :� �' i - t.� .carr r .z AIC(y! Y X11 ^e16� 1 +n,y i l T A/v 0 0 0 n '---3 TO R 11 n QMiu @)A cevru5 Ann Baker Landscape Architecture 1535 A SAN ANSELMO AVE SAN ANSELMO, CA 94960 CELL: 510.926.2557 EMAIL: landarches@comcast.net Observatory Park, Ukiah, California Perennial and Annual Selections Angelica tomentosa - Foothill Angelica Helianthus angustifolius - Swamp Sunflower Heracleum lanatum -Cow Parsnip Carex praegracilis - California Field Sedge Iris douglasii - Douglas Iris Montia perfoliata - Miners Lettuce Scrophularia californica - California Figwort i It_ �: i � � 4„ �+,, - .. � ,;� •ate J r, °nib �"' � � f yiif �..XP '� 1 4: t�- � i..' •a'r'c .},In wsp¢Ns sdnlb cpm_ , 4 t aR'ir" i 7i!17 Festuca rubra - Red Fescue Agrostis exarata - Western BentGrass Ann Baker Landscape Architecture 1535 A SAN ANSELMO AVE SAN ANSELMO, CA 94960 CELL: 510.926.2557 EMAIL: landarches@comcast.net Observatory Park, Ukiah, California Shrub Selections Arctostaphylos manzanita'Dr. Hurd' - Manzanita Arctostaphylos 'John Durley' - John Durley Manzanita Ceanothus thyrsiflorus 'Snow Flurry' - Blue Blossom fd FI 1 a ' WA pr 7�4 q�m ;I�p V -u kit, 4 n4!k • • Yom• ' i •_�'r4�iril sti3tt< d �• City c!/ 'ZJk:7h ITEM NO.: 11a MEETING DATE: AGENDA SUMMARY REPORT January 18, 2012 SUBJECT: APPEAL OF THE PLANNING COMMISSION'S CERTIFICATION OF THE WALMART EXPANSION PROJECT ENVIRONMENTAL IMPACT REPORT (EIR) Background: In 2009, an application was received requesting approval of a Site Development Permit to allow the expansion of the existing Walmart Store at 1155 Airport Park Boulevard in the Airport Industrial Park. Most of the expansion would be devoted to grocery sales. The applicant requested and staff required that an environmental impact report (EIR) be prepared for the project. As a result of a request for proposals, Environmental Science Associates (ESA) was selected by the City to prepare the EIR. On December 14, 2011 the Planning Commission voted 4-1 to certify the EIR and a timely appeal was filed by William Kopper on behalf of Citizens for Sustainable Commerce, Steve Scalmanini, Alan Nicholson, and Continued on Page 2 Recommended Action(s): Deny the Appeal and thereby Uphold Planning Commission's certification of the Walmart Expansion Project Environmental Impact Report (EIR) Alternative Council Option(s): 1) Uphold the Appeal thereby Overturning Planning Commission's certification of the EIR 2) Grant the two week continuance requested by the appellant, Steve Scalmanini 3) Other Action as determined by City Council. Citizens advised: Persons on the Walmart Interested Parties List, Property owners within 300 feet and within the Airport Industrial Park, Adjacent Tenants, Posted on the Project Site, Published in the Ukiah Daily Journal Requested by: Charley Stump, Planning and Community Development Director and Kim Jordan, Senior Planner Prepared by: Kim Jordan, Senior Planner Coordinated with: Charley Stump, Planning and Community Development Director and Jane Chambers, City Manager Attachments: 1. William Kopper appeal letter date stamped December 27, 2011 2. Steve Scalmanini Continuance letter date stamped January 10, 2012 3. Public Comment 4. Planning Commission Minutes Excerpts 8/10/2011, 11/9/2011 & Draft 12/11/2011 5. Resumes for EIR Legal Review, Urban Decay & Traffic Engineering (provided to City Council 12/22/2011) 6. William Kopper's 11/9/2011 letter numbered to correspond with ESA Response and Steve Scalmanini's 11/9/2011 letter (provided to City Council 12/22/2011) 7. ESA Memo - Response to Mr. William Kopper's 11/9/2011 letter (provided to City Council 12/22/2011) 8. ALH Urban & Regional Economics Response to Steve Scalmanini's comments (provided to City Council 12/22/2011) 9. ESA Memo — Review and Explanation of Urban Decay Methodology (provided to City Council 12/22/2011) 10. Walmart Expansion Project Final EIR (provided to City Council 12/22/2011) �r TMd Approved:_� �a�• •..:. J,ano Chambers, City Manager�� c�=t Jeffrey Blankfort on December 27, 2011 (see attachments 1 and 6). The appeal was scheduled for the first available City Council meeting. Subsequently, Mr. Scalmanini, one of the appellant's, submitted a letter requesting that the City Council delay the hearing on the appeal for two weeks (see attachment 2). The purpose of this item is to conduct a public hearing and for the City Council to determine if the appeal should be upheld, overturned, or if the hearing should be continued as requested by Mr. Scalmanini. EIR Process. On March 11, 2010 a Notice of Preparation (NOP) of an environmental impact report for the Walmart Expansion project was published. The purpose of the NOP is to inform agencies, interested parties, and the public that an EIR will be prepared and to provide an opportunity for people to comment on what environmental issues should be addressed as part of the EIR. The comment period for the scope of the EIR was open from March 11 to April 12, 2010. On March 18, 2010, a scoping meeting was held on the EIR which was attended by approximately 25 people, many of whom commented on what should be addressed as part of the EIR. Many of the commenters expressed concerns related to aesthetics, hydrology and drainage, traffic, and urban decay. At the June 9, 2010 Planning Commission meeting, a report on the scope of the EIR was provided to Planning Commission by ESA, the City's EIR consultant. Also at this meeting, the Planning Commission received training on the California Environmental Quality Act (CEQA) which was also provided by ESA and focused on the EIR preparation and review process. On July 5, 2011 a Notice of Availability (NOA) of the Draft EIR (DEIR) was made available. As required by CEQA, the comment period on the draft EIR was 45 days (July 5 to August 18, 2011). On August 10, during the comment period, the Planning Commission held a public hearing and received public comment on the draft EIR. At the meeting more than 20 members of the public spoke on the DEIR with most people speaking more than once (see attachment 4, Planning Commission minutes). Most of the public comment on the DEIR focused on general plan consistency, traffic impacts, and urban decay. On November 9, 2011 Planning Commission held a public hearing on the certification of the Walmart Expansion Project Environmental Impact Report (EIR). At the meeting, the Planning Commission received public comment from 45 people over approximately 3 hours (see attachment 4). Due to the extent of the public comment, the Planning Commission did not have time to complete its review of the EIR or questions of the EIR consultant and staff. Written public comment was also provided at this meeting, including the letter from William Kopper dated November 9, 2011 which is included as part of this appeal (see attachment 1). The Commission closed public comment on the certification of the EIR and continued the item to the December 14, 2011 Planning Commission meeting. Most of the public comment received on the EIR focused on urban decay and traffic and circulation impacts. . On December 14, 2011, Planning Commission held a public meeting on the certification of the Walmart Expansion Project EIR (see attachment 4). No public comment was taken at this meeting since the public comment was closed at the November 9t" meeting. The information provided to the Commission for the meeting included responses to the comments in the letters provided by William Kopper and Steve Scalmanini (see attachment 6). At the meeting, the Commission asked questions of staff, deliberated, and voted (4-1) to certify the EIR. Most of the questions of staff and comments from the Commission were related to traffic and circulation and urban decay. On December 27, 2011, a timely appeal of the Planning Commission's decision to certify the EIR was received from William Kopper on behalf of Citizen's for Sustainable Commerce, Steve Scalmanini, Allen Nicholson, and Jeffrey Blankfort (see attachment 1). The appeal was then scheduled for the first available City Council meeting. Subsequently, Mr. Scalmanini submitted a letter requesting that the City Council delay the hearing on the appeal for two weeks to allow additional time for the traffic engineer working for the appellants to complete a design to mitigate the traffic impacts identified in the EIR and to run traffic volume calculations (see attachment 2). Discussion: The letter from William Kopper provides the following reasons for the appeal: 1. The Final EIR failed to adequately respond to comments as more particularly set out in the attached letter of November 9, 2011. 2. The EIR failed to include feasible mitigation measures for the Project's impacts on the Talmage Road, Southbound US 101 off ramp. 3. The EIR failed to identify inconsistencies with the City's General Plan and to include a discussion of those inconsistencies. 4. The EIR failed to analyze transportation energy consumption. 5. The EIR failed to include an adequate analysis of the Project's impact on urban decay. 6. The EIR failed to include an adequate analysis of the Project's traffic impacts. 7. The Project's hydrological impacts were not properly addressed in the EIR. 8. The November 9, 2011 letter more particularly sets out Citizens for Sustainable Commerce's reasons for appealing the certification of the EIR. Staff and the EIR consultant have reviewed the reasons for the appeal and provide the following analysis and response. Failure to respond to comments as specified in letter of November 9, 2011. City staff and consultants prepared 134 pages of responses to every comment received on the Draft EIR (Chapter 3 of Final EIR, October 2011). The comments received did not constitute "significant new information" that would require a recirculation of the Draft EIR. In other words, no substantial evidence was provided that there would be a significant impact not already identified in the Draft EIR, or that a significant impact identified in the Draft EIR would be substantially worse and require additional mitigation measures, or that a feasible alternative or mitigation measure considerably different from those analyzed in the Draft EIR would clearly lessen an environmental impact. In addition, a twenty-four page memorandum was prepared by ESA in consultation with City staff addressing the issues raised in the appellant's letter of November 9, 2011. This memorandum was received and reviewed by the Planning Commission at the December 14, 2011 meeting. ESA in consultation with City staff responded to each comment provided in Mr. Kopper's letter dated November 9, 2011 and the Planning Commission considered this information as part of its decision to certify the EIR. No significant new information was provided as part of the review of the DEIR or Mr. Kopper's November 9, 2011 letter; therefore, staff is able to conclude that this item does not provide grounds to overturn Planning Commission's decision to certify the EIR. 2. The EIR failed to identify feasible mitigation measures for impacts to the Southbound ramp at US 101 and Talmage Road. The Draft EIR identified potentially significant cumulative traffic impacts (resulting from the project in combination with other development) to the US 101/Talmage Road interchange (see FEIR, Chapter 2, Summary, Impacts Statements 4.10-2, 4.10-4 and 4.10-5). The EIR identifies three potentially feasible options to mitigate the impacts to the interchange. These measures were discussed with Caltrans, whose participation would be required in any interchange improvements. The applicant (Walmart) would be required to contribute their "fair share" of funding to the solution selected provided the project is approved. However, a funding source for the remaining improvement costs has not been identified. Therefore, the EIR finds this impact to be significant and unavoidable, even though mitigation measures have been identified. The City is pursuing cost estimates for the alternative solutions and has dedicated RDA bond proceeds to potentially contribute to the improvements. If the City capital improvement program is updated to include these improvements, the impact may no longer be considered significant and unavoidable. As required by CEQA, the EIR identifies measures that would mitigate the impacts to the Southbound ramp at Talmage Road and US 101 identified in the EIR. The responses provided as part of the record include the Draft and Final EIR, staff reports, public hearings, and the Memorandum from ESA dated December 7, 2011 that addresses these impacts; therefore staff is able to conclude that this item does not provide grounds to overturn Planning Commission's decision to certify the EIR. 2. The EIR failed to identify inconsistencies with the City's general plan. The EIR included a discussion of potential inconsistency with the general plan pursuant to the CEQA Guidelines (see Table 4.7-1 of the Draft EIR, July 2011). The Final EIR included additional discussion of general plan consistency (see Master Response #3, page 3-4, Final EIR, October 2011). Pages 1 through 7 of the memorandum to the Planning Commission (December 7, 2011) includes additional discussion of general plan policies and standards. It is noteworthy that while the EIR discusses potential inconsistency with land use plans (and the environmental effects a potential inconsistency would have), ultimately the matter of consistency must be decided by the decision making body (initially the Planning Commission, and upon appeal, the City Council). The responses provided as part of the record include the Draft and Final EIR, staff reports, public hearings, and the Memorandum from ESA dated December 7, 2011 identify and analyze the Project's consistency with the General Plan and the Planning Commission concluded that the project was consistent with the General Plan as part of its certification of the EIR; therefore staff is able to conclude that this item does not provide grounds to overturn Planning Commission's decision to certify the EIR. 3. The EIR failed to adequately analyze transportation energy consumption. The Draft EIR assessed the effects of energy consumption by the project in all areas: construction, building operations, and transportation. The key effects are air quality emissions and the potential to generate greenhouse gases (see DEIR, Chapters 4.2 and 4.11). In addition, the amount of potential increase in electricity and natural gas consumption was included (related to public utilities and facilities impacts). The Draft EIR did not include a separate quantification of project -related transportation fuels potentially consumed. Contrary to the appellant's comment, this is not a requirement of CEQA. CEQA requires an examination of the environmental effects of the project. The environmental effect is the potential impact on the environment of fuel consumption and not gallons of gasoline per se. Nevertheless, an estimate of fuel consumption based on the air quality and greenhouse gas analysis was provided in the memorandum of December 7, 2011 (see attachment 7). The responses provided as part of the record include the Draft and Final EIR, staff reports, public hearings, and the Memorandum from ESA dated December 7, 2011 adequately analyze transportation energy consumption; therefore staff is able to conclude that this item does not provide grounds to overturn Planning Commission's decision to certify the EIR. 4. The EIR failed to include an adequate analysis of the Project's impact on urban decay. Urban Decay is defined as "physical deterioration that is so prevalent and substantial it impairs the property use of affected real estate, or the health, safety, and welfare of the surrounding community" (see DEIR, Chapter 4.3 Urban Decay, page 4.3-1). Urban decay is distinct from "urban blight" which is defined by the Health and Safety Code and are a set of standards required in order to adopt redevelopment project areas. The EIR included an extensive analysis, in the form of an EIR impact section (see DEIR, Chapter 4.3), and a stand-alone report (Appendix D of the Draft EIR). Additional discussion was provided in the Final EIR (see FEIR, Chapter 3, Response to Comments) and the memorandum from ESA and ALH Urban and Regional Economics dated December 7, 2011 prepared in response to the comments received at the November 9, 2011 Planning Commission meeting, including the written comments provided by Mr. Kopper and Mr. Scalmanini. While members of the public may disagree with the ultimate finding of this analysis (a less than significant impact), the Planning Commission discussed this issue extensively and found that the analysis provided the information and disclosure required by CEQA. The urban decay analysis finds that the project would likely result in important economic changes in the grocery sector in the City of Ukiah, which when combined with other probable retail projects could result in the closure of one to two grocery stores. However, based on extensive research, the economic study and EIR found that these potential closures would not result in significant changes in the physical environment. Pursuant to CEQA Guidelines section 151551, disagreement among experts does not make an EIR inadequate. Additionally, despite the concerns raised by the appellants, no expert testimony has been entered into the record that would contradict the findings of the urban decay analysis. The responses provided as part of the record include the Draft and Final EIR, staff reports, public hearings, the Memorandums from ESA and ALH Regional and Urban Economics dated December 7, 2011 adequately analyze the Project's urban decay impact; therefore, staff is able to conclude that this item does not provide grounds to overturn Planning Commission's decision to certify the EIR. 5. The EIR failed to include an adequate analysis of the Project's traffic impacts. The EIR extensively analyzed the potential traffic impacts that would result from the proposed project (see DEIR, Chapter 4.10 and Appendix B, FEIR, Chapter 3, Response to Comments, and ESA Memo dated December 7, 2011). As discussed in the Final EIR, the analysis was in many ways conservative, as it analyzed a larger store than currently proposed, and did not "discount" vehicle trips that may make more than one stop in the Airport Industrial Park (known as "linked trips" in traffic studies). Three potentially significant impacts related to vehicular traffic were identified and mitigation measures identified (see DEIR, Chapter 4. 10, Impacts 4.10-2, 4.10-4 and 4.10-5). As stated above, these impacts were found to be significant and unavoidable—not because an engineering solution is unavailable, but because future funding cannot be guaranteed. The responses provided as part of the record include the Draft and Final EIR, staff reports, public hearings, and the Memorandum from ESA dated December 7, 2011 adequately analyze the Project's traffic impacts; therefore, staff is able to conclude that this item does not provide grounds to overturn Planning Commission's decision to certify the EIR. 6. The project's hydrological impacts were not properly addressed in the EIR. Changes in drainage (both quantity and quality) were identified as a concern during the scoping process for the EIR and subsequently discussed in the EIR (see DEIR, Chapter 4.6 and FEIR, Chapter 3, Response to Comments). A mitigation measure which provided a performance standard that must be met was included in the EIR (Measure 4.6-5). When the feasibility of this mitigation measure was questioned by the appellant, storm drainage calculations were prepared using standard City methodology that demonstrated adequate land capacity exists on the project site to meet the mitigation standard of no net increase in peak run off methodology (see ESA memorandum of December 7, 2011). The responses provided as part of the record include the Draft and Final EIR, staff reports, public hearings, and the Memorandum from ESA dated December 7, 2011 and the storm drainage calculations prepared adequately analyze and address the Project's hydrological impacts and demonstrate that the Project can comply with the mitigation standard; therefore, staff is able to conclude that this item does not provide grounds to overturn Planning Commission's decision to certify the EIR. 7. The attached letter of November 9, 2011 sets out the reasons for this appeal. Please see the memorandum prepared by ESA dated December 7, 2011 that addressed each individual point raised in the appellant's letter. ESA in consultation with City staff responded to each comment provided in Mr. Kopper's letter dated November 9, 2011 and the Planning Commission considered this information as part of its decision to certify the EIR. No new information was provided as part of the review of the DEIR or November 9, 2011 letter; therefore, staff is able to conclude that this item does not provide grounds to overturn Planning Commission's decision to certify the EIR. In considering the appeal, the City Council will be deciding whether or not to uphold the Planning Commission's decision to certify the EIR. Staff provides the following information from the California Environmental Quality Act (CEQA) regarding the review and certification of an EIR. ■ CEQA Guidelines Section 15204(c): Reviewers should explain the basis of their comments, and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of their comments. Pursuant to Section 15064, an effect shall not be considered significant in the absence of substantial evidence. CEQA Guideline Section 15151: An EIR should be prepared with a sufficient degree of analysis to provide decision -makers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects need not be exhaustive, but the sufficiency of the EIR is to be reviewed in the light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among the experts. The courts have looked not for perfection but for adequacy, completeness, and a good faith effort at disclosure. In order to certify the EIR, CEQA requires the lead agency to make the following specific findings pursuant to CEQA Guidelines section 15090(a): 1. The final EIR has been completed in compliance with CEQA; 2. The Final EIR was presented to the decision-making body of the lead agency and that the decision-making body reviewed and considered the information contained in the final EIR prior to approving the project; and 3. The final EIR reflects the lead agency's independent judgment and analysis. Public Comment: The comments received regarding the appeal are included at attachment 3. Conclusion: The CEQA process and Planning Commission review process have provided an opportunity for thorough public review and comment on the Walmart Expansion EIR as described above. The Planning Commission review process included review and consideration of written comments, more than 6 hours of public hearings, and comments from more than 60 speakers. Written and verbal comments from the public and Planning Commission have been addressed in the EIR and as part of additional information prepared by ESA and City staff. On December 14, 2011, Planning Commission voted 4-1 to certify the EIR. In staff's opinion, no new information has been presented in the appeal; therefore, staff recommends that the City Council deny the appeal and uphold Planning Commission's decision to certify the EIR. Fiscal Impact: Budgeted FY 10/11 ❑ New Appropriation Not Applicable Budget Amendment Required William I.J. Kopper Attorney at Law 417 E Street Davis, CA 95616 (530) 758-0757 Fax (530) 758-2844 SENT VIA FEDERAL EXPRESS December 21, 2011 City Clerk City of Ukiah 300 Seminary Avenue Ukiah, CA 95482 AT LACH RRcivT ;rte rLEM DEC 2 T 2011 RE: Appeal of Certification of Environmental Impact Report for City of Ukiah Walmart Expansion Project Dear City Clerk: Citizens for Sustainable Commerce, a California Association, Steve Scalmanini, Allen Nicholson, and Jeffrey Blankfort hereby appeal the Planning Commission certification of the Environmental Impact Report for the City of Ukiah Walmart Expansion Project. The Planning Commission certified the Environmental Impact Report on December 14, 2011. I have enclosed a $100 fee to appeal certification of the Environmental Impact Report. In summary, Citizens for Sustainable Commerce, Steve Scalmanini, Allen Nicholson, and Jeffrey Blankfort appeal the certification of the Environmental Impact Report for the following reasons: 1. The Final Environmental Impact Report failed to adequately respond to comments as more particularly set out in the attached letter of November 9, 2011. 2. The Environmental Impact Report failed to includes feasible mitigation measures for the Project's impacts on the Talmage Road, Southbound US 101 off ramp. 3. The EIR failed to identify inconsistencies with the City's General Plan and to include a discussion of those 'inconsistencies. 4. The EIR failed to adequately analyze transportation energy consumption. 5. The EIR failed to include an adequate analysis of the Project's impact on urban decay. 6. The EIR failed to include an adequate analysis of the Project's traffic impacts. City Clerk City of Ukiah December 21, 2011 Page 2 7. The Project's hydrological impacts were not properly addressed in the EIR. 8. The attached letter dated November 9, 2011, more particularly sets out Citizens for Sustainable Commerce's reasons for appealing the certification of the Environmental Impact Report. Sincerely,V 4 \ 1 J William D. Kopper Attorney at Law WDK/wrn enclosure William D. Kopper Attorney at Law d.17 F Street Davis, CA 95616 (530)758-0757 Fax (530) 758-2844 November 9, 2011 RECOMM DEC 2 7 2011 City of Ukiah Planning & Community Development Dept CITY OF UWAH 300 Seminary Ave. PMNING DEBT. Ukiah, CA 95482 RE: City of Ukiah Wal-Mart Expansion Project Final Environmental Impact Report Dear Members of the Planning Staff and Planning Commission:: I represent Citizens for Sustainable Commerce, a California Association, Steve Scalmanini, Allen Nicholson, and Jeffrey Blankfort. These are their comments. We incorporate into these comments those of all other individuals and entities commenting on both the Draft Environmental Impact Report (DEIR) and the Final Environmental Impact Report (FEIR) for the City of Ukiah Wal- Mart expansion Project. Citizens for Sustainable Commerce, Steve Scalmanini, Allen Nicholson. and Jeffrey Blankfort, oppose the expansion of the Ukiah Wal-Mart. We incorporate into these comments the attached comment letter from Dr. Mark Grismer, Hydrologist. With respect to the Final Environmental Impact Report for the City of Ukiah Walmart Expansion Project, we have the following comments. On page 4 of Ms. Linda Sanders' letter to the Planning Commission, Ms. Sanders indicates that the City has incorrectly determined that the Project is consistent with General Plan Policy 25.2. She stated that the expansion of the parking lot, loss of turf area and established trees will add to the urban heat island effect. CEQA Guidelines §15088(c) states: "The written response shall describe the disposition of significant environmental issues (e.g. revisions to the proposed project to mitigate anticipated impacts or objections). In particular, the major environmental issues raised when the lead agency's position is at variance with recommendations and objections raised in the comments must be addressed in detail giving reasons why specific comments and suggestions were not accepted. There must be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information. will not suffice. Ms. Sanders, a Planning Commissioner, raises the issue that the loss of turf area and trees, and adding asphalt at the Project site will contribute to the urban heat island effect. She is not the only commenter on the DEIR to point out that increasing the paved area will add to the urban heat island effect. The EIR fails to respond to Ms. Sanders' comment or any of the other comments that suggest adding pavement and loss of turf area and trees will add to the urban heat island effect. The City of Ukiah Planning & Community Development Dept November 9, 2011 Page 2 urban heat island effect is a well-known environmental impact that has been documented in the Record. The EIR needs to respond to comments concerning the urban heat island effect. On page 6 of Ms. Sanders' letter (Comment F-23), Ms. Sanders points out that the planter island spaces in the existing parking lot are too confined, and replacing the old trees with -other trees will not provide shade because the trees cannot grow in such confined spaces. The FEIR does not provide an adequate response to this comment. The FEIR states that suitable trees will be selected, but does not identify any trees that would be able to grow -in the confined spaces and provide adequate shade. The response does not comply with CEQA, but merely includes speculation. On page 8 of Ms. Sanders' letter, she raises concerns about the Project's consistency with General Plan Policy CT -1.1, which requires land use entitlements to be based on the classification and capacity of the street or road providing primary access. In response to this comment, the EIR states that "The EIR does identify existing deficiencies in the State highway facilities (US 101 southbound exit) and future limitations of the interchange." The EIR also identifies a range of mitigation measures and requires a fair share contribution from the Applicant. The response also refers to Response A-6 which states that "Mitigation measures for both vehicular and non -vehicular traffic improvements identified in the EIR are above and beyond improvements contemplated in the CIP." In light of the severe queuing problems at the Talmage Road/ US 101 interchange, which will be exacerbated by the Project; there is no plausible way that the EIR can conclude the Project will be consistent with Policy CT- 1.1. An EIR must find that a Project is inconsistent with the General Plan Policy when the Policy is unambiguous and the Project is clearly contrary to a Policy. The Ukiah Walmart Expansion EIR assumes that if the EIR finds that a Project is inconsistent with a General Plan Policy, the City must automatically reject the Project. However, CEQA's analysis of an inconsistency is different than for a decision under the planning and zoning laws. "An inconsistency [identified in an EIR] might indicate a likelihood of environmental harm and thus trigger a careful review of any potential impacts. An inconsistency may also support the conclusion that the underlying physical impact is significant." (Kostka and Zischke, Practice Under the California Environmental Quality Act (CEB 2011), p. 612.) The EIR in this case fails to identify the Project's inconsistency with the City's General Plan Policies, when the inconsistencies are clear and unambiguous. The EIR then fails to provide the necessary analysis that is required by CEQA. As has been pointed out in Ms. Sanders' comment letter, the Project is clearly inconsistent with Policy CDA i . l that requires commercial and industrial parking lots to be designed to be subservient to the structure it serves. The Project is clearly inconsistent with OC -28.1 that requires projects to upgrade the visual appearance of the corridor along Highway 101. It, in fact, blocks views with a concrete building. This Project does nothing to enhance the visual appearance of the corridor. In fact, The Project is inconsistent with General Plan Policy OC -28 that requires projects to visually enhance the Highway 101 corridor through the City's planning area. The Proj ect is inconsistent with EG -5.1, which requires projects to encourage minimum canopy coverage of all paved areas on a lot. This Project will not obtain the minimum standard set forth in the City's Code. The Project is not City of Ukiah Planning & Community Development Dept November 9, 2011 Page 3 consistent with OC -29, which requires projects to maintain and enhance' the `urban forest" which create a sense of urban space. Despite Ms. Sanders' request for perimeter planting of redwood trees to screen the Project along the eastern perimeter, the FEIR refuses this request. The redwood trees would create a screen from Highway 101, and would protect the US 101 visual corridor. However, compliance with the General Plan would likely defeat Walmart's goal of having it's store visible from Highway 101. The Project is clearly inconsistent with Policy OC -25.1, which requires a proj ect to protect existing healthy mature trees to maintain shade and area attractiveness. This Project would remove trees, and the newly planted trees may not survive based upon the -Applicant's historical record. The Project is not consistent with GP -25.2 which requires projects to insure useable open space and common space. The open space would be lost due to the Project. The Project is not consistent with GP -26, which requires that landscaping be a significant component of development proj ects. These commenters contend that the EIR has made a mistake by failing to use Costco's actual counts of trip generation for the purposes of calculating cumulative impacts of the Project. Costco provided a report from its traffic engineer, Kittelson & Associates, with actual counts demonstrating the peak trip generation in the weekday pm peak hour that will be caused by the Costco Warehouse. The counts were based upon traffic at comparable Costco Warehouses. Under the directions set forth in the ITE Traffic Manual, agencies are supposed to use the actual counts, when available, in comparison to the estimates to be provided by the standard ITE trip generation rates. Moreover, it is the City of Ukiah policy to use actual counts when they are available and the actual counts should be used in this case. The conservative approach would be used to provide actual counts, since these figures are higher. The actual counts would provide amore realistic projection of the cumulative impacts of the Project. In Comment Q-2, the commenters ask where trailers and containers will be stored on the site once the expansion is complete. Response to Comment Q-2 is incomplete and only states, "No storage of trailers or other containers will be allowed in the parking area." The response does not state where the trailers and storage containers will be located on the site. The response fails to comply with the requirements of CEQA. As set forth in Comment Q-5, under the title, "Areas of Controversy", in section 3.4 of the DEIR, the DEIR states that one area of controversy includes `'heat island effects of parking lot." As explained in Comment Q-5, an EIR is generally required to include a discussion of the areas of controversy. The Project EIR fails to discuss the heat island effect, and states instead: "The.evidence submitted to date has been general information about urban heat island effect, but does not specifically address how the Project would create such an effect, or what the specific environmental impact would be." This statement is inconsistent with the evidence that has been submitted. The evidence shows that the urban heat island effect is created by paved over areas of land absorbing heat and increasing the temperature in the urban environment. The evidence submitted shows that parking lots increase the urban heat island effect. The increase in temperature in parking lots causes the cars parked in the parking lots to emit additional ROG (Reactive Organic Gas), which.is a component of ozone. Additionally, the added heat increases the use of energy for air conditioning, causing additional GHG emissions. Also, vehicles under warmer conditions emit City of Ukiah Planning & Community Development Dept November 9, 2011 Page 4 more GHG emissions while they are parked. There is certainly substantial evidence provided in the Record that the urban heat island effect is an environmental impact. In light of the fact that the "heat island effect of parking lots" was identified as an area of controversy, the: EIR is required to address this impact. The failure to do so is a violation 'of CEQA. The EIR refused to respond to Comment Q-6. The commenters asked for information on whether Walmart had contributed to the Capital Improvement Program to pay for street and intersection improvements that would be needed as the Redwood Business Park build out occurred. The commenters asked for information on the amount of fees that Walmart paid into the Capital Improvement Program for the Redwood Business Park Association, and how the fees were expended for infrastructure improvement since the formation of the Redwood Business Park Capital Improvement Program. The Response is non-responsive. The information is relevant to determine if there are funds that Walmart has contributed to help pay for bike paths and other needed improvements in the area of the Walmart Expansion that are available for bee based mitigation. The EIR needs to provide more information in response to Comment Q-6. In Comment Q-7, commenters asked why the City or Walmart did not implement the requirement for T -intersection with Talmage Road and the signalization of the intersection as was required by the conditions of approval of Site Plan Permit 90-87. The EIR refused to answer this comment. The response states that the existing conditions are the baseline conditions. It states that some improvements were made on Talmage Road, but they are not identified. Further, the Response states that Mitigation Measure 4.10-2 would supersede the improvements described in Condition 2B. This information is not adequate to comply with CEQA. If the City policy is not to enforce the conditions of approval of its development permit, then an additional permit should not be permitted for the expansion. Public policy and State statutes require a city to enforce the conditions of approval for developments. The City needs to explain why it has allowed Walmart to get by without paying for the traffic improvement it was supposed to pay for with its initial approval. The EIR should discuss whether the cost of signalization of the Talmage Road/southbound US 101 off ramp should be assessed to Walmart since they did not previously pay for this improvement. The money that Walmart did not pay for this approval should be made available for the additional traffic improvements that are now required for the expansion. Additionally, Mitigation Measure 4.10-2 is not effective, and does not require Walmart to pay fees. Walmart may avoid the mitigation measure, just as it did the prior mitigation measure, and expand without paying for its traffic impacts. Mitigation Measure 4.10-2 states as follows: Prior to issuance of building permits, the Project Applicant shall provide proportional -share payments to the City of Ukiah for the planned improvements and reconfiguration of the interchange, which would improve the queuing to acceptable conditions (i.e., accommodated in the available storage) at Talmage Road and US 101 southbound off -ramp. This mitigation measure is included in either option A (roundabout only), or option B. City of Ukiah Planning & Community Development Dept November .9, 2011 Page 5 The improvement plan by the City of Ukiah Talmage Road/Airport Park Boulevard (described in future transportation improvements, above) would need to be implemented in addition to Mitigation Measure 4.10-2. However, this improvement is currently unfunded and does not appear in the City of Ukiah's Capital Improvement Program, so the improvement cannot be considered a feasible mitigation measure. Because this improvement addresses existing queuing problems, it is legally infeasible to require the Applicant to pay more than its fair share for the cost of this improvement. The balance of funding required for this improvement, over and above the Applicant's fair share, has not been identified. Without a funding mechanism, this impact would remain significant and unavoidable. The above mitigation measure is entirely insufficient under CEQA. Firstly, the Record shows that Option A is not feasible. There is also no evidence that Option B can be feasible. Before Walmart can be required to pay a fair share, the City must have an acceptable design (not at blue print level) of Option B, a cost for Option B, and a calculation of Walmart's fair share. This all must be completed prior to the approval of the Project and certification of the EIR so that the Project's impact may be mitigated. In the event that these steps are not taken. Walmart may be issued Building permits and allowed to construct its expansion without paying for the mitigation for both its direct impacts and cumulative impacts. Mitigation Measure 4.10-2 is not a real mitigation measure, but only a speculative mitigation measure that does not comply with CEQA. It is a palliative to allow the City and decision makers to think that some mitigation measure is in place when it is not. Apparently, the City allowed Walmart to get out of the prior mitigation measure at Talmage Road and the Highway 101 south to Talmage Road East exit ramp. In order to provide the history to the City so that the City can make the correct decision on the environmental impacts of the Project, the EIR needs to explain why this was allowed to happen. In Q-8, the tcommenters point out that Development Permit 9047 included a. Condition 20, that stated that a bike lane shall be extended to the site from Hastings Road/State Street intersection following the completion of the widening and improvement of Talmage Road. The FEIR states as follows: "Bike lanes were to be provided extending from Talmage Road to South State Street following the widening and improvement of Talmage Road. Talmage Road was not widened and improved to a level that allowed the installation of bike lanes." The EIR is silent as to why the condition for the bike lanes along Talmage Road was not complied with or why the widening for the bike lanes was not -paid for, which was a condition of approval for the Walmart. The EIR does not state why Walmart was let out of this condition of approval, and why it should not be imposed as part of the current approval process. It is not just the physical conditions on the ground that set forth the baseline conditions for this Project, but the baseline conditions also include the conditions of approval, some of which have not been complied with. The EIR has improperly failed to. consider City of Ukiah Planning & Community Development Dept November 9, 2011 Page 6 the conditions of approval and implementing these conditions, as part of -the environmental setting and baseline conditions. Comment Q-9 requests information concerning Walmart's existing car pooling program for its employees. The comment asks for a copy of the written report that Walmart was to file with the Director of Community Development describing the program. The comment asks for the information furnished by Walmart showing that Walmart has complied with the car pooling condition of approval, which requires monitoring the progress and success of its car pooling program on a semiannual basis, and making appropriate adjustments. The EIR fails to respond to this comment. It does not include the requested information, and simply states that Condition of Approval 21 remains in effect. It states the City has requested more information on the transportation coordinator role. The Response further states: "As the car pool coordinator does not relate to a finding of significance or a .required mitigation measure, it need not be included in the EIR." CEQA requires this information to be included in the EIR. The car pool program is a mitigation measure to reduce both traffic and air pollution impacts. If Walmart has not complied with the previous Condition of Approval No. 21, and the City has not enforced this condition, then it is clear that the Mitigation Measure 21 is not effective, and the impacts it was intended to mitigate that have been considered insignificant after mitigation may, in fact, be significant. Therefore, the requested information is highly relevant and the EIR must provide it. If there is no such information because Walmart did not implement the program, then the City also needs to know that fact. Comment Q-10 asks that the EIR comply with Appendix F and provide information about the energy use of the Project. In response to Comment Q-10, the FEIR points out that the DEIR did discuss the increase in use of natural gas and electricity that would result from the Project. Additionally, sections of the Project Description set forth the energy conservation features of the building. Page 4.9-9 also identified energy conservation regulations that the Project would be required to comply with, and pages 4.1-11 to 4.11-21 sets forth energy conserving features and water conserving features of the building. What is missing from this discussion is information about the transportation energy use related to the Project, and conservation of energy related to transportation. By far, the largest amount of energy that will be used by the Project is transportation related energy use, but there is no discussion of the amount of energy to be used in transportation for the Project, or any conservation of that energy. In Comment Q-11, commenters point out that Appendix F specifically states that an EIR is to provide the "total estimated daily vehicle trips to be generated by the Project and the additional energy consumed per trip by mode." The economic study for the Project shows that the primary market area for the Walmart extends north to Willetts, approximately 20 miles away on Highway 101, and almost to Cloverdale south of Ukiah, approximately 25 miles away. The market area extends east and west based upon an approximately 30 minute drive. The transportation energy use will be very. significant, The case law interpreting CEQA as well as the guidelines states that the energy use of a protect is a significant environmental impact and should be analyzed in. an EIR. The Final EIR fails to analyze or consider the energy.use related to transportation. The FEIR's response City of Ukiah Planning & Community Development Dept November 9, 2011 Page 7 to Comment Q-11 is non-responsive and does not comply with CEQA. In response to Comment Q- 12, the EIR states that there is no necessity for an analysis of additional energy conservation features for the Project such as an active cool roof, solar electric collectors, solar water heating, or light colored paving material, such as white concrete in the parking lot to reduce energy use and the urban heat island effect. The response to Comment Q-12 states that there is no need to consider additional mitigation if there is no significant environmental impact. Energy use is resumed to be a significant impact that is to be analyzed in accordance with Appendix F. Without an analysis of energy use, it is not possible to determine the extent of the _impact, Moreover, the additional use of fossil fuel energy generates additional GHG, which is a significant impact. Comment Q-14 asks how the primary market area for the Supercenter compares to the primary market area considered in the economic study for the original Walmart Project. In the F-EIR, the response to Comment Q-14 indicates that the original Walmart economic study did not include a description of the primary market area. Therefore, the information in the EIR describing the increase in the distance of vehicular trips is unreliable. There is no basis in the EIR to conclude that most of the vehicular trips for the supercenter will be local. It is the assumption that most of the vehicular trips will be local that allows the EIR to conclude that the GHG emissions for the Project are so small. In Comment Q-15, these commenters point out that the Project is inconsistent with the original Condition of Approval for Site Development Permit No. 90-87. Site Development Permit No. 90-87, Condition 8, required the Project to plant one shade tree per four parking spaces. Instead, this condition was not implemented and the Project has one planter island for eery eight spaces. The Project proposes to plant new trees in the existing parking lot, but does not propose to meet the one tree per four parking spaces requirement as a condition of the original Walmart. The Project EIR does not discuss why the City does not have to bring the existing Walmart into compliance with the conditions of approval before allowing expansion of the-Walmart. The FEIR relies on Master Response 1, and points out that the new sections to the parking lot will have landscaping planters between every four parking spaces as required by ATP Ordinance 1098. Moreover, Master Response 5 states that the overall shading of the parking lot will improve with the expansion and the new trees, but will not meet the requirements of the City Code or the AIP Ordinance 1098. The Response in the EIR is not satisfactory. The two cases cited in Master Response 1 (Fat v. County of Sacromento and River Watch v. County of San Diego) are not applicable to the facts confronting the City of Ukiah in the approval of the expanded Walmart Project. In Fat, the City had failed to complete environmental review and allowed an illegal expansion of the Executive Airport. The Court held that the illegal expansion of the airport was the baseline condition. Here, part of the Project is the improvement of the shading throughout the Project. Therefore, the EIR needs to discuss the previous conditions of approval, why they were not implemented, and why they should not be implemented as part of the expansion which includes improving shading both on the existing property and the new property. Additionally, an EIR is required to discuss the permits required for a property and permit conditions. The permit conditions and the performance of the permit City of Ukiah Planning & Community Development Dept November 9, 2011 Page 8 conditions is a relevant matter to be included in an EIR. Finally, to the extent that the condition did apply to the tentative or final map, Government Code §66473 requires that the final map be disapproved if the conditions are not met. An EIR needs to include the information necessary for an agency to make this assessment. With respect to the response to Comment Q-19, it appears virtually impossible that the expanded parking lot will have no new light poles. If the expanded parking lot will have no new light poles, how will lighting be provided in the expanded parking lot. The FEIR's response to Comment Q-20 is inadequate. The FEIR is. required to provide information on the illumination levels in the parking lot so that an assessment can be made whether these levels exceed standards that may disrupt migrating, feeding, and breeding habitats of birds and other wildlife, as well as growth patterns of trees. Only if the level of lighting is specified can an assessment be made of this impact. The FEIR is non-responsive to Comment Q-20. With respect to the FEIR's response to Comment Q-21, the EIR does not establish that the Project lighting is less than a significant impact. There is no data or analysis that would support such a conclusion. With respect to Comment Q-23, Ordinance 1098 does not supersede the underlying Municipal Code requirement for parking, and landscape coverage. Therefore, the City is required to proceed with a variance to reduce the landscaping on site. With respect to Comment Q-25, if the City is not going to comply with the requirement of 50% shading on site, as required by the City's Municipal Code, the City must process a variance, Comment Q-28 asks for clarification as to what items are included in the food category since the space allegedly devoted to food in the proposed Walmart expansion is much smaller than in other supercenters. The response to Q-28 is non-responsive and does not include the requested information. Instead, the response indicates that the purpose of CEQA is not to generate paper. However, to understand the economic impacts of the Project, it is necessary to know the actual area that is devoted to food sales as these sales are generally defined. Similarly, the FEIR fails to properly respond to Comment Q-32. In Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.AppAth 1184, the court precluded speculation about the re -tenanting of stores that are vacated. The response to Q-32 is simply speculation that the market area would attract new retailers to pick up the space vacated by the Lucky -Market and the Grocery Outlet. However, no retailers are identified, and the authors of the FEIR also admit that there is no unmet need. Speculation is not substantial evidence. The FEIR fails to adequately respond to Comment Q-35. As pointed out in Q-35, based upon the growth in the market area, it would take 20 years to absorb the estimated 200,000+ sq. ft. of vacant commercial space that would become available under the cumulative analysis. The question raised is whether the 20 years of vacancy would be sufficient to create urban decay. This comment is not answered. Instead, the FEIR states that the attractiveness of the market to other areas would fill the space. The authors speculate. that there would be a demand for more services, such as banks, insurance companies, postal services, copy services, hair salons and health clubs. However, no specific tenants looking for space are identified. Moreover; the broad speculative analysis fails to take into account that retail sales from brick and mortar stores are falling City of Ukiah Planning & Community Development Dept November 9, 2011 Page 9 as more people buy their books, clothing and other items online. The EIR fails to include any substantial evidence supporting the claim that the attraction and success of retailers to the Ukiah Market is not dependant upon economic growth. This would set Ukiah apart from all other places in the United States, There are no studies that would show that the success of retailers and the growth of retailing in an area is not dependent upon economic growth. If there is such a study, the authors of the FEIR need to produce it. The response to Comment Q-35 is non-responsive, conclusory, and fails to comply with CEQA. Comment Q-44 asks the authors of the EIR to produce the number of residential permits in the market area for the years 2008 -2011, because this is one of the indicators of economic growth and the increase in demand for retail space, In response to Comment Q-44, the FEIR does not provide the number of residential permits in the market area. Instead, the EIR states: "The number of building permits issued in the market area has been low in recent years, which is consistent with the flat household growth noted in Exhibit 8 from 2008-2011." The answer is non-responsive. The request for information, which is highly relevant, was for the number of residential building permits. The EIR fails to respond to a comment in the manner required by CEQA. With respect to Response to Comment Q-45, while it is true that Bakersfield Citizens indicate that the definition of "blight" used in the context of a redevelopment plan is not necessarily the same as "urban decay", the areas that are blighted are necessarily subject to some form of urban decay. Therefore, the fact that an agency has determined that an area is blighted, is evidence that urban decay has occurred in the area. The FEIR should be modified to reflect this fact. Response to Comment Q-46 is inadequate. It fails to include any explanation as to why the EIR should not include additional information showing that Mitigation Measure 4.6-5 is feasible. This mitigation measure states that: "The Applicant shall design, implement, and maintain a stormwater retention and/or detention feature such that there would be no net increase in Project Condition Peak Flows (e.g. Project Condition Peak Flows would be reduced by approximately 10%) " The proposed mitigation measure is impermissible future mitigation because the EIR does not include sufficient information to show that the mitigation measure is feasible. There are only 2 ways to prevent an increase in stormwater runoff under peak flow or flood conditions: 1) Include in the Project design an on-site stormwater retention basin; or, 2) to include an underground storage system in the form of on-site pipes that retain the stormwater flow. There is clearly insufficient land on the site for a storm water retention pond. Additionally, there is no information that it is feasible to construct the extensive piping network underneath the store and parking lot in order to retain the stormwater peak flows on site. The EIR needs to include additional information showing that the proposed mitigation is feasible. The Regional Water Quality Control Board, a responsible agency, indicated that this information was necessary and missing from the EIR. Comment Q-47 points out that the City's MS -4 permit specifies that LID methods are to be used as best management practices. The LID methods are to be worked into the Project design, and are to be discussed as part of the CEQA process. Comment Q-47 states that the EIR ignores the City of Ukiah Planning & Community Development Dept November 9, 2011 Page 10 application of the LID measures and does not provide sufficient detail about the mitigation measures to comply with CEQA. The response to Q-47 is not adequate. The authors of the FEIR•contend that LID measures do not need to be designed into the Project and considered as part of the CEQA process. This is contrary to OPR direction and the position of the Regional Water Quality Control Board as set forth in their comments on the Project. The evidence is overwhelming that LID measures must be designed into the Project. If the Project is to have no LID measures, the EIR should so state. Comment Q-48 asks for information in the Project Description of the mitigation measures for the control of spillage of fertilizers and garden chemicals on the Project Site. The response to Comment Q-48 is legally inadequate. The response states that the Applicant would be required to comply with City standards to protect water quality. Because of the unique nature of the management of a garden center, the EIR and Conditions of Approval need specific measure to protect from water quality impacts related to the operation of the garden center. The EIR needs to specify that the chemicals and fertilizers will be kept in close containers and not on outdoor pallets, that the chemicals and fertilizers will be swept up and that there will be a special designed shield to prevent the washing of fertilizers and chemicals into the storm drains. The EIR needs to include adequate mitigation measures to prevent the Project's garden chemicals from impacting water quality. In Comment Q-49, the commenters ask that the EIR discuss the environmental impacts associated with varying the landscaping requirements so that the Project would not be required to have the 20% landscaping on site, and the 50% shading in 10 years. The lower standard to be applied to the Project will have an environmental impact, and the EIR fails to discuss this environmental impact. The response to Comment Q-49 is non-responsive, does not comply with CEQA, and does not furnish the missing information. The FEIR is also non-responsive to Comment Q-51. While adding shading will reduce the temperature of the parking lot, compliance with City standards will further reduce the temperature of the parking lot. The EIR fails to discuss the environmental impacts of the Project's failure to comply with City standards. Moreover, there are no other mitigation measures proposed that could help mitigate these environmental impacts, such as paving the parking lot with light colored paving material, such as white concrete. The EIR fails to state that the Project is inconsistent with General Plan Policy OC -31.1, which requires projects to encourage mass transit and limit automobile use. As pointed out in Comment Q-58, all available studies indicate that superstores cause greater automobile use because consumers must drive farther to superstores to buy their groceries, rather than patronizing local stores which are closer. Comment Q-58 is allegedly answered in Response F-33, but F-33 is non- responsive because it provides no information showing that the Project would encourage mass transit and limit automobile use. The Project is unambiguously in conflict with General Plan Policy OC - 31.1, and the EIR needs to identify this conflict and discuss the impact. In Comment Q-59, these commenters state that the Project is inconsistent with General Plan Policy EG -1.1, which requires local shopping within walking or bicycling distance of proposed and existing houses. In view of the fact that the supercenter, in combination with the discount City of Ukiah Planning & Community Development Dept November 9, 2011 Page 11 warehouse, will close down neighborhood grocery stores, the consumers will have to drive farther to obtain their groceries, and will not be within walking or bicycling distance. The EIR,provides no evidence or studies to show how the Project is consistent with EG -1.1 or adequate explanation of the finding of consistency. As stated in Comment Q-60, PR -13.3 requires safe bicycle lanes and Project street design. In view of the fact that Airport Boulevard is a busy street, and the only bicycle designation is a Class -III bicycle route, the Project is inconsistent with this policy. The FEIR admits this fact. It states that the.existing streets do not have enough right of way for Class -I and Class -II bicycle facilities. However, the Project will add vehicular traffic to Airport Boulevard and surrounding streets. thereby making bicycling even more unsafe. The Project is clearly inconsistent with PR -13.3. The EIR fails to identify a conflict with section CT -1.1 of the General Plan, as alleged in Comment Q-61. Scetion CT -1.1 states: "Land use entitlements shall be based on the classification and capacity of th;; street providing primary access." As pointed out in the comment that the Talmage Road/US 101 interchange is severely impacted and cannot be improved because of lack of funding. The FEIR states that the Project is consistent because it is in an area designated for commercial development, and the roads providing primary access to the site consist of arterial and collector streets appropriate for such development. However., the capacit-v of these roadways is used up, and the FEIR does not address this problem. The FEIR points out that the General Plan still allows approval if road capacity is impaired and certain requirements are met. One of the requirements is to condition the Project on the developer funding of improvements needed to maintain services «nd/or provide additional traffic improvements. However, the way the Project is structured, the City has not yet determined the improvements needed at the Talmage Road/US 101 interchange and has not determined the cost of the improvements or W almart's fair share. Therefore. if the Project is approved and Walmart processes its application for building permits before the cost of the Talmage Road/US 101 interchange are added to the CIP,- the conditions of GP 16.41) would not apply. The developer would -net -provide funding to improve the interchange. In comment Q-64, the commenters point out that there is a conflict in the language of the EIR. In response to General Plan Policy CT -6.3, the EIR states that the Project will provide "a Class -II bicycle route along Airport Park Boulevard." On page 4.10-28 of the EIR, the EIR states the Project will install Class -III bicycle routes along both sides of Airport Boulevard. The EIR needs to clarify the inconsistency, and fails to do so. : In Comment Q-67, the commenters state that there is no evidence in the Record that the Project is consistent with General Plan Policy CT -11, which is intended to encourage the use of car pooling and van pooling. The commenters state the EIR should provide a description of the current car pool and van pool policies, and how they have effectively worked to encourage the increased use of car pools or van pools. The FEIR replies that it does not have to provide information about pre- existing conditions. That is not true. The existing car pool and van pool program is part of the baseline conditions. The effectiveness of the car pool and van pool program effect both air quality and traffic congestion. Therefore, this information has to be provided, and it must be determined whether a continuation of the existing car pool and van pool program is, in fact, consistent with Policy CT -11. The failure to provide the information about the existing car pool and van pool City of Ukiah Planning & Community Development Dept November 9, 2011 Page 12 program is a violation of CEQA. This is especially true since the City was required to obtain written reports about the car pool and van pool program and Walmart was required to provide these reports to the City. Comment Q-69 asks for information regarding the proposed security measures in the parking lot and the Walmart property. The Comment points out that the EIR fails to explain how 'interior and exterior cameras will reduce the number of police calls. It asks whether the surveillance cameras will be constantly monitored by a Walmart employee, and how the interaction between the parking lot patrol and surveillance cameras will work to lower the number of police calls after the Supercenter is open. This information is not provided. The FEIR claims that these are not issues that affect environmental matters, but are economic issues. This is not correct, and the required information should be made available. The diversion of police resources to the Walmart site affects public health and safety in other areas of the City, which is an environmental issue. The requested information should be provided. The EIR fails to respond to Comment Q-70. Comment Q-70 asks "what is the current treated water supply in the City, and would the treated water supply have to be increased in order to serve the Walmart expansion." In response, the FEIR states that the City is the water supplier. Further, "the City's water demand is anticipated to be 5217 AFY by 2035, with a projected supply of 23,295 AFY. The Project is anticipated to have the water demand of about 4.59 AFY." This is non- responsive because the issue is not the water supply, but the treated water supply. The City may have 23,295 AFY available to it, but if the water treatment plant can only process a much lower amount of water, the Project may have a significant impact on public utilities and the availability of treated water. The FEIR should provide an additional more complete answer to Comment Q-70. In order to respond to comment Q-76, and the claim that the EIR incorrectly calculated GHG emissions attributable to transportation, the EIR needs to determine how many vehicular trips that are now going to the Luckys and Grocery Outlet will be diverted to the Wal-Mart, and how many more vehicle miles will be driven because of these diverted trips. Also, the EIR states that there will not be that many out -of -Ukiah trips to the Supercenter, but provides no data to support this. The EIR should include a study showing the change in the trip patterns associated with the construction of the Ukiah Supercenter. This information is missing from the EIR. Although the FEIR criticizes the French study showing that the distance covered by cars traveling to the Supercenter in comparison to a supermarket is 244% greater, the authors, of the EIR do not state what the comparison is for the Galt Supercenter or a similar Supercenter. All of the studies have shown that Supercenters cause a much greater distance covered by cars. Without additional information, the GHG emission calculations are not supportable and are simply speculation. In response to comment Q-77, the FEIR does not state why the authors have chosen not to run the Air Resources Board program that is specifically designed to calculate the Pavely Reduction. It would appear that running the specifically designed program.to calculate the Pavely Reduction would be appropriate rather than basing an estimate on another EIR done for LA County or comments on Assembly Bill 1493. Obviously, the program has been prepared to accurately calculate the Pavely Reduction. City of Ukiah Planning & Community Development Dept November 9, 2011 Page 13 Traffic Issues As pointed out in Caltrans comment W-2, February is the lowest retail month of the year. Therefore, the traffic counts in February are misleading and should be adjusted. The fact that school is not in session in the summer, is irrelevant since school traffic does not affect the pertinent intersections surrounding the Project site. The EIR has intentionally selected a low volume period for the baseline in violation of CEQA standards and, therefore, does not comply with CEQA's requirement to complete an accurate basline. In comment W-11 Caltrans' comments as follows: The DEIR gives an unclear explanation about the potentially significant and unavoidable impact designation of transportation and circulation impacts due to the fact that the interchange improvement is not on the City's existing capital improvement project (CIP) list. This would appear to be a technicality that the City is capable of remedying. During preliminary discussions with the City about feasible mitigation measures at Route 101/222, we were told that the City intended to construct the mitigation and collect fair share mitigation funds to partially offset the costs. If this is no longer being proposed, we recommend delaying project approval until mitigation can be constructed or fair share funds collected. In response to this comment, the EIR .states that "the availability of funds, other. than those that would collected from the Project applicant, is undetermined at this point." Further, the FEIR states that it is assumed a regional UVAB traffic mitigation fee would fund a portion of the improvements to L'S 101 and Talmage Road. However, the FEIR points out that neither the City or County is actively pursuing a mitigation fee that would cover the improvements to US 101 and Talmage Road. The FEIR further states that in the absence of an established fee program, these mitigation measures may not be implemented in a timely manner. Mitigation Measure 4.10-2 and 4.10-4 state "Prior to issuance of building permits, the project applicant shall provide proportionate -share payments to the City of Ukiah for the planned improvements and reconfiguration of the interchange, which would improve traffic conditions to acceptable conditions (as shown in Table 4.10-12) at Talmage Road/Airport Park Boulevard and Talmage Road/US .101 southbound off -ramp. This mitigation measure is included in either option A (signal or a roundabout), or option B. The mitigation measure is not feasible mitigation. The City cannot condition the issuance of building permits on the payment of a proportionate share payment if the City has no fee plan in place. The issue of building permits is ministerial. Therefore, as Caltrans suggests in comment W- 11, the approval of the Wal-Mart expansion would allow the Wal-Mart Supercenter to go forward City of Ukiah Planning & Community Development Dept November 9, 2011 Page 14 without contributing mitigation measures to the Talmage Road/Airport Park Boulevard interchange improvements. As Caltrans suggests, the approval of the Wal-Mart expansion should be delayed until the improvements needed at Talmage Road/US 101 southbound off -ramps have been identified, developed into a conceptual plan, priced, and included in a fee program. Caltrans comments that the City, is capable of implementing this remedy and therefore providing feasible mitigation for the Project's impacts. The FETR fails to answer comment W-11 and explain why it would be infeasible to delay the Project until the mitigation necessary at the Talmage Road/Airport Park Boulevard is worked out. The. EIR's response to Comment W-11 is inadequate and does not meet the requirements of CEQA. Further, the EIR fails to adopt feasible mitigation for Project impacts at the US 101/Talmage Road intersection. As pointed out in comment Q-85, and comment W-3 and W-4, that the addition of Project traffic (especially after the Costco Warehouse is added) will have a significant impact on traffic queues on the US 1.01 southbound off ramp at Talmage Road. To the extent that the south off -ramp westbound traffic backs up past the V both vehicles intending to go to the west and also intending to go to the east after exiting on the southbound off ramp will have to queue up. This will dramatically extend the traffic queues. The FEIR only answers Comment Q-85 by stating that traffic queues on the southbound off ramp are already considered a potentially significant impact. This is not an adequate response because an EIR is intended to provide information both to the public and the decision makers. The public and decision makers need information about how lengthy the queues are likely to be because the safety impacts change dramatically depending upon the length of the queues and how far the extend on to the freeway. The FEIR does not respond to comment W- 3. Comment W-3 points out that the eastbound through movement for the southbound ramp intersection is expected to experience queues beyond the storage capacity under future plus Project conditions during the PM peak hour. Caltrans points out that the off -ramps will not operate at acceptable levels of service. This comment is simply answered by stating that the southbound off - ramps will operate: at an unacceptable level of service. Comment Q-85 specifically asks for the length of the queues and the safety implications associated with longer queues. The EIR fails to respond to comment W-4. Caltrans' comment W-4 is directed to the fact that the problems at Talmage Road and the Airport Boulevard intersection will cause queuing that will block the southbound 101 off -ramp in the westbound direction. Caltrans asked whether SYNCHRO/SIM traffic modeled traffic progression through both intersections or whether the intersections were modeled independently. The FEIR fails to answer this comment. It is non- responsive and violates CEQA. It states "the study intersections were evaluated using SYNCHRO. SIM was used to determine queuing conditions." The FEIR does not respond as to whether they were modeled independently or in progression. Therefore, it is impossible for the public to understand and evaluate the data. In comment W-7, Caltrans points out that the EIR includes insufficient information to determine haw a traffic signal at the intersection of Airport Park Boulevard and Talmage Road would operate and that such a signal would likely diminish the effectiveness of a round -about. City of Ukiah Planning & Community Development Dept November 9, 2011 Page 15 Caltrans asked for a traffic progression analysis. In response to W-7, the EIR states that a traffic progression analysis is necessary, but does not have to be completed prior to certification'of the EIR: Clearly, this information is necessary to determine whether there is any feasible mitigation for the Project's impacts at the intersection of Talmage and the southbound 101 off -ramp, and the Project's potential to create unacceptable freeway queuing at the US 101 southbound ramps. In comment W-8 Caltrans points out there is a need for additional information about the round -abouts. Caltrans asked for the number of lanes, the degree of saturation, the inscribed circle diameter and the design speed. This basic information is necessary to determine whether the round -abouts will work.. Rather than providing this information, the EIR fails to provide the information, but states that the SIDRA lane geometries are available on request.. This information should be provided'in the EIR as an appendix. Further, the information should be provided in the EIR as a response to Caltrans request. In comment W-9, Caltrans points out that it is concerned about the feasibility of the round- about from a design, and constructability perspective. Caltrans sets forth four reasons why the round- about approach may not be feasible. These concerns are not answered in the response to comments. The response is conclusory and does not comply with CEQA. In comment Q-87, Mr. Dan Smith sets forth a number of reasons why the proposed round -about solution is probably not feasible and will not work. Instead of addressing the information included in the comment and providing additional information to show that the round -about solution would be feasible, the EIR simply reiterates that "the DEIR identifies three potentially feasible mitigation measures." The response to comment Q-87 is clearly non-responsive and does not include any additional. information that would show that the round -about solution or any of the alleged three potential feasible mitigation measures are in fact feasible. The EIR fails to answer both Caltrans comments and Mr. Dan Smith's comments asking for information to show that the round -about solutions could be feasible mitigation. . In the Project FEIR, the authors of the FEIR have a habit of failing to respond to comments in the manner that is prescribed by the Guidelines. In Comment W-10, Caltrans states that in order to resolve the problems at Route 101 it will be necessary to have an estimate of the cost to construct the mitigation. Caltrans offered to work cooperatively with the City to determine the preferred alternative or mitigation measure and develop a reasonable cost estimate. The authors. of the FEIR do not indicate a feasible alternative or reasonable mitigation measure will be prepared or why these steps could not be completed before certification of the EIR. The response is inadequate and violates CEQA. In comment Q-86, Mr. Dan Smith points out that it is not sufficient to point out that the Project will cause simply a significant impact on queuing lengths on the US 101 southbound off - ramp. Mr. Smith points out that the length of the queues could make a significant difference on highway safety and accidents and both the public and the decision makers need information on how great an impact the Project, with the Costco Warehouse, will have on queue lengths. Otherwise there will not be sufficient information on Project impacts to make a decision, even if the Project is approved on a statement of overriding considerations. The FEIR is non-responsive. It points out that the queuing on the US 101 southbound off -ramp is a.traffic hazard. However, it fails to address City of Ukiah Planning & Community Development Dept November 9, 2011 Page 16 Mr. Smith's point that the length of the queuing may have an impact on how serious the hazard may be. This information needs to be provided in the FEIR. The response to the comment is inadequate. The EIR's response to comment Q=89 is inadequate and does not comply with CEQA. The comment sets forth a number of inconsistencies in the traffic analysis. Even though Mr. Smith is an expert witness, the EIR fails to explain the inconsistencies and how the traffic modeling effort can be acceptable in light of the many inconsistencies. The response simply states that the SIM traffic software was used to prepare the queuing results. Further, the response states that the queuing results do not follow a logical linear computation. However, there is no explanation as to why the queuing analysis would result in illogical results. The illogical results pointed out by Mr. Smith shows that the queuing analysis is not substantial evidence and is incorrect. Finally, there is no response to Mr. Smith's comment as to why the EIR does not include an analysis of impacts in the morning AM, when the peak traffic is expected to be as high as in the PM period under cumulative conditions. Sincerely, William D. Kopper Attorney at Law . WDK/wrn enclosures Mark E. Grismer PhD PE vadose-Zone Engineering Hydrologist 7311 Occidental Road Sebastopol, CA 95472 (530) 304-5797 1 November 2011 TO: Bill Kopper JD RE: Review of Ukiah WalMart expansion FEIR Hydrology section responses As requested, I have reviewed the Hydrology and Water Quality response sections of the Ukiah WalMart Expansion FEIR with particular focus on the proposed project impacts on site hydrology, contaminant transport, and stormwater drainage. While reviewing several comments and responses, I focused on the particular responses on p. 3- 67, 3-83 and 3-84 related to stormwater runoff and treatment. They corrected the typo error in Table 2-1 and that under mitigation measures for 4.6-3. They recognize that removal of the Tire & Lube Express Center pads and sand oil filters should be done with care but only suggest that soil sampling may occur to determine if visual observations were correct; it seems to me that soil sampling and analyses below the pads should simply be required. Indeed, the drainage plans and related BMPs as guided by performance standards come back to whether or not they are actually implemented by local city, county or Regional WQCB staff through the permit process. Unfortunately, there is little opportunity for the public to intervene at this point after permits are released. While I did not demonstrate that sufficient land area was not available for the required detention storage, or proposed LID -type controls, it seems that the DEIR should in fact demonstrate that such area does exist within the project and not leave it to speculation by the reader. This set aside of stormwater treatment "area" should be estimated and included as it may affect the other more detailed assessment provided with respect to building footprint, landscaping, parking and the like. Post -project performance monitoring and evaluation of filters, bio-swales, detention storage and other such stormwater containment/treatment structures is critical and seldom completed in order to determine if in fact the DEIR performance standards are actually met (hence, my previous inclusion of the quotes from the NCHRP report from 2006). Kim Jordan, Senior Planner Planning and Community Development Department City of Ukiah 300 Seminary Avenue, Ukiah, CA 95482 cc: Charlie Stump, Planning Director cc: Mary Anne Landis, Mayor Dear Ms. Jordan, ATTACHMENT 12" 907 N Oak Street Ukiah, CA 95482 January 9, 2012 JAN 10 2012 CilyOFUK141 PLANNING DEPT I am a member of Citizens for Sustainable Commerce. On our behalf, attorney William Kopper appealed the Planning Commission's certification of the Environmental Impact Report for the Walmart expansion application. I hereby request a two-week delay in the date for the City Council's hearing of the appeal. The Traffic Engineer who is working with us has indicated that the mitigations proposed in the EIR for traffic problems at the interchange of Highway 101 and Talmage Road are all inadequate. None of these mitigations prevent the traffic problems from being significant. However, he is rendering a reconfiguration of the interchange that would likely mitigate the traffic problems identified in the EIR to less than significant. To do this thoroughly requires completing his design and then running traffic volume calculations using a specialized computer program. An extra two weeks to complete this analysis will provide the time he needs to adequately evaluate this important factor in the review of the project. Please reply to me as soon as possible regarding this request for delay. Sincere regards, Stephen Scalmanini (707) 391-5853 CXXyfes, Sit A17ACHMENT 5 Ukiah does not need a Wal -mart expansion and Wal -mart does not need Ukiah. Our planning commission made a horrendous decision in okaying this expansion. Wal -mart is owned by the Walton family. Listed as the sixth wealthiest by Forbes magazine, Christy Walton is the widow of John Walton. John died in a plane crash seven years ago. Christy is also the wealthiest woman in the U.S. Her wealth is listed at twenty-four and a half (24.5) billion. Next is Jim Walton, the ninth richest at twenty-one point one (21.1) billion. At number ten is Alice Walton at twenty point nine (20.9) billion. Last, but not least is S. Robson Walton with twenty point five (20.5) billion. The total wealth of the Walton family is over eighty-seven billion dollars. When I spend twenty dollars in Ukiah, I want it to go to someone making a living wage, not sent to Bentonville, Arkansas or China. A large number of residents in the neighborhood of Lucky are low income. Many without care will be left high and dry. Note the shopping carts left on the comer of Ford and Orchard. This council has the choice of supporting the ninety-nine percent or sending millions to the one-tenth of one percent. We also have that same choice. Ernie Olson �f JAN -9 2012 EEZS t * 10699 ANNANNNA 00000007070'MUSU07tot gr 117" Wtm 0163-I(6 6) RECONd"ED J'All 09 NIQ CITY OFUKIAH PLANNING DEPT. "I III V -L— City Council City of Ukiah 300 Seminary Avenue Ukiah, CA 95482 lit 1�hi �� i V -C /� r JAN - 9 20,12 We would like you to know that we support the appeal of the EIR submitted for the Walmart expansion project for the following reasons: To begin, we believe having the EIR prepared by a subsidiary of the Walmart Real Estate Division casts a shadow on the whole process. It is hard to imagine they would be as critical to corporation HQ's as they would any other cause. Secondly, the proposed expansion will likely cause the closure of existing stores such as FoodMax and Lucky. Other retail stores will also find it hard to compete against the giant Walmart. The City of Ukiah does not need to have multiple boarded up stores downtown and in its malls, especially with the demise of the Rural Development Agency. Also, we are concerned about the increased traffic in an already congested area. Often traffic is backed up on the Highway 101 off ramp to Talmage Road because the the left turn lane onto Airport Park Boulevard is stacked with drivers headed for the existing Walmart. We -understand the intersection of Talmage Road and Airport Park Blvd. will need to be reconfigured to accommodate the increased traffic. Who will pay for these construction costs? Please know now that we will certainly object in the future if somehow the City of Ukiah is forced to pay for this betterment. Thank you for the opportunity to comment on the current appeal of the EIR of the Walmart expansion. koyl Ron Caviglia Anne Caviglia 390 Hillcrest Avenue Ukiah, CA 95482; 1 UKIAH PLANNING COMMISSION 2 August 10, 2011 3 Minutes Excerpt 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 COMMISSIONERS PRESENT Judy Pruden, Chair Jason Brenner Linda Helland Linda Sanders Mike Whetzel ATTACHMENT q COMMISSIONERS ABSENT None STAFF PRESENT OTHERS PRESENT Charley Stump, Planning Director Listed below, Respectively Kim Jordan, Senior Planner Jennifer Faso, Associate Planner Cathy Elawadly, Recording Secretary 1. CALL TO ORDER The regular meeting of the City of Ukiah Planning Commission was called to order by Chair Pruden at 6:00 p.m. in the Council Chambers of the Ukiah Civic Center, 300 Seminary Avenue, Ukiah, California. 2. ROLL CALL 3. PLEDGE OF ALLEGIANCE - Everyone cited. 4. APPROVAL OF MINUTES — The July 13, 2011 meeting minutes are included for review and approval. The minutes from the July 27, 2011 meeting will be available for review and approval at the August 24, 2011 meeting. The following corrections were made to the July 13, 2011 minutes: Page 1, line 41, change storages to shortages. Page 5, lines 11-13, change sentence to read, `There may be a very good reason shy the landscaping approved for the Skateboard Park had to be changed, but it would be helpful to provide feedback as to why projects change.' M/S Sanders/Helland to approve July 13, 2011 minutes, as amended. Motion carried (5-0). 5. COMMENTS FROM AUDIENCE ON NON -AGENDA ITEMS — None. 6. APPEAL PROCESS — N/A 7. SITE VISIT VERIFICATION - N/A 8. VERIFICATION OF NOTICE — N/A 9B. Walmart Expansion Draft Environmental Impact Report File Nos: 09-42 EIR-PC/09-28-SDP- PC. Conduct a public hearing and take public and Commission comment on the Walmart Expansion Draft Environmental Impact Report (DEIR). The project proposes a 47,621 foot expansion of the existing 109,030 square foot store, for a total square footage of 156,651 to include expanded general merchandise floor area and expanded grocery sales floor area, indoor and outdoor garden centers, as well as the possibility of distilled alcohol sales, and a medical clinic and/or vision center on the 13.44 acre site located at 1155 Airport Park Boulevard, APN 180-070-38, in the Airport Industrial Park. Also included as part of the project is a change in store hours to 24 hours per day, seven days per week, modifications to the design of the exterior of the MINUTES OF THE PLANNING COMMISSION Page 1 August 10, 2011 I ING 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 building, the addition of new parking spaces, modifications to the landscaping, and other associated site improvements. The expansion of the store requires approval of a Major Site Development Permit. Chair Pruden: • The purpose of tonight's Planning Commission meeting is to receive public and Planning Commission comments on the adequacy of the analysis presented in the DEIR. • There is a 45 -day comment period on the DEIR which runs from July 5, 2011 through August 18, 2011 at 5:00 p.m., so it is relevant for the public to submit their comments as soon as possible. • In terms of format for tonight's meeting, recommends review of the DEIR chapter by chapter. Planning Director Stump: • The intent of tonight's meeting is to discuss the information in the DEIR and determine whether or not the document meets California Environmental Quality Act requirements for adequacy of the analysis and not whether the project should be approved or not. • Introduced Brian Grattidge of Environmental Science Associates (ESA), the City's EIR, who will give a Powerpoint presentation about the DEIR and to answer questions. Senior Planner Jordan • Noted public comment cards and a sign-up sheet to receive email/hard copy notices related to the Walmart project are available in the Council Chambers lobby. • The DEIR and DEIR appendices are on the City's website, in the Planning Department, and at the library. Introduced Brian Grattidge of ESA. Brian Grattidge, Environmental Science Associates (ESA), the City's EIR consultant, addressed the adequacy of the analysis for the DEIR and provided an overview of the EIR process, discussed the steps completed to date as part of the process for the Walmart EIR, as well as identified the next steps in the process with regard to the following relevant topics: Background • Application submitted for expansion of existing store in 2009 • Notice of Preparation — March 11, 2010 • Scoping Meeting held March 18, 2010 • Scoping Report to Commission presented June 9, 2010 • Draft EIR published July 5, 2011 • Review Period ends August 18, 2011 The proposed project: • Expansion and alteration of the existing 109,030 sf Walmart store. • The EIR analyzes a maximum project of 161,350 sf (current proposed plan is 156651 sf) • Project components include: - 24-hour operation from current 7 a.m. to 11 p.m. - Expansion of the grocery and general merchandise sales - Additional ancillary area (including tenant space) - Update o the building exterior and signage - Inclusion of energy saving features - Expansion of the parking lot from 567 to 612 spaces - Landscaping modifications: shade tree replacement, new tree planters, less turf - Potential inclusion of a vision care center and/or limited -service medical clinic - Potential distilled spirit sales - Eliminates Tire Lube Express Scope of the EIR: • Aesthetics • Air Quality MINUTES OF THE PLANNING COMMISSION Page 2 August 10, 2011 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 • Urban Decay • Geology & Soils • Hazards and Hazardous Materials • Hydrology & Water Quality • Land Use • Noise • Public Services & Utilities • Transportation & Traffic • Global Climate Change • Biological Resources Potentially Significant Impacts: • Geology and Soils • Hazards and Hazardous Materials • Hydrology and Water Quality • Noise • Traffic • Biological Resources Less than Significant Impacts: • Urban Decay • Global Climate Change Project Alternatives: • No project • Reduced Project Size Alternative • No Footprint Expansion Alternative • Other alternatives considered: Two story alternative, alternative location Next Steps: • DEIR review period closes August 8, 2011 at 5:00 p.m. • Comments evaluated and written responses prepared • Final EIR prepared prior to project hearing PUBLIC COMMENT PERIOD OPENED: 7:44 p.m. CHAPTER 1: INTRODUCTION No comments. CHAPTER 2: SUMMARY Steve Scalmanini: Page 2-13, Questioned `Impact 4.9-9: The Project would not make a cumulatively considerable contribution to public services and utilities impacts associated with cumulative development in the Project vicinity.' What does this mean? Chair Pruden: Stated Chapter 2 is a summary of impacts and mitigation measures and asked if impact 4.9-9 can be flagged for later discussion within the context in the chapter associated with this impact. Commissioner Helland: • Page 2-4, Mitigation Measure 4.1-2: How do LEED Goals and Green Globes lighting criteria compare with International Dark Sky Association (ISA)? The City typically uses ISA as the standard. MINUTES OF THE PLANNING COMMISSION Page 3 August 10, 2011 1 • Page 2-4, Impact 4.2-1: Under `mitigations,' in addition to `none required,' clarify that the 2 Mendocino County Air Quality Management District has rule F-430 with which the project must 3 comply that will further reduce fugitive dust emissions. 4 • Page 2-9, Impact 4.6-1, somehow clarify that there would be a less than significant impact and no 5 mitigations would be required after complying with required permits, plans and regulations. 6 • Page 2-13, Mitigation Measure 4.10-2: Options A & B: Where are they described (reference to 7 page or section)? Also states, `The improvement planned by the City of Ukiah at Talmage 8 Road/Airport Park Boulevard described in Future Transportation Improvements, above' would 9 need to be implemented in addition to Mitigation Measure 4.10-2, but there is no such description 10 above. 11 Page 2-14, Mitigation Measure 4.10-3c: Can right-of-way be taken from the sidewalk and 12 landscaped area for a Class II bike lane? Or, can the Right-of-way along Airport Park Boulevard 13 between Talmage Road and Commerce be used to install a Class I shared -use path by widening 14 the existing sidewalks? Or, can property owners be asked to deed sufficient right-of-way to put 15 Class II bike lane on street? Applicant will put in new sidewalks on Airport Park Boulevard and 16 Commerce Drive anyway. 17 18 CHAPTER 3: PROJECT DESCRIPTION 19 20 Chair Pruden: Requested clarification regarding the expansion of the parking lot from 567 to 612 spaces 21 provided for in the Powerpoint document and noted section 3.1 of DEIR document uses a different 22 number of 584 to 640 spaces. 23 24 Brian Grattidge: The difference is up to 28 of those spaces will be occupied by the cart corrals or other 25 things. 567 usable spaces have been identified. The rest have been taken out by cart corrals or other 26 things. 584 spaces is the number of spaces the site has, but usable number of spaces is the 567. 27 28 Chair Pruden: Have the parking spaces been accounted for that are blocked out for the garden 29 department with fertilizers, potting soil etc., that are existing behind the chain link fence on the south end 30 of the parking lot? The correct number of spaces and number of spaces available need to be clarified. 31 32 Commissioner Whetzel: Section 3.2.1 — In 1995 the City certified a Program EIR for the buildout of the 33 remaining Redwood Business Park area. The City adopted a Capital Improvement Program (Traffic 34 Impact Fee) in 1997 to pay for street and intersection improvements that would be needed as buildout 35 occurred. The program was updated in 1999. Is the program still active? 36 37 Planning Director Stump: The City has been collecting money ever since the Traffic Improvement 38 Program began. 39 40 Commissioner Sanders: How much is in the account? 41 42 Planning Director Stump: Does not have this figure available tonight, but can obtain the information. 43 44 Commissioner Helland: Page 3-3, section 3.2.1 Project Background, What does the CIP (traffic impact 45 fee) pay for? Could it contribute to adding Class II bike lane on Airport Park Boulevard? Or, creating 46 Class I with signage having shared use trail in sidewalk right-of-way? 47 48 Planning Director Stump: 49 • When the Traffic Improvement Program began, specific projects had to be identified for which the 50 money would be spent. Some of these projects have been completed while others have not. 51 • The money continues to accumulate. 52 • If the Walmart expansion is approved, the City may choose to amend the CIP to incorporate 53 additional improvements. 54 MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 4 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Chair Pruden: Did the CIP (traffic impact fee) originate as a result of the adopted Airport Industrial fll...-.-�-1 Development ll..-1: /AIf1 1'1 �'1\ L L_ lA/_I.v _..a -1 L_ .-:—n Planned Development Ordinance (AIP-ruJ or when the existing vvalmarr store was approved by the t-,nyr Planning Director Stump: The Program came as a result of the 1995 Program EIR for the buildout of the remaining Redwood Business Park. Chair Pruden: Would projects that were already developed in the AIP-PD prior to the creation of 1995 Program EIR have to pay more? Planning Director Stump: All development since adoption of the ordinance establishing the Program has paid a fee to help pay for traffic impacts resulting from the development. Projects developed prior to adoption were not subject to the fee. Commissioner Whetzel: Page 3-2, Figure 3-1, map is inaccurate. Betty Street now extends through and intersects with Talmage Road. This was changed when the original Walmart store was approved in 1992. Chair Pruden: There have been name changes to some of the streets in this area. Don Flager: • Is retired from Caltrans. Has consideration been given for other alternative off -ramp improvements going south to help alleviate traffic congestion in the area of Talmage Road and Airport Park Boulevard? • An entirely new interchange would be required for an off -ramp going north. Chair Pruden: The EIR document does talk about a ramp in the southerly direction basically where Jack- in-the-Box is located behind Walmart as a possible route change. Virginia Renolds: It is her understanding funds can be taken out of existing projects pending street/intersection improvements for the Walmart project or is Walmart required to pay additional money in this regard? Chair Pruden: Staff has indicated the CIP is not fully funded. Planning Director Stump: • If this project is approved, Walmart will be required to pay their fair share of improvements needed for new traffic impacts their project would cause. • No funding from projects from around the City earmarked for traffic or streets would be used for the Walmart project. Virginia Renolds: Who decides on the fair share of traffic impact fees Walmart must pay? Planning Director Stump: The Ukiah City Council decides the amount of traffic impact fees Walmart must pay for the expansion project. Don Larsen: Questioned why Orchard Avenue cannot be a straight shot to Airport Park Boulevard as opposed to having to go through neighborhoods as this will impact them to get to Walmart. Commissioner Whetzel: This is likely a discussion for the traffic section. Commissioner Helland: Page 3-5, Project Objectives: Bullet 7, `Develop a state-of-the-art retail facility that serves local residents and visitors with essential goods and services in a safe and secure 24-hour, seven days a week, shopping environment' and Bullet 8, "Improve the building sustainability through implementing more efficient energy management practices, designs and equipment,' would entail compliance with the AIP-PD guidelines of providing at least 20% of the site area in landscaping or it will not be consistent with zoning ordinance relative to Bullet 10, that states `Design a project that is consistent with the City's General Plan and Zoning Ordinance.' MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 5 I G lifldif Pruden: Page 3-3, AUfroUnUlllLand uses, InIUIfIIdl1UI1 Is not entirely d(;(:Urale or I$ incoiTpleie. 3 There is no mention of Savings Bank of Mendocino County, the mini -mart across the street from the bank 4 or car wash. The description is very general. 5 6 Mary Anne Miller: Page 3-5, section 3.3 Description of the Project and 3.3.1 Project Objective: These 7 are very important because CEQA requires most of the project objectives be satisfied in the final decision 8 on the project. The objectives are `very nice' and are everyone's objectives. The project objectives can be 9 met with the proposed project alternatives as well. 10 11 Steve Scalmanini: Page 3-5, section 3.3 Description of the Project and 3.3.1 Project Objectives: Bullet 12 1: Provide a commercial development that results in a net fiscal benefit to the City by providing new sales 13 tax revenue and increasing property tax revenues. What about the County? 14 15 Chair Pruden: Possibly add language that tax revenue sharing is an important component in our 16 community. 17 18 Steve Scalmanini: 19 • While the proposed project can result in a net fiscal benefit to the City, what about the potential 20 fiscal debt to the County by having to pay the medical costs of employees who do not have health 21 insurance. 22 • Bullet 2: Provide a commercial development that can be adequately be served by existing public 23 services and utilities. Is to assume that additional public services will be required? It is his 24 understanding that additional public services are required for 24-hour Walmarts. 25 26 Chair Pruden: Is concerned about having Walmart open 24 hours and will comment about this issue 27 later. 28 29 Steve Scalmanini: 30 • The project objective talks about a commercial development that can adequately be served by 31 existing public service, but what about the possible need for future public service and whether or 32 not this is possible. 33 • Bullet 3: Provide commercial development that creates new jobs for City residents. What about 34 other residents or persons residing outside of the County such as in Willits? Objective talks about 35 new jobs' what about `net new jobsT Is not sure if the net number of jobs will be positive or 36 negative and this information should be reflected in the EIR. How will new jobs for City residents 37 be measured and will this be a part of the mitigation monitoring plan? Need the number of full 38 time equivalent jobs. 39 • Bullet 5: Expand and provide new retail options in close proximity to local consumers by providing 40 daytime and night-time shopping opportunities in a safe and secure environment. Define `close 41 proximity' and does this mean surrounding neighborhoods in the vicinity of the site. There is a 42 neighborhood located to the north of the project site. 43 • Bullet 6: Enhance the commercial retail offerings in the City of Ukiah. How will this be measured? 44 45 • Bullet 8: Improve the building sustainability through implementing more efficient energy 46 management practices, designs and equipment. Does this objective apply only to new 47 construction or to the existing building? 48 • Bullet 11: Provide sufficient off-street parking to minimize impacts to the surrounding residential 49 neighborhood, and ensure that adequate on-site parking is provided for store customers and 50 employees. Is not aware this is an issue. Believes there is a sign on Airport Park Boulevard that 51 prevents traffic from entering the surrounding residential neighborhood. 52 53 Alan Nicholson: 54 0 Regarding jobs, the assumption that Walmart creates jobs does not add up. It is documented in 55 many studies nationwide that for every less than living wage Walmart adds, we lose 1.8 living MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 6 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 wage jobs. Replacing living wage jobs with low-wage jobs is an excellent way to continue 1. L a4 Imo... II.. rt-- a L.:.dive a 11 a the do 1 new ' 4 ` sluggish economic growth hvt:aty. IIIC prU—JUUL VvjcLA1VU Lahh{s abviii L11 creation oI IICVV JUUO 1U1 the Walmart expansion and is of the opinion the EIR does not reflect adequately studying the impacts of this job creation. The tax revenue for groceries and related items is not going to offset the decline in other groceries and the decline in living wage jobs in the community. If the project closes some significant anchor grocery stores in the community, this will impact lesser stores creating a domino effect. The Walmart expansion will clearly be a net loss to Ukiah and certainly not representative of any kind of net gain like that reflected in the EIR. Rather than bring stability, this project will have very long term destabilizing consequences. Chair Pruden: The Tire and Lube Express will close. The question is what will happen to these employees. Will these employees be offered a job in another department. Commissioner Helland: • Page 3-11, #6, Food Displays: typographical error, should read, `the building will include a film on the freezer doors that combats condensation and requires no energy, unlike heating systems that are typically used to combat condensation. • Page 3-13, Landscaping Modifications, provide for ADA compliant facilities. Narrative does not talk about ADA compliant facilities in parking areas. Gene Hoggren: • Has traveled extensively in the US and usually stays overnight in Walmart parking lots. • There are many 24-hour Walmart stores around the country and has observed that many small retail establishments are lost as a result. • Walmart is in financial position to lower or raise prices at -will until all their competition no longer exists. • His wife worked as a cashier in Walmart for 10 years and is familiar with their corporate policy. Walmart can raise or lower the price of any item sold in the store. Smaller stores cannot compete with Walmart. • Unlike Safeway or Lucky, Walmart is non-union. • Allowing for a 24-hour Walmart is a mistake because all of the small local convenience stores should be allowed six or eight hours during the 24-hour period to do business. • Allowing Walmart the advantage of operating 24 hours will bring about a big change to Ukiah. Chair Pruden: Mr. Hoggren did not comment on the EIR, he provided information about Walmart. Rex Cipher: Wondering what is wrong with competition? This is called capitalism. Steve Scalmanini: • Page 3-13, Lighting Modifications, `The lights in the parking lot will be modified to provide adequate lighting levels. Questioned is existing lighting adequate in the first place? • Page 3-15, Security Measures, 1. Conduct a risk analysis (crime survey) of the area to evaluate the security needs for the store and implement a security plan based upon this analysis. Why is this aspect not part of the EIR? 2. As appropriate based upon the crime survey, establish a parking lot patrol that assists customers, ensures safety and takes action to identify and prevent any suspicious activity (such as loitering and vandalism) both during the day and nighttime hours; and a plain clothes patrol inside the store to ensure safety and security. What is the legal definition of `appropriate.' Why does Walmart not have an existing parking lot patrol? 3. Install closed-circuit camera systems (surveillance cameras) inside and outside the store. Why are these not existing? 4. Establish a Risk Control Team, which is a team of associates responsible for and trained to identify and correct safety and security issues at the site, including inside the store. Why are these safety precautions measures not already existing? 5. Provide lighting in the parking areas that will ensure public safety (See Lighting Modifications, above). If lighting ensures public safety, we would not need a police department. MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Commissioner Brenner: There appears not to be enough information in the project description. With the questions raised above, it may be beneficial to give reference in the project description where these types of questions can be addressed and this would facilitate reading of the EIR document. Steve Scalmanini: Page 3-16, Hours of Operation Modifications, `The proposed change in square footage and hours would add approximately 85 new positions.' It does not indicate how many of these positions are full-time. Will these positions be minimal time? What is the number in full time equivalents? Chair Pruden: More information is necessary in the EIR document about the 85 new positions and the elimination of the Tire and Lube Express department. Steve Scalmanini: Page 3-18, section 3.4 Regulatory Requirements, Permits, and Approvals, `The principal discretionary permits and approvals for the Project will be granted by the City of Ukiah. Questioned, `will be granted' thought permits and approvals are being `considered' by the City. Is under the impression the permits and approvals are not guaranteed by the City. CHAPTER 4: SECTION 4.1 AESTHETICS Chair Pruden: • Section 4.1 discusses aesthetics which addresses the environmental setting and describes where the project is located and what surrounds it. It mentions scenic roadways, scenic vistas known as `viewsheds,' and light and glare. • Page 4.1-5, Scenic Vistas, `The project site is located in a developed commercial and industrial area of Ukiah. No scenic vistas are located within or adjacent to the Project site; however, in the distance to the east and west, hills provide background to area views.' The wording of the information is misleading. While the information is generally correct, disagrees that no scenic vistas are located within the project site because the east and west hills can be seen from the site and do offer an extraordinary `viewshed.' Viewshed is the term Ukiah uses in documents in place of scenic vistas. Disagrees with the reference of scenic vistas as used in the context for this project because the `scenic vistas' do not occur on site but rather in the east and west hills. Scenic Vistas are integral to how the project is developed. • Section 4.2 discusses Air Quality with regard to physical setting, local setting to include an Air Quality Data Summary table for the project area. This section also addresses regulatory Setting and Application Air Quality Regulations with comparison to local rules, impacts/impact analysis and mitigation measures Joan Griswald: In her opinion, there will be a higher percentage of businesses being siphoned from as a result of this new business. Ike Heinz: From an aesthetic standpoint, is it possible instead of expanding the parking lot to have parking underneath the building? In this way trees and landscaping would be maintained on the site as well as have room to add more trees. There would be much less heat generated from the parking lot with landscaping and less runoff from the pavement/asphalt during the winter. Carrie Hartman: • Has a comment about every section of the EIR and will submit her comments in writing. • It would be helpful if the document were put on the Powerpoint screen to better understand the discussions and stay on topic. Steve Scalmanini: Page 4.1-10,Mitigation Measures, `The project applicant will be required to prepare a photometric plan demonstrating that lighting will not spill over onto adjacent properties.' Why is the plan not part of the EIR. MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 8 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Commissioner Helland: Page 4.1-9, Impact 4.1-2, Mitigation Measure 4.1-2, `Fixtures shall be full cut - oil and night—Lime riri:e_ dly , consistent with Lrry goals and Gree_ Globes criteria aiu- light pollution reduction.' The City tends to use International Dark Sky Association applications and would like the criteria and how they differ from the International Dark Sky Association. Commissioner Whetzel: Many of the questions raised by Mr. Scalmanini will be examined at the permitting process. Chair Pruden: Some of the questions/comments raised by Mr. Scalmanini require clarification in the EIR document and some concerns will be answered along the process. CHAPTER 4: SECTION 4.2 AIR QUALITY Mira G.: • Referred to Section 4.2.2, pages 4.2-2 that states, Mendocino County Air Quality Management District (MCAQMD) maintains several monitoring stations in the Project vicinity that monitor air quality and compliance with associated ambient standards. The closest station to the Project site is the East Gobbi Street Monitoring Station approximately a half mile away. The pollutants monitored at this station are ozone and carbon monoxide. The Ukiah County Library Monitoring Station is located approximately 1 mile away was used to collect data for particulate matter less than ten microns and particulate matter less than 2.5 microns. The most recent published data for ozone and particulates at the East Gobbi State and Ukiah County Library Monitoring Stations are presented in Table 4.2-1. Respirable particulate matter PM10 and PM2.5 that consist of particulate matter that is 10 microns or less in diameter and 2.5 microns or less in diameter are not measured every day. • Questioned the statistical data and methodology for collection of greenhouse gas inventory (GHG) provided in the criteria Table 4.2-1 on page 4.2-2 concerning the measurement of ozone particulates and carbon monoxide particulates and whether these greenhouse gas emissions are adequately monitored because the Greenhouse Gas (GHG) inventory impacts are global. It appears carbon monoxide is not well monitored. Data indicates an increase in ozone since 2007 to 2009. This is worrisome. Greenhouse gases should be monitored particularly with the claim that these gases need to be reduced. The City needs to take measures to reduce these gases and not adequately measuring them is not a good idea. • Important to have the 2010 data as part of the table. • It is important the purpose of the table and data are understood. The report does state the Project will generate greenhouse gases that may have significant impacts on the environment or conflict with an applicable plan, policy or regulation adopted to reduce greenhouse gas emissions so the overall task is not how much we allow to happen, but the overall task is the need to reduce greenhouse gases. Chair Pruden: If there are no numbers in the table does this mean the local monitoring agency is not monitoring that or they were not available for this report? Brian Grattidge: That is correct. The stations at the County Library and Gobbi Street only monitor ozone and carbon monoxide. Regarding the comment that carbon monoxide is not well monitored what was done was to use statistical models to estimate the level of carbon monoxide. This is true in Ukiah, California, the US and the world. Carbon monoxide is not monitored as closely as to what we call criteria air pollutants which is what you see on Table 4.2-1. It is a good point in that greenhouse gases are modeled in a manner similar to air quality and in some EIR's you will see that combined. More frequently you will see GHG and climate change separated as a topic and it is just for purposes of discussion but it is part of the emissions issue. In this case, the Table is basically the criteria pollutants. Then we also look at toxic air contaminants (TACs) and potential health risks relating to those and separately look at greenhouse gases, carbon monoxide and other GHGs that are there and calculate the CO2_ Hopefully this helps explain what to look for in the table. MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 9 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Chair Pruden: In terms of modeling even if you do not have good figures locally does not mean this invalidates the section so the best effort Is made or does testing have to be done. Brian Grattidge: There are different methodologies and as he understands it, the City and County actually are embarking on a project that is called a GHG Inventory. This presents an interesting issue to analyze within the confines of an EIR because we are looking at a local project and a local impact that is basically analyzed at an air shed or even a state or national level but the area of impact that you are looking at is basically global. So what occurs is to look at the current and future conditions of a project and try to tie that to the state's goal for reduction that is basically spelled out in A1332. This occurs in the absence of a Local Climate Action Plan so in the future if you have a project of this sort it comes back and through these joint City/County efforts by way of a Local Climate Action Plan that provides for more sources of information. So what we are doing in the EIR is providing the best available sources until those future efforts are completed. Commissioner Sanders: Requested a statement be made to this effect in the EIR in that the table is inadequate to the issue of adequately monitoring greenhouse gases raised by the public member. Brian Grattidge: Additional information can be added to this that the monitoring that is done basically by the Air District is for a different purpose. Commissioner Sanders: I think this is very important. Commissioner Helland: Page 4.2-3 to 4.2-4, At bottom of each description of the Criteria Air Pollutants, note whether the region is in attainment of state and federal standards as was done for SO2. Also discuss why not in attainment and the implications of this for the project. Public Member: The PM10 data should be found at the County library if this information is locally monitored. Chair Pruden: We will check on this information and see. Commissioner Helland: • Page 4.2-13, BAAQMD CEQA Air Quality Guidelines which must be met, Items #2 and #3, read `The Project traffic would not increase traffic volumes at affected intersection to more than 44,000 vehicles per hour (in #2) and to more than 24,000 vehicles per hour ... (in #3). It does not say `by.' more than 44,000 vehicles per hour ... This suggests that the analysis must take into account not only the proposed increase in traffic volumes as done below on the same page, but must add proposed increase to the existing volume to get the total. What is the existing traffic volume plus the project traffic volume at affected intersections? In Appendix C dealing with the Air Quality analysis I saw the URBEMIS reports, but I did not see reports of the AERMOD model, nor the guidelines by California Office of Environmental Health Hazards Assessment (OEHHA). Nor did I see `additional information on the limitations and conservative nature of the models and techniques within a Health Risk Assessment' as stated in footnote 6 on page 4.2-15. CHAPTER 4: SECTION 4.3 URBAN DECAY Chair Pruden: • Section 4.3 discusses Urban Decay within the project market area taking into consideration the retail market characterization, identifies major commercial areas in and near Ukiah, addresses the regulatory setting, impacts/impact analysis and mitigation measures/methodology, study tasks and resources, provides for a table that includes information concerning maximum sales impacts from the proposed project in 2013, cumulative impacts and other relative data and information. Joan Griswald: Page 4.3-15, asked about urban blight. If the total revenue for the new store is $20.4 million of which $12.2 million will be diverted/siphoned from existing food stores businesses what about MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 the remaining $9.2 million and what areas will this impact. Statistically speaking, the numbers represented are not good for the community and `will likely result In business closures and corresponding urban blight that will occur from unoccupied buildings. Chair Pruden: Asked if the concern is the statistics are too low and inadequately represent the true impact. Jeffrey Blankford: • During the March scoping session last year for the Walmart expansion project urban decay was of concern and appreciates this is covered in the EIR. Unfortunately, the information is out of date. • The Powerpoint presentation regarding Urban Decay indicates the `Market is relatively strong.' • Anyone paying attention to the American economy can understand that the data in the EIR is based on older data because the economy has gone down tremendously all around the country with business foreclosures/home foreclosures and so on. • Finds a lot of problems with the analysis. • The report mentions that Walmart's expected income will be $21.6 million of which $12.2 million or more will come from existing businesses or markets. The report also suggests that four markets, Food Max, Lucky's, Raley's and the Grocery Outlet will be impacted. • The report states most of these stores appear to be performing well enough to adapt to the new competition according to the sales performance by CBRE Consulting, 2010. Where is the data? The data is insufficient. • In particular Food Max may face the largest individual impact due to its proximity to the project and its discount orientation but the store's existing sales volumes suggest it will be able to compete effectively when the Walmart space opens. • This reflects to me a total failure not only to understand the present economy which was not included in the analysis, but the history of Walmart as a retailer across the country. • Walmart can lower its prices to the point where Food Max, which is a discount store, will not be able to compete and stay open. • The idea as suggested in the report is in the Food Max shopping center and in Pear Tree Center where Lucky's is located, which is the same owner by -the -way, that if these retail establishments do go out of business and that is the way it goes it is likely these stores will not be re -tenanted rather soon. The reality is in this current economic situation and with every economic expert predicts the economy will get a lot worse, the likelihood that these stores would be re -tenanted is not very great. • Under the circumstances the EIR statement dealing with urban decay does not deal with economic realty of the present situation. • We also know that Walmart tends to pay less in wages and provides no health care benefits. Whenever there are employees with these types of wages and lack of benefits adds to the community to those who are laid off many of which might be homeowners would not likely be able to pay their mortgages that results in home foreclosures. • California is one of the leading states in home foreclosures. • The overall impact of the Walmart project to gratify its `greed' to the detriment of the welfare and the urban setting of this City is simply something the Planning Commission needs to consider in overall decision to be made. • This particular section needs to be re -done in order to use economic data that is relatively current and not the data used to produce this report. Raging Grannies of Ukiah commented on Urban Decay and performed a song entitled 'Walmart:' `Last night I had the strangest dream about the Walmart store, I dreamed it grew beyond its walls and thru the Food Max door. Then it turned the corner and went north on 101 when it got to the Lucky store those union jobs were done. And soon we all will have fresh food shipped in from China's farms and all your health and vision needs will be safe in Walmart's arms. They'll be no need for Friedman's now or Oak Valley Nursery the Walmart octopus will soon be competition free. The Walmart octopus is here to shut MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 11 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 down local shops if you have a problem now call the Walmart cops. Come buy your cradle and your valve 2_.. .._ heart here'_ 1__i,_ lett L_ l_ 'VVal. ' grave, a pig valve i�r y�i,ir heart, there's just Dile store that's reit ill town the super galactic vvaiftiart. They find it offensive that this is a lesser environmental impact report. Concerned with the jobs lost to other retail establishments when all this income goes to Walmart. The people working for Walmart cannot afford private health care because Walmart does not pay health care benefits. We, the taxpayers, will pay for this when such employees have to go to the emergency room. This is unacceptable and especially in this economy. Request the Commission consider this issue closely. Gene Hoggren: Has witnessed all around the country that Walmart can at -will reduce hours to avoid having to pay their employees for full-time work or to avoid paying health care costs. There is no union representation for Walmart employees. This is Walmart's department policy and this company does this sort of thing all over the country. Chair Pruden: Is the definition of urban decay the physical deterioration of a particular piece of real estate. Theoretically speaking, if a vacant building is maintained this is not considered urban decay and constitutes just a vacant building. Brian Grattidge: This is correct, it is just the physical deterioration. Steve Scalmanini: Inquired about the mention in the document of having possible vision care and a medical clinic in the Walmart store and while he did not see this in the document. Will this cover Walmart employees? Jeffery Blankford: • With regard to re -tenanting, for at least seven or eight years there has been a very large vacant commercial space behind the County Courthouse with no prospect for a new tenant. The idea that a corner building not having a tenant after a long period time brings about the concern and problem of what to do about vacant buildings that have gone out of business. • Because of the introduction of Home Depot, the last of the hardware stores, Ukiah Valley Lumber, went out of business. There appears to be no one interested in taking over this business. • Having lived in San Francisco and seeing vacant buildings that after a while the business owners no long care for become urban decay. The same can occur in Ukiah with vacant buildings for businesses that are no longer operating and the concern these building will deteriorate and be vandalized thus alluding to urban decay. • In reality and in this economy, what is the likelihood vacant buildings will be re -tenanted. Chair Pruden: Section 4.3.2, provides the boundaries of the market area that was determined to be just north of Cloverdale. The figure is conservative and questioned the origin. It has been our experience that Ukiah has a considerable market coming from Cloverdale to shop, but is not in possession of the zip code information to say exactly how many people are coming from Cloverdale. The information provided by CBRE Consulting, 2010 with regard to Cloverdale as a market area does not appear to be entirely correct. Accordingly, to say `just north of Cloverdale' does not seem accurate. The boundary likely extends to Cloverdale rather than just north of it. While it may be cross-referenced in another place in the document, recommends looking at this information. She did not find such information in the appendix portion of the document. There is so much material in the document that she may have overlooked this aspect. Mira G.: • The $12.9 million income drawn from other businesses extends to other areas, including Cloverdale. The draw area essentially continues until it reaches another Walmart market area. Walmart stores are often more detrimental to communities that do not house/host one partly because Walmart will draw a certain amount of traffic to a location. Walmart draws sales from other businesses. For a County seat having a Walmart that draws sales from commercial retail MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 12 1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 establishments in Ukiah and in other market areas that include Sonoma and Lake Counties is not a good thing. • Does not support milking communities dry of their resources for Walmart's gain. Mary Anne Miller: • Page 4.3-19, Cumulative impacts reference the year 2013 in the document which is the first full year of operation for the expansion project. Questioned the cumulative impacts in 2013 and the model being used for the transportation impacts, which has a future date of 2030. Please explain why the use of a transportation model which was developed for the UVAP Study, which may be a perfectly good model but how is this model useful for the year 2013 when the effects of the transportation impacts would be apparent. We will see the effects of the transportation impacts in 2013 for the expansion project. • Page 4.3-15, with regard to the proposed project impacts expected to divert $12.2 million from other food stores within the market area and the remaining impacts among general merchandise/apparel of $4.8 million and other retail of $3.4 million that would be lost in revenue for a grand total of $20.4 million not $12.2 million. • Continues to be amazed at the way marijuana sales are factored into people's income. Page 4.3- 14, recapture of existing sales leakage, states, `one potential source of demand for the expanded Walmart is the share of local residents shopping currently occurs outside the market area. Estimating the extent of any such current sales leakage is difficult for the market likely due to under -reporting of residents' actual incomes. For example, an economic study prepared for Mendocino County in 2007 indicates that area household income figures may be as much as 10 to 22 percent higher than demographic estimates due to marijuana cultivation, which is reportedly common. The range translates into an approximate increase of between $6,000 and $12,800 in annual per household income based on the market area average of $58,570 in 2009.' A retail demand, sales attraction and spending leakage study prepared by CBRE Consulting indicates that almost all retail categories attract sales (i.e. to generate spending in excess of the assumed market area household demand). The analysis is based on area income estimates that are likely to be lower than actual household incomes, which would lead to an under -estimate of market area demand. A leakage study cannot be prepared because the extent of reported income is not realistic due to the fact that reported income does not include marijuana profits. Commissioner Whetzel: That study was prepared by the County. Mary Anne Miller: County or no, it says household incomes may be higher than demographic estimates by 10 to 22 percent due to unreported income from marijuana cultivation. This range translates into an approximate increase of between $6,000 and $12,800 in annual per household income. Questions whether these income figures are accurate. Commissioner Whetzel The figures represent an average. Chair Pruden: Mary Anne Miller is essentially questioning the facts. It may very well not be a fact, but rather an estimate even though it is a County study. Charley Vaughn: • Pays his taxes and does not shop at Walmart. • Addressed the issue of urban decay and this is one of biggest factors Walmart causes. • In his opinion, Walmart is destroying the local economy and given the economy today is helping to destroy our middle class. • Walmart is the largest retail employer in the nation and has the largest number of employees who do not have health care benefits. They keep their employees `under the line' so they will not get their employee benefit package. This is how Walmart provides us with these wonderful low prices. They claim to be helping the economy with these wonderful low prices. Walmart encourages its employees to get food stamps and how to use some of the government services that are available. This is about government subsidy for an operation like Walmart. MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 13 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 We have to stop supporting these people. We have to stop inviting them into our community and definitely do not allow them to expand. If Walmart were to pay a living wage to all of its employees and equal pay to woman, there would not be the wonderful Walmart low prices and would not be expanding at the rate they are. We need to pay attention. We need to say `no.' Chair Pruden: • Page 4.3-7, 2nd paragraph, left out Staples and Lazy Boy. • The report has one very small sentence about the Downtown. • There are about three sentences about the Palace Hotel and she is not sure why. • There is no mention that Ukiah is the County seat. One of the major businesses in the Downtown is the Courthouse. • There are no numbers about the number of businesses and/or employers in the Downtown. • Less needs to be said about the Palace Hotel. It is empty. It is identified as a blighted area for redevelopment. • The Downtown is underwritten as it functions as a shopping node. Commissioner Helland: • According to page 4.3-9 of the EIR, Where economic or social effects of a proposed project will directly or indirectly lead to an adverse physical change in the environment, then CEQA requires disclosure of the resulting physical impacts.' On the same page, urban decay is defined as `physical deterioration that is so prevalent and substantial it impairs the proper utilization of affected real estate, or the health, safety and welfare of the surrounding community.' The DEIR acknowledges the real possibility that Grocery Outlet and Lucky's supermarket in the north end of Ukiah may go out of business. Losing access to groceries, particularly at Lucky's to which many residents of nearby affordable housing complexes can walk, is a physical impact. Studies show that on average, people who live in proximity to grocery stores consume more fruits and vegetable which leads to better health. The possible adverse health effects on people of the potential loss of Grocery Outlet and Lucky's supermarket make this physical change significant. Please address it in the final EIR. • Page 4.3-12 of the EIR states `In accordance with CEQA Guidelines, a project's economic impacts on a community are only considered significant if they lead to adverse physical change in the environment.' The EIR fails to mention the role of social and economic factors in determining the significance of environmental impacts. According to the CEQA Guidelines Article 5 Section 15064: Where a physical change is caused by economic or social effects of a project, the physical change may be regarded as a significant effect in the same manner as any other physical change resulting from the project. Alternatively, economic and social effects of a physical change may be used to determine that the physical change is a significant effect on the environment. If the physical change causes adverse economic or social effects on people, those adverse effects may be used as a factor in determining whether the physical change is significant. For example, if a project would cause overcrowding of a public facility and the overcrowding causes and adverse effect on people, the overcrowding would be regarded as a significant effect. Chair Pruden: Page 4.3-13, table 4.3-3: Table indicates the indoor garden center has zero square footage. In the spring and summer there is space used as a garden center and this same space will be full of Christmas items, including Christmas Trees in the fall/winter. Requested clarification if this area is not used year around is it not considered an indoor garden center? Apparently, areas that are changed seasonally are viewed as a general retail area. Commissioner Helland: Page 4.3-15, Table 4.3-5: It appears from the table that all or 100% of new sales at the expanded Walmart are expected to be diverted from existing retailers. If so, please state. MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 14 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 tion of Chair Pruden: rage t.o-ia, VVI ting VV It have a ucn iv^iiipoi�enL. Iiicic is no iiienuvII Ul competition about other delis in the area. It is quite common in the super Walmarts to have a bakery component. There is no mention of competition to our local bakeries of which we have several, anything from donut shops to sophisticated pastry and baking products. Bill Durham: • Works and shops in Ukiah. • Walmart pays really low wages. • Not only being the largest retailer in the country, they are the retailer with the largest percentage of employees on public assistance and this public assistance constitutes a public subsidy or subsidy under wages. I believe this is despicable. Chair Pruden: Should we be talking about wage structures or is this component not appropriate to be talked about in the EIR. Brian Grattidge: Wage structure and jobs in general within the context of an EIR are very narrow. So the short answer is `no.' The way jobs typically come into play in an EIR is looking at potential changes in housing stock. For example, if you have a very large employer coming into an area, is there sufficient housing stock to absorb those employees. In terms of the type or quality of the jobs or the benefits that would be associated with the jobs or replacement of the jobs that may very well be an economic factor related to the project that the Planning Commission considers, but it is not within the confines of an EIR. Chair Pruden: Inquired about the 85 new employees anticipated and with an approximate 12% unemployment rate is not going to get a net increase in housing stock, but simply going to get unemployed people. Or again, we have to look at the statistics for people in the `auto end.' Does not know how it works with the factoring in of the 85 new employees. This may be something we need to take a look at. Brian Grattidge: • Page 4.2-15, Table 4.3-5, confirmed the total potential sales is $20.4 million. The focus on the $12.2 was because the urban and decay analysis indicates that the grocery stores are the ones that will take the biggest hit in terms of the existing store that will expand from about 700 sq.ft. of groceries, which is less than 711 s to basically a full service grocery. While Walmart does propose to increase its overall square footage for general merchandise and other retail areas, it will lose the Tire and Lube Express. This amounts to approximately two million in sales that is basically dispersed in the community and essentially offsets the $20.4 million down to $18 million. • On the topic of sales leakage and unreported income, those other sales general merchandise ($4.8 million) and other retail stores ($3.4 million) also come out of the market area and is not what is called leakage, which basically means people leaving to shop in some other locale. We assume the dollars come from within the market area. We further assume and this is a conservative assumption that there is sales leakage that we do not know about because it is in the `underground' economy. The point is we are basically trying to be conservative by using reported income statistics. There may be additional dollars that would tend to lessen the impact that Walmart would have on the area, but we do not want to make those assumptions because we are not completely confident with what those underground economy figures really are so we are using tax reported income and trying to be fairly conservative with how we look at those numbers. The point being we are not just talking about $12.2 million and we are talking about additional conversions within the market area. Steve Scalmanini: • With regard to the topic of wages and overall wages to exclude information from the DER is insufficient. I think a relationship can be drawn between less wages in the community, less overall money to spend and additional urban decay. It is up to the EIR authors to figure it out. We know we are stuck with less wages in the grocery business in this town and in the market area because of this expansion if it happens. MINUTES OF THE PLANNING COMMISSION Page 15 August 10, 2011 • Less money to spend means less overall sales and more decay of existing infrastructure. • Figure it out and put it in the EIR. • Page 4.3-1, Urban Decay, `The analysis and findings in this section are based on the information contained in the Walmart Expansion Economic Impact and Urban Decay Analysis prepared in June 2010.' One speaker already commented that this information is outdated and since this was written over a year ago why was this information kept secret? How was the particular agency that wrote this information chosen? There is no information or reference to this process. • Page 4.3-1, paragraph 5, sentence that reads, `The Court ruled that the cumulative impact analysis for the proposed shopping centers should consider all other past, present or reasonably foreseeable future retail projects with the project's market area.' Would like the definition of `reasonably foreseeable' and how this is documented. • Page 4.3-2, Section 4.3.2, Environmental Setting, Project Market Area, paragraph 1, sentence that reads, `The market area definition is based on the principle that most consumers will travel to the shopping destination most convenient to their homes.' Where does this principle come from? Sounds like an assumption to me and would like to see this corrected. • Page 4.3-2, Says Lakeport was considered but then with the presence of other general merchandise stores over there it is unlikely residents will make frequent trips. Has not seen anything in the EIR that the local Walmart is not going to advertise. Therefore in Lakeport please include the commitment that somehow they agree Lakeport is out of the market area. • Page 4.3-5: Retail Market Characterization, `Analysis of California Board of Equalization (BOE) data on taxable sales within Mendocino County and its cities, shows that the City of Ukiah is a major retail hub for Mendocino County, drawing customers from nearby cities and unincorporated areas, as well as tourists who travel to and through the area on Highway 101. According to CBRE Consulting, the City of Ukiah accounted for an estimated 49 percent of the market area's sales in 2008. CBRE Consulting utilized data from the BOE to determine market value.' Does not see the data in the document. This information may be in the Appendix and missed it. If the document refers to the data, it should be there and is insufficient without it. • Page 4.3-6, talks about major commercial areas in and near Ukiah within the market area there are three major retailers and 10 grocery stores. Does not see that Hopland is included in the information. There is a grocery store in Hopland and is pretty sure this store is locally owned by someone who lives in Hopland. • Page 4.3-7, paragraph 3, last sentence, `Each of these three stores had moderate shopper volumes during CBRE Consulting's field research.' What is the definition of `moderate shopping volumes?' Can we get some numbers on this please. • Page 4.3-8, paragraph 2, last sentence, `A few sources indicated that a sale of this site had either been completed or was in process;' Can we get more specific about the sources here. Did not know secret sources were quoted in formal documents. • Page 4.3-8, paragraph 3, last sentence, `CBRE Consulting also noted a small retail center at the southwest corner of Ford Road and North State Street that was being rebuilt after fire damage.' That is a `heck' of an observation because I have been looking at this building for over a year with blue tarps over it. The deli and gun store in the small retail center was known as Diamond Jim's that has moved to the next building to the south. Diamond Jim's formerly occupied the left south most end of the building in the complex that is still not repaired due to fire damage. A discount store occupied a building in the middle of the retail center that is no longer in business and the building occupied to the north in the retail center is still in business. Does not see any rebuilding going on. • Page 4.3-8, Willits Retail Market, paragraph 1, last sentence, `Given the distance to Ukiah and other retail areas, it appears that Willits residents shop locally for most groceries and convenience items but probably travel to Ukiah for a more diverse selection of apparel, general merchandise, and other goods.' This indicates that distance is the reason for shopping locally when possible and this does not make any sense since Willits is included in the market area. It appears Willits residents shop locally, but how is this determined? Looks as though this information is unsubstantiated. MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 16 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Page 4.3-8: Willits Retail Market, paragraph 2, second sentence, `This supermarket includes a pharmacy, d JtaruuGres, and a more upscale selection or grocery items, similar to the Safeway store in Ukiah.' Questioned the definition of `upscale.' Carrie Hartman: One thing the EIR does not really address is that all the small stores are already gone like Purity, Bi -Lo, all of those places. In reference to how vacant buildings get re -tenanted, so far it is just County and State agencies. Bi -Lo is now an elementary school, the former Rexall pharmacy building is now occupied by the County, The building where Purity used to be located is now occupied by the County. Is this something the EIR should look at because we keep filling in buildings with our County and State agencies every time a business leaves an area. It may be important to look at the previous EIR for the original Walmart project and look at some of the issues/impacts being mitigated at that time but still have not been addressed such as sidewalks on Talmage Road. Jeff Blankford: • Wanted to get back to the issue of wages and the connection to the EIR. We have to remember this Walmart project is coming to the City of Ukiah requesting things of the City. You may be aware of a recent Supreme Court decision that was overturned involving a class action suit initiated by woman against Walmart for unequal pay received. The Supreme Courts does typically cater to the corporations. It is important the Planning Commission get information as to Walmart's wage structure. • We have heard discussion tonight about the way Walmart pays its employees and how it lowers working hours so that health care benefits are not paid and with Walmart employees having to apply for government assistance such as for food stamps. There is no money to pay for many of these government assistance programs. Our County is well into deficit. So the matter of wage structure is a critical aspect. Are we going to contribute more to this problem by allowing Walmart to expand? Wage structure information should be included in the EIR. Walmart should be required to provide this information to answer the question, does Walmart in fact encourage its employees to seek public assistance. Wage structure information for Walmart should be made available to the community, the City and the County. Dorothy A.: • Walmart has a history of abandoning communities when things get tough. • Walmart's food department would bring in more poisoned sprayed food from out of the area may be even from China dependent upon a fossil transportation system in which we can expect breakdowns. • We know we are going to see infrastructure and grid breakdowns in the future. We have bridges that are inadequate. This food is all coming from out of the Ukiah area. • We have a very strong local movement to create a localized food supply that is an organic non - poisoned supply and the last thing we need is competition from a cheap out -of -here corporation where money leaves the community and goes into the corporate coffers somewhere else and is not spent locally and does not support our local economy. Commissioner Helland: • Page 4.3-17: What rate of population growth is projected from 2010-2013 and what is the source of that growth rate? • Page 4.3-18 Footnote 20: `Retail vacancy is estimated at 5% or less by one retail broker who works in the market area.' Who is this retail broker and was this estimate corroborated or triangulated with others? If not, why not? • Page 4.3-19: `An estimated 584 new households are projected to be added to the market area between 2010-2013 and these residents are expected to add approximately $12.9 million in new retail demand.' On what is this estimate based? The US Census shows that the population of all of Mendocino County only increased by 1.8% over 10 years. MINUTES OF THE PLANNING COMMISSION Page 17 August 10, 2011 Break: 8:201 p.m. Reconvene: 8:42 p.m. Chair Pruden: Asked that the public comments be more germane and/or focused on the EIR document. CHAPTER 4.4 GEOLOGY AND SOILS Chair Pruden: One of the concerns identified in the EIR is loss of life or injury to people due to a seismic event but only deals in the report with structure and geology when most injuries are caused inside of a facility. Big box retail establishments are notorious for the stacking of merchandise and saw no discussion about injuries or the stacking process in the report. This issue may be addressed in the Building Code regulations that merchandise that is stacked must be secure and earthquake proof in buildings. Commissioner Helfand: Page 4.4-8: Typographical error at of second to last line, .....building the also city contracts.... CHAPTER 4.5: HAZARDS AND HAZARDOUS MATERIALS Commissioner Helland: Page 4.5-5, Hazardous Building Materials Survey, second to last sentence, `A survey did not identify any equipment that could potentially contain PCBs, mercury or CFCs.' Fluorescent lights contain mercury and the store has florescent light tubes. Commissioner Whetzel: Page 4.5-3, Table 4.5-1, Gordon Ag Service has not been around for a long time and the site remediated some time ago. Chair Pruden: Ernie's Chevron has not gone by that title for many years and to the west of this site there is ground contamination from an oil company operation. Commissioner Sanders: It is interesting of the 10 sites listed in Table 4.5-1, where groundwater is a concern, 4 of the contaminated sites are on the Airport. Chair Pruden: • The sites listed in Table 4.5-1 should be identified by address and not by historical name because some of these businesses have not been in business for more than 10 years. • The table should be updated. Commissioner Whetzel: • There are monitoring devices all over the Airport. • In response to public member inquiry about safety at the Airport (not audible), page 4.5-5, `project located within an Airport Land Use Plan would not result in a safety hazard.' Table 4.5-2a & 2b, Ukiah Airport Land Use Compatibility Safety Zones, lists land use compatibility safety zones and their limitations. Page 4.5-11 provides information about the Mendocino County Airport Comprehensive Land Use Plan (CLOP) that was adopted by the Mendocino County Airport Land Use Commission. `The CLUP regulates land use through safety zones, noise zones, and height restrictions and provides land use compatibility guidelines for lands near the Airport to avert potential safety problems and to ensure unhampered Airport operations.' Mira G: Was involved in the initial Walmart project and as a reporter one of the first things done was to call the FAA office in Sacramento and asked if there were concerns about development occurring near airports. The FAA responded it had concerns since airports are being lost left and right due to development. We are at a stage where we cannot recreate an airport. We cannot just move someplace else because land like this is no longer available. We can never really do expansions anymore. The FAA spokes person was no longer available when I came to actually do a report. MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 • Has a great appreciation for the rescue and fire fighting services that are part of Airport operations. The Airport is essential and there are no airports like the one we have in Ukiah. it is really important to have the Airport. • Apparently the City did a study about what may or may not happen around the airport. • The Airport Compatibility Safety Zones A through D specifies what is allowable in each zone. • Walmart is located within Airport Compatibility Zone C where large shopping malls are normally not an acceptable use. • According to Ukiah's standards for airports, there should not be a shopping mall in that area. • According to Table 4.5-213, 15% open space is recommended, which is not `very strong' but is quoted in the EIR. • Just wants to plead with you to protect the Airport. Chair Pruden: All developments must comply with the standards in the Airport Master Plan as they pertain to density, safety, noise, height and other relevant issues or potential impacts. Walmart's density falls within the standard because we do not want to shut an airport down so the compatibility issues if not addressed in the EIR is addressed in other documents because an incompatibility cannot be created with the Airport. Commissioner Whetzel: Page 4.5-13, Table 4.5 2B provides information about the compatibility zones including the density requirements for each zone. Commissioner Helland: Page 4.5-16, Impact 4.5-2: Spell out Preliminary Asbestos Inspection (PAI) instead of using an abbreviation, as the original definition is many pages back. CHAPTER 4.6: HYDROLOGY AND WATER QUALITY Commissioner Helland: • Page 4.6-16: Mitigation measure 4.6-3: typographical error in first line. • Page 4.6-17: Typographical error in second line, ....'toward into...' Choose one word or the other word. • Page 4.6-18-19: While the mitigation measures will assure there is no net increase in project condition peak flows, and the filters should remove grease and contaminants, the mitigation measures do not address the following requirements of the MS4 permit: `Properly design the areas to reduce impervious land coverage of parking areas and infiltrate or treat runoff.' • Page 4.6-19: Mitigation measure 4.6-5, does not discuss how or to what extent water will be infiltrated versus detained by Treatment Control Best Management Practices (BMPs). Thus, it is inadequate to conclude, as in 4.6-6, that `increase in the impervious surfaces under the proposed project would not significantly affect groundwater recharge in the project area.' • Page 4.6-21: As above, the treatments and mitigations discussed in 4.6-3 and 4.6-5 deal with slowing and treating of storm water, and do no demonstrate how storm water will be infiltrated on the site. It has not been adequately demonstrated that, together with the proposed Costco, cumulative increases in impervious surfaces will not significantly affect groundwater recharge in the project area. CHAPTER 4.7: LAND USE AND PLANNING Commissioner Helland: • Page 4.7-3 & 4: The Airport Industrial Park development standards were determined through a democratic process with extensive citizen involvement and reflects the will of the people of Ukiah. The project should be modified with the development standards. Development standards adopted by a city should not be modified for or determined by particular projects. • Page 4.7-4, Table 4.7-1 Goals GP -1 and GP -2: Goal -1: Promote, attract or assist in developing businesses, particularly those that add value to resources already found or processed in the Ukiah Valley. Goal -2: Promote business development, emphasizing local ownership of businesses in order to keep capital growth within the community. The project is clearly not MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 19 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 consistent with either of these goals of the General Plan adopted by the City of Ukiah with extensive publicr_ input. rr he EIR itseIt acknowledges (Page 4.30-8) that the project is nKe_iy .w cause store closures that `increase vacancies in and around the market area,' including possibly Lucky's and Grocery Outlet. A suggestion for a mitigation measure is the project could possibly be consistent with these two goals if a condition of approval were a commitment to a high percentage (>30%) of local sourcing of products, and patronage of local advertising agencies, banks, accountants, insurance agents, legal counsel, janitorial and security services, construction, repair and maintenance, etc. Chair Pruden: Asked if Consistency Determination was a product of ESA or some other source? Does the Commission have to work through these consistencies determinations during review of the DEIR? Staff: The `Consistency Determinations' in the document were formulated by ESA in conjunction with staff. The Planning Commission will make the consistency determination. The Planning Commission can make comments now about the `consistency determinations.' Chair Pruden: It may be each Commissioner has a different opinion about the consistency determinations. This matter can be revisited. Page 4.7-5, GP 29.3: Promote public transportation, services within walking distance in neighborhoods, and any other feasible means of preventing needless vehicle use and pollution. The consistency determination states, `While regional shopping uses rely heavily on the automobile, the project is located at an existing retail site served by transit, and mitigation measures will upgrade the bicycle and pedestrian infrastructure (see Section 4.10, Transportation). Further, by including groceries, the store will provide a one-stop shopping opportunity, which will prevent the need for customers to visit multiple stores for their general merchandise and grocery purchases.' The goal is to promote public transportation services within walking distances of neighborhoods and to prevent needless vehicle use and pollution. The solution is to do one stop shopping according to the consistency determination. Most of us do not consider one-stop shopping as perhaps an effective or consistent determination on this particular GP goal and thus questioned whether this solution is compatible with the Ukiah General Plan. Commissioner Helland: • Page 4.7-4, GP -25.2 and GP -26: GP -25.2: `In areas to be developed or redeveloped, ensure usable open space and common space.' GP -26: `Require that landscaping be a significant component of development and redevelopment.' The project includes less than 20% landscaping. This is not a `significant component' and does not provide for `usable open space.' The project as proposed is inconsistent with these two goals of the Ukiah General Plan. • Page 4.7-5 OC -13.1: `Maintain long-term sustained yield of the Valley's groundwater system shall be the standard for evaluation for groundwater protection programs.' Not necessarily consistent. While the mitigation measures will assure there is no net increase in project condition peak storm water flows, and the filters should remove grease and contaminants, the mitigation measures do not address the following requirement of the MS4 permit: `Properly design the areas to reduce impervious land coverage of parking areas and infiltrate or treat runoff.' Mitigation measure 4.6-5 does not discuss how or to what extent water will be infiltrated versus detained by the Best Management Practices (BMPs). Thus it is inadequate to conclude, as in 4.6-6 that `increase in the impervious surfaces under the proposed project would not significantly affect groundwater recharge in the project area.' Mary Anne Miller: • Not going to go after General Plan text, but it seems there must be something that says we promote a compact Downtown. Is looking for a compact downtown because if we continue to approve projects of this large scale on the periphery we are never going to have a compact Downtown. • Asked staff if a goal or policy exists in the General Plan that promotes a compact Downtown. MINUTES OF THE PLANNING COMMISSION Page 20 August 10, 2011 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Planning Director stump: The Ukiah General Plan was adopted in i 995 and does not recall offhand any goal or policy in reference to a compact pedestrian -oriented Downtown. Chair Pruden; With reference to the Ukiah General Plan does not remember using the term `compact; but does remember language that addresses the importance of local businesses in support of a local economy. Mary Anne Miller brings up a good point that needs to be looked at. John McClain: • Is a person with disabilities and commented on the issue of one-stop shopping • If there is an area where one-stop shopping is possible, it really benefits your life. • He is not able to run from store to store or from one end of town to another. • As a person with disabilities, he is on a very limited income. • He appreciates the more upscale stores in this town and that they are local, but many times we cannot afford to shop at them. Alan Nicholson: • Walmart's expansion is not consistent with the Ukiah General Plan or the Ukiah Valley Area Plan. It is not a `go local' strategy. It does not promote a wakable, pedestrian friendly community, but promotes a regional automobile centered mod adding to our air pollution and lowering our quality of life. • The Walmart expansion will clearly be a net loss to Ukiah. Rather than bring stability, this project will have very long term destabilizing consequences. Chair Pruden: • Did notice in this section that cutting down the olive trees would mitigate several issues and suggests that perhaps it does not mitigate all the landscaping and energy issues that were brought up. • Page 4.7-8, EG -5, `The site design shall incorporate shade trees for energy conservation.' Again, this section is talking about removing the olive trees. What this meant was getting shade over the building that is the energy conservation strived for, `but this one is a reach.' It is about putting shade over a building at certain time of the day to help mitigate both the active and passive gains. Putting olive trees in the parking lot will not save energy on a building. Commissioner Helland: • Page 4.7-8 EG -5 (Incorporate solar energy considerations into the design, review and approval of all development): The project, while incorporating skylights in the food areas, does not substantially incorporate solar energy considerations, which could include daylighting of the entire store or most of it, passive solar design to reduce heating and cooling needs, solar hot water heaters, or photovoltaics to create electricity onsite. The project as proposed is not consistent with EG 4.1. • Page 4.7-9 PR -13.3 (All new developments shall incorporate safe bicycle lanes in project street design): A class III bike route is usually merely signage and not a designated safe lane. This would be inconsistent, but the project is not a new development and thus this policy does not apply. • What the project calls for is a class III bike route. A class III is not a striped lane, it is generally signage. Bicycle planning experts at UC Davis say that a bike route should only be signed and established if bike routes offer a higher degree of service than alternative streets and if some of the following apply: provide for through and direct travel, (kind of), connect discontinuous segments of bike lanes from Hastings Road, (yes, kind of) signals and stop signs have been adjusted to accommodate bicycles better than adjacent streets, (not so much). Obviously, some kind of bicycle accommodation might be better than none since people will bike there. People who don't drive, can't drive, lost their cars or licenses. Is definitely torn about putting them in an area with a lot of traffic that has not had special accommodations made by bicyclists and where there will not be a class II lane striped for them. MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 21 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Providing for sharrows which is a class III bike route signage option is probably acceptable and definitely better than people riding on the sidewalk which is what is currently happening in that location. Is hoping we can be creative whether the applicant can deed some right-of-way from the sidewalk landscaped area between the parking lot and the road or the City can prioritize eventually purchasing right-of-way to add a class II bike lane. Is not sure what the solution is, but just signing that it is a bike route without a lane kind of gives a false impression of safety on that street. Page 4.7-10: CT -6 — CT -6.3: Signage with no lane markings (Class III bike route) does not qualify as `providing bicycle lanes or paths....' This is not consistent. I think there is also a typographical error in the Consistency Determination that reads, `The proposed project includes a Class II bicycle route along Airport Park Boulevard. If an adequate right-of-way exists, a Class II bicycle route will be installed on Airport Park Boulevard.' Most of the EIR has referenced a proposed Class III bike route (signage, no lane markings) for Airport Park Boulevard. Additional right-of-way would be required for a Class II striped bike lane. Commissioner Whetzel: In the General Plan — The goal is to support the creation the combined public and private facilities in the Downtown areas for educational, business/civic and personal growth purposes. The Policy GP 3.1 — Locate public and private facilities so they enhance existing Downtown businesses; GP 3.2 — Promote the private development of a Downtown to promote a seven day a week economy. Basically, this is all the General Plan says about the Downtown. There is no goal or policy related to a compact downtown. Chair Pruden: Suggests the Commission and public read through the General Plan consistencies and those that do not seem consistent with the text submit in writing and turn before August 18, when the public comment period ends for the DEIR. Commissioner Sanders: • Page 4.7-6, OC 16.1, `Protect surface water supplies from water generated in parking lots.' OC 16.2, `Manage stormwater flows to reduce the hazard of flooding from increased stormwater flows.' This is a comment for the General Plan consistency determination because it only addresses construction. The project will be pulling up a lot of turf and is concerned about the bioswales that are being anticipated. How is this going to work with handling the contamination from the parking lot and the flooding? Also, we are getting rid of and I think this is in the Ukiah General Plan having tree planting strips so we are talking about putting trees in pots. It will take 10 years in order to have adequate shade coverage. What we have in the parking lot have a bonsai effect on the trees so how are we going to know maintenance is going to result in adequate canopy coverage in relation to the requirements in the General Plan for 50% coverage? Does not feel this aspect is adequately covered in the document. Commissioner Whetzel: This issue would be covered during review of the major SDP for the project. Commissioner Sanders: • The whole idea of surface water and getting rid of what is out there now and the potential impacts does not believe these issues are being appropriately addressed in the document as mitigation for construction and is bringing this to the attention of the consultant. • Will submit additional comments in writing. Commissioner Helland: Page 4.7-10: Policy CT -7 (Develop pedestrian access): It is great that sidewalks on Airport Park Boulevard and Commerce will be provided, but a separated walkway through the parking lot to store (from sidewalk) must also be provided to be consistent with this policy. Page 4.7-11 Policy CT -11: (Encourage increased use of car — or van -pooling): Should maintain or increase current rate of carpooling by requiring continuation of carpool coordinator position. Page 4.7-12 Policy CD 4.1 (Establish and enforce landscaping standards in all non -single family residential, multi -family residential, commercial, and industrial development and all MINUTES OF THE PLANNING COMMISSION Page 22 August 10, 2011 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 redevelopment projects): The proposed landscaping plan is not consistent with the Airport 1 nUUJlrlal rGtlR IdIIUJI;dpllly $lCat llda. lUJ leglllling Cit ICdJt GV /O of UIC sllC W UG IdIIUJl:dpeU. Page 4.7-14, Cumulative Impacts — Land Use and Planning The Project itself is not consistent with the 11 goals and policies enumerated in the document. The cumulative land use impacts of the project and other developments in the vicinity are significant. Impact 4.7-4: states, `The proposed project, in combination with other developments in the vicinity, would not contribute to potential cumulative land use impacts.' Dorothy A.: Since the projected area for development is in an area that should stay open space for the Airport, the only thing you can plant are these little lollypop trees that don't provide any substantial shade. Recalls when trees were magnificent and the great Elms that provide shade in the eastern and New England towns. Great shade trees can provide 15 degree difference in temperature. You cannot plant trees that provide a lot shade in a protected area of the Airport in the flight zone. Chair Pruden: • We can in this particular area where Walmart is located call forth a significant tree planting program. Trees that reach 80 to 100 feet would not be planted there. • We are looking for shade so height is not so much of a factor as is canopy spread to get the shade out over the parking lot and drop those temperatures. Commissioner Whetzel: The trees for the site can be as tall as the Hampton Inn. Dorothy A.: • The other thing is we are in the flood zone. Downtown Ukiah does flood very seriously, in fact. • Recalls people whose homes had three -feet of water in them. • The last thing we need is more asphalt, more concrete and more paving. • The reason we have all of this flooding is the paving of surfaces. • Development is really retrogressive in an area like this. • Lived in Denver for nine years that has beautiful bicycle trails. They are not just painted lanes in roadways, which are really quite dangerous. At 73 years of age, am still a bicycle rider and has been hit in one of those painted lanes by somebody who could not see to drive and dragged underneath the truck. This was a terrifying experience. You need real bicycle lanes which are separate and if you are going to have development then the developer needs to provide those improvements and not dump it on the City. • 1 am opposed to the Walmart expansion project. I do not see any great blessing to Ukiah that can possibly come out of more big -box expansion. Alan Nicholson: • Page 4.7-12, CD -1.1, `Encourage appropriate scale, materials, setbacks, and landscaping to enhance the Valley's beauty and historic fabric.' This project does nothing to enhance the Valley's beauty and historic fabric. The consistencies determinations claimed are bogus and not consistent with this goal/policy. • CD -1.2, `Encourage developers to construct new buildings and settings of such quality that Ukiah's future citizens will wish to protect them.' The project is a suburban sprawl, big box where they are proposing to give us a curved section of roof to make it unique. This is a joke. The project has no redeeming, enduring aesthetic qualities. It is not something the citizens of City would want to protect in the future and is inconsistent with Ukiah's General Plan. Chair Pruden: It has been noted the `consistency determinations' do not match up with some of the General Plan goals. Mary Anne Miller: The General Plan goals and policies are chosen by whom? By staff, by Walmart, by consultant? MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 23 Chair Pruden: As Planning Director Stump has indicated with regard to the consistency determination it V .mato. 2 f f d the la.. 1 was d c,uriiuniduuii vi aiaii d�iu the �uiiaui�ani. Staff: The process regarding the consistency determination was to review every General Plan goal and policy and decide whether or not they apply to the project. If there was even a remote chance that they could apply to the project, they were included in the table. 4.8: NOISE Chair Pruden: Asked during the scoping session for the project about noise at night with regard to idling cars, slamming doors, people getting in and out of vehicles and just regular human activity at a store. The consultant indicated what noise might be measured at 60 decibels during the day may sound like 80 decibles at nighttime. She did not see any section in the document related to the shopper and what they sound like at nighttime, especially between 10 p.m. and 6 a.m. The mitigation measures only address the maintenance issues and no maintenance would be done in the parking lot at this time. Again, there was no data given about the noise factor of the customer or any discussion about noise generated in the parking lot at nighttime. She attended a Super Walmart where a gigantic sale was going on at night in Florida. She was unable to find a parking space in a very large parking lot. There were police in the store maintaining order. All of this was going on at approximately 1:30 in the morning. She is thinking that perhaps these special sales events do generate a great deal of activity at unusual hours. Regarding this middle of the night noise where people come from great distances for a sale, the information addressing this type of activity is deficient. Commissioner Whetzel: Has some issues concerning this but they tie in with traffic. 4.9: PUBLIC SERVICES AND UTILITIES Chair Pruden: Public utilities section, Water Supply System: The document contains a lot of statistics about flow and other associated data, as well as talks about the 85 new employees. It is anticipated that 1,000 to 1,500 new customers will shop at the store every day. What about toilet flushing? In a year's time there would be a considerable amount of wastewater treatment facilities being used just in the way of hand -washing and toilet flushing. There is no figure in the document that talks about the customer creating a demand on the City's wastewater treatment plant and she is not sure why. Flagged this as an issue. Commissioner Sanders: Inquired if there could be a table for police protection under public services. She was going through the text and was sort of creating her own table and noticed in 2008 there are no statistics and inquired as to the reason. The range jumps from 2007 to 2009. It would be helpful to see how UPD had to respond to this southern beat for at least a three year period because 2010 only goes through June. Chair Pruden: Page 4.9-11, Impact 4.9-1: Implementation of the Project would not result in the need for new or physical or altered police facilities.' She agrees, but at this point believes a mitigation measure for public safety issues at the site requires a security management plan. This factor is not mentioned in the document and is not offered as a mitigation, but rather states the need for new or altered police facilities is not significant and no mitigation is required. Commissioner Helland: A security management plan is mentioned in the document. Will the parking lot be patrolled 24 hours a day? Chair Pruden: While the document lists many bullet points related to significant impacts to public services, it does not refer to a security management plan. What needs to occur is to offer a security management plan as a mitigation measure for public safety issues. MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 24 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Commissioner Sanders: It is not her understanding that the general practice of Walmart uses staff to patrol their parking lot. Chair Pruden: Walmart may have to train individuals to do this. Commissioner Whetzel: Or hire an outside security agency to patrol the parking lot. Gene Hoggren: • If you go south on Highway 101 past San Jose, you will come into three Walmart stores that have armed guards in the store and the parking lot. It is a different culture there, but is a culture we are currently experiencing. Security is very necessary. • Has experienced problems with the public just coming into town a few times a month so security is very important for the Walmart parking lot. • When Walmart first opened, there was some type of security precaution for the parking lot. Commissioner Helfand: Page 4.9-6: Typographical error in first line of third paragraph: `.....two oxidation ponds for evaporation/percolation.' Page 4.9-10: Identify the source of the significance criteria? Brian Grattidge: • The significance criteria is from Appendix G of the CEQA Checklist. The last bullet about energy efficiency is from Appendix F of the CEQA Guidelines. Chair Pruden: It may be the criteria should be cross-referenced. Chair Pruden: Did not see discussion about the impacts of a 24-hour store that would tie into public safety. There needs to be a paragraph about this element. Commissioner Helland: Page 4.9-11: Would the parking lot patrol be 24 hours/day? Chair Pruden: • Page 4.9-13, Impact 4.9-5: Implementation of the Project would not significantly increase the demand for water supply. Again, this section talks about the 85 employees, but not the thousands of persons per year that will be using the toilets. The document should at least indicate Walmart will be using energy efficient commodes, etc. • Questioned water usage for food preparation, particularly the vegetable department that uses water to prep the food. There is no mention in the document about water usage in this regard and recommends including some data. Does this include water for landscaping? • Need to have information about the anticipated increase in gallons of water used. Commissioner Whetzel: The watering of plants outdoors should also be factored into water usage. Commissioner Helland: Page 4.9-13, states the building's water demand would increase 26 percent to 4,100 gpd from 3,250 gpd. Brian Grattidge: This figure includes complete building operations and this is the number from the Project's mechanical engineer as to what the increase would be for the square footage including preparation, patronage, HVAC, and other systems. Chair Pruden: Requested a sentence that is inclusive of everything such as garden, food preparation, toilet flushing, etc. Would not say a 26% increase in water is any little demand. 4.10: TRANSPORTATION AND TRAFFIC MINUTES OF THE PLANNING COMMISSION Page 25 August 10, 2011 Commissioner Helland: Page 4.10-14: last line typographical error `....at LOS E or F' instead of `E of F.' Page 4.10-29: Mitigation Measure 4.10-3d: Add `A separated walkway through the parking lot to the store (from sidewalk) shall be provided.' Commissioner Whetzel: • Page 4.10-2, Residential Roadways, Section does not mention the traffic impacts to Betty Street, Lorraine Street, Orchard Avenue or Marlene Street since the Walmart store originated. • With Betty Street straightened to go directly to Talmage and the Waugh Lane bridge closed Betty Street is now the thoroughfare to get to Walmart from the north. Orchard Avenue, Marlene Street and Betty Street have been used as access streets as a quick way to get from Gobbi to Talmage for some time now. • Because of heavy traffic on Lorraine Street and Betty Street speed bumps had to be constructed. • Even the Parcel Post driver has noticed the increase in traffic on Betty Street. Chair Pruden: There has been a substantial increase of traffic on the Betty Street, Lorraine Street, Orchard Avenue and Marlene Street since the Waugh Lane bridge was closed. People are backing up and going through Cooper Lane and right into these neighborhoods. Chair Pruden: Page 4.10-2, Residential Roadways, questioned the connection of Mill Street in this section to the Walmart project. Commissioner Whetzel: • Page 4.10-3, Pedestrian Facilities, `Waugh Lane, Betty Street, Lorraine Street, and Henderson Lane are all narrow local streets that provide access to residences on the north side of Talmage Road. Sidewalks and streetlights are generally not provided along these local streets.' • Traffic in this area has increased since Walmart initially opened. Chair Pruden: A great deal of mitigation was done to get the Betty Street/Lorraine Street neighborhood to stop being a shortcut to Walmart. Commissioner Whetzel: • It is still a shortcut to Walmart. • Would like to see more of a study of that neighborhood. Commissioner Helland: Page 4.10-29, Mitigation Measure 4.10-3d, recommends adding as a separate mitigation measure for a separated walkway through the parking lot to the store from a sidewalk that will be provided along Airport Park Boulevard. Commissioner Whetzel: Noted when studies regarding street lights were done, much of the information was done in February and should have been done in June or July when there is more road traffic. There is more traffic in the spring and summer than in the winter. Chair Pruden: Page 4.10-7, Existing Intersection Levels of Service, and identified the peak hours are the highest volume in Ukiah from 4-6:00 p.m. The reality is some of Ukiah's peak traffic count actually occurs between 2:15 p.m. and 3:30 p.m. when school is out of session for the day. A person cannot get down Dora Street or through Gobbi Street and barely get off of Washington Avenue. In fact, a person avoids those streets because they are so congested. There is also bus traffic because many Ukiah children are bused to and from school. Commissioner Whetzel: Actually the congestion continues until 5:00 p.m. for those streets. Chair Pruden: • The peak hours for Ukiah are mid-afternoon and they are so severe at 3 or 3:30 p.m. that Gobbi is impacted almost all the way from Orchard Avenue up to Dora Street. We do not seem to have MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 26 1 traffic studies for how the town functions for this. She realizes these are unconventional peak i 4 .. -ut L 1 to 4. 14:.... bo .a 14 .. fact 14 1 111 : 4 4 1 4 hours, LL) LhCre ought L LJ JVllleLilllll� aUVUL UIC Iitl;L LIICU Ur%l11 11 rel�lllttl congestion when 3 school is released. School hours are staggered to help offset the congestion. The information in 4 the document does not truly reflect how Ukiah operates in terms of traffic and traffic congestion 5 and figures are slightly askew. 6 Page 4.10-22, Trip Generation, a sentence in this section reads, `Based on guidance in Trip 7 Generation, the outdoor garden center area was excluded from the square footage applied to the 8 trip generation rates for both the existing and proposed Walmart store.' Does not know the 9 rationale for excluding the outdoor garden area. The figure is used in many other places but in the 10 trip generation it is not a square footage figure that they use. This will need to be clarified. 11 12 Commissioner Whetzel: Page 4.10-16, Future Transportation Improvements, With regard to the design 13 study for intersection improvements within the general vicinity of the Project area does not see and would 14 like to see improvements from Talmage Road to State Street. 15 16 Staff: The information represents the improvements currently being designed. 17 18 Commissioner Whetzel: Are there plans to widen Talmage Road? 19 20 Planning Director Stump: Talmage Road is a State highway. There have been discussions about 21 relinquishing that section of road in the area of Airport Park Boulevard to State Street to the City. The City 22 was interested provided the road is upgraded to City standards and includes the widening of sidewalks 23 and bicycle lanes. Most recently, the City negotiated with Caltrans to have this section relinquished. 24 25 Commissioner Whetzel: Can these improvements be added to future transportation improvements? 26 27 Staff: Not at this time until more information is known about the 2030 UVAP traffic model and associated 28 fees for future intersection/interchange improvements in the Project area. 29 30 Alan Nicholson: 31 • Could not find what makes a less than significant impact. I know this must be documented in 32 many places in the EIR document, but persons that do not frequently travel Talmage Road do not 33 realize there is a traffic problem there. It does state in the EIR that traffic does back up onto the 34 freeway. 35 • He lives in Talmage and experiences the congestion every day with traffic backed up on Talmage 36 Road from the freeway off-ramp to Airport Park Boulevard. 37 0 Has observed that people cannot get off the freeway, particularly all day on Saturdays and early 38 on Sundays when people want to go shopping at Walmart. However, there are times when there 39 is very little traffic and times when there is a lot of traffic. 40 • The Walmart expansion will add thousands of people coming into that shopping area every day. 41 0 Is of the opinion the EIR does not adequately address the traffic and congestion problem on 42 Talmage Road in the area of the project. 43 • The problems with traffic near the project area is dangerous now and will be more dangerous in 44 terms of public safety with the proposed project with the traffic impacts as addressed in the EIR 45 being brushed off as less than significant. 46 • He finds the traffic impacts in the vicinity of the project to be very significant and does not 47 understand how this criteria works. 48 Elected officials are trustees for the public good and need to be fully informed about the 49 consequences of this project. The EIR can be certified and turned into a good document, but 50 finds it very deficient at the present time. The project should be denied for both traffic and urban 51 blight with non-mitigatable impacts to the environment and the economy. There can be no 52 overriding considerations. Essentially, the EIR can be certified and the project denied, as 53 proposed, whereby the project can easily move forward with the existing footprint. It is important 54 to give Ukiah the best project possible and do the right thing for the community. MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 27 1 • Has a problem with the perspective on some of these less than significant impacts in the traffic 2 and urban decay sections of the EIR. 3 4 Brian Grattidge: 5 • Clarified that traffic impacts for the project right now have been identified as significant and 6 unavoidable. 7 0 Probably did not stress the point enough during the initial presentation. 8 • Traffic impacts related to the operation of Talmage Road and 101 southbound and Talmage and 9 Airport Industrial Park would be significant and unavoidable and this is despite requiring 10 mitigation measures from the applicant. 11 12 Chair Pruden: 13 • The staff report points out the significant and unavoidable impacts, some of which cannot be 14 m itigated. 15 0 Page 4.10-16, Approach to Analysis, with regard to the future year 2030 traffic volumes figure 16 derived from the UVAP traffic model plan addressed in the EIR that provides if there is money 17 and the plan for intersection/interchange improvements can move forward the City would be able 18 to bring the intersections referenced back to `LOS A.' However, this is 19 years in the future. 19 What do we do in the interim? She has a problem with trying to figure out this how works in the 20 EIR document concerning the need for intersection improvements and the significant and 21 unavoidable impacts the project can bring. Again, while the document identifies significant and 22 unavoidable impacts some of which cannot be successfully mitigated does not provide a solution. 23 24 Brian Grattidge: 25 • The way the EIR looks at traffic is it identifies near and long term problems. The long term 26 problems include the list of projects that are used for the other cumulative analysis including the 27 potential Costco and other stores in the area and also takes the background volumes that were 28 used for the 2030 UVAP. 29 • There is an engineering solution to the problem. This project would be required to commit their 30 portion of Capital Improvement Program funding for improvements. 31 • The problem for purposes of the EIR as alluded to is that the other funding sources are not 32 solid enough. There is not an adopted UVAP fee that can be relied upon. There is not identified 33 state sources so even though there is a possible solution that this project would commit to, it 34 cannot be guaranteed within the time frame of our analysis of 2030 that this interchange would 35 be built; Therefore, the significant and unavoidable impacts. So sometime between now and 36 2030 there will be impacts where the level of service is deficient until such time as those 37 improvements can be made. 38 39 Chair Pruden: Is not sure the community can live with 19 years of backed up traffic. It is a concern and 40 the document identifies that a major problem exists that is underfunded. Her concern is that there is 41 essentially room for one more project if Costco comes. She is not sure if the proportional share of 42 Walmart and proportional share to Costco of CIP improvements will even be enough to alleviate any 43 impacts of the project. 44 45 Commissioner Sanders: We do not know the balance in the CIP Fund. 46 47 Chair Pruden: I do not think this community can live with 19 years of traffic issues in the Project area, but 48 perhaps between the two projects there is enough to successfully mitigate the impacts. 49 50 Planning Director Stump: When the project comes before the Commission for decision making, we 51 hope to have additional information about how potentially the overall traffic mitigation can be achieved. 52 53 Dorothy A.: Supports what Alan Nicholson said and cited an example of the Coddingtown shopping 54 center and what it has done to the traffic in Santa Rosa. There are hours where a person is simply 55 backed up in traffic. We are talking five miles per hour and breathing all that pollution. It is not just traffic, MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 28 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 it's air pollution. It is a mess and now they are building a whole new lane on highway 101 and we are in a broken economy. it is not going to get any better if the money system collapses internationally. Chair Pruden: This document clearly identifies that we have a problem with traffic and we do not have a financial solution. Mary Anne Miller: • Does not understand the less than significant designation impact information that states `the implementation of the project would increase the traffic volume on area roadways. This impact is less than significant and therefore no mitigation measures are required.' She questions this language and referred to her favorite page on the whole document 6-14, Section 6.5 Environmentally Superior Alternative, Table 6.5, Summary of Alternatives that provides information about potentially significant and less than significant impacts with regard to the environmental effects for each alternative in comparison to the proposed project She wants to make certain the decision makers do not have to grasp for or even turn down proposed project and waste all of this time and money in the EIR because there are alternative options. In the table the environmental impacts listed, aesthetics (light/glare), air quality, economics/urban decay, geology and soils, hazards and hazardous materials, hydrology and water quality, land use, public services and utilities, transportation and traffic, climate change and biological resources indicate the potentially significant (PS) and less than significant impacts (LTS) prior to mitigation with an indicator of +/- of whether the alternative impact is comparatively greater or lesser than that of the Project. • This section suggests the `no project alternative' would avoid all potentially significant project impacts to all resources areas including aesthetics, air quality, biological resources, hazards, hydrology, noise and traffic whereby the no project alternative would be the environmentally preferred alternative, but CEQA requires that a second alternative be identified when the `no project' alternative emerges as the preferred environmental alternative. • Questioned the table for alternative 3, No Footprint Expansion Alternative that shows these minus less than significant indicators and finds it interesting the environmental topics listed as `PS with a minus' that have been reduced but have not been eliminated. The transportation and traffic impact is listed as potentially significant. • Would like to have justification for retaining a potentially significant level of impact on the environmental topics of hazards and hazardous materials, noise, and transportation and traffic. • With regard to Table 6.5, this is where if you are getting the right facts in the document you would have reduced these impacts to less than significant, particularly for transportation and traffic impacts. 4.11: GLOBAL CLIMATE CHANGE Commissioner Helland: Page 4.11-17 Second to last paragraph: Greenhouse gas emission calculations for construction were completed `assuming that construction would take 6 months.' Previously, on page 4.2-11 under Air Quality, `construction duration was estimated to be one year.' The information is not consistent. 4.12: BIOLOGICAL RESOURCES Chair Pruden: Page 4.12-15, Tree Protection Ordinance: `The City of Ukiah does not have a specific ordinance relating to the protection of trees within the City limits. Tree protection measures and mitigation for impacts to tree resources are typically incorporated into the SDP.' This is not correct. The City has a street tree ordinance which governs right-of-way trees. What the City does not have is an ordinance governing trees on private property. The City is codified for street trees. This information needs to be corrected. All SDPs that have landscaping requirements are protected although this would not be an ordinance on its own because if a required landscaping tree is removed, it must be replaced. CHAPTER 5: OTHER CEQA CONSIDERATIONS MINUTES OF THE PLANNING COMMISSION Page 29 August 10, 2011 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Commissioner Helland: Page 5-5: Effects Found Not To Be Significant, The introductory paragraphs refers to the Jlgllll ll;cll 11 llllaVolUitVIC eI1Cl:W to I:III11dLC 1a 1d11lj.0 allU UctIIJt.JVIIQUVn, IUCIIUIICU above...' While both were addressed in Chapter 4, only transportation was addressed in Chapter 5 under Significant Unavoidable Impacts. `Except for the significant unavoidable effects to climate change and transportation, identified above, the environmental effects of the proposed Project would be less than significant or less than significant after implementation of the identified mitigation measures.' Was climate change a typographical error? CHAPTER 6: ALTERNATIVES Chair Pruden: Is there an option to do a mix and match of the alternatives for the Project or do we have to stick to the alternatives as presented? Staff: Is the question related to can a new alternative be created as part of the EIR or how the alternatives affect the decision on the project? Chair Pruden: Can we create another alternative using the alternatives presented? Staff: Do you want a third alternative analyzed in the EIR or are you concerned how it affects making changes to the project? Commissioner Whetzel: What Chair Pruden is likely saying is the Planning Commission may not want certain components of the project as proposed. Staff: This sounds like a project discussion. Is there some component missing in the alternatives that the Commission has a problem with? Commissioner Helland: May best be understood as how the analysis for the hypothetical alternative helped to understand the environmental effects. If not, this can be answered in the final EIR. Commissioner Sanders: Asked Chair Pruden if she had another option. Chair Pruden does not have another option but there might be options where you consider one thing but you do not necessarily want a certain component. For instance, with regard to the two-story alternative that the food component would not be a part. In reference to the section on alternatives, the question is does each alternative contained within itself or can you take a component from one alternative and match it with another alternative so as to create essentially a new alternative. Staff: Is the question: what is the purpose of a new alternate and what is missing in the analysis or not understood with the alternatives that are presented. Chair Pruden: Is asking about the process and whether or not there is flexibility. This reminds me of the UVAP process where there were many alternatives and what results is a hybrid of these alternatives that works. Is asking process wise whether or not a hybrid can be created for the Walmart project. The project is required to have alternatives including environmentally superior alternatives as provided for in the CEQA guidelines. Commissioner Brenner: Is his understanding the alternatives are there for cross -comparison between the different values for the CEQA by asking Walmart to put forth their best alternative judgment and/or scenario by considering the positive, the negative and the in between scenarios. Commissioner Whetzel: It does not really matter what building is constructed because this aspect will be covered under review for the major SDP. For purposes of the EIR, we are interested in looking at the square foot of the area for that site. MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 30 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Commissioner Helland: Page 6.4, section 6.3.1, two-story alternative, Should pay more attention in the text, for instance, why a two-story alternate would not avoid or substantially lessen any of the significant or unavoidable greenhouse gas emissions or traffic impacts. Does the document consider why a two- story alternative would or would not be an environmentally superior alternative? What is the consideration and how is the environmental effect addressed as an alternative. Chair Pruden: Is not sure if every alternative has been identified. We are talking about alternatives to the project and not alternatives to design. Commissioner Whetzel: CEQA requires only three alternatives. Staff: If something is missing in the alternatives, this should be identified now. Brian Grattidge: • If you approve something that is within the envelop square footage wise and operationally looks like it but is not exact, as long as it is not more than that and fits within the box, you are fine. This is why the three alternatives were selected. Basically, the analysis looked at the project which is what the applicant wants and then took a range going from what the applicant wanted down to zero in terms of square footage and this is the reason for the reduced project size alternative, which is basically half way. • The analysis had to look at what may be approvable and develop the alternatives accordingly. • Would caution the Commission not to consider the two-story alternative namely because it does not reduce any of the impacts and would probably have to revisit the visual issues west to east in this regard. This may be problematic, but in terms of either a reduction of square footage or operations probably would be possible within the range of alternatives that were provided. Chair Pruden: Using the two-story alternative because it would be the most noticeable and more radical of all of the approaches in terms of reconfiguring square footage that it is best to work within the parameters that there may be some flexibility since most environmental impacts have been identified. Commissioner Whetzel: `And still work within the parameters of the EIR.' Mary Anne Miller: • Referred to the Environmentally Superior Alternative table and if the Commission finds the environmentally superior alternative does not lower the transportation and traffic impact because of the 24-hour operation, for instance, then it is not the alternative that you want. The Commission may want to eliminate that 24-hour operation component in addition to other components. However, the Commission does not get that satisfaction because the EIR does not tell what component of that significant transportation impact is due to the 24-hour operation. But to eliminate this component, the Commission would have to justify that this is being done in order to get a less than significant impact concerning transportation and traffic. The problem is the significant impact cannot be separated out from the No. 3 Alternative, No Footprint Expansion.' • She would prefer to see no footprint expansion and hours of operation reduced to 7 a.m. to 11 p.m. to lessen the environmental effects. Commissioner Whetzel: Referenced the `No Project Alternative' and noted if the 7 a.m. to 11 p.m. hours of operation were to remain, seven days per week, as opposed to a 24-hour operation no grocery sales would occur and would essentially be a no project alternative. The `No Project Alternative' assumes no change in the existing environment and would result in a continuation of existing conditions on the site and would eliminate or substantially reduce all project -related impacts. Commissioner Helland: It is likely the reasoning in the document was that when the traffic queues are going to back up to a significant unavoidable level is during peak hours and so the thinking was that this would not occur overnight when it is going to be additionally open to what it currently is. Commissioner Helland: MINUTES OF THE PLANNING COMMISSION Page 31 August 10, 2011 1 Page 6-4: Under 2 -Story Alternative: Another reference to `significant and unavoidable GHG 2 emission' impacts. is this a typographical error? 3 0 Page 6-4: Typographical error on last line: `two Walmart stores.' 4 • Page 6-13: Typographical error: Transportation and Traffic, third sentence, `Weekend end....' 5 6 Chair Pruden: Asked if the document should contain a glossary of terms? A glossary may be helpful. 7 8 Staff: It would be helpful to know what terms the Commission would like defined to make the document 9 easier to understand. If the Commission would like to have a glossary it should be included as part of the 10 comments within the comment period. It may be helpful to define/clarify the acronyms. It may be a 11 glossary is not necessary but rather a better explanation of terms as they occur or by way of a footnote 12 for clarification. 13 14 Commissioner Sanders: A glossary is not likely necessary. 15 16 Commissioner Brenner: Would like the acronyms to be clarified. 17 18 Public Member: (inaudible) Commented on whether the City really has a say in the Walmart project. 19 20 Steve Scalmanini: Inquired about the number of square footage analyzed for the original Walmart 21 including the proposed expansion square footage that was approved for the initial project and how this 22 corresponds with what was built and the expansion currently being proposed. 23 24 Staff: Additional area for expansion was analyzed as part of the original EIR which analyzed a 93,000 25 square feet of store and an additional 30,000 square foot expansion. There is some concern this 26 guaranteed Walmart another 30,000 square feet without having to come back to the City for approval. As 27 part of the construction of the existing Walmart, they built the 93,000 square feet plus part of the 30,000 28 square feet approved as "expansion." 29 30 Planning Director Stump: Walmart decided they did not want to expand at the time when the original 31 Walmart store was approved. When Walmart proposed the expansion project the square footage went 32 beyond what the applicant originally anticipated for future expansion. While Walmart had approval for a 33 30,000 square foot expansion, they want a much larger building than the originally approved 30,000 sq.ft. 34 expansion, so the original 30,000 sq.ft. expansion matter from the City's perspective is now moot. 35 36 Alan Nicholson provided additional written comments as follows: 37 • Walmart in Ukiah expansion by 48,000 square feet primarily for the purpose of selling groceries 38 and competing in the local health and eye care business on 24-hour basis. 39 • As consumers and a city looking for revenues the project looks appealing on the surface. The 40 fundamental question before us is whether this proposed project is good for Ukiah or is it to be a 41 further negative impact on our city and community. 42 • The City Council, which will soon review the plan, will likely focus on the assumed sales tax 43 generation and job creation such an expansion will provide. 44 0 It is important to recognize that an expansion of mainly grocery items will not generate a large 45 amount of additional sales revenue, and the assumed loss of two existing supermarkets could 46 lead to fewer jobs, reduced tax revenues, less consumer choice and create a significant vacancy 47 problem in the City of Ukiah and nearby cities. 48 • The issue for Ukiah decision makers is whether the environmental impact report has adequately 49 assessed the cost/benefits of this expansion. An objective evaluation shows there will be many 50 hidden costs. 51 0 Regarding product selection: except for private label brands, almost all grocery items are 52 available at existing stores. Walmart just undercuts everyone else and shuts down other tax 53 revenues for the City. As these other stores are typically anchor tenants, many lesser businesses 54 will fail as a result. This means that most, if not all, of Walmart's estimated increased sales MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 32 1 following the expansion will come at the expense of existing local retailers, which will increase the 2 potential for store closures and decreasing revenues for the City and County. 3 The proposed project Economic Study is based on an economy almost four years old from 2008. 4 We are in a second downturn of a unprecedented global economic recession and the EIR 5 projections are clearly inadequate for Ukiah to rebound within two years. We will still be 6 recovering in five to 10 years. 7 8 PUBLIC COMMENT PERIOD CLOSED: 10:03 p.m. 9 MINUTES OF THE PLANNING COMMISSION August 10, 2011 Page 33 I UKIAH PLANNING COMMISSION 2 November 9, 2011 3 Minutes Excerpt 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 COMMISSIONERS PRESENT Judy Pruden, Chair Jason Brenner Kevin Doble Linda Sanders Mike Whetzel COMMISSIONERS ABSENT None STAFF PRESENT OTHERS PRESENT Kim Jordan, Senior Planner Listed below, Respectively Jennifer Faso, Associate Planner Cathy Elawadly, Recording Secretary 1. CALL TO ORDER The regular meeting of the City of Ukiah Planning Commission was called to order by Chair Pruden at 6:00 p.m. in the Council Chambers of the Ukiah Civic Center, 300 Seminary Avenue, Ukiah, California. 2. ROLL CALL 3. PLEDGE OF ALLEGIANCE - Everyone cited. 4. APPROVAL OF MINUTES — September 28, 2011 M/S Sanders/Whetzel to approve September 28, 2011 minutes, as submitted. Motion carried with Commissioner Doble abstaining. 5. COMMENTS FROM AUDIENCE ON NON -AGENDA ITEMS 6. APPEAL PROCESS — Chair Pruden read the appeal process. For matters heard at this meeting, the final date to appeal is November 21, 2011. 7. SITE VISIT VERIFICATION - Site visit for agenda item 9B was verified. 8. VERIFICATION OF NOTICE — Agenda items 9A & 9B were properly noticed in accordance with the provisions of the Ukiah Municipal Code. 9. PUBLIC HEARING 9A. Walmart Expansion Project Environmental Impact Report (File Nos.: 09-42-EIR-PC/09-28- SDP-PC). Conduct a public hearing, take public and provide Planning Commission comment, and possibly adopt a resolution to certify the Walmart Expansion Project Environmental Impact Report (EIR). The project proposes a 47,621 square foot expansion of the existing 109,030 square foot store, for a total square footage of 156,651 to include expanded general merchandise floor area and expanded grocery sales floor area, indoor and outdoor garden centers, as well as the possibility of distilled alcohol sales, and a medical clinic and/or vision center on the 13.44 acre site located at 1155 Airport Park Boulevard, APN 180-070-38, in the Airport Industrial Park. Also, included as part of the project is a change in store hours to 24 hours per day, seven days per week, modifications to the landscaping, and other associated site improvements. The EIR analyzes an addition of 52,320 square feet for a total store size of 161,350 square feet (a 3% MINUTES OF THE PLANNING COMMISSION Page 1 November 9, 2011 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 increase of the proposed square footage). The expansion of the store requires approval of a Major Site Development Permit. Chair Pruden: Briefly advised the public about Planning Commission meeting procedures/protocol concerning tonight's review of the FEIR and Site Development Permit for the Walmart Expansion project for the benefit of those public members wanting to comment and specifically asked commenters to stay on topic because the FEIR and Site Development Permit are two different matters. Many of the comments received and/or made publicly concerning the DEIR did not relate to environmental impacts or the adequacy of the EIR, but rather to the existing development on the site and Walmart's corporate business practices. It was noted since this type of comment is not related to the potential environmental effects of the Project, they are not addressed at length in the FEIR. Planning Director Stump: • The Walmart expansion is a big project for Ukiah. • The project is controversial to many people. • Welcomes public testimony regarding the Walmart expansion project. • The purpose of tonight's meeting is twofold and will include Site Development Permit portion of the Project can be reviewed, the FEIR must be determined to be adequate and certified by the Planning Commission. • It may be review of the Walmart Expansion Project FEIR and Site Development Permit will not get finished tonight and will be continued for further discussion/review at a Commission meeting in December. • Advised project consultants will be available to participate in the discussion for the FEIR. • Also, explained the how discretionary review of the Walmart Expansion Project will proceed. • Introduced Brian Grattidge of ESA, City (Lead Agency) consultant for the Walmart EIR. Brian Grattidge of ESA, gave a PowerPoint presentation regarding an overview of the Ukiah Walmart Expansion FEIR and provided information about relevant/applicable topics that include project location, architect renderings & design concept, EIR process, selection of the EIR consultant and Administrative process, scoping/DEIR/FEIR processes, the five `Master Responses' contained in the FEIR made to public comments/questions about the existing Walmart store, scope of urban decay and job impacts, General Plan consistency, market area and existing and future shade. Other topics discussed in the presentation included information about the existing Walmart Store, 1992 Mitigation Measures and Conditions of Approval, the CIP that was adopted in 1999, Walmart business operations, scope of the what constitutes urban decay, how urban decay is analyzed, EIR General Plan consistency, market area and grocery stores, shade calculations, landscaping and the 50% shade coverage in 10 years requirement, EIR certification, and CEQA requirements in conjunction with the standard of adequacy of an EIR. Mr. Grattidge: • Noted CEQA review `basically takes the environment as it exists and does not attempt to go back in time and determine how it is that it got there.' For purposes of the EIR analysis as of March 2010, this is Walmart as it exists today and it is consistent with the Ukiah General Plan and corresponding zoning designation when the project was initially approved in 1992. Senior Planner Jordan commented on the PowerPoint topics as follows: Selection of EIR Consultant • Once it was determined an EIR was necessary for the Walmart Expansion project, a RFP went out for a consultant. The City received approximately 10 proposals and interviewed the top three consulting firms, including each firm's subconsultants. Based on this interview process, staff recommended Environmental Science Associates (ESA) and corresponding subconsultant W - Trans from CBRE to prepare the EIR. City Council approved staff's recommendation in this regard. MINUTES OF THE PLANNING COMMISSION Page 2 November 9, 2011 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Work begins on the EIR after payment is received from the applicant. The City pays the EIR consultant directly from the money deposited for this purpose. The contact between the consultant and applicant, in this case Walmart, is limited and what contact there is the City is aware of. This represents the City of Ukiah's process for the preparation of an EIR and this is the process that was followed for the Walmart Expansion Project. CEQA does not require this relationship. CEQA allows an applicant to prepare an EIR and submit it with the project to the local agency. Accordingly, some commenters have stated there was a conflict of interest because of Walmart's relationship with CBRE and asked how CBRE was selected. CBRE is an international real estate and economic/fiscal consulting firm. The CBRE real estate division is separate from the economic/fiscal consulting division. CBRE was the subconsultant to two of the EIR consulting firms interviewed as part of the selection process. Amy Herman of CBRE was interviewed as part of the selection process. Staff is of the opinion based on Ms. Herman's experience and expertise in fiscal and economic data collection, analysis and reporting was highly qualified to prepare the urban decay analysis and fiscal impact study for the Walmart DEIR. Prior to the preparation of the FEIR, CBRE dissolved its economic consulting division. Ms. Herman established ALH Economics and conducted the work on the FEIR. CBRE had no relationship or input on the preparation of the FEIR. Even without the dissolution of CBRE consulting, staff disagrees a conflict of interest exists. CBRE operated the real estate division and economic consulting division as separate units. There is no evidence to suggest or reason to believe Walmart, through CBRE's real estate division, unduly influenced the outcome of the urban decay analysis or fiscal impact report. The following topics are not part of the EIR discussion, but are being addressed because of public questions/concerns raised: 1992 Mitigation Measures & Conditions of Approval • As alluded to by Mr. Grattidge, the 1992 Mitigation Measures and Conditions of Approval are not related to the EIR or to CEQA, but since there were so many public comments made on this topic they are being addressed. • The 1992 approval of the Walmart store included mitigation measures and conditions of approval and there were many inquiries whether or not the project complied with those mitigation measures. • One of the mitigation measures required that US 101 south to Talmage Road exit ramp be reconfigured in some way. It specified one way the ramp could be reconfigured. It also stated an alternate design could be configured if it was approved by the City Engineer and Caltrans. An alternate design was in fact configured and approved by the City Engineer and Caltrans so the project is in compliance with this mitigation measure. • The second issue raised was the requirement to install sidewalks from South State Street along Hastings Road to Commerce Drive. Bike lanes and sidewalks were installed as required. The only section of bike lane that was not installed was at the intersection of South State Street and Hastings Road because of inadequate right-of-way. The project is consistent with this mitigation measure. • Street trees were to be planted on Hastings/S. State Street to Hastings/Commerce provided they comply with Airport Compatibility. No trees were planted in this area due to Airport Compatibility. The project is consistent with this mitigation measure. • There was concern expressed about the landscaping requirements whether or not 1 tree for every 4 parking were planted. Compliance with this mitigation measure was determined as part of the building permit review and prior to occupancy of the building. Based on the number of parking spaces, 147 trees were required and 221 were planted on the site. The project is consistent with this mitigation measure. • Lastly, there were comments related to the requirement pertinent to the carpool coordinator. The applicant did provide additional information about carpool for the sites and incentives are provided as part of the program. Capital Improvement Program MINUTES OF THE PLANNING COMMISSION Page 3 November 9, 2011 • Inquires were made about the CIP for the Redwood Business Park and whether or not Walmart was subject to the CIP at the time. • The CIP for the Airport Industrial Park (AIP) and Redwood Business Park did not exist when Walmart was initially approved. • The CIP was adopted in 1999 so projects approved prior to adoption were not subject to the fee. • The CIP did not exist at the time when Walmart was approved so no fees were paid. • There were questions about what projects are currently included in the CIP. They include Airport Park Blvd./Talmage intersection improvements, minor widening of Talmage Road and intersection improvements at Hastings Road/South State Street. • The CIP balance as of November 2, 2011 is $260,348.79 • The estimated CIP fee for the proposed Project is $17,835.99. Walmart Business Operations • There were questions about Walmart business operations and this aspect is not related to the EIR. • There were inquires as to whether or not the outdoor garden sales were permitted. Walmart did apply for a use permit and it was approved by the Planning Commission. • Another use permit that was approved was for seasonal outdoor sales for 30 days or fewer per year. • Panhandling is prohibited by City Code section 6091. • Camping is prohibited by City Code section 6091. • There were questions about Walmart's current hours of operation and what City limitations might exist for store operations. Currently Walmart operates 6 a.m. to midnight. Food Max and Safeway have 24-hour operations. • The City Code does not have any limitation on hours of operation. • As part of the original approval for Walmart there were no limitations placed on its hours of operation. • Based on information from the applicant, the majority of new jobs resulting from the expansion would be full-time. • Medical and vision services are available to Walmart employees. Brian Grattidge: • Added the aforementioned topics did come up so we wanted to address them. For purposes of the FEIR, these are separate from the environmental issues. • Noted the matter of urban decay was subject to numerous public comments. The topic came up during both the scoping and draft EIR hearings. • An EIR is not required to analyze a project's social or economic effects. • An EIR may trace a chain of cause and effect through economic or social change to a physical change in the environment. • An urban decay analysis is included in this EIR and is frequently prepared for big box development. • Although other socio-economic considerations such as quality of jobs and the nature of the businesses that may be misplaced are not EIR issues, they may be appropriate for consideration when the decision makers act on the Project. Senior Planner Jordan further commented with regard to the urban decay analysis: • Commenters stated Walmart has used CBRE for real estate services and this presents a conflict of interest for the EIR. • CBRE had a real estate division and economic/fiscal consulting division. • Amy Herman of CBRE (economic consulting division) prepared the urban decay analysis included in the DEIR. • After the DEIR was released, CBRE dissolved the economic consulting division. • Amy Herman subsequently established ALH consulting. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 4 ALH consulting prepared the responses to the DEIR. CBRE had no relationship or input on the preparation of the FEIR. There is no evidence to suggest Walmart influenced the urban decay analysis or fiscal impact report though its relationship with the CBRE real estate division. Brian Grattidge: General Plan Consistency • An EIR is required to consider the extent to which a project is consistent with applicable general plans and/or specific plan, in this case, the Ukiah General Plan. • A potential inconsistency does not necessarily mean the project will have a significant impact on the environment for purposes of CEQA. It is merely a factor to be considered in determining whether a particular project may cause a significant environment effect. • Final determination for an EIR as to whether or not it is consistent with the general plan can only be made by the decision making body and this body is the Ukiah Planning Commission. • A general plan must consider a wide range of competing interests. Market Area & Grocery Stores • The determination was deliberated prior to the urban decay analysis. • This analysis is not meant to encompass everybody who may potentially shop at Walmart. • The analysis is intended to capture approximately 85% of those who shop at Walmart. • The analysis takes into consideration competing retail shopping nodes, travel time/distance and population density. • Smaller local food stores do not compete directly to the extent larger and closer grocery stores so, such that grocery stores in Willits and Calpella and smaller markets in Ukiah are not considered as likely to be displaced. Shade Calculations/Landscaping 50% Shade Coverage Requirement • Has been the subject of comments. • Relates to the CEQA analysis for identifying what is or is not an issue for purposes of the EIR. • Is an important consideration with regard to the Site Development Permit aspect of the project. • The 50% landscaping standard for the AIP was not in effect when the original store was approved. • The level of shade that exists in the parking lot depends upon how it is calculated. • There are some difficulties in applying the City's shade requirements. • The calculation used for the draft EIR was 19% taking into consideration existing shade, mid-day. • For the drive isles, back-up spaces, and entryways and/or other paved sections of the parking lot calculated for the existing conditions is 8.3% shade. • Existing conditions under CEQA is not an effect even if the existing store fails to meet current or even past standards. • Since there is a net improvement using any of the methodologies, failure to meet current standards is not a significant impact. • For existing conditions under CEQA whether the calculation used is 8.3% or 19% acknowledgement that this meets the current 50% shade coverage standard is not an impact because the intent is to look at what the change is. In terms of future proposed shade using either the methodology for the draft EIR or other methodologies considered, the shade coverage roughly doubles from what is existing. Future proposed shade for the parking spaces is calculated at 45% for the DEIR and 15% for the FEIR using the Forest Service method that considers all paved areas using a 10 -year growth rate or 40% using the City of Davis calculation method over the entire area and 61% in the new parking area. Not many cities use the 10 -year growth rate method because it is rather difficult to do. What is involved is the existing parking lot that will be retrofitted and the parking area for the expansion. There is the expectation the expansion area would come closer to the 50% landscaping standard than the older existing parking lot. It is for this reason, the existing and proposed parking lot shade scenarios are addressed separately. Because the landscaping would be an improvement, it would not be considered an adverse MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 5 1 impact. The failure to meet the landscaping standard is a separate issue the Planning ll G Commission will addrC7J for the Site Development Permit. . 3 4 Senior Planner Jordan: 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Landscaping 50% Shade Coverage Requirement • The proposed project is subject to AIP Ordinance 1098 adopted in 2007. This ordinance requires 50% shade coverage of paved parking areas within 10 years of planting. This requirement was not in place at the time of the existing development and does not apply to the existing parking areas. The existing parking lot does not meet this requirement and is not required to comply with the 50% landscaping standard. • There is no requirement the existing parking lot must be retrofitted to comply with the 50% landscaping requirement. • The new parking for the expansion area is required to comply with the standard. • Consistency with the landscaping standards will be discussed during review of the Site Development Permit. City Attorney Rapport: • Is available to answer legal questions regarding the FEIR and Site Development Permit. PUBLIC HEARING OPENED: 6:44 p.m. Chair Pruden: Commenters either support or oppose that the EIR is adequate and should therefore be certified. Just because the EIR may be certified does not approve or disapprove the project. Again determining whether or not the Final EIR is adequate stands apart from the Site Development Permit portion of the project. Also, if commenters do not stay to the topic of the EIR process, they will be asked to sit down. Brent Lorenz: • EIR is adequate. Project is good for the community. Dennis Owen: • Is disabled and on a fixed income. • Would like to be able to one-stop shop as much as possible and purchase food and other items at a lower price more in keeping with his living situation. • Supports certification. Pamela Whitiker: • EIR is adequate and should be certified. • Supports that Walmart be allowed to expand so the community can take advantage of the affordable grocery component part of the project. • Noted Walmart donated money toward a worthy cause she is involved with. • Project is good for the community as it provides local jobs and lower prices. • Likes the concept of a one-stop shop because it is convenient. • Community will profit from the local revenue generated. Debbie Vinson: • EIR is adequate. • In terms of EIR and growth inducement, the project does provide jobs for handicapped, disabled and senior persons. • Lives in Redwood Valley and shops at Walmart every day. • Is disabled and likes to one-stop shop. • Supports the expansion so she will not have to spend the time shopping in other stores and it is affordable. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 6 • With regard to urban decay is of the opinion that smaller stores will not be affected by the expansion. • Does shop at other local stores. • Project would prevent sales leakage into other areas, such as Santa Rosa. Penny Vinson: • Is disabled. • Has friends that work at Walmart. • Walmart provides good jobs. Chris Brown: • Is the County air quality control officer. • Worked with Mr. Grattidge and staff concerning the EIR. • This is the first EIR project under the new air quality guideline recommendations that include GHG modeling and other analysis and provides for a much more expansive air quality analysis than has been seen before in an EIR document. • Mr. Grattidge has done an excellent job putting together the air quality section of the EIR document, noting the new guidelines that were adopted by the Bar Area Qir Quality Control District are stringent. • The air quality effects in the EIR analysis are adequate and acceptable, but is of the opinion the project should not move forward without some changes. • He will speak to the Site Development Permit portion of project when it is reviewed. Clayton Mulberg: • Has professional expertise for assessing road conditions and functioning adequacy. • Has some concerns about the EIR pertinent to significant and unavoidable impacts to traffic volumes and queues. • The current road conditions on Airport Park Boulevard are poor; The road was likely designed for light to moderate traffic and is inadequate for large volumes of traffic. • Is cognizant of the large freight trucks that use Airport Park Boulevard to accommodate Walmart. • Larger store means more trucks. • The EIR document does not require Walmart to help maintain Airport Park Boulevard. Local taxpayers pay to fix City roads. • The document mentions some efforts made for mitigation to traffic queues, but understands the CIP for this area remains unfunded for this improvement. • Addressed the issue of urban decay and noted there are a significant number of large stores already per capita in Ukiah. • Allowing Walmart to sell groceries will have a negative impact on the other local food stores by potentially decreasing the demand for sales and corresponding revenue for these stores. • Other larger local grocery stores pay a livable wage and while he is not familiar with the Walmart wage structure understands they are not comparable to these other stores. It is likely these jobs could be replaced with Walmart jobs if an expansion to include an increase in the sales area for food sales is approved. • Asked the decision makers to take a closer look at the supply and demand issue and traffic situation in the area of the project. • FEIR is not adequate in the area of traffic and urban decay. Dorotheye M. Dorman: • There is a severe conflict of interest with the hiring of a `spin off' subconsultant for the preparation of the urban decay analysis for the EIR who worked for CBRE Consulting that had a real estate division that had business affiliations with Walmart and an economic/fiscal consulting division that is now dissolved. This is an outrage. • This type of `spin off' company having a `revolving door of employees' is what has ruined our governmental regulatory agencies. • Our regulatory agencies are working with corporations instead of working on the public's behalf. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 7 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 • The acceptance of ALH to do the urban decay analysis is a disgrace. Jeff Spharler: • The EIR is adequate and should be certified. • Is currently a vendor at Walmart and is of the opinion Walmart is a `fantastic' company to work for. • Some of his employees have or are working at Walmart and enjoy it. • His company maintains the Olive trees in the existing parking lot and has knowledge that Walmart is looking at replacing them with a species that provides better shade canopy and requires less maintenance. • Supports Walmart having a 24-hour operation. • Does shop at Walmart while his wife does not; People that shop at Walmart will continue to do so no matter how big the store becomes. • The project will create 85 more jobs for people wanting to be employed with Walmart. Ukiah needs more job opportunities. Craig Davis: • Is the store manager of Walmart. • Appreciates the work in process and that has been done on the project by staff and the consultants. • With regard to General Plan Consistency, Goal G-7, which pertains to improving the appearance of the community's gateways is of the opinion given the location and a remodeled store will improve the gateway in this area. • Walmart is working with Ukiah Main Street Program in an effort to draw more people to the Downtown area. • The expansion project would be beneficial to the community. • Referencing the section on recapturing of existing sales leakage, is aware that many of his customers drive to other cities to shop. • It is important that Ukiah keep that tax dollar and sales revenue by encouraging people to shop locally. • Supports approval of the project. Pascal Milon: • Is a frequent shopper at Walmart. • Supports that Walmart expand. • Likes that food at Walmart; The food is cheaper and there is a variety. Sandra Wilhart: • EIR is adequate and should be certified. • Is grateful that Walmart hired her when she needed to work. • Walmart has paid 100% of her husband's medical bills. • Her family members shop at Walmart as well as other stores. Miro (Inaudible) • Is employed at Walmart and is thankful for his job. • Walmart provides employment for many people in the community. • An expanded Walmart will provide further employment opportunities in the community. • Highly supports the Walmart Expansion project. • The EIR is adequate and should be certified so Ukiah can enjoy an expanded Walmart with new affordable grocery products. An expanded Walmart is good for the future of our community. Serena Stanford: • Is employed at Walmart. MINUTES OF THE PLANNING COMMISSION Page 8 November 9, 2011 • EIR is adequate and should be certified so Ukiah can enjoy the amenities of an expanded Walmart. • Customers have expressed to her the need for an expanded Walmart that includes increased sales area for general merchandise and for food sales. • Has been a patron of `Super Walmart' stores in other areas and they are really nice. • The project will create new jobs for people in the community. • Has high regard for Walmart. • Project will provide one-stop shopping benefits for the elderly and the disabled. Chair Pruden: Reminded public speakers to stay on the topic of the EIR as it relates to environmental impacts rather than subject matter that pertains to the existing development and/or the proposed Site Development Permit. Laura Fogg, Speaking on behalf of herself and Jeannie Sheppard • The section relative to urban decay has not been adequately addressed. • The expansion project would result in long term decay of commercial buildings and disagrees with page ES4, Table ES -1, Summary of Impacts and Mitigation Measures, urban decay, Impact 4.3-1: The Project would not result in long term commercial building vacancies and therefore would not result in increased urban conditions and Impact 4.3-2: The Project in conjunction with other development would not result in long term commercial building vacancies and therefore would not result in increased urban decay conditions. • Has lived in Ukiah for a long time and has witnessed one shopping center after another decay after a new shopping center has been built and cited examples of such shopping centers that no longer exist. • Asked the Planning Commission to look closely at how the EIR reached the conclusion that no mitigation is required and that the level of significance after mitigation is `LTS' regarding urban decay and that the project would not result in long term commercial building vacancies and result in increased decay conditions. • The independent entity having a connection to Walmart should not have been allowed to prepare the urban decay analysis for the EIR and should have been prepared by an independent entity having no prior connection to Walmart. • While the decision to close the US Post Office on Oak Street was not up to the community and its decision makers, the Walmart Expansion project is. It is time for the community to say `enough is enough' and to encourage projects that benefit the community not draw from it. • Asked the Planning Commission to closely look at the project and whether or not it would be good for the community given certain potential impacts and cumulative impacts addressed in the DEIR. Ellen Faulkner: • Lives on a fixed income. • Appreciates that Walmart has affordable prices. • Finds problems with the adequacy of the EIR. • Does not agree with the EIR with regard to the issue of traffic and traffic impacts. The existing infrastructure is inadequate relevant to the issue of traffic and the potential significant impacts that will occur as a result of the Project and noted the taxpayers will have to pay to make the improvements to the infrastructure in order to accommodate expansions of operations and new developments leaving less money for subsistence purposes because taxpayers would be responsible for improvements to the infrastructure. • Supports the concept of `localization' and/or shopping locally and purchasing food that is grown locally so that the wealth generated stays in the community to benefit the people living here rather than going to large corporations whose corporate offices exist outside of the area and/or whose produce would comes from outside of the community or country. • Unlikely Walmart would support the local community. Jeffrey Blankfort: • The EIR is inadequate and inaccurate. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 • Since participating in review of the DEIR found information that CBRE consulting firm did, in fact, have along standing business relationship with Walmart. Specifically, CBRE Portfolio Services has sold 197 assets on behalf of Walmart. In other words, the largest real estate company in the world, CBRE, is the real estate agent to the largest commercial retail company in the world, Walmart. • The conflict of interest that occurred alone relative to CBRE should be sufficient grounds to negate the entire EIR because the public, staff and Planning Commission was not informed. • Commented on people having to work at low paying jobs with little or no medical benefits and how this is allowed to occur. Questioned the legality under CEQA guidelines of allowing intermediaries such as ESA to work with CBRE subconsultants on the urban decay analysis portion of the EIR. This appears to be unethical wherein the EIR was prepared by consulting staff from ESA under contract to the City of Ukiah, the Lead Agency, in accordance with CEQA. • He referred to CEQA guideline section 15151 on page 5 of the staff report that states, `An EIR should be prepared with a sufficient degree of analysis to provide decision makers with information which enables them to make a decision which intelligently takes account of the environmental consequences. An evaluation of the environmental effect need not be exhaustive, but the sufficiency of the EIR is to be reviewed in the light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among the experts. The courts have looked not for perfection but for adequacy, completeness, and a good faith effort at disclosure.' Accordingly, City staff was not aware of the CBRE connection with Walmart until he informed them. As far as he is concerned this is not ethical. • Is of the opinion the law is even worse according to the PowerPoint presentation by ESA consultant Brian Grattidge, that CEQA allows the applicant to prepare their own CEQA document for consideration by the Lead Agency. • Elaborated on the EIR process and what was allowed to occur without disclosure in this case with the preparer consultant and subconsultant. • It is good the City does not allow direct contact with the applicant and subconsultants, but how can this be enforced? • ESA and City staff do not believe there is a conflict of interest. CBRE is an international corporation with various business groups. • The claim is the economist working on the EIR was part of the CBRE consulting firm, which is a distinct business group was not part of commercial real estate business and this is not true. • CBRE consulting is or was until recently a division of CBRE worldwide. • The public was told that Walmart had no influence on CBRE's analysis but is of the opinion the analyst would act favorably toward such an influential and prestigious company as Walmart. • The information regarding CBRE subconsultants in conjunction with the preparation of the urban decay analysis of the Walmart EIR should have been disclosed according to CEQA guidelines. • CBRE's analysis regarding potential urban decay is insufficient/inaccurate because urban decay already exists in this community. If the EIR concluded that urban decay would be less than significant this is simply ludicrous. • If approved, Walmart would be directly competing with Food Max selling all products at a lower price so low that Food Max would be unable to compete, but according to the EIR Food Max has business or retail experience or sales to demonstrate it will probably survive. This is nonsense because anyone who has studied economics and the track record of Walmart would know it is a possibility Food Max would not survive if Walmart were to increase its sales area for food sales and merchandise. • Eventually, the beautiful shade trees along School Street across from the Courthouse might resemble parts of Oakland because of urban decay not to mention the closure of the US Post Office in the Downtown. The closure of the US Post Office was not mentioned in the EIR. There will be businesses in the Downtown that will close if Walmart is allowed to expand. • Imagine what two or three empty supermarkets would be like in this community. • The EIR talks about the fiscal benefit to the City with commercial development that provides for increased sales tax revenue and increased property tax revenues and this is nonsense. Whatever sales tax Walmart would generate would be reduced by the revenue losses from the MINUTES OF THE PLANNING COMMISSION Page 10 November 9, 2011 other stores and when some of these stores are forced to close, their property tax will decrease so there is no financial gain in this regard. • The EIR states Walmart's revenue will come from existing stores. • The EIR talks about new jobs that will be created for residents of this community with the expansion, which is ludicrous because what will be created is new low paying jobs and put scores of employees with good paying jobs and health benefits out of work. • Those persons criticizing the EIR were told the document was not intended to address economic issues for the lives of the workers in Ukiah's better paid supermarkets and the families that will be severely impacted should this project be approved. The economic consideration in this regard will be left to the decision of the Ukiah City Council. `Let's not wait for this.' • This is the kind of review where the members of the Planning Commission representing Ukiah have the opportunity to stand up against corporate Walmart and vote not to approve the EIR. Don Larsen: • Walmart was featured on the front page of the New York Times November 8 advising the corporation will be going into the finance business by offering check cashing services and charging lower fees. Walmart will be directly competing with banks and other financial institutions. • There are people who do not want to deal with banks anymore and are going to Walmart for financial services. This represents a problem in the future. • Walmart is planning to set up `full-fledged' banks inside their stores. Chair Pruden: Asked Mr. Larsen what this has to do with the EIR the Planning Commission is discussing tonight. Don Larsen: • Setting up banks inside Walmart stores represents an environmental impact. This is a new approach that has not been done before. Fred Innerebrer: • Preference is to shop at stores that have lower prices. • Supports that Walmart expand. • The Project will offer more jobs to people in the community. Ann Vanderhart • The Project presents urban decay and traffic impacts. • Asked the Commission to look closely at these issues in their review of the FEIR. Gene Hoggrene: • The Project does present impacts to the environment. • Does not dispute Walmart's right to expand the store. • He objects to a change in store hours to 24 hours per day, seven days a week because this will significantly impact other retail stores. • Is familiar with Walmart's business practices because his wife used to work at a Walmart store for 10 years and in his travels around the country has observed how this corporation operates. • Walmart has the ability to change and/or lower prices any time they want to the degree other stores are not be able to compete. He used the price of a can of soup as an example that was lowered to the point no other grocery store could compete. Wes Canby. • Of concern are the shade trees that create an environment for panhandling. • Walmart is very good about asking panhandlers/camping transients to leave if they bother customers. • The EIR is sufficient and should be approved. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 11 1 L 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 • This country was created to encourage competition and what the expansion of Walmart would do is to `stand up and take notice and compete.' Charley Vaughn: • Does not make a lot of money and does not shop at Walmart. • Does not support approval of the EIR and corresponding expansion project. His opinion likely represents that of other persons not speaking tonight. • People will lose their jobs if the expansion project is approved. • Walmart does not pay living wages or provide health benefits. • Walmart uses unfair business practices to manage competition. • Walmart lowers the employment standards in this country and this is what people have come to expect. Walmart is destroying our economy with their business practices. Nathan Porter: • He and his wife shop at Walmart as well as a variety of other stores. • Does pay attention to pricing and value. • Where a person shops is a matter of choice. • The EIR is adequate and encourages the City to certify it. • Commented on the topic of economics and it is a mistaken idea to think that the other stores somehow own those sales by offering values to customers. If Walmart can do a better job at creating values they should have the opportunity to do this. • Urban decay is present in Ukiah and has not occurred because of the presence of Walmart. It is a process that occurs in communities. • Competition is part of market conditions. • Sales leakage does occur because people shop outside of the area. • As long as the community is not willing to grow, sale leakage will occur. • There may be stores that are unable to compete with Walmart competition, but they certainly have the opportunity to do so. • People also have a choice where they want to work because employment is voluntary. If a person does not want to work at Walmart, he/she would not. Rex Ramsey: • Has been a resident of Mendocino County for some 30 years. • Is involved with planting trees for the good of the county. • Finds the proposed new parking lot to be `exciting.' • Would seek volunteers to maintain the trees in Walmart's parking lot, but is of the understanding Walmart plans to replace the existing trees with tree species that provide for a better canopy. • Is pleased to see Walmart expand. • Likes to shop at Walmart and will drive a hundred miles to do so to find a product he cannot find in other stores. • Larger Walmarts carry items that are not normally found in other stores. • Fully supports the Project. Chair Pruden: The Planning Commission will review the parking lot requirement during discretionary review of the Site Development Permit. Lasara Allen: • Was present for review of the EIR for the initial development of Walmart. • Because of Walmart businesses practices, this community is at risk for losing other businesses that financially support many people and offer a higher standard of living than Walmart does. • Does not necessarily agree with the statement that if a person does not want to work at Walmart, he/she would not because existing economic conditions make finding a job more difficult. A person may have to settle for a job at Walmart because there are no other employment opportunities available and work for less money than he/she would elsewhere. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 12 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Also, if Walmart made other businesses close, there would be fewer job opportunities available than there are currently. The infrastructure for traffic in Ukiah was not built to support the growing population. Airport Park Boulevard was built to accommodate light to moderate traffic at best and is still problematic. Traffic in the vicinity of Redwood Business Park and Talmage Road is congested. The expansion of Walmart is not a good idea for this community. The impact the project will have on the infrastructure in our community will be significant. Dianne Durham, on behalf of Sheila Blake: • The negative impacts of the Walmart Expansion Project far outweigh the positive. • Walmart already exists in Ukiah making money and lots of it. • The expansion of Walmart is not necessary. • Once again the negative impact on our community include: job losses and with this is the loss of health insurance, possible home foreclosures, more people having to impact the County with the need for food stamps and other living services to subsidize for the low wages and non -health benefits that Walmart gives its employees, traffic issues particularly in view of the Downtown US Post.Office, increasing noise and pollution levels, increase in safety and security concerns with a 24-hour store operation which this community has no need for, high probability for the closure of Lucky that will result in the loss of available food within walking distance for people living in the area and other relative negative impacts to the community. • Martin Luther King once stated `our lives begin to change the day we remain silent about things that matter.' • 1 will not remain silent with regard to the Walmart Expansion Project. • Asked the Planning Commission for the good of community to let Walmart remain at its current level of business operation. • Allowing Walmart to expand, a decision obviously motivated by greed will permanently impact Ukiah and Mendocino County in ways that cannot be recovered from. Dianne Durham: • Wonders if the decision makers have already made up their minds about the Walmart Expansion Project. • When the US Postal Service informed Ukiah about its intent to close the Downtown post office on Oak Street and expand to the Orchard Avenue location, public comment was allowed on the issue. Despite overwhelming opposition to the closure by the public and City officials an opposition based on sovereign researched facts related to the economic detriment to our community dispute the large opposition, the Downtown post office is going to close. We know now the public hearing and appeal process were a farce. The US Postal Service wants this closure and got its way. • Walmart wants the expansion and wonders if this million dollar operation of Walmart already has its expansion. • Asked the Planning Commission not to allow themselves to become like the Federal government agency that made a mockery of the public hearing for the US Post Office in downtown Ukiah. • Asked the Planning Commission to seriously consider the overwhelming evidence that the Project is not good for Ukiah. Common sense clearly indicates that the economic and environmental well- being of Ukiah will be gravely jeopardized by the Walmart Expansion Project. • Encourages the Commission to do what is right for the people and businesses in Ukiah. Terry Poplawski: • Commented on the element of how wealth is created. Wealth is created by paying workers their fair share of labor in place of profit. This is the system Walmart uses in its business practices. • Allowing Walmart to increase its sales area for food will put this store in direct competition with other stores that pay union wages. • Walmart is one of the leaders in the race to the bottom in the economy that this nation is experiencing. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 • Allowing Walmart to expand will take that much more dollars out of Ukiah and not in the pockets of workers that live here. • Is of the opinion the urban decay issue of the EIR is `too rosey', if not inadequate. Aurora: • Has lived in Ukiah for 12 of her 14 years. • Walmart is an entity that many community members turn to for cheap resources. • Most basic needs for people can be met at the Walmart store we currently have. • Allowing for an expanded Walmart would create a much larger carbon footprint compared to what exists for the current building footprint. • Supports Walmart's building footprint remains the same. Kerri Porter: • Shops at a variety of stores. • Supports certification of the EIR. • Where a person shops reflects values and is a personal choice. • It is immoral to limit someone's choice. People need to have choices where they shop. • People shop at Walmart by choice. • Not every grocery store carries the same quality produce. • Environmentally speaking, more carbon emissions are created by persons driving out of the area to shop. There are also more emissions created driving to multiple stores. • The only way to keep people shopping locally is to have an adequate market place in Ukiah. • Ukiah needs more choices. • Supports other retail establishments come to Ukiah. • Supports approval of the EIR. Alan Nicholson: • Commented on the traffic impacts in the EIR. • Traffic on Talmage Road between Highway 101 and Airport Park Boulevard is awful. • There will be an increase in the daily and weekend number of trips on these roads should Walmart be allowed to expand so the traffic congestion will be even worse. • No plan has been developed and approved by Caltrans that will solve any of the traffic problems on Talmage Road because a plan and a funding mechanism are not in place • The EIR somehow recommends the City adopt a Statement of Overriding Considerations approving the project on the grounds that while the project impacts are significant, they are unavoidable where the project objectives or benefits outweigh these significant traffic impacts. There are three issues with this reasoning: 1) It makes no sense to approve any project that will control/contribute to the continued degradation in the level of service (LOS) for traffic on Talmage Road and Highway 101 until an approved plan and funding mechanism are in place. In this way any additional projects will be required to contribute to the upgrade of these roadways rather than getting a `free pass' at the ultimate cost of taxpayers. 2) Why is the implementation of the project objectives being promoted by the EIR as an overriding consideration regarding traffic issues that will affect the public's safety. These traffic issues include inadequate merging lanes for traffic exiting Highway 101 and inadequate lanes for making a left turn at Talmage Road and Airport Park Boulevard. Both of these issues could create traffic accidents and as stated in the EIR is a significant safety hazard. 3) Almost all of the project objectives will be achieved if the City adopts `Alternative 3' of the project, `no footprint expansion' allowing `groceries sales within the existing store and expanded hours.' No footprint expansion will not add to existing traffic impacts. Project alternatives include: 1) No Project Alternative (Existing Conditions, No change); 2) Reduced Project Size; 3) Grocery Sales within Existing Store and Expanded Hours. • Is of the opinion the tax benefits to the City and the job gains from the expansion are illusory and therefore, should not be a basis for approving the expansion. • Alternate 3 meets all of the project objectives. It is recommended the City approve Alternate 3 as the best means of avoiding traffic impacts while also meeting project objectives. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 • Recommends the Planning Commission approves the EIR as presented and approve Alternate 3 as the superior environmental alternative. Tara McMillin: • Is employed by Lucky grocery store. • Is of the opinion if the Walmart Expansion project is approved, she will lose her job. • She is representing herself and all other Lucky employees. • Opposes the project expansion. • Her life has already been negatively affected by Walmart and explained the reason why. • Many customers of Lucky have expressed concern about the Walmart expansion and how it could potentially impact Lucky. • The 85 new jobs at Walmart that would be created as a result of the expansion do not offset the 100 plus jobs that will be lost at Lucky. Chair Pruden: Asked Tara McMilin if she knows the exact number of Lucky and Food Max employees because this information is not included in the EIR. Tara McMillin: Did not know the exact number of employees Lucky has and had no knowledge about Food Max. It was noted Lucky has over 120 employees. Pinky Kushner: • Has some objections to the EIR. • Lucky is a good and centrally located grocery store. Many customers walk to this store to shop. • Staff states on page 4 of the staff report that CBRE is an international real estate and economic and fiscal consulting firm. The CBRE real estate division is separate from the economic and fiscal consulting division. Even though there are two divisions of the same company they are still interlocked and this has not been fully accounted for. • Page 5 of the staff report refers to how an EIR is adequate or not adequate and further referred to CEQA Guidelines section 15151 that states `An EIR should be prepared with a sufficient degree of analysis .......... The Courts have looked not for perfection but for adequacy, completeness and good faith effort at disclosure.' Is of the opinion the lack of disclosure at the outset that CBRE was associated with Walmart should raise flags and make you Planning Commissioners request a new economic report on urban decay. • Page 6 of the staff report provides a summary of environmental topics that resulted in less than significant (LTS), potentially significant impacts and significant and unavoidable impacts. Requests `Urban Decay' be moved to significant and unavoidable impacts rather than LTS. • As addressed by public members tonight, urban decay will occur. • According to the Environmental Quality Act, urban decay is defined as `buildings that are decayed.' The buildings should include the houses that go into foreclosure, the shopping centers and small shops that `go under.' • John Pinches before he was a County Supervisor stated when Walmart first came in `there was a huge `sucking noise' in Laytonville.' • Is of the opinion aesthetics (light and glare) should be moved to significant and unavoidable impacts. The EIR states with regard to light and glare that lighting will be fully shielded and shine downward, but the problem with this is lights do shine downward but once they are downward the light goes back up into the heavens and this will happen 24 -hours a day. • The lights are shielded fully downward for the auto sales car lots in Petaluma, but they shine right back up into the heavens because the lights reflect off the shiny surfaces of the new cars and go right back upward. Even pavement will send lights back upward. • Yesterday, it was announced the State Department of the United States Federal Government Inspector General will review the Tar Sands Pipeline project in response to complaints concerning conflicts of interest in the preparation of the environmental impact statement for the Keystone XL Pipeline. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 15 Danny Jacques: • The EIR is more than adequate. • Talmage Road and the freeway ramp southbound existed long before Walmart and has always been a problem. • A 24-hour operation would be a deterrent for panhandlers/homeless. • In terms of urban decay and with vacant buildings in the Downtown because of business closures would not likely occur if they were more competitive with their prices. • New stores always make a draw but after a while people revert back to their shopping habits. • While there may be some environmental impacts, new jobs will be created so the issue becomes inconsequential because there are no jobs available in Ukiah. Ross Mayfield: • Is a life-long resident of Ukiah for 62 years. • Shops in Walmart and other stores. • Has observed many businesses come and go over the years. • The concern for loss of jobs was the same when Safeway and the other grocery markets came to town. • Competition is competition. • Urban decay in this community has existed for a long time. • Do not be afraid of change. Change happens, we adjust to it and make it work. • Fully supports certification of the EIR and expansion project. Fred Thompsen: • Likes that Walmart will offer more jobs. • Asked about plans for road improvements in the area. Mary Anne Miller: • The Planning Commission has no obligation to consider cheap groceries as part of the environmental impacts. • CEQA provides for a range of project alternatives that can be considered by the Planning Commission. • It is important to have a viable set of alternatives that can replace the project being proposed by determining whether or not it is environmentally superior. • The most significant environmental impacts regarding the project are Transportation and Traffic and Urban Decay. These impacts are significant and unavoidable. • Impacts having significant effects to the environment cannot be ignored and must reduced to less than significant with the incorporation of mitigation measures. • With regard to the environmental impact of urban decay, grocery stores will close as a result of the Walmart Expansion Project. • Supports Alternative 3, Grocery Sales within Existing Store and Expanded Hours (no footprint expansion). This alternative would add food sales to the existing Walmart store without expanding the building footprint. • Table 6-3 provides a breakdown of the floor plan for a project with no footprint expansion. • Recommends the public review Chapter 6 of the EIR that describes and evaluates the alternatives to the proposed Project as alternatives are developed to reduce or eliminate the significant or potentially significant adverse environmental effects that would result from development of the proposed project. • CEQA requires that an EIR describe and evaluate a reasonable range of alternatives to the proposed project, or to the location of the proposed project, and evaluate the comparative merits of the alternatives. • Table 6-5 provides a summary of the environmental effects of each alternative in comparison to the proposed Project. Alternative 3 would avoid impacts in five significant categories where the proposed project would result in potentially significant (PS) impacts that would be reduced to less than significant (LTS). MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 • Under CEQA provisions, the decision making body is obligated to approve the environmentally superior alternative. • Chapters 3 and 6 of the EIR addresses `Project Objectives' and noted the current Walmart operation is doing all these things. A new project is not necessary in order to meet their project objectives. • With regard to Objective 3, provide commercial development that creates new jobs for City residents. Jobs will be lost as a result of the Project. • The EIR does have alternatives to the proposed Project. Break: 8:31 p.m. Reconvene: 8:43 p.m. William B. Kopper: • Is an attorney and represents Citizens for Sustainable Commerce, a California Association, Steve Scalmanini, Alan Nicholson and Jeffrey Blankfort. • Provided written comments to the Planning Commissioners on the FEIR, dated November 9, 2011. • Specifically drew the Commission's attention to Mitigation Measure 4.10-2 and 4.10-4 of the EIR that are essentially the same. Page ES 14 of the FEIR, Mitigation Measure 4.10-4 states `Prior to issuance of building permits, the project applicant shall provide proportionate -share payments to the City of Ukiah for the planned improvements and reconfiguration of the interchange, which would improve traffic conditions to acceptable conditions at Talmage Road/Airport Park Boulevard and Talmage Road/U.S. 101 Southbound Off -Ramp. This mitigation measure is included in either option A (signal or a roundabout), or option B. The improvement is planned by the City of Ukiah at Talmage Road/Airport Park Boulevard (described in Future Transportation Improvements, above) would need to be implemented in addition to Mitigation Measure 4.10-2. This improvement is currently unfunded and does not appear in the City of Ukiah's Capital Improvement Program, so the improvement cannot be considered a feasible mitigation measure. Because this improvement addresses existing queuing problems, it is legally infeasible to require the applicant to pay more than its fair share for the cost of this improvement. The balance of funding required for this improvement, over and above the applicant's fair share, has not been identified. Without a funding mechanism, this impact would remain significant and unavoidable.' This mitigation measure is not a feasible mitigation, is misleading and does not comply with CEQA. The City cannot condition the issuance of building permits on the payment of a proportionate share payment if the City has no fee plan in place. As Caltrans suggests in comment W-11, the approval of the Walmart expansion would allow the Walmart Supercenter to go forward without their proportionate -share contributions to the City of Ukiah for the planned improvements needed at Talmage Road/US 101 Southbound Off -Ramp. Caltrans suggests the approval of the Walmart Expansion Project should be delayed until the improvements needed at Talmage Road/US 101 Southbound Off -Ramp have been identified, developed into a conceptual plan, priced, and included in a fee program. Caltrans comment W-11 states, `The DEIR given an unclear explanation about the potentially significant and unavoidable impact designation of transportation and circulation impacts due to the fact the interchange improvement is not on the City's existing capital improvement project (CIP) list. This would appear to be a technicality that the City is capable of remedying. During preliminary discussions with the City about feasible mitigation measures at Route 1-1/222, we were told the City intended to construct the mitigation and collect fair share mitigation funds to partially offset the costs. If this is no longer being proposed, we recommend delaying approval until mitigation can be constructed or fair share funds collected.' MINUTES OF THE PLANNING COMMISSION Page 17 November 9, 2011 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 • The FEIR fails to answer comment W-11 and explain why it would be infeasible to delay the project until the mitigation necessary at the Talmage Road/Airport Park Boulevard is worked out. As such, the EIR's response to Comment W-11 is inadequate and does not meet the requirements of CEQA, as well as fails to adopt feasible mitigation for project impacts at the US 101 Talmage Road intersection. • What will occur if the EIR is certified and the project is approved is that Walmart will get out of paying their fair share of the improvement because the issuance of a building permit is ministerial. • If Walmart complies with all the project conditions of approval and project plans, a building permit has to be issued and if there is no funding mechanism in place or plan, their fair share contribution cannot be assessed. • Mitigation Measure 4.10-4 is not an effective mitigation measure and will allow Walmart to get out of paying their fair share of the improvements. Caltrans in their comments to the DEIR brought this information forward, noting the issue to be a technicality. • Again, what needs to be done is to develop a conceptual plan, price it and include it in a fee program so Walmart can be assessed their fair share for improvements and provide for a feasible mitigation. This will not happen if the FEIR is approved. • Page 5 of the staff report regarding the Walmart Site Development Permit & Modification to Landscape Standards portion of the project, Table 1, mitigation measures and conditions of approval, #2b: Traffic is from the initial Walmart project. In mitigation measure 2b, Walmart was required within three months of the approved Site Development Permit to coordinate with Caltrans for constructing an additional access approach to Talmage Road east exist ramp. Such an approach would include a `T' intersection with Talmage Road on its southern border. Construction regarding the necessary improvements was required to be completed within six months of receiving all necessary permits. Walmart was allowed to construct an alternate design provided the design is approved by Caltrans and the City Engineer. According to staff, the mitigation measure allowed the construction of an alternate design if the design was approved by Caltrans and the City Engineer. An alternate design was constructed; therefore the project is consistent with mitigation measure/condition of approval #2b. • Did Walmart pay for the improvements as alternatively designed for the necessary improvements? • Did Walmart meet this condition and actually provide for a site plan and do the construction for the improvements? Did the City pay for improvements or did Walmart get out of that particular mitigation measure that somebody else paid for? This is information the City should have knowledge of when the store was first built. • Walmart is notorious at getting out of requirements and responsibilities with respect to their projects because there was a time that still exists in other communities where such communities were so desperate to have a project, they would cut all sorts of breaks just to get the project to come to fruition. • Would like to know if this is what happened in Ukiah for the Walmart store and mitigation measures/conditions of approval regarding transportation and traffic. • There are other issues very important to traffic that are not adequately addressed in the EIR and corresponding traffic study. Traffic consultant, Dan Smith, pointed out with regard to the work-up in the traffic study of the queuing that will occur at the southbound US 101 off -ramp was not sufficient because it did not provide any numbers as to how far out the queues would go under different circumstances. One circumstance would be the addition of Walmart and the other would be cumulative circumstance when Costco is added. The reason this is important is if the queuing is not properly addressed traffic backup becomes more severe and depending upon the length of the backup, minor rear -end accidents are likely to occur becoming much more serious when there is more high speed traffic. It is important to know the length of the queues and this information is not provided in the traffic study. • When asked for the queuing information was told the issue has already been considered a significant impact and this is all that has to be done. Is of the opinion an EIR has to be more than this and should provide information to the decision makers about the environmental impact and part of this information is about how serious the traffic impact will be and how long the queues will be. This information is not available. MINUTES OF THE PLANNING COMMISSION Page 18 November 9, 2011 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Is familiar with many EIRs but has never seen a scenario like the Walmart EIR where a company comes forward and says not all the traffic impacts have been considered for the project. Accordingly, a letter from Costco included in the EIR says their pm traffic is not going to be the 600 trips per hour, but rather 933 trips in the pm peak hour. The general rule according to the Institute of Traffic Engineers Trip General manual actual counts are supposed to be used instead of estimates through the use of equations to calculate the general traffic counts. While the actual counts are known they are not included in the EIR because this would show the traffic impacts for the project and under cumulative conditions would be much worse. Why would Costco come forward and provide information about traffic impacts which could be very detrimental to them. The only explanation in this regard is the concern the project would be approved without assessing any fees on Walmart for improvements and Costco would get stuck paying for them. Another issue concerning the EIR includes Condition of Approval 8b for the initial project that clearly states for every four parking spaces in the existing Walmart parking lot there is supposed to be one tree to shade four parking spaces. The initial project is clearly in violation with this project condition and, as such is relevant and should be addressed properly in the EIR. Why this is relevant is under CEQA, the whole of the project must be considered. The proposed project is adding new trees in the existing parking lots so the shading of the parking lot becomes relevant wherein you have to go back and determine what the appropriate shading is supposed to be. The last issue concerning the EIR being brought to the Commission's attention tonight is the issue of carpool. `Carpooling' was a requirement as a mitigation measure for the initial project relevant to traffic and air pollution. In this regard, Walmart was supposed to monitor the carpool program and make the appropriate adjustment so that the program would be effective. There is no evidence in the staff report for the Site Development Permit or the EIR that this was done. Walmart was also supposed to file a written report with the City Director of Community Development describing the carpooling project. There is no evidence this was ever done. The reason this issue is important is because there is no evidence the carpool program was ever addressed because carpooling is supposed to be a continuing mitigation measure for the proposed project moving forward. If this is the case, the EIR should contain much more information about the carpooling program whether or not it worked, what changes were made and the report made to the City. This information is missing. Susan Sher: • In reference to the democratic process, many Americans are saying they are sick and tired of watching large corporations suck the life out of communities in the U S. • Emphasized the importance the Commission look at the EIR with extreme scrutiny. We are not talking about a small business operation, but rather a large conglomerate with unlimited funds to get what it wants. • Is skeptical that Walmart believes there is no significant impact relative to urban decay and the likelihood that local grocery stores would close as a result of the Walmart Expansion Project. • Resides in the Wagonseller Neighborhood where many residents have low incomes are without cars and walk everywhere, including the Lucky grocery store in the Pear Tree Shopping Center. • It is very important to have local grocery stores and not just one Walmart superstore where people can just walk to. • The public has heard testimony that Walmart is getting into the banking and financing industry and medical clinics so this is not just a grocery and a dry goods store, it is a monolithic enterprise/large retail chain resulting in economic impacts having a net loss of jobs and a strong negative effect on existing retail establishments. The goal of Walmart is to be the largest retail store in town with proposed expansion and other development goals such as a bank and/or medical clinic. • Addressed the concept that Walmart is necessary because of the lower prices. Understands while we are experiencing economic hard times and want to take advantage of stores that offer lower prices, encourages people to look at the bigger cost. In order to save some money on our groceries, we might further add to the deterioration of school and local infrastructure as the tax base continues to decrease. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 19 Mariam Montesinos, Attorney for Walmart: • Commented on the mitigation measure that says you would pay improvement fees prior to issuance of a building permit and that this was basically an unfunded mitigation measure. • Noted many years ago EIRs used to say that if you had an improvement identified, you would pay your fair share. Then a lawsuit was brought against a Walmart project probably by Mr. Kopper in the City of Anderson where he contended this was not a feasible mitigation measure because a reasonable program plan was not in place that says this measure will get carried out. The Court agreed with Attorney Kopper and said you cannot say that improvement is a feasible mitigation measure. Ever since that day EIRs now have to say if a measure is not funded with a reasonable plan in place that shows that measure and/or improvement is going to be carried out you cannot say it is feasible and the environmental impact has to be declared significant and unavoidable. • What Mr. Kopper is complaining about to some degree in his comments above and in his letter to the Planning Commission is the result of a law he created. • What has occurred is while project improvements have been identified they are not currently part of your CIP. • The key to the mitigation measure is the part that says prior to the issuance of building permits ..., and the reason for this language is should the City decide to extend the list of improvements in the CIP to include some of the improvements identified in the EIR or the Costco EIR or somewhere else and if this list is increased by the time Walmart goes to pull a building permit Walmart will pay fees that cover those improvements. • Mr. Kopper is also familiar with a case in the City of Gault when preparing the EIR for that Walmart project, the City did not have an updated CIP. By the time the project went to public review the CIP had been updated to include a lot of the improvements. It is for this reason the City had to include the 'prior to issuance of building permits,' language in Mitigation Measures 4.10-2 and 4.10-4. • Providing this background information shows that Walmart is not trying to avoid anything, but rather abiding by the law created as a result of the City of Anderson lawsuit for a Walmart project in that city. • If the improvement fees are increased, Walmart will have to pay those fees. Chair Pruden declined to allow Debbie Vinson to comment again on a topic that was not relevant to the EIR. Ken Steely: • On the subject of urban decay, has observed over the years that shopping centers in Ukiah come and go and get redeveloped. • Understands it is scary to lose a major business in Ukiah, but this is part of the cycle of business life. • Worked in the grocery industry for 20 years locally and every time a new store comes to Ukiah, people shop at that store. Eventually people return to their shopping habits and things even out. • Recalls the same concern of adding another competitive grocery store when Raley's supermarket came to town in the mid -80s. • Agrees it is important to look at potential environmental impacts for new stores, but not with the attitude that the `sky is falling.' • On the issue of allowing for a 24-hour operation, finds this to be a convenience to the consumer. • Walmart offers items that other stores do not. • Does support the concept of shopping local first and he tries to do this, but it is not always possible. • Allowing Walmart to expand will make him think again about going out of town to shop or shopping on the internet for items that are not offered locally. • Many of the local stores including Walmart do support local events. • While Walmart certainly has its issues and this is the reason for public hearings, is of the opinion that Walmart is not the monster people perceive. • Supports approval of the EIR. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Susan Knopf: • Thanked Senior Planner Jordan for helping her to better understand the EIR process for the Walmart Expansion Project. • Also thanked the Planning Commission for the giving of their time without compensation and the many hours reviewing documents and preparing for the public hearing on the Walmart Expansion Project. • Has concerns about the FEIR: ■ Is concerned with such environmental impacts as air, water, and light pollution. The project will cause an increase in traffic, runoff from the parking lot, air pollution from the idling of car engines and other associated pollution impacts. • If the project causes other businesses to fail then there will be additional acres and acres of unused asphalt or blacktop that creates pollution and blight. • Is concerned about safety and issues that would involve service by the City police department. ■ It has been interesting to read how dramatically the police calls to the Redwood Business Park have increased since Walmart came to town. It is anticipated these police calls will go up even more if Walmart operates 24 hours a day and is allowed to expand. ■ The City is already stressed financially and is concerned the cost of providing the store with City services, such as road maintenance, police and fire will further encumber the City's financial situation. ■ In terms of lighting pollution, Walmart has made some attempts to subdue lighting in the parking lot and with the new project more of the same will likely occur by installing lighting that is downcast and energy efficient. The problem is the lighting on the building does create lighting impacts and recommends such lighting fixtures be a maximum of 15 feet high on the building, the parking lot, and other outdoor areas. ■ Is concerned with economic issues in that Walmart is a huge conglomerate with the ability to adjust prices any time such that other stores are unable to compete. ■ Walmart profits go outside of Mendocino County and California and do not help sustain our local economy. • Employees of Walmart are poorly paid, part-time without health benefits and as a result in some cases are forced to seek public assistance or pay for themselves to maintain a decent/modest life style. Ed Nieves: • The EIR is inadequate. Is particularly concerned with issues of traffic and urban decay. • Can attest to the traffic and congestion problems in the area of the Redwood Business Park and the safety concerns created as a result. • The Walmart project will only add to the traffic problems that exist in the AIP. • The issue of traffic impacts needs to be addressed in the EIR. • Big box retailers such as Walmart provide for depressing wages and no benefits. • Using his mother as an example of a person who took pride in shopping at locally -owned stores and in a variety of stores changed when she discovered Walmart and now buys everything at this store. This demonstrates how the arrival of a big -box retailer can displace sales at existing businesses which must then downsize or close resulting in job loss and subsequent declining tax revenue. • Supporting locally grown food establishments is very important to the health of people and to the local economy that would be compromised if Walmart is allowed to expand the sales area for food sales. • The expansion of Walmart would fail to produce real economic benefits to the community. • Does not support approval of the EIR. Steve Scalamini: • The Planning Commission was given documents that were submitted by Mr. Scalamini i.e., Walmart's Economic Footprint: A literature review prepared by Hunter College Center for MINUTES OF THE PLANNING COMMISSION Page 21 November 9, 2011 Community Planning & Development and New York City Public Advocate Bill de Blasio, dated January 10, 2010 and a publication entitled, `Key Studies on Waimart and Big-Box Retail.' • The obligation on the part of the public and decision makers is to determine whether or not the EIR document is adequate and represents `your' judgment and standards of the environmental situation. • Would like to comment on both sides of the EIR. • Regarding the traffic problems on Talmage Road and Airport Park Boulevard intersections, despite the details being incomplete as alluded to by a former public speaker the traffic impacts are significant and cannot be mitigated. • Addressed an annoyance that is reoccurring in the EIR document and referred to the number of `coulds' and `possibilities' versus the number of `likelys' and `probables in the document. • Regarding the information in the EIR, the `coulds' and `possibilities' relate to the possible risks that make the project not look so good. The `likelys' and the `probables' are all about the back- filing and good news they want to put in the report. The counter of these represents the goods and possibilities. • Two most significant examples of `back-filing' used in the document were Home Depot and Mervyns wherein Mervyns does not apply. • When Mervyns closed and the building purchased by Kohl's there was no competitor that went in that increased the square footage in the City with that kind of merchandise/goods. This is not what we are talking about with the Walmart Expansion Project because Walmart proposes to add more square footage for food sales and then whatever grocery stores go out of business the hope is they are back-filled. The scenario is essentially apples and oranges. The EIR wants you to believe and accept this. Is of the opinion this is nonsense. The same square footage was used for apparel products for the new Kohl's store as was used for Mervyns. No other competition came in this regard. The Walmart project does not represent the same sort of situation. • Regarding the topic of jobs that has been discussed is confused how this issue was addressed in the EIR because there is an economic component and physical impact report from the City that is a separate document. Is unsure what to say on this topic. However, since jobs were mentioned, drew attention to the publication, Walmart's Economic Footprint' and noted these document explains what happens when Walmart comes to town or expands. The document states the local economy will lose three jobs for every two jobs that are created at Walmart. • Suspects that of the many Walmart employees speaking none had threatened jobs. The only threatened job concern was from an employee of another grocery store. • Questioned how many of the Walmart employees supporting adequacy of the EIR actually read 10% of the document. • Regarding the tax revenue calculation done to the City General Fund is actually in a separate fiscal document analysis and found the document to be incorrect in some areas and will explain the details later. PUBLIC HEARING CLOSED: 9:28 p.m. Chair Pruden thanked the public for speaking. Chair Pruden commented Mr. Kopper and Mr. Scalamini have both submitted documents that require review by the Planning Commission and asked staff how to proceed because it would not work to take a break and read the documents in order to make an effective analysis as to the subject matter and charges made. Planning Director Stump recommended taking a break to determine how best to proceed. Chair Pruden asked the City Attorney to respond concerning the charged laid out tonight that there is a conflict of interest concerning the consulting firm and the urban decay element of the EIR. She is not sure how CEQA addresses conflict of interest and questions whether or not there is a concern. Staff is of the opinion there is no concern. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 22 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 City Attorney Rapport: • CEQA does not address conflict of interest. • There was a lot of references to disclosure in the public comments. The disclosure and the CEQA Guidelines referred to is the disclosure of environmental effects or information related to those effects. • There is nothing in CEQA that says a consultant has to disclose some relationship to an applicant. • State conflict of interest laws are addressed in the Political Practices Act. • Is not prepared at this time to have an opinion about whether or not there is an issue. • If there is an issue this would have more to do with remedies for the violation of that kind of conflict of interest and are either administrative sanctions or other remedies against the party that has the conflict. The economic conflict of interest of that type does not advise staff whether they can or cannot rely on a study that was done by a consultant. What staff did was look at the information they had available to determine whatever relationship the division of that company has had with Walmart and whether this had the potential to result in an exercise of undue influence over the way the report was prepared. Based on the information staff looked at concluded it would not be an exercise of undue influence both because of the separation between the divisions and the person who prepared the report was actually in a separate company when they prepared the response to comments. This in combination with just looking at the report itself should be able to provide staff with a sufficient basis to make that judgment as to whether there was any potential for undue influence. Break: 9:35 p.m. Reconvene: 9:45 p.m. Planning Director Stump: • Is of the opinion the Commission needs to read the documents provided by Mr. Kopper and Mr. Scalamini. • Staff reviewed the documents during the break and is of the opinion most of the concerns expressed in the documents have been responded to in the final EIR. Chair Pruden: • Implementation of the proposed project would result in three significant an unavoidable impacts that cannot be mitigated to a LTS level: ❖ Impact 4.10-2, Implementation of the Project would substantially increase potential traffic safety hazards by increasing the degree to which an existing queuing backup would exceed the available storage length. o US 101 Southbound Off -Ramp at Talmage Road ❖ Impact 4.10-4, Implementation of the Project would increase traffic volumes on area roadways under cumulative conditions. o Talmage Road / Airport Park Blvd would operate at an unacceptable level of service (LOS). o Talmage Road / US 101 Southbound Off -Ramp would operate at an unacceptable LOS. ❖ Impact 4.10-5, Implementation for the Project would substantially increase potential traffic safety hazards by causing queuing backups that exceed, or by increasing the degree to which queuing backups are projected to exceed the storage length under 2030 No project conditions. o The northbound right -turn lane on Airport Park Boulevard at Talmage Road would extend past the Walmart access, and the westbound Talmage Road left - turn lanes at Airport Park Boulevard would have maximum queues that extend beyond the available storage more than under Future No Project conditions. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 23 o The US 101 Southbound Off -Ramp at Talmage Road would have maximum queues that extend beyond the available storage more than under Future No Project. In order to allow the impacts that cannot be mitigated to go forward, the Commission would have to make a Statement of Overriding Considerations that require findings. A project with significant and unavoidable impacts may be approved if the economic, legal social, technological or other benefits of the proposed project outweigh the significant and unavoidable environmental effects of the project in which case these environmental effects may be considered acceptable. This process may be lengthy and will probably initiate quite a discussion. In addition to certifying the EIR is adequate, the Planning Commission must review the Site Development Permit for the project to make certain the expansion project is consistent with the Ukiah General Plan. Commission: • Would like to defer acting on the final EIR until the Commissioners have had the opportunity to review the new documents submitted by Mr. Kopper and Mr. Scalamini, as well as take time to further review and revisit the Transportation and Traffic to include corresponding studies and Urban Decay sections of the EIR. Commissioner Doble asked on the topic of fair share payment for improvements as to what controls the City has once the building permits have been applied for if the City has not determined what the fair share costs are to be. If a condition of approval is made, is it dependent upon the City then to determine those costs before the building permit is issued? City Attorney Rapport: • The City had a situation like this before when Friedman's Home Improvement came to Ukiah. The CIP for the Redwood Business Park had not been adopted. An EIR was completed for the project that identified what the probable mitigation measures would be for traffic impacts, but the improvement plan was not in place or a determination made as to what the fee would be. The condition was that Friedman's had to sign an agreement that they would pay their fair share as determined through a study that was done for the mitigations identified in the EIR. Commissioner Doble: Was this similar to a development agreement? City Attorney Rapport: It was an agreement between the City and Friedman's requiring Friedman's pay their fair share of traffic impact fees. Another approach as alluded to by Attorney Montesinos would be if the City had the CIP fee in place before a building permit was applied for, this would be a way to collect. The latter would probably be the preferable approach. Between the time identification is made as to what the CIP improvements are in an EIR and the time a CIP plan is actually developed and design the project in more detail situations can change in which questions can be raised. Commissioner Doble: Was the option of an assessment district or bonding for the necessary improvements to the Talmage Southbound Off -ramp discussed as a mitigation? Planning Director Stump: Is not aware this occurred as part of the EIR. Chair Pruden: The Redwood Business Park and/or Airport Industrial Park (AIP) is governed by Ordinance 1098 and does not recall discussion about an assessment district for the business park. Planning Director Stump: Since his tenure of 18 years with the City to his knowledge does not recall a discussion about establishing an assessment district for the AIP. The CIP for the traffic impacts did originate as a result of the 1996 program EIR that was done for buildout of the AIP at that time. Chair Pruden: Commented on the approximate $260,000 that currently exists in the CIP fund as of November 2, 2011 that is slated for three projects noting the estimated CIP fee for the Walmart Expansion Project is almost $18,000 so some figures regarding the CIP for the AIP have been discussed. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 24 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 !� !1•_...1 Stump: TL_ [_.. L_ AIM 2 L- ellen Planning Director .Slump: i hes remaining improvements 1U1 tnc Mir- as pari of rile sir are not 1egU11UU for `traffic impacts today or tomorrow' but rather are required for buildout of the Park. The City wants to move forward on getting those necessary improvements done. Ways in which to fund for those improvements in their entirety are being discussed. It is his understanding there is not enough funding available to make the necessary improvements at this time. Chair Pruden: Regarding the issue of traffic impacts, Mendocino Council of Governments has talked about a mitigation program and funding for the year 2030, which is not part of the current CIP. Planning Director Stump: • Suggested Amy Herman who did the urban decay analysis for the EIR comment on the conflict of interest issue that has been raised tonight. She is considered an extension of staff as a subconsultant to ESA hired to complete the urban decay analysis for the Walmart EIR. Amy Herman: • Is formerly of CBRE Consulting and currently of ALH Economics. • When she was with CBRE Consulting and doing urban decay studies involving Walmart projects or other projects, did not have an affiliation with other divisions of the company other than a mapping group to help support our work and contribute to the study. For purposes of the studies, there was no communication between divisions or who the divisions were affiliated with. • In terms of CBRE Consulting, there were many `lines of command' and had no knowledge at what point those lines of command overlapped other than to say the president of the company. The number of layers between the president and herself were numerous. • There was never any interaction between CBRE international real estate division and the economic and fiscal consulting division. • The approach, the methodology and the conclusions reached in the EIR were really no different than what have been done for any other study of this nature depending upon what the findings are and these kinds of studies were done for many types of applicants not just for Walmart applicants. Chair Pruden: Asked if Ms. Herman had a conflict of interest and/or was biased in any way? Amy Herman: There is no bias in any way. Commissioner Sanders inquired how long Ms. Herman worked for CBRE Consulting in the economic and fiscal division? Amy Herman: • In 1999 CBRE purchased another consulting firm she was affiliated with and was a principal of the firm at that time so she was acquired into CBRE in November of 1999 and worked there until July of 2011. Commissioner Brenner: 01. What do you mean that you do not know the chain of command? 02. Was the payroll through the larger firm portion of the firm, the international real estate division? 03. What was the timeline difference between the time you did the report and left CBRE Consulting and started your own firm? 04. Do you still reference CBRE Consulting on your resume? 05. Is it nice to say I used to work for CBRE Consulting, that you can trust my work and it is a reputable firm? 06. Do you use CBRE Consulting for getting other work? Amy Herman: MINUTES OF THE PLANNING COMMISSION Page 25 November 9, 2011 Al. Has no knowledge how the people in the property division reported as to chain of command or even if there was any overlap between the two groups, i.e., real estate division and economic/' fiscal division. A2. Yes. A3. The report was first completed in 2010 to include some updates toward the end of 2010 and as early as May 2011. Began her own firm in June 2011 and was an employee of CBRE Consulting until July 7, 2011. Confirmed there was an approximate two week overlap between the time she left CBRE Consulting and began her own firm, ALH Economics. A4. I worked for CBRE Consulting effectively for 20 years with the acquisition so this represents the bulk of my professional career. A5. This does not have any relevance. A6. To date, work has come from my personal and professional connections. Commissioner Brenner: His concern is about the relationship between international real estate division and economic and fiscal division that Ms. Herman was once affiliated with. It does not make any sense to hire someone to do the urban decay analysis fiscal impact study who might have had a connection to larger division, which in this case is the international real estate division that has had business relationships with Walmart. Ms. Herman was working for CBRE Consulting in the economic/fiscal division that was affiliated with the international real estate division of CBRE Consulting at the time when the urban decay analysis was written even though economic/fiscal division was dissolved prior to the preparation of the FEIR. There still exists that `I don't know' concern. It would have made more sense to have another consultant do the entire urban decay analysis and fiscal impact report. Chair Pruden: The Commission will have to determine whether or not the urban decay analysis is adequate and conclude whether or not to agree with the report. The `General Fund Analysis' is very interesting and adds another layer to the matter of economic decay she was not aware of. The Planning Commission has a lot of decisions to consider and make. Commission consensus: To continue certification of the Walmart Expansion Final Environment Impact Report and Walmart Expansion Site Development Permit to the regular Planning Commission meeting of December 14, 2011. M/S Sanders/Brenner to continue the Walmart Expansion FEIR and Walmart Expansion Site Development Permit and Statement of Overriding Considerations to the regular Planning Commission meeting of December 14, 2011. Motion carried (5-0). City Attorney Rapport advised public comment on the Walmart Expansion Project Environmental Impact Report is now closed. Staff advised the public will have the opportunity to comment on the Walmart Expansion Project Site development permit and Statement of Overriding Considerations once the EIR has been certified. MINUTES OF THE PLANNING COMMISSION November 9, 2011 Page 26 i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 COMMISSIONERS PRESENT Judy Pruden, Chair Jason Brenner Kevin Doble Linda Sanders Mike Whetzel UKIAH PLANNING COMMISSION December 14, 2011 Draft Minutes Excerpt COMMISSIONERS ABSENT None STAFF PRESENT OTHERS PRESENT Charley Stump, Planning Director Listed below, Respectively Kim Jordan, Senior Planner Jennifer Faso, Associate Planner Cathy Elawadly, Recording Secretary 1. CALL TO ORDER The regular meeting of the City of Ukiah Planning Commission was called to order by Chair Pruden at 6:04 p.m. in the Council Chambers of the Ukiah Civic Center, 300 Seminary Avenue, Ukiah, California. 2. ROLL CALL 3. PLEDGE OF ALLEGIANCE - Everyone cited. 4. APPROVAL OF MINUTES — November 9, 2011 The Commission made the following changes to the minutes: Page 15, Line 50, correct the spelling of Tarzan's Pipeline project to Tar Sands Pipeline. Page 25, Line 1, sentence corrected to read, 'The City wants to move forward on getting those necessary improvements done.' Page 26, Line 20, sentence corrected to read, 'It would have made more sense to have another consultant do the entire urban decay analysis and fiscal impact report.' Mary Anne Miller made the following change to the minutes: Page 16, Line 25, sentence corrected to read, `The Planning Commission has no obligation to consider cheap groceries as part of the environmental impacts.' M/S Benner/Sanders to approve November 9, 2011 minutes, as amended. Motion carried (5-0). 5. COMMENTS FROM AUDIENCE ON NON -AGENDA ITEMS 6. APPEAL PROCESS — Chair Pruden read the appeal process. For matters heard at this meeting, the final date to appeal is November 21, 2011. 7. SITE VISIT VERIFICATION - Site visit for agenda item 9B was verified. 8. VERIFICATION OF NOTICE — Agenda items 9A & 9B were properly noticed in accordance with the provisions of the Ukiah Municipal Code. 9. PUBLIC HEARING 9A. Walmart Expansion Project Environmental Impact Report (File Nos.: 09-42-EIR-PC/09-28- SDP-PC). Conduct a public hearing, take public and provide Planning Commission comment, and possibly adopt a resolution to certify the Walmart Expansion Project Environmental Impact Report MINUTES OF THE PLANNING COMMISSION Page 1 December 14, 2011 i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 (EIR). The project proposes a 47,621 square foot expansion of the existing 109,030 square foot store, for a total square footage of 156,651 to include expanded general merchandise floor area and expanded grocery sales floor area, indoor and outdoor garden centers, as well as the possibility of distilled alcohol sales, and a medical clinic and/or vision center on the 13.44 acre site located at 1155 Airport Park Boulevard, APN 180-070-38, in the Airport Industrial Park. Also, included as part of the project is a change in store hours to 24 hours per day, seven days per week, modifications to the landscaping, and other associated site improvements. The EIR analyzes an addition of 52,320 square feet for a total store size of 161,350 square feet (a 3% increase of the proposed square footage). This item was continued from the November 9, 2011 Planning Commission meeting. Public comment on this item is closed. Planning Director Stump: • Thanked the public for being present and taking an interest in the Walmart Expansion Project. • The consultants hired by the City to do the EIR are present to participate in the discussion and to answer questions. Brian Grattidge of ESA: • Tonight, the Planning Commission has the opportunity to comment on the adequacy of the Walmart Expansion EIR and decide whether or not to adopt a City resolution to certify the Walmart Expansion Project EIR. • Planning Commission will have the opportunity to review and consider City Resolution for adoption to certify the Walmart Expansion EIR (attachment 1 of the staff report) and the Memorandum from ESA that provides comments to the written comments received at the November 9, 2011 Planning Commission public hearing for the certification of the Ukiah Walmart Expansion Project Final EIR (Attachment 4 of the staff report). In addition to numerous oral testimonies, the Commission received a letter dated November 9, 2011 at the Planning Commission meeting from William D. Kopper, attorney at law. While CEQA does not require written responses to comments received after the Draft EIR public review period, which closed on August 18, 2011, these comments are provided to give the Planning Commission and members of the public additional information and requests for additional information where it is reasonable to do so with the hope of clarifying the analysis and conclusions in the EIR. None of the responses constitute significant new information within the meaning of CEQA Guidelines. • The Commission also received copies of two reports from Steve Scalmanini entitled 'Walmart's Economic Footprint: a literature review prepared by Hunter college Center for Community Planning & Development and New York City Public Advocate Bill de Blasio' and `Key Studies on Walmart and Big -Box Retail' whereby the consultant team has prepared a separate memorandum and referred to ALH Urban & Regional Economics memorandum of December 7, 2011 in this regard (attachment 5 of the staff report.) • Is available to answer questions. Senior Planner Jordan: • Staff requests the Commission view and consider as part of agenda item 9A a letter from the County of Mendocino Board of Supervisors dated December 6, 2011 regarding comments to the Walmart Expansion EIR, Site Development Permit and Statement of Consideration and a letter from public member Steve Scalmanini, dated December 12, 2011. Since public comment is closed on this agenda item these letters are provided simply for information purposes. • The intent of tonight's meeting is for Planning Commission to comment on EIR, ask questions of staff, and certify the EIR if the Commission determines the document is adequate. • A draft resolution certifying the EIR is provided for Commission review. Commission preference for discussion about the adequacy of the EIR was to review pages ES -3 through ES -15, Table ES -1, Summary of Impacts and Mitigation Measures for each of the environmental impacts addressed in the FEIR. MINUTES OF THE PLANNING COMMISSION December 14, 2011 Page 2 i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Commission: Aesthetics — No questions/comments. Section adequate. Air Quality — No questions/comments. Section adequate. Urban Decay Commissioner Sanders: • Referred to the Draft EIR, Chapter 4, Urban Decay and noted the document states `for purposes of the analysis, urban decay is defined as physical deterioration that is so prevalent and substantial it impairs the proper use of affect real estate, or the health, safety and welfare of the surrounding community (CBRE Consulting, 2010).' According to CEAQ, impacts to be analyzed in an EIR must be related to physical changes in the environment. While the CEQA Guidelines do not directly require an analysis of a project's social or economic effects because such impacts are not in and of themselves considered significant effects on the environment, the guidelines do state: An EIR may trace a chain of cause and effect from a proposed decision on a project through anticipated economic or social changes resulting from the project of physical changes caused in turn by the economic or social changes. The intermediate economic or social changes caused in turn by economic or social changes need not be analyzed in any detail greater than necessary to trace the chain of cause and effect whereby the focus of the analysis shall be on the physical changes'. CEQA guidelines also provide that physical effects on the environment related to changes in land use, population, and growth rate induced by a project may be indirect or secondary impacts of the project and should be analyzed in an EIR if the physical effects would be significant. Physical deterioration can include abnormally high business vacancies, abandoned buildings and industrial sites, boarded doors and windows, long term unauthorized use of properties and parking lots, extensive gang or offensive graffiti painted on buildings, dumping of waste or overturn dumpsters on property, dead trees or shrubbery, uncontrolled weed growth and homeless encampments. Generally, the economic and social effects of a proposed project are not considered by CEQA. Where economic or social effects of a proposed project will directly or indirectly lead to an adverse physical change in the environment, then CEQA requires disclosure of the resulting physical impacts. Economic or social changes need not be analyzed in any detail greater than necessary to ascertain what physical changes may occur as a result of economic or social changes. In the urban decay study four supermarkets were identified as being impacted should Walmart expand its grocery sales floor area and for the store to operate 24 hours per day. There was a lot of public comment about the selection of the EIR consultant and preparation thereof with regard to the controversy about the connection between CBRE international real estate division and the economic and fiscal consulting division. As a Planning Commissioner, we are required to report to the California Fair Political Practices Commission if there is any possible economic conflict of interest. Commissioner Sanders: Q1. Acknowledged the resumes for the consultants and corresponding subconsultants were impressive and asked when staff was interviewing the 10 potential consultants to do the EIR for the City of Ukiah, at what time did staff learn about CBRE International representing Walmart's real estate interests? Was the timeframe in and around when the City received a letter from Jeffery Blandfort advising that a possible conflict of interest exists regarding the Draft EIR? Q2. In the course of the selection of the consultant along with their subconsultants, did staff request Fair Political Practices (FPP) forms be completed for the consultant and subconsultants? Planning Director Stump: Al. Staff did not learn of a possible relationship between CRBE economic and fiscal division the subconsultant hired to complete the urban decay analysis and the international real estate MINUTES OF THE PLANNING COMMISSION Page 3 December 14, 2011 i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 division until around the time of the first Planning Commission public hearing for the DEIR. Staff may have become aware of a potential conflict right before Mr. Blandfort's letter to the City of Ukiah. A2. FPP forms are not used as part of the selection process but rather staff typically drafts a standard professional services contract in which the City Attorney oversees. Accordingly, if staff or the City Attorney in reviewing the contract believes there may be some sort of conflict of interest concerning the consulting firm this would raise a red flag where a filing of a FPP form may be required or follow some other measure. City Attorney Rapport: • The local conflict of interest codes address what disclosures apply to a consultant. • The Fair Political Practices Act requires the City to adopt a local code that meets State standards. • The conflict of interest provision of the FPP Act and definition thereof would apply to a consultant deemed to be the equivalent of a public official in which this person has an obligation to disclose a potential conflict of interest. The EIR consultant and subconsultants for the Urban Decay and Transportation and Traffic portions of the EIR do not come under this definition. A consultant in order to be subject to the disclosure and conflict of interest requirements has to either be hired to make a decision on behalf of the agency which is not the case here or, they have to serve in the capacity of a staff person. The Fair Political Practices Commission decisions of which there have many typically address situations where a consultant serves in the capacity of a staff person. The Commission has held repeatedly that a consultant is serving in the capacity of a staff person only if they perform all the regular functions of a staff person. The consultant hired to do a specific short term project like an EIR is always not considered performing in the capacity of a staff person so they are not considered a public official and not subject to the disclosure requirements and, therefore are not subject to the conflict of interest provisions of the Act. Chair Pruden: • The urban decay section appears to be the most controversial to the public. • Is of the opinion while the urban decay section is probably adequate, it is not as good a document as it could have been. Compared to other sections in the EIR, the Urban Decay section is not one of the stronger sections because it is the least quantifiable and most speculative of the all the sections in the EIR. • With regard to the urban decay section, it is speculative whether or not the Walmart expansion project will shut down three other grocery stores thus creating a blighted situation when such commercial retail establishments close and the buildings become vacant. The former Kmart building became Home Deport and the former Mervyn's store became Kohl's and represent examples of buildings that did not succumb to blight because the former uses closed. • You cannot factually say that Lucky's grocery store is going to close because of the Walmart Expansion Project. Commissioner Brenner: • Agreed, it is difficult to quantify urban decay. What he looked at was whether or not sufficient information was provided about the issue in terms of being able to make an informed decision about the project. Is of the opinion the urban decay section of the EIR provided the necessary information to make an informed decision. • EIRs are written to define the parameters in which possible environmental impacts are investigated. While the necessary information was provided about the environmental impact, the 'parameters' of the impacts fell short of addressing what the actual weight of impacts would be.' • The Draft EIR did an adequate job of defining what the impacts would be within the parameters of what was being looked at. It may be some of the impacts/issues looked at 'went out too far' such that they affected other things that are not necessarily evaluated under the current system and/or methodology for EIRs. This is where the EIR fell short and questions what can be done about this. MINUTES OF THE PLANNING COMMISSION December 14, 2011 Page 4 i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 • An EIR is given the task of addressing issues that are social in nature in which there may be no answers. Decision makers have the task of looking at the information presented so as to form opinions and exercise good judgment. • Within the context of an EIR, you have to look at whether or not the document provides the necessary information to make an informed decision. • The EIR definitely presented `unknowns', but 'unknowns' aside, the document did show the impacts that were listed. It is correct the impacts identified were evaluated, but again there was a number of subject matter that was not looked at in the EIR. However, the Commission is being asked to make a decision based on legal requirements as part of the EIR methodology rather than about some of the information provided or consideration about information that was not included. Overall, the document did adequately address the project impacts/issues the community requested. • Supports that El Rs go deeper with regard to information. • It was not difficult to do further research to go beyond what the EIR evaluated in order to formulate and draw effective conclusions about the environmental impacts identified. Chair Pruden: • Cited an example of identifying impacts that affect other things that are not necessarily evaluated. For instance, Walmart wants to expand its grocery space that includes a bakery. There are bakeries in town. Whether or not the proposed bakery would impact other bakeries was not included in the document. This does not mean the document is inadequate, but it did not cover all the basis. • Found the environmental document raised more questions than it answered. While the EIR raised a lot of issues, the purpose is not to answer every question. There is probably no EIR that can answer any question. • The Commission only deals with the urban decay definition in the EIR and not blight. The urban decay definition is quite different than that of blight. Commissioner Brenner: • Explained we are only allowed to evaluate the quality of the EIR and he had to do research in order to fill in the gaps as they relate to urban decay and corresponding blight issues of which if issues related to blight were allowed in the EIR this would have painted a different picture for him. Commission Whetzel: • Is of the opinion the EIR provides the necessary information in order for the Planning Commission to make an informed decision. • It is doubtful the shopping habits of people would change should the Walmart Expansion Project be approved. • It is ashamed the Commission has to deal with a document that only has to be adequate. • The EIR covers the impacts to the point the document is adequate and the Commission has to make a decision on the information presented. Chair Pruden: • Some of the sections in the EIR are adequate and some are less. Commissioner Doble: • With regard to Urban Decay, the document does address the possible closure of some grocery stores so this was forthright. • It is possible some of the details contained in the document should be dealt with on a project -by - project basis rather than in the EIR. Commissioner Sanders: • Referred to Volume III of the DEIR, page 7 and asked if the Commissioners had concerns about the information regarding the current market conditions that state, `the field research, market research, and interviews that CBRE Consulting conducted indicated that many of the retail MINUTES OF THE PLANNING COMMISSION December 14, 2011 Page 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 centers in the market area and the surrounding environs are performing reasonably well. New retailers have continued to relocate in the area despite the economic downturn either by taking over vacant store spaces or by moving into new build -to -suit properties. Moreover, retail landlords appear to be making necessary improvements to keep their properties competitive and/or prepare for longer term redevelopment of their sites.' Commissioner Brenner: • Did not receive the same feedback from the different leasing agents he spoke to. In fact, the information is just the opposite and found that it is difficult to lease vacant retail store space. Chair Pruden: • Economic decay is directly tied to how a building presents itself. While Ukiah Valley Lumber Company has gone out of business, the building, now vacant, is in very nice shape in terms of paint and presentation. Despite the fact the building is vacant, as long as the building is maintained in a presentable manner, this does not represent urban decay in our community. • The decay is the actual a physical deterioration of a building. As long as a building is well maintained, there is no decay. Commissioner Brenner: • When looking at the definitions and information, the EIR covers the basis. While he had different input, different input is allowed in an EIR. Chair Pruden: After reading Amy Herman of ALH work on the FEIR in context with other documents presented, there are opposite opinions as to what Walmart does to a community. It may well be that none of documents can be used as supporting documents because the information is `polar opposite.' Commissioner Sanders: • While not an expert, the characterization of the current market conditions is not based on reality. Commission consensus — urban decay • Commissioner Sanders - Primary concern is why there was not full disclosure about CBRE International Real Estate division that represents Walmart interests and CBRE economic and fiscal consulting division that prepared the urban decay section of the DEIR. • Commissioners Doble, Brenner, Whezel, Chair Pruden — EIR could be better, but is not inadequate. Geology and Soil Chair Pruden: Only concern in terms of safety is the stacking of merchandise inside the store. This appears to be a common practice in big box retail stores. This matter does not get addressed in the EIR. No other questions/comments. Section adequate. Hazards and Hazardous Materials No questions/comments. Section adequate. Hydrology and Water Quality Commissioner Sanders: Impact 4.6-5 states, 'the proposed expansion of the existing Walmart building and the parking lot would result in an increase in impervious surfaces onsite. This would decrease storm water infiltration increase storm water flows, causing downstream flooding. This is a potentially significant impact to water quality.' Read that impervious surfaces would increase by 61,000 square feet. Chair Pruden: The aforementioned occurs based on the removal of lawns to the north with the expansion of the building and parking lot. The question is do the mitigation measures sufficiently suffice MINUTES OF THE PLANNING COMMISSION December 14, 2011 Page 6 i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 the expansion in this particular area and if this section has adequately identified the probiem and can be addressed. Commission: Mitigation measure 4.6-5 states the applicant shall design, implement, and maintain a storm water retention and/or detention feature(s) such that there would be no net increase in project condition peak flows.' Section adequate. Land Use Planning Chair Pruden: The project represents an expansion of less than 50,000 sq. ft. where the tendency is to look at it as a new project. There is typically information and studies about new Walmart stores and/or the relocation of stores within communities and the impacts thereof, but not so much documentation/facts about what expansions would do in communities. Commissioner Doble: There is not a lot of information about what Walmart does within their existing footprints of buildings because Walmart stores often change what they sell. No other questions/comments. Section adequate. Noise Chair Pruden: This section deals with noise from construction that is regulated in this community. Noise generated from a 24-hour operation is not part of the EIR process. No other questions/comments. Section adequate. Commissioner Doble: In a roundabout way the 24-hour operation is addressed with relation to traffic noise i.e., Impact 4.8-3, Traffic associated with the Project in combination with other local development would not result in cumulatively considerable noise increases.' Staff: Additionally, Impact 4.8-2, Operational activities associated with the Project could increase ambient noise levels at nearby noise -sensitive land uses. This impact would be potentially significant and 4.8-4, Noise associated with the Project in combination with other local development would not result in cumulatively considerable noise increases' do address operational activities. Chair Pruden: This section also deals basically with maintenance that is to be done during the day as opposed to nighttime. Brian Grattidge: Acknowledged that maintenance was looked at as a potential 24-hour activity which was a concern and this is the reason for Mitigation Measure 4.8.2 that states, 'All on-site maintenance shall occur only during the daytime hours between 7:00 a.m. and 7:00 p.m.' because the parking lot extends so far north where maintenance activities could be heard. ESA also looked at 24-hour operations at the loading docks that include forklifts and other noises associated with loading docks, which is always a concern for big box retail. Ambient noise generated from the parking lot from car doors slamming and cars turning on and off as well as other noises one would expect from a 24-hour operation was taken into account. No other questions/comments. Section adequate. Public Services and Utilities No questions/comments. Section adequate. Transportation and Traffic Chair Pruden: • The document has identified significant environmental impacts that cannot be mitigated. MINUTES OF THE PLANNING COMMISSION Page 7 December 14, 2011 i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Brian Grattidge: • The document does identify why the impacts cannot be mitigated. If there was a Capital Improvement Program (CIP) in place and the corresponding mechanism attached to the project the impacts would be considered mitigated. Chair Pruden: • While most of the impacts identified for Transportation and Traffic can be reduced to less than significant with the incorporation of mitigation measures, but impact 4.10-2 (Implementation of the Project would substantially increase potential traffic safety hazards by increasing the degree to which an existing queuing backup would exceed available storage length), impact 4.10-4 (Implementation of the Project would increase traffic volumes on area roadways under cumulative conditions) and impact 4.10-5 (Implementation of the Project would substantially increase potential traffic safety hazards by causing queuing backups that exceed, or by increasing the degree to which queuing backups are projected to exceed, the available storage length under 2030 No Project conditions) would remain significant and unavoidable since they cannot be mitigated because these mitigated measures are unfunded and are not included as part of the City's CIP. Commissioner Brenner: • Is of the understanding that having a design in place would facilitate the anticipated costs from which improvement fees can be determined. Brian Grattidge: • Really not feasible to move forward with a design without the required funding mechanism in place for the Project. Chair Pruden: Having a design for the improvements does not take care of the traffic impacts since the improvement required by the Mitigation Measure referenced above for each of the impacts identified is unfunded and not a part of the City's CIP, the measure cannot be considered legally feasible such that the impact remains significant and unavoidable. Commissioner Sanders: • It appears an associate planner for the State Department of Transportation suggests the project be delayed until the mitigation measures for the impacts are formed and/or the fair share of funds for the traffic improvements collected. However, the associate planner does not have the authority to make that request. Chair Pruden: It may be at some point during the process the Commission will have to entertain and approve a Statement of Overriding Considerations pursuant to CEQA Guidelines for a project with significant and unavoidable impacts if the economic, legal, social, technological or other benefits of the proposed project outweigh the significant and unavoidable environmental effects of the project in which case these environmental effects may be considered acceptable provided the necessary Findings in support of the Statement of Overriding Conditions can successfully be made. Commissioner Sanders: • It is possible the mitigation costs would be in the millions and likely not be plausible until 2030 and/or 18 years. Commission: • Some of the impacts identified that without funding are significant and unavoidable. • The transportation and traffic environmental impacts in this section have been adequately identified. Global Climate Change MINUTES OF THE PLANNING COMMISSION Page 8 December 14, 2011 i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 No questions/comments. Section is adequate. Biological Resources No questions/comments. Section is adequate. Commissioner Dobler: • The EIR provides project alternatives selected for further consideration and they include 1) No Project Alternative (Existing Conditions, No change; 2) Reduced Project Size; 3) Grocery Sales within Existing Store and Expanded Hours and found it difficult to understand the difference between the no project and the no expansion footprint alternative and referenced Table 6-3, Proposed Project and No Footprint Expansion Floor Plan on page 6-11 of the DEIR. The no footprint expansion alternative results in a 25,000 sq. ft. of dedicated food sales area and questioned whether or not this currently exists. Brian Grattidge: What was looked at as part of a project alternative is an alternative that significantly reviews or avoids one or more potentially significant impacts while achieving most of the project objectives. Included in that array is the required 'No Project' alternative. Table 6-5, Summary of Alternatives on page 6-14 compares the environmental effects of each alternative in comparison to the proposed Project. The potentially significant (PS) and Less than significant (LTS) impacts are shown prior to mitigation with an indicator of whether the alternative impact is comparatively greater or lesser than that of the Project. The No Project Alternative would avoid all potentially significant Project impacts to all resource areas, including aesthetics, air quality, biological resources, hazards, hydrology, noise and traffic. Queues that extend beyond available storage at the US 101 Southbound Off - Ramp at Talmage Road would remain under the No Project Alternative, The No Project Alternative would be the environmentally superior alternative, but does not meet any of the objectives and goals of the project. CEQA required that a second alternative be identified when the 'No Project' alternative emerges as the environmentally superior alternative. Alternative 3, No Footprint Expansion would avoid impacts in five significant categories compared to the proposed Project, but the significant unavoidable impacts that would result from the proposed related to traffic would not be reduced to a less than significant level. Alternative 3 may not meet most of the project objectives provided for on page 6-2 of the DEIR. The difference between No Project and the No Footprint Expansion is the No Footprint Expansion will add food sales to the existing Walmart store without expanding the building footprint. Approximately 25,000 sq. ft. would be dedicated to food sales and the general merchandise sales floor area would be reduced in comparison to the proposed Project. The total square footage under this alternative would be identical to the existing store. Only interior modifications to the existing store would occur under the scenario in order to allow for grocery sales. Additionally, the store would extend its operating hours to 24 hours per day, seven days a week whereas the No Project alternative, the proposed Project would not be undertaken and no development would occur on the site. The existing store and its associated parking, landscaping, and other infrastructure would remain in its current condition. Hours of operation would remain as 7:00 a.m. to 11:00 p.m., seven days a week and no grocery sales would occur. Consideration of a No Project alternative is required under CEQA. The purpose of describing and analyzing a no project alternative is to allow decision makers to compare the impacts of approving the proposed Project with impacts of not approving the proposed Project. It is possible within the parameters of existing approval to consider a project mix. ESA consulting tried to look at the No Footprint Expansion alternative as a more 'radical makeover' of the store, which was to displace a large area of the existing square footage to devote to grocery sales, 24 hours a day, seven days a week. This alternative gives Walmart the opportunity to reallocate space within the existing building footprint in order to reallocate space for a grocery component. MINUTES OF THE PLANNING COMMISSION Page 9 December 14, 2011 i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 • it is true Walmart could sell groceries today, but not operate 24/7. This would constitute the primary difference between a No Project alternative and a No Footprint Expansion alternative. Commissioner Whetzel: Inquired with regard to the original Site Development Permit, Walmart was approved for 30,000 additional square feet and why this was not included in the EIR as an option. Brian Graftidge: This space was essentially partly used up in the original site plan and not having 'preapproval' to use what was originally envisioned in the 1992 EIR has to go through the Site Development Permit process. Having to go through the Site Development Permit process now, takes into account the existing conditions and not what could have been the size of the building. Walmart does not have any entitlements that allow the store to expand even though the original EIR might have ultimately envisioned a bigger store than what was constructed. Senior Planner Jordan: Acknowledged the original Site Development Permit did allow for an additional 30,000 square feet of which approximately one half of the square footage became part of the existing store. Commissioner Whetzel inquired about the remaining 15,000 square feet. Senior Planner Jordan: • A Site Development Permit expires after a certain period of time, which is typically 24 months Commission consensus: Commissioners Whetzel, Doble, Brenner and Chair Pruden: The Walmart Expansion Project EIR is adequate overall, does identify the environmental impacts and therefore, supports the City Resolution to certify the Walmart Expansion Project EIR. Commissioner Sanders: Supports the mitigation measures identified in the EIR document except those for Transportation and Traffic and Urban Decay. Commissioner Brenner referred to Attachment 1 of the staff report, City Resolution that certifies the Walmart Expansion Project EIR and inquired regarding section 'B' and whether the address reads correctly, 'The City retained ESA of San Francisco, California, to prepare the Draft and Final EIR documents for the proposed project.' Brian Graftidge: Confirmed the address referred to in the Resolution is correct M/S Whetzel/Dobie pursuant to CEQA Guidelines Section 15090 the Ukiah Planning Commission adopts City Resolution certifying the Walmart Expansion Project EIR with the following roll call vote: AYES: Commissioners Whetzel, Brenner, Doble, Chair Pruden NOES: Commissioner Sanders Break: 7:20 p.m. Reconvene: 7:27 p.m. MINUTES OF THE PLANNING COMMISSION Page 10 December 14, 2011 Ukiah Walmart Expansion Environmental Impact Report Certification Appeal City of Ukiah City Council January 18, 2012 Cit tali P' ESA _4i Approvals Required for Expansion to Occur 1. Certification of EIR (subject of tonight's public hearing -limited to reasons for the appeal) Occurs only after EIR Certification (future public hearing) 2. Adoption of Statement of Overriding Considerations — based on the benefits of the project 3. Approval of Two modifications to the Airport Industrial Park Planned Development (AIP PD) Ordinance 1098 landscaping standards 4. Approval of Site Development Permit Step 1: Environmental Impact Report EIR (Tonight's Meeting — Limited to Reasons for Appeal) OAn EIR is an informational document. The City must determine if it provides the information needed to fully understand the environmental consequences resulting from the project. The EIR is an objective analysis of potential environmental impacts and its authors do not support or oppose the project. Olf the City concludes that the EIR accomplishes this, then it can "certify'the document as meeting all legal requirements. Off the City concludes that the EIR does not provide all the information it needs to fully understand the environmental consequences resulting from the project, it must clearly articulate what information is needed for the document to meet legal requirements. OCertifying the EIR does not mean that the City must approve the project. 1/18/2012 1 Step 2: Statement/Findings of Overriding Consideration (Future Public Hearinq(s)) OThe EIR indicates that the Wal-Mart expansion project, when combined with otherfuture development in the Airport Business Park, will cause significant traffic impacts. OThe EIR also indicates that there are street improvements that can be made to significantly lessen those impacts, but because at this time the funding source for those improvements is uncertain, the construction of the improvements is also uncertain. Oln this circumstance, if the City decides that it wants to approve the Wal- Mart expansion project, it must weigh whatever benefits the project provides to the City against the traffic impacts that would be created, and decide if approval of the project is appropriate. Off the City decides that the benefits outweigh the traffic impacts, it must make specific findings supporting its conclusion before it can actually approve the project. If it cannot make the findings, then the City cannot approve the project and cannot proceed to Step 3. Step 3: Site Development Permit (Future Public Hearing(s)} OA site development permit is the permit Wal-Mart must secure to move forward with its expansion project. Off the City makes specific findings supporting a conclusion that the benefits of the project outweigh the traffic impacts, then it can proceed to Step 3, and consider granting the site development permit. ❑Landscaping modification requests (shade coverage and landscape coverage) OSite Development Permit findings (general plan, airport compatibility criteria, zoning, site and architectural design) Tonight's meeting ❑Conduct a public hearing (limited to reasons for appeal) OPresentation from staff and ESA, EIR Consultant CIPresentation from Appellant OQuestions from City Council ClOpen public hearing for Public Comment ❑City Council discussion and deliberation ❑Outcomes Uphold the appeal and overturn the certification of the EIR Deny the appeal and uphold certification of the EIR Request additional information be provided Continuethe item as requested by the appellant 1/18/2012 2 Project Location 1155 Airport Park Blvd The Proposed Project Expansion and alteration of the existing Walmart store from 109,030 square feet (SF) to 156,651 SF (the EIR analyzes a maximum project size of 151,350 SF). • 13.44 acre site Key project components include: - 24 hour operations (from current 7 am to 11 pm) - Expansion of grocery and general merchandise sales areas - Addition of an indoor garden center - Landscaping modifications, including replacement of olive trees, additional shade trees (and parking lot tree planters), new shrubs and ground cover, less turf - Additional energy -savings features - Update of building exterior and signage - Elimination of Tire Lube Express California Environmental Quality Act (CEQA) Compliance Environmental Impact Report Process 1E* S,�C��"�.�'�u E*`�'j �� i, ..i 1/18/2012 91 Key Dates — EIR Process • Notice of Preparation issued March 11, 2010 Scoping Meeting held March 18, 2010 Scoping Report presented to Planning Commission June 9, 2010 Draft EIR published July 5, 2011 Hearing Held August 10, 2011 • Review Period ended August 18, 2011 • Final EIR issued October 28, 2011 First Final EIR Certification Hearing November 9, 2011 (continued) Second Final EIR Certification Hearing December 14, 2011. FEIR certified by Planning Commission Draft EIR • An environmental impact report (EIR) is a detailed informational document that analyzes a project's potential significant effects on the environment and identifies mitigation measures and reasonable alternatives to avoid significant effects. • 57 impact statements - 16 potentially significant - 3 significant and unavoidable (all traffic -related) =Three Project Alternatives Analyzed - Two additional alternatives assessed and "screened out" form further analysis Final EIR • Responses to Comments on the Draft EIR - 24 written comment letters received - 489 individual comments (including hearing) - Master Responses The Existing Walmart Store (Baseline) Scope of Urban Decay and Jobs Impacts General Plan Consistency Market Area Existing and Future Shade - Responses to each comment 1/18/2012 91 Certification • Certification Hearing continued after receipt of written comments on November 9, 2011 – Although not required, a written response was prepared for the Planning Commission • Final EIR certified December 14, 2011 • Certification of the EIR must occur prior to approval of the project to comply with CEQA, but does not represent "approval" of the project – The Planning Commission will separately consider approval or denial of the project—the EIR neither supports nor opposes the project Standard of AdegUacy of an EIR • An EIR should be prepared with a sufficient degree of analysis to provide decision makers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among the experts. The courts have looked not for perfection but for adequacy, completeness, and a good faith effort at full disclosure. – CEQA Guidelines Sec. 15151 • CEQA does not require a lead agency to conduct every recommended test and perform all recommended research to evaluate the impacts of a proposed project - Association of Irritated Residents v. County of Madera (2003) 107 CaLApp.4th 1383 Appeal of Certification Appeal letter identifies eight reasons 1. The FEIR fails to respond to comments as specified in letter of November 9, 2011. 2. The EIR failed to identity feasible mitigation measures for impacts to the Southbound ramp at US 101 and Talmage Road. 3. The EIR failed to identify inconsistencies with the City's general plan. 4. The EIR failed to adequately analyze transportation energy consumption. 5. The EIR failed to include an adequate analysis of the Project's impact on urban decay. 6. The EIR failed to include an adequate analysis of the Project's traffic impacts. 7. The project's hydrological impacts were not property addressed in the EIR. 8. The attached letter of November 9, 2011 sets out the reasons for the appeal. See staff report for discussion of these items 1/18/2012 C William D. Kopper Attorney at Law 4 1 7 J Street Davis, CA 95616 (530) 758-0757 Fax (530) 758-2844 January 18, 2012 City Council City of Ukiah Planning & Community Development Dept 300 Seminary Ave. Ukiah, CA 95482 RE: Apj.,eal of Certification of the City of Ukiah Walmart Expansion Project Final Environmental impact Report Dear "Members of the City Council: I represent Citizens for Sustainable Commerce, a California. Association, Steve Scalmanini, Allen Nicholson, and Jeffrey Blankfort. These are their comments. We incorporate into these comments those of all other individuals and entities commenting on both the Draft Environmental Impact Report (DE{;IR) and the Final Environmental Impact Report (FEIR) for the City of Ukiah Walmart Expansion Project. Citizens for Sustainable Commerce, Steve Scalmanini, Allen Nicholson, and Jeffrey Blankfort, oppose the expansion of the Ukiah Walmart. We incorporate into these comments the attached comment letters from Mr. Daniel Smith, Traffic Engineer, Dr. Philip King, Economist, and Mr. Dale LaForest, Architect. With respect to the Final Environmental Impact Report for the City of Ukiah Walmart Expansion Project, we ask the Court to grant our appeal based on the information included in the November 9, 2011, letter, .s well as this letter. 1. Traffic Issues. The Project. EIR has adopted an improper standard of significance for the Project's traffic impacts on the US 101 Southbound Off -Ramps at Talmage Road. The standard of significance suggested in the E:IR is that the Project will have a significant impact if it causes traffic queues that exceed 600 feet from the "gore point" northward toward the point where vehicles leave the freeway and enter the off rarnp. The FIR sets forth no basis for the use of this threshold of significance. There is no studN. that sets forth a basis for the 600 -foot standard. There is no City ordinance or regulation that supports the 600 -foot standard, and there is nothing in CEQA Guidelines Appendix G that would support the standard. In Protect the Historic Amador Water Ways v. Amador Water .Agency (2004) 11.6 Cal.AppAth 1099, 1111, the court held that if evidence is submitted tending to show that the City of Ukiah Planning & Community Development Dept January 1 V, 2V 12 Page 2 environmental impact might be significant despite the significance standard used in the EIR, the agency must address that evidence. Here, Mr. Daniel Smith has provided expert testimony that the 600 -foot standard does not adequately reflect the environmental impacts of the Project and the City should formulate an additional standard of significance to reflect safety issues associated with longer queues. As set forth in Mr. Smith's comments, if traffic backs up to a 600 -foot queue line, a car coming off the freeway might be involved in a low -speed crash. However, if a car coming off the freeway is involved in a collision where the cars are backed up onto the freeway at the off -ramp, the collision is likely to be much more severe. The EIR should formulate an additional standard of significance stating; that if the Project would cause queues at the US 101 Off -Ramp out onto the freeway, then the Project would have a significant impact on the environment within the meaning of Guideline §15065(a)(4). Additionally, as stated in the comments of Mr. Daniel Smith, the EIR failed to include information about `;he actual lengths of the traffic queues that are likely to result both with Project conditions, and with cumulative conditions (when the Costco is added). In the attached letter from the County of Mendocino, the County states as follows: Existing levels of service are understated for the US 101 Southbound/ Talmage Road off -ramp which currently results in queuing backups that. extend onto the travel lane of the freeway. Based on the understated existing level of service, the Project impacts and mitigations seem to assume that the anticipated additional queuing backup will decrease the amount of the southbound off -ramp that is safely available for deceleration. In fact, the additional queuing backup generated by the Project will increase the frequency and severity of queuing backups onto the freeway. In order for the EIR to provide sufficient information to the decision makers, it needs to include a calculation of the additional length of queues on the southbound off -ramp from US 101 that will be attributable to Project traffic, as well as cumulative traffic. This information will help the decision makers understand how frequently cars will be lined up on the freeway to exit at the southbound Talmage Road off -ramp. This information will provide the decision makers with an understanding of the risks to human health and safety associated with the Project. The EIR is inadequate because it states that any queuing beyond the 600 -foot gore point is a significant impact; and therefore does not provide the information as to how the Project and the Project under cumulative conditions will contribute to cars queuing out on the freeway. This information is essential for the public and the decision makers to determine whether the health and safety costs associated with this Project will be offset by the perceived economic benefits. The Project EIR fails to include a proper baseline. In Communities for a Better Environment v. South Coast Air° Quality Management District (2010) 48 Cal.4th 310, the court stated that the determination of the baseline conditions is not inflexible. The court quoted Save our Peninsula as City of Ukiah Planning & Community Development Dept Janua�y� 18, 2012 Page 3 follows: "As one appellate court observed, `the date for establishing the baseline can not be a rigid one. Environmental conditions may vary from year to year and in some cases it is necessary to consider conditions over a range of time periods. In some circumstances, peak impacts or recurring periods of resource scarcity may be as important environmentally as average conditions. Where environmental conditions are expected to change quickly during the period of environmental review for reasons other than the proposed project, project effects might reasonably be compared to predict the conditions at the expected date of approval, rather than to conditions at the time analysis is begun."' (Communities for a Better Environment, supra, 48 CalAth at p.328, quoting Save our Peninsula Committee v. Monterey County Board of Supervisors ('200 1) 87 Cal.AppAth 99.) In Save our Peninsula, the court addressed baseline traffic levels: "For instance, where the issue involves an impact on traffic levels, the FIR might necessarily take into account the normal increase in traffic over time. Since the environmental review process can take a number of years, traffic levels as of the time the Project is approved may be a more accurate .representation of the existing baseline a;ainst which to measure the impact of the project.'' (Save our Peninsula, supra, 87 Cal.AppAth at ,gip. 125-126.) As stated in the comments of Mr. Daniel Smith, Caltrans, and the County of Mendocino, the EIR did not use a _proper baseline, The use of February traffic counts is improper because these counts are substantially below the traffic counts for commercial areas during other months were commerce is historically higher. Additionally, the baseline traffic conditions are inadequate because we are in an era of historically depressed retail. sales. The businesses in the Redwood. Business Park where the Walmart is located is only producing about 71.58% of the ITE trip generation rates. In baseline conditions, the EIR assumes that Walmart is producing at full ITE rates for its category, and that the under -generation relative to ITE rates occurs in the rest of the Redwood Business Park. However, as set forth in the comments of Daniel Smith, there is not adequate data to :support this assumption in the FIR. Furthermore, as set forth in the ruling of Sunnyvale West Neighborhood Association v. City of Sunnyvale City Council (2010)190 Cal.AppAth 1351, the FIR should increase the baseline conditions to account for the depressed economic conditions. The FIR violated CEQA by using baseline conditions that are contrary to law. The EIR fails to include adequate information to allow the decision makers to understand the environmental. impacts of the Project. Comment Q89 in the FEIR documented that in future traffic scenarios, different increments in traffic resulted in wildly disproportionate. changes in queue lengths, and even in wrong -direction changes in queue lengths on the US 101 Southbound Off -Ramp to Talmage. The FEIR is not able to explain in any rational way why the traffic modeling produces such illogical results. Because the traffic model produces illogical results, the FIR traffic section is inadequate and is not substantial evidence for the conclusions included in the FIR. Additionally, the EIR refuses to include in its analysis the facts in Costco comment letter O, which states that the Costco pm peak generation should be 925 trips in the hour, instead of the EIR's estimate of 630 trips. The FEIR suggests that the difference is really only 5% after taking into account Costco shoppers that are attracted passers by. Therefore, 263 vehicles would have to be attracted in the pm peak hour. City of Ukiah Planning & Community Development Dept January i 8, 2V 12 Page 4 As set forth in the analysis of Mr. Daniel. Smith, for the EIR's analysis to be correct of the non- Walmart shoppers, which are mostly daily users, each of the other users would have to stop at the Costco in the pm peak hour once every four days. The EIR includes no data that would support such an unrealistic assumption. Because important sections of the EIR's traffic analysis addressing both Project traffic impacts and cumulative impacts is supported by analysis in the EIR that has no factual basis and is irrational, the EIR's conclusions are not supported by evidence in the EIR or in the record. A lead or responsible agency adopts mitigation measures described in the EIR when it approves the Project. The mitigation measures that are adopted must be enforceable through conditions of approval, contracts, or other means that are legally binding. (Public Resources Code §21081.6(b); CEQA Guidelines §15126.4(a)(2).) A reviewing court will not defer to the agency's determination that mitigation measures will work when their efficacy is not apparent and there is no evidence in the record showing they will be effective in remedying the environmental problem. (C -ray v. County of Madeira (2008) 167 Cal.AppAth 1099, 1116.) In Communities for a Better Environment v. City of Richmond (2010) 184 Cal.AppAth 70, 9�, the court rejected the EIR's measure for greenhouse gas mitigation because it determined the EIR improperly deferred formulation of greenhouse gas mitigation measures. In this case, the DEIR :has set forth Mitigation 4.10-2 as the mitigation measures designed to mitigate Impact 4.10-2, which is the dangerous conditions at the southbound US 1.01 Off -Ramp at Talmage Road. Mitigation Measure 4.10-2 includes Option A and Option B, which propose round -abouts at the Talmage Road/-LJS 101 intersection. As set forth in the comments of Mr. Daniel Smith, these solutions will not work because there is insufficient room, and the round -abouts will not meet Caltrans standards. The County of Mendocino also states, "the proposed `mitigations' are insufficient to correct problems that are inherent in the existing improvements because the `existing and proposed ramp intersections and local road intersection separations do not meet minimum design standards. "' Caltrans also stated that the proposed mitigation measures will not work. The EIR does not contain evidence showing that Options A or B will be effective in remedying the environmental problem in light of the evidence showing the proposed solutions will not work and will not meet Caltrans standards. As stated in the comments of the County of Mendocino, the Project EIR is inadequate because it was not evaluated for its consistency with the Ukiah Valley Area Plan. The County states the Project does not meet Goal CTI to "provide for efficient and safe circulation -networks throughout the Ukiah Valley." Additionally, the County sites other policies that the EIR fails to meet. However, the basic shortcoming pointed out by the County is that the Ukiah Valley Area Plan (UVAP) is not considered in the Environmental Impact Report. As part of the CEQA Guidelines provisions governing the environmental setting, the Guidelines require an EIR to discuss any inconsistencies between the proposed Project and applicable General Plans, Specific Plans and Regional Plans, (C EQA Guidelines § 15125(4).) An "applicable plan" is a plan that has already been adopted and, thus, legally applies to a project. (Chaparral Greens v. City of Chula Vista (1996) 50 City of Ukiah Planning & Community Development Dept T18 ,,, 1 lini 1) January i , Z,vi/. Page 5 Cal.AppAth 11341-1145 FN2.) In light of the fact that the UVAP is a Regional Plan that applies to the proposed Proje,.t, the Project EIR should have considered consistency with the UVAP. An EIR must respond to specific suggestions for mitigating a significant impact unless the suggested mitigation is "facially infeasible." (Los Angeles Unified School District v. City of Los Angeles (1997) 58 Cal.AppAth 1019, 1029.) In this case, Mr. Daniel Smith proposed a mitigation measure that is likely to be effective in reducing the Project's impacts at the US 101 Southbound/Talmage Road intersection. Mr. Smith proposed that the overcrossing of US 101 on Talmage Road be widened, so that there would be sufficient room to complete improvements at the US 101, Southbound ramp/Talmage Road intersection. The EIR fails to respond to this suggested mitigation, and violates CEQA by failing to do so. In response to Comment Q-87, the FEIR states: "The options [A and B for mitigation of the US 101 Southbound. Off-Ramp/Talmage Road interchange] have yet to go through conceptual design (a step which is beyond the scope of the Project Level EIR)." Further, the response states: "At such time, the geometric issues raised by the commenter, and other design construction issues, will be further examined, in consultation with Caltrans, and it will be determined which mitigation option will be carried forward." This explanation of the proposed mitigation measures A and B is inadequate because it constitutes future mitigation. Even if the assumption is made that the EIR sets forth the standard of performance for the mitigation measure, which it does not, the lack of even a conceptual design .or conceptual approval from Caltrans shows that the mitigation measure is impermissible future mitigation. The EIR and record are devoid of any evidence that the mitigation measures are feasible, which is necessary before future mitigation is acceptable. The fact that the mitigation measures may be "potentially feasible" is not sufficient. Assuming that Mitigation Measure 4.1-2 is acceptable mitigation, which Citizens for Sustainable Commzrce contends is not the case, the EIR still violates CEQA. The EIR states: "This improvement is currently unfunded and does not appear in the City of Ukiah's Capital Improvement Program, so the improvement cannot be considered a feasible mitigation measure." This analysis is inadequate. As the Supreme Court stated in City of Marina v. Board of Trustee's of California State University (2006) 39 CalAth 341, 360-361, "Each public agency shall mitigate or avoid the significant effects on the environment of projects that it carries out or approves whenever it is feasible to do so." Additionally, "CEQA does not authorize and agency to proceed with a project that will have significant, unmitigated effects on the environment, based simply on a weighing of those effects against the project's benefits, unless the measures necessary to mitigate those effects are truly infeasible." (Id., at 368-369.) In light of the recent holding in City of San Diego v. Board of Trustees of the California State University (2011) Ca1.App.4th (WL 6155 755), the Project EIR is not adequate. The EIR fails to discuss possible feasible modifications of the Project that could reduce or eliminate the need for the Project's "fair -share" funding, of off-site mitigation costs or ways to reduce its impacts to zero impacts at the US 101 Southbound Off- Ramp/Talmage Road Intersection. The EIR did not contain an adequate discussion ofthe possible feasible on-site measures that could reduce or avoid the need for the off-site mitigation. Therefore, City of Ukiah Planning & Community Development Dept January 10, E V I G Page h the Project EIR is inadequate. Further, the EIR did not comply with the holding of City of San Diego v. Board of Trustees of the California State University because it did not include a broad enough discussion and adequate information regarding the Project and feasible sources for funding of the significant off-site mitigation measures. 2. Stormwater Runoff. The EIR fails to include sufficient information about water quality. As stated in the comments of the County of Mendocino, the EIR deals only with the volume of stormwater runoff, while ignoring the content. The County states that unless mitigation measures are taken to filter runoff from impervious parking and driveway surfaces, the amount of pollution flowing from the Project to neighboring agricultural lands to the east (and subsequently into the Russian River) will increase. The County further comments that the increase in polluted runoff is likely to negatively impact the neighboring agricultural lands and the waters of the Russian River, which is a source for drinking water and irrigation for numerous downstream users, and habitat to federally listed anadromous fish species. The EIR is inadequate because it fails to include an adequate discussion of pollution from the parking lot and other impervious surfaces. The Project parking lot will include petroleum products as well as heavy metals. Further, the EIR includes no discussion of the Project's cumulative impact on ground water quality and surface water quality. The development of the Costco Project and other projects in the area will likely have similar impacts on water quality, which cumulatively may be significant. 3. Urban Decay Impacts. The attached report of Dr. Philip King shows that the Project will have urban decay impacts. It shows that the economic study completed by CBRE does not furnish sufficient information to support the conclusion that the Project will not have economic impacts that will cause urban decay. As shown in the report of Dr. King, the claim that the City's downtown will not be impacted by the Project cannot be supported. Sincerely, William D. Kopper Attorney at Law WDK/w-rn enclosures CARNFEL J. ANG ELO Chief Executive Officer Clerk of the Board December 6, 2011 a .a IVdt�+'• A,I C1gfM�i"'� COUNTY OF MENDOCINO BOARD OF SUPERVISORS City of Ukiah Planning and Carnmunity Development Department 300 Seminary Avenue Ukiah, CA 95482 CONTACT iNFORMA1lON 501 Low Gap Road • Room 1010 Ukiah, California 95482 TELEPHONE: (707) 463-4221 FAX: (707) 463-7237 Email: bos®co.mendocino.ca.us Web: wwv%,,co.mendocino.ca.us/bos RE: Comments to the Walmart Environmental Impact Report (EIR), Site Development permit and Statement of Overriding Considerations Thank you for the opportunity to comment on the Walmart EIR, Site Development Permit and Statement of Overriding Considerations. The need for a Statement of Overriding Considerations, results, in part, from the historic inability of the City and County to work more collaboratively on land use planning issues for the Ukiah Valley. The current lack of an agreed upon formula for tax sharing continues to impede the ability of the City and County to work collaboratively on land use planning and a range of other public policy initiatives, including economic development, housing policy, water policy and more. Whatever the decision regarding the current Project, the future "Discount Club" scenario, or any other individual project, it is imperative that the City and County reach agreement on an equitable tax sharing proposal so that today's planning decisions do not result in tomorrow's "significant but unavoidable" impacts. Please see the attached sheet for the specific comments of the Mendocino County Board of Supervisors. Thank you again for the opportunity to comment. Sincerely, Kendall Smith, Chair Attachment THE BOARD OF SUPERVISORS CARRE BROWN JOHN MCCOWEN JOHN PINCHES KENDALLSMITH First District Second District Third District Fourth District l -d 699ZSZSN9 DAN HAMBURG Fifth District u9 L:O I LL SH oen The Mendocino County Board of Supervisors offers the following specific comments as an attachment to their letter to the City of Ukiah, dated December 6, 2011: LANG USE PLANNING: Upon review of the EIR, it appears that the Ukiah Valley Area Plan (UVAP), adopted August 2011 by the Board of Supervisors was not adequately addressed or considered as it relates to land use consistency. The UVAP represents a commitment to a comprehensive and long range inter -jurisdictional planning document that represents the vision and foresight of the people who live and work in the Ukiah Valley, As noted in the UVAP itself, the UVAP process began in 1990 when the City of Ukiah began an extensive process to formulate a "Ukiah Valley general Plan and Growth management program." Yet, with this noted, it appears that the Environmental Impact Report has only addressed land use consistency with the City's own planning documents, but failed to look beyond its immediate boundaries and consider the UVAP. TRAFFIC: Existing levels of service are understated for the U.S. 101 southbound Talmage Road off -ramp which currently results in queuing backups that extend onto the travel lane of the freeway.' Based on the understated existing level of service, the project impacts and mitigations seem to assume that the anticipated additional queuing backup will decrease the amount of the southbound off -ramp that is safely available for deceleration. In fact, the additional queuing backup generated by the Project will increase the frequency and severity of queuing backups onto the freeway. Existing intersection levels of service are understated for the west bound left turn lane from Talmage Road onto Airport Park Boulevard which currently experiences queuing problems that interfere with the operation of the freeway interchange.z Based on the understated existing intersection level of service, the identified mitigations are unlikely to address the additional impacts from the Project or the cumulative impacts associated with the "Discount Club" scenario. Mitigation Measure 4.10-2 requires the project applicant to "provide proportional share payments—for the planned improvements and reconfiguration of the interchange, which would improve queuing to acceptable conditions." However, this statement appears to be contradicted by the Future Year 2030 analysis, with or without the Project, which states that area intersections will experience queues that extend beyond the maximum storage. Neither Option A (signal), Option A (roundabout), nor Option B (roundabout) will reduce queuing to acceptable levels. The interchange improvements called for in Mitigation Measure 4.10-2 are currently unfunded. Therefore, the proportional payment will do nothing for the foreseeable future I Page 4.10-7 of the DEIR states the data was collected in February, arguably the opposite of peak usage. 2 Table 4.10-2 Existing Intersection Levels of Service, page 4.10-9 represents "conditions for the overall intersection," however, on page 4.10-33, in describing multiple Future Year 2030 turning movements at the Talmage Road/Airport Park Boulevard intersection that result in queues that extend beyond the available storage, it states "Only the westbound queue is considered significant as it would affect the U.S, 101 interchange." Intended or not, describing existing intersection levels of service based on the overall functioning of the intersection has the effect of masking a significant existing impact, Z'd 699ZSZ901,9 e9L:01, 4 60 0e4 Page 2 to mitigate the impact. Further, the mitigation does not identify a pro -rata share that the project applicant would be responsible for. • The cost of the mitigation has been identified as ranging between $5,136,000 and $10, 576,000 in 2005 dollars.3 In the absence of an identified funding source, it is likely the City of Ukiah would seek State Transportation Improvement Funds (STIP) through the Mendocino Council of Governments which would reduce the amount of funding available for other projects throughout the County. The discussion under Mitigation Measure 4.10-2 states that improvements by the City to the Talmage Road/Airport Park Boulevard intersection described in "Future Transportation Improvements "need to be implemented in addition to Mitigation Measure 4.10-2." The discussion further states "this improvement is currently unfunded." • Even if funding were available for Mitigation 4.10-2 and the City of Ukiah Future Transportation Improvements, the proposed "mitigations" are insufficient to correct problems that are inherent in the existing improvements because the "existing and proposed ramp intersections and local road intersection separations do not meet minimum design standard."' • Comment Letter O, (FEIR) raises the concern that the installation of a roundabout could exacerbate, rather than mitigate, existing problems, and recommends supplemental analysis via computer modeling to determine the best long term solution.5 The response to comments (page 3-37 FEIR) fails to address the merits of this reasonable and prudent recommendation. • The project has the potential to affect areas outside of the City of Ukiah and thus should be reviewed for consistency with the UVAP. The following goals and policies contained in the UVAP would be applicable and are outlined below: Goal CTI (page 5-14 of UVAP) states "provide for efficient and safe circulation networks throughout the Ukiah Valley." Policy CT1.2 (page 5-14) states "Maintain an acceptable level of service conditions on exiting roadways." Policy CT1.2b (page 5-15) states 'Roadway and Intersection Improvements - when possible, improve existing roadways and intersections in favor of building new transportation facilities" URBAN DECAY The discussion of the potential for the Project to contribute to urban decay is superficial at best. The discussion notes that past anchors closed in response to internal conditions, not as a result of economic competition. Therefore, the assumption that closures related to the Project, or the Project plus the "Discount Club" Scenario, will be reoccupied in a reasonable amount of time are speculative. The analysis also seems to ignore the likely migration of mid and small size retailers to the Airport Business Park once anchor stores in other locations close. Many of the mid and small size retailers rely on the presence of the food retailers to generate customer traffic. Therefore, when one or more major food retailers close as a result of the Project 3 Route 101 Corridor Interchange Study in Mendocino County, by TJKh4 Transportation Consultants for Mendocino Council of Governments, August 30, 2005, Page 46, Table 16; Preliminary Cost Estimates. 4 Ibid, note 7. 5 Comment Letter O, "Talmage Road Corridor Mitigations," page one, and bullet one, page taro. 9'd 699Z9Z90L9 e91,:M It 60 oea Page 31 or the Project plus "Discount Club" scenario, mid and small size retailers will close as well, resulting in a negative impact to sales tax receipts for Willits, Fort Bragg and the County's We disagree strongly with the finding that there is no significant urban decay impact associated with the Project. These impacts are likely to be felt primarily within the City of Ukiah, but retail areas in the Cities of Willits and Fort Bragg, as well as retail areas in the unincorporated area of the County are also likely to be impacted. These impacts will be exacerbated under the "Discount Club" scenario. STORMWATER RUNOFF The EIR deals only with the volume of stormwater runoff, while ignoring the content, Unless mitigation measures are taken to filter runoff from impervious parking and driveway surfaces the amount of pollution flowing from the project to neighboring agricultural lands to the east (and subsequently into the Russian River) will increase. The increase in polluted runoff is likely to negatively impact the neighboring agricultural lands and the waters of the Russian River which is a source for drinking water and irrigation for numerous downstream users and habitat to federally listed anadromous fish species. h We believe the "Project Market Area" as depicted on Figure 4.3-1, which includes the 101 corridor from the south County line to just north of Willits is likely to be understated. V'd 699Z9Z9069 e9l:O1, 1,6 60 oea 5 �' 2BYLf s 3C � J CAR�I_L J. ANGELO CONTACT INFORMA110N Chief Executive Officer 501 Low Cap Road • R-1010 Clerk of the Board Ukiah, California 95482 TELLPHONE'(707) 463-4221 M (07M 463-7237 Email: bosaco.mendacino.ca.us COUNTY OF MENDOCINO Web: a rww.co.mendgcino.ca.us/bos BOARD OF SUPERVISORS December b, 2011 OR .4 �po„ City of Ukiah + Planning and Community Development Department 300 Seminary Avenue Ukiah, CA 95482 RE' Comme'sts to the Walmart Environmental Impact Report (EIR). Site Development Permit and Statemcr¢ of Overriding Consideradors Thank you for the opportunity to comment an the Walmart E1R, Site Development Penrut and Statement of Overriding Considcradons. The coed for a Statement of Overriding Considerations, sults, in part, from the historic inability of the City and County to work mete collaboratively or.land use planningissues for the Ukiah Valley. The current lack of an agreed upon formula for tax shating continues to impede the ability of the City and County to work collaboratively on land uae planning and a range of other public policy infdadves, irdudiig economic deve'.opmerq housing polity, water, policy and more. Whatever the decision tga-di...g the current Project, the future `Disccuct Club" scenario, or any otF.er individual project, it is imperative that the City and County reach agreement on an equitable tax sharing proposal so that today's platu'.ing decisions do not result in tomorrow's's gnificant but unavoidable" impacts. P:case sec the attached sheet for the specific comments of the Mendocino County Hoard of Septnisors. Thark you again for the opporturue/ to comment. Sincerely, Kendall Smith, Chair Attachmeet THE BOARD OF SUPERVISORS CARIC BROWN fOHNVICCOWEN )OHNPLHCHES KENDALLSAIrrH DAN HAMBURG First District Second District Thud District Fourth District Fifth District ld 699NMI9 s9GOl it 60 000 SIO b OZ:T 69WSZSOTS aA!-aaad Cc: ZZ: OT �nsa� s061?d UOL4pano UOL123LJ�4Uapl ad/' amL1 ITEM /ZT 5888 a4pa qOC 8Z:OT TTH-6-aaa MNSMCS Tcaujojgy jaddoN W.LlM jjodaH ileo xe� 0500 JapaseZ CIH January 18, 2012 Memo To: William Kopper, Attorney at Law From: Philip King, Ph.D. Re: Analysis of proposed Wal-Mart Supercenter in Ukiah I have examined the CBRE Urban Decay Analysis contained in the DEIR/ FEIR for the proposed Wal-Mart Supercenter expansion in Ukiah and the General Fund Fiscal Impact Analysis, prepared by CBRE for the City (Nov. 12, 2010). I also evaluated the efficacy of this project to achieve three of the Project Objectives contained in the DEIR (3.3.1, p. 3-5) and listed below. • Provide a commercial development that results in a net fiscal benefit to the City by providing new sales tax revenue and increasing property tax revenues. • Provide commercial development that creates new jobs for City residents. • Develop a fiscally beneficial project that provides sufficient revenues to maintain municipal services. In brief: In my professional opinion, the Wal-Mart expansion will not result in a net increase in general fund tax gains or an increase in jobs. In addition, the Wal-Mart expansion, especially in conjunction with the planned Costco, will lead to urban decay. Here is a summary of my findings. • CBRE erred in its calculation of sales tax benefits: o CBRE states that sales diversions will be "up to" 75% but, in fact, the analysis employed in the EIR assumes only a 39% sales diversion overall, which is far too low. o Since there will be no increase in the employment base (see below) there will be no gain in franchise taxes. o The City's general fund share of sales tax receipts is not 1%, but .75%. • When taxes are properly evaluated, the project will result in a net general fund tax loss of $9,821 once one nets out the (CBRE estimated) incremental service costs to the City of $32,488.1 • CBRE also estimates this project will generate $45,890 in property taxes for the Ukiah Redevelopment Agency, however, the State past legislation last year which move these funds back to Sacramento and the California Supreme Court upheld this legislation in December 2011. In addition, CBRE failed to 1 Excluding Measure S which will sunset. Even with Measure S the project will only generate a few thousand dollars in net sales taxes—see discussion below. account for decreases in market values and hence property taxes at other retail properties in the City as a result of store closings. The employment gains touted by CBRE fail to account for employment losses at other stores due to sales diversions/closings. In fact, it is likely there will be a net loss in jobs following the expansion. Moreover, Wal -Mart's wages and benefits are significantly lower than many other retailers, especially grocery stores, and these lower wage and benefit levels will put a greater strain on social services in Ukiah and Mendocino County. The EIR dismisses the potential for urban decay due to store closures and a significant decline in the vitality of downtown Ukiah. However, the cumulative impacts of the Wal-Mart, Costco and other smaller projects will lead to a sales diversion (according to the DEIR) equivalent to 20% of Ukiah's total current sales. It should be obvious that the impacts on current Ukiah's retail businesses will be serious. It is also a mistake to view downtown Ukiah retail as somehow catering to a different clientele than other retail nodes, as many of the downtown stores have overlapping merchandise with the new competition. Furthermore, the downtown has now lost the draw of the main post office (which closed December 2011), and will likely loose the county courthouse (which is scheduled to relocate in a few years). The downtown vacancy rate currently stands at 14.9%, and would jump to 23.5% when County courthouse related services relocate. Also, as mentioned above, the recent court ruling on redevelopment will greatly reduce the City's ability to maintain the downtown with beautification projects and loans for building renovations. Given the serious issues cited above, it is my opinion that the City of Ukiah would be better off simply allowing Wal-Mart to operate on a 24-hour basis with the potential for expanded groceries. While there might be some displacement in the food industry, the impacts would be significantly lower. Indeed the EIR itself refers to this alternative as "environmentally superior alternative," while providing no specific reasons why it should be rejected as infeasible. The remainder of this memo will discuss these issues in more detail. Fiscal Impact Sales tax The November 2010 CBRE memo concludes (Table 4, p. 4) that the expansion could generate $73,680 in regular sales tax revenue and an additional $36,930 in Measure S sales tax revenue, which will sunset in 2015 if the measure is not re -approved by voters. The memo states (p. 4) that: "The analysis adjusts for the nontaxable components of this amount and assumes that up to 75 percent of these potential diversions could come from retailers within the City of Ukiah boundaries... " Since Ukiah has by far the largest assortment of retail stores in Mendocino county, a 75% impact is actually quite optimistic - especially as the Wal-Mart expansion will focus on groceries and garden supplies. Exhibit 5 (unlabeled but after Exhibit 4 in CBRE Appendix D to DEIR) and Exhibit 6, present the major retail outlets that would compete with the Wal-Mart expansion. All of the competitive stores in Mendocino County, including every major grocery store plus JC Penney, Ross, Sears, Kohl's, Home Depot and Friedman's are in Ukiah. The map lists a few competitive stores in Fort Bragg and Lakeport, but these are duplicative of Ukiah stores. And while Santa Rosa offers a larger variety of stores, these stores are far away-- over an hour drive for most people in the trade area. It is unlikely that the addition, of 47,612 sq. ft. will make much difference in terms of drawing people to Ukiah who are already going to Santa Rosa. Consequently a more realistic estimate for sales diversion in Ukiah is probably 80-90%. Furthermore, careful examination of CBRE tables in their fiscal impact memo shows that the actual estimate for sales diversion applied is far lower than 75% --indeed the average overall is 39%. Table 1 below indicates that CBRE's estimates imply that only about one- third of the Supercenter's General Merchandise and other retail will come from existing stores in Ukiah, implying that two-thirds of their sales will be "new" to Ukiah. This is simply absurd and is essentially contradicted by the text of the CBRE memo, which implies that the 75% estimate has generally been applied. Table 1: Implied Sales Diversion from Ukiah Stores in CBRE's Fiscal Analysis Retail Category CBRE Estimated Taxable Sales CBRE Estimated Taxable Sales Diversion CBRE % Diverted from existing Ukiah Stores General Merchandise $ 4,578,577 $ 1,532,278 33% Food Stores $ 3,872,326 $ 2,038,883 53% Eating and Drinking $ 76,455 $ - 0% Other Retail $ 3,561,490 $ 1,131,670 32% Total $12,088,848 $ 4,702,831 39% Astonishingly, even in food stores, the effective amount is only 53%, despite the fact that most people shop locally for groceries. The text in CBRE's Fiscal Impact report is not consistent with the tables presented for sales diversions. (The estimates for the percentage of sales subject to sales tax, though a little high, are reasonable.) I re -estimated the net taxable sales using the same methodology and assumptions applied by CBRE, except assuming that in fact 75% of the Wal-Mart expansion sales represent sales diversion from Ukiah Stores. The results are presented in Table 2 below. Table 2: Implied Sales Diversion from Ukiah Stores in CBRE's Fiscal Analysis CBRE Net Taxable Sales Tax Measure S Estimated Sales with with 75% Tax with Taxable 75% Diversion 75% Sales Diversion 8,904 Diversion $4,578,577 $1,144,644 11,446 5,723.22 $3,872,326 $968,082 9,681 4,840.41 $76,455 $19,114 191 95.57 $3,561,490 $890,373 8,904 4,451.86 $12,088,848 $3,022,212 $30,222 $15,111 As indicated in Table 2 above, assuming a 75% sales diversion yields only $30,222 in regular sales taxes and $15,111 in Measure S taxes, far lower than the figures touted in the CBRE Fiscal Impact Analysis memo. However, the $30,222 in sales tax benefits shown above should be further reduced, because County officials revealed that the City (General Fund) does not retain 1% of sales tax receipts, but .75%, with the remaining .25% earmarked to the County for transportation projects. This reduces the annual taxable benefit to the City to $22,667. Triple -Flip Property Tax In Lieu and Franchise Tax CBRE also assumes the project will provide additional General Fund benefits in the form of annual increases of $2,320 and $3,618 for Triple -Flip property Tax in lieu and Franchise taxes, respectively. These estimates assume this project qualifies for redevelopment funding (Triple -Flip) and will add 85 new employees (Franchise Tax). However, both of these assumptions are flawed. As detailed below, the project will lead to job reductions at other stores, which offsets the 85 jobs CBRE claims as new jobs. Redevelopment funding is slated to disappear and a recent California Supreme Court decision, California Redevelopment Assoc. v. Matosantos, upheld the State of California's ability to end the current method for funding redevelopment, which uses increments in property taxes which would otherwise go to the State.2 Considering the recent court case affecting redevelopment agencies, and the net loss in jobs if Wal-Mart expands (see below), these so-called benefits are illusory. Cumulative General Revenue Benefits Based on the foregoing, it is much more reasonable to assume that the annual General Fund benefits to the City will be approximately $22,667. However, CBRE has estimated that the police budget will increase by $32,488 primarily due to Wal-Mart operating on a 24-hour basis. Therefore, the net annual impact to the City's. General Fund as a result of this expansion will be a negative $9,821 ($32,488 minus $22,667). Even if one assumes that the City of Ukiah received 1% of the sales tax, as CBRE does, the costs to the City still exceed the sales tax gains. Property Tax CBRE also estimates that the project will generate $58,103 in property taxes, of which $45,890 will go to the local Redevelopment Agency (RDA) and $12,213 to Mendocino County. However, the State of California has changed current legislation on redevelopment areas, effectively ending the current mechanism. A recent decision by the California Supreme Court (California Redevelopment Assoc. v. Matosantos3) upheld these new laws. Consequently, future projects like the Wal- Mart expansion will no longer qualify for redevelopment. It is therefore reasonable to assume that the City will receive limited property tax benefits from this project. In addition., the analysis ignores negative impacts on property values at other commercial properties in Ukiah. As indicated in the EIR and discussed below, the Lucky and Grocery Outlet stores could close and although the owners are still liable for property taxes, it is likely that as the property values of these stores and other stores nearby fall, property tax values will be adjusted downward. One cannot simply add on the projected property taxes for the expansion without accounting for reductions elsewhere. Employment Impact CBRE estimates that the proposed Wal-Mart expansion will add 85 employees. However, they fail to account for a reduction in employment at other stores. Elsewhere in the same report they mention sales diversions from other stores and the EIR mentioned potential closings of the Lucky and Grocery Max stores as well as reductions in sales at the Food Maxx store. Table 3 below summarizes data on 2 See http://media.fresnobee.com/smedia/2011/12/29/10/37/KwsOn.So.8.pdf. 31bid. wages at Wal-Mart and the competing stores that, according to the EIR, are most likely to be impacted by the Wal-Mart expansion. Table 3: Employment/Wages/Benefits at Food Stores in Ukiah4 Store # Est. % Full Full Time Annualized Benefits Employees time Wage/hr. Wage Wal-Mart expansion 85 $ 12.61 $ 26,229 Partial Medical Lucky 67 33% $ 25.08 $ 52,166 Full Medical Dental Grocery Outlet 31 87% $ 30,000 Medical Food Maxx 71 35% $ 21.61 $ 44,949 Full Medical Dental As shown in Table 3 above, if the Wal-Mart expansion results in the closing of both the Lucky and the Grocery Outlet, 98 jobs will be lost versus the 85 jobs added at Wal-Mart. Even if just the Lucky closes, as was suggested by CBRE and has been affirmed by the Lucky store manager, and there are staff reductions at other grocery stores to account for sales declines, the result could also be a net employment loss. Moreover, since Wal -Mart's wages are significantly lower than other grocery competitors in Ukiah there will be a decline of almost 50% in the wage levels of Wal- Mart employees versus those jobs that will be replaced. Recent data on medical benefits are harder to come by. A 2004 study concluded "the average Wal-Mart worker required $730 in taxpayer -funded healthcare and $1,222 in other forms of assistance, such as food stamps and subsidized housing, to get by.5" After the study was completed Wal-Mart did improve its benefits somewhat, but this fall Wal-Mart has again begun to reduce benefits back to earlier levels.6 Consequently, the total change in employment following the Wal-Mart expansion will likely be a net loss, and there will certainly be an overall decline in wage scales and employee benefits, contributing to lower local spending and higher social services costs. None of these offsetting impacts were estimated in the report. 4 Sources: For local stores data was obtained from store managers. Wal-Mart data was obtained www.walmart.com, also see "LIVING WAGE POLICIES ANDBIG-BOX RETAIL: HOW A HIGHER WAGE STANDARD WOULD IMPACT WALMART WORKERS AND SHOPPERS," by Ken Jacobs, Stephanie Luce, UC Berkeley Center for Labor Research and Education, April 2011. S ""Hidden Cost of Wal-Mart Jobs," UC Berkeley Center for Labor Research and Education, August, 2004. 6 See Wal-Mart Cuts Some Health Care Benefits By STEVEN GREENHOUSE and REED ABELSON, New York Times, October 20, 2011 Urban Decay Sales Impacts The FEIR also dismisses potential urban decay impacts due to the proposed expansion. However it does indicate that two stores, the Lucky and the Grocery Outlet are at risk if both the Wal-Mart expansion and the Costco move forward: "Therefore, it is possible that one to two weaker performing stores such as Lucky supermarket and Grocery Outlet could close due to the introduction of new competition. In addition, other stores in Ukiah are also likely to face diversions; in particular, Food Maxx, which has a Discount format and is along Airport Park Boulevard, probably will experience sales losses ..."(CBRE report, DEIR Appx D, p. 42) However cumulative impacts of the Costco and Wal-Mart (and a few other smaller developments) would be enormous. Table 4 below presents CBRE's estimates of the total sales diversions created by the Wal-Mart expansion. Overall the sales diversion would be close to 20% of total retail sales in Ukiah in 2008—and sales have actually fallen since 2008. Table 4: Cumulative Sales of Wal-Mart/Costco as Percentage of Ukiah Market Item Estimate CBRE estimate total Ukiah sales 2008 (DEIR Appx D Table 5) $ 483,700,000 CBRE estimate cumulative sales impacts (DEIR Appx D Table 10) $ 94,300,000 Cumulative Sales/ Total Sates 19.5% It should also be noted that the above is hardly a worst-case scenario. CBRE only uses 70% of Costco's sales, since 30% of Costco's sales are to business members. Clearly, however, most of these members are currently purchasing their goods through retailers or suppliers in Ukiah and these businesses will also be severely impacted by the cumulative impacts. If this had been properly taken into account the impacts above would be even greater. Even if one looks at the entire market area, the sales diversion is close to 10%. Store Closings The result of a 20% sales diversion will be devastating to local Ukiah businesses. The DEIR only identifies grocery store closing, (the Lucky and Grocery Outlet) but its clear that many other retail categories will be affected. The DEIR (Appx D, Table 10, p. 41) estimates close to $20 million in general merchandise followed by $17.3 million in "other retail, $6.9 million in home furnishings and appliances, 4.8 million in eating and drinking, $3.6 million in service stations and $1 million in motor vehicles and parts. While it is impossible to predict exactly which stores will close, it is reasonable to assume that weaker stores, especially ones that compete nearby or in similar market segments, will be the most vulnerable. However, the cumulative impacts of these proposed development is sufficient to take down even retailers that are currently healthy. Downtown Ukiah The DEIR states that the downtown is a "separate" shopping area, implying that downtown will not be impacted by these cumulative impacts. However, given the close proximity of downtown Ukiah to other shopping areas and the fact that the downtown offers many competing services (e.g., food, general merchandise, auto, etc.) it seems disingenuous to assert that the new projects will have no impact on the downtown. Further, the analysis contained in the EIR has not taken into consideration three important developments that will add to the cumulative impacts on downtown Ukiah. 1. The downtown post office closed in December 2011. This facility brought many people to downtown that will now conduct their business elsewhere. 2. The County courthouse, will relocate, the most likely four blocks east of the current location and separated from downtown by railroad tracks. The current courthouse is well located to several downtown restaurants and retail stores that depend upon this traffic for much of their business. 3. The elimination of redevelopment funds for downtown will reduce the viability of downtown Ukiah since in the past RDA moneys was used for beautification and to assitance to landlords for structural upgrades. Without this aid, downtown vacancies will continue to rise and urban decay will follow. Indeed the City of Ukiah has included the downtown in its redevelopment area (declaring it blighted), an acknowledgement that the area requires ongoing assistance. Downtown Ukiah already has a number of long term vacancies and buildings that are experiencing urban decay. The following aerial of downtown shows the location of existing occupied and unoccupied buildings for all forms of uses in downtown Ukiah. This data is summarized in Table 5 below. Figure 1: Downtown Ukiah Vacancies The data shows that the existing vacancy factor in downtown is currently 14.9% and will rise to 23.5% when county courthouse offices relocate.' This would be an alarmingly high vacancy factor, and coupled with the loss of redevelopment funds for the beautification of the downtown, would be a major contributor to downtown urban decay. Indeed the Ukiah Redevelopment Authority has stated that it's 'primary focus of the Redevelopment Agency's efforts is the revitalization of Ukiah's downtown.'8 7 Note that I have included non -retail vacancies. The general health of the downtown includes both retail and non -retail uses. Also the CBRE report makes clear that some vacant retail could be converted to non -retail uses. However, the converse applies—empty non -retail buildings also make it more difficult to retenant for alternative uses. More importantly, empty public buildings also contribute to urban decay—even if they are maintained. 8 Ukiah Redevelopment Project Five -Year Implementation Plan July 2007 to July 2012, p. 6, http://www.cityofukiah.com/pdf/ecoiiomic development/URAL/n20Finalo/)20Implementation%20P1 an%20Augest%2020070/)2OAmended%208-18-10.1)df. Table 1: Downtown Vacancies Category Square Feet' "Library 12,215 Court House 19,592 Court House Related 18,263 Banks 21,152 Retail 217,613 Office 57,753 Storage 1,945 Community Centers 28,546 Vacancies 66,191 Total 443,270 Vacancy Rate 15%'' Vacancies with empty Courthouse 104,046 Vacancy Rate with empty Courthou: 23% Evidence of urban decay The photos below (Figures 2-9) indicate the potential for urban decay. A large number of stores are closed. Some are boarded and many are already blighted. Figure 2: This building at N. Street and Empire is blighted—windows are boarded up and the roof needs replacement but has instead been covered with Mylar. Figure 3: This boarded -up old hotel in downtown Ukiah has been closed for years. Figure 4: Another closed store downtown. Figure 5: Closed store downtown. Figure 6: Closed store near Stephenson Street at S. Main. Figure 7: Closed stores/offices on Stephenson Street at S. Main. Figure 8: Closed former service Station on State Street Figure 9: Closed store on State Street Potential for Back -Filling The DEIR makes much of the potential for back -filling existing vacancies and provides a number of examples. While retenanting some buildings will undoubtedly occur, as it does in any real estate market, this discussion misses the point—the cumulative impacts created by these projects will create an excess supply of retail and retail space. Further, most of the examples cited in the DEIR involve projects from the height of the real estate boom during the middle of the last decade. It is unrealistic to expect this kind of build -out in the future. Indeed, the DEIR's own data indicates that consumers in Ukiah (as elsewhere) are retrenching, increasing savings, reducing the unsustainable levels of consumption (at all time highs) from this era. The DEIR also fails to mention that Internet sales are growing steadily and now provide serious competition to local bricks and mortar businesses ranging from books and DVD rentals, to TVs and appliances. In fact, during the 2011 Christmas holiday period, Online sales increased nationally by 15% versus just 4% for brick-and-mortor retail.9 Finally, Exhibit 11 of the CBRE analysis shows that except for a small amount of leakage for apparel stores all other Ukiah retail categories are attracting 58% more sales than available market area expenditures. With very little sales leakage, it is disingenuous for CBRE to conclude that vacant space can be easily re -tenanted. Rather, the CBRE analysis suggests there is no unmet demand, and that any new retail offerings will be at the expense of existing retailers. In sum, the potential for backfilling is grossly overestimated in the DEIR. What is far more likely is a gradual deterioration of buildings as vacancies increase and are prolonged. Gradually, the condition of these vacant buildings reach the point where they become unable to sustain a tenant—figures 1 and 2 above. Conclusion The DEIR, FEIR and Fiscal Impact analysis prepared in conjunction with the proposed Wal-Mart expansion paint a very unrealistic picture of the development's impacts. However a closer examination of the issue indicates that the benefits to the City of Ukiah are quite limited while the costs are significant, particularly when one considers the cumulative impacts of a Costco and other developments. First, when sales taxes are properly evaluated using CBRE's own stated 75% sales diversion estimate only $30,222 in regular sales taxes and $15,111 in Measure S taxes, far lower than the figures touted in the memo. This $30,222 is basically offset by the $32,488 that CBRE estimates as the additional costs to the City of the project. Further, CBRE assumes that 1% of the tax goes to Ukiah's general fund when in fact only 0.75% does—this reduces the annual taxable benefit to the City to $22,667. Consequently, the net sales tax benefits to the City of Ukiah are at best a wash and most likely negative. 9 Source: Time Magazine, January 16, 2012. The property tax benefits cited fail to account for recent legislation and a Supreme Court ruling which prevent RDA funds from going to Ukiah. Further, the analysis fails to account for decreases in market values and hence property taxes at other retail property in the City. Once again, what is already a modest increase is likely to be essentially a wash or even negative when these impacts are accounted for, as they should have been. The employment impacts touted by Wal-Mart are also grossly overstated, since they completely fail to account for the impacts of sales diversions (even though these are discussed in the DEIR) and the possibility of store closings. Moreover, as shown in this report, Wal -Mart's wages and benefits are significantly lower than other retail, particularly grocery retail. When one accounts for these factors the net employment effect will almost certainly be negative—essentially a shift form relatively high wage jobs to low wage jobs with lower benefits. It is also likely that the lower wage and benefit levels will put a greater strain on social services in Ukiah and Mendocino County. The lack of job creation also implies that CBRE's estimate of franchise tax benefits due to employment gains is also erroneous. The EIR dismisses the potential for urban decay and a significant decline in the vitality of downtown Ukiah. However, once again a careful examination of the facts leads to a different conclusion—the cumulative impacts of the Wal-Mart, Costco and other smaller projects will lead to a sales diversion (according to the DEIR) equivalent to 20% of Ukiah's total current sales. It should be obvious that the impacts on current Ukiah's retail businesses will be serious and significant. These impacts will be compounded by the lack of funding for Redevelopment, the recent move of the Post Office away from downtown, and the planned moving of the courthouse. It is also a mistake to dismiss downtown Ukiah retail as different given the small size of Ukiah and the fact that many downtown businesses will indeed compete directly with the new development. Much of the retail that does not compete (e.g., banks) will be drawn away from downtown, leading to further urban decay. Alternative Projects Given the serious issues cited above, it is my opinion that the City of Ukiah would be far better off simply allowing Wal-Mart to redesign its current store to allow for expanded groceries. This would allow Wal-Mart to remain competitive. There would still be some displacement in the food industry, but the impacts would be significantly lower. Indeed the EIR itself refers to this alternative as "environmentally superior." PHILIP G. KING Economics Department, San Francisco State University E-mail: pking@sbcglobal.net Cell: (530)-867-3935 Education: July, 87 Ph.D. in ECONOMICS CORNELL UNIVERSITY Fields: Applied Microeconomics, Economic Development, International Economics Dissertation: Bargaining between Multinational Corporations and Less Developed Countries over Mineral Concessions Contracts. May, 78 B. A. in PHILOSOPHY & ECONOMICS WASHINGTON UNIVERSITY Nominated to Omicron Delta Epsilon (Economics Honor Society.) Work Experience: 1/06 -present ASSOCIATE PROFESSOR SAN FRANCISCO STATE UNIVERSITY 9/02-12/05 CHAIR, ECONOMICS DEPARTMENT SAN FRANCISCO STATE UNIVERSITY 9/93 -present ASSOCIATE PROFESSOR SAN FRANCISCO STATE UNIVERSITY 9/87-9/93 ASSISTANT PROFESSOR SAN FRANCISCO STATE UNIVERSITY 9/83-5/85 ASSISTANT PROFESSOR, ECONOMICS S.U.N.Y. at CORTLAND Policy Papers prepared for Government and Non -Profit Organizations: Contributed Economics portion of Regional Sediment Master Plan for BEACON (Beach Erosion Authority for Clean Oceans and Nourishment—Santa Barbara and Ventura Counties), February 2009, with Noble Consultants, ESTIMATING THE POTENTIAL ECONOMIC IMPACTS OF CLIMATE CHANGE ON SOUTHERN CALIFORNIA BEACHES, prepared for the California Energy Commission (Energy Commission) and the California Environmental Protection Agency (Cal/EPA), with Linwood Pendleton, Craig Mohn, D. G. Webster, Ryan K. Vaughn, and Peter Adams. Prepared for the City of Stockton: Economic Analysis of A Proposed Ordinance to Limit Grocery Sales at Superstores in Stockton, California, May 10, 2007 Contributed Economics Portion of: "The ARC GIS Coastal Sediment Analysis Tool: A GIS Support Tool for Regional Sediment Management Program: White Paper, Draft Technical Report for U.S. Army Corps of Engineers, by Ying Poon (Everest Consultants), Los Angeles District, April 2006. Contributed Economics Portion of: "Coastal Sediment Analysis Tool (CSBAT) Beta Version --Sediment Management Decision Support Tool for Santa Barbara and Ventura Counties," Draft Technical Report for U.S. Army Corps of Engineers, by Ying Poon (Everest Consultants), Los Angeles District, June 2006. 'The ArcGIS Coastal Sediment Analyst: A Prototype Decision Support Tool for Regional Sediment Management, John Wilson et. al., USC Geography Department, 2004 (contributed economic analysis for paper). "The Economic of Regional Sediment Management in Ventura and Santa Barbara Counties," prepared for the California State Resources Agency, Final draft (refereed) , Fall 2006, prepared for the Coastal Sediment Management Work group (CSMW). "The Potential Loss in GNP and GSP from a failure to Maintain California's Beaches," with Douglas Symes, prepared for the California State Resources Agency, 2002, http://userwww.sfsu.edu/—pgking/pubpol.htm. "The (Economic) Benefits of California's Beaches," prepared for the California State Resources Agency, 2002, http://dbw.ca.gov/beachreport.htm. "The Economic and Fiscal Impact of Beach Recreation in San Clemente," presented as part of Hearings on Congressional Appropriations for California Coastal Projects, US House of Representatives, April 2002. Also completed similar projects for Cities of Carlsbad, Carpinteria, Encinitas, and Solana Beach. San Francisco's Economic Growth 1995-2000: The Fiscal Health of the City and Implications for the Future," prepared for the San Francisco Committee on Jobs Summer 2001. This report was widely cited in the San Francisco press including front page articles by the Chronicle and Examiner. "The Demand for Beaches in California," prepared for the California Dept. of Boating and Waterways, Spring 2001. "Cost Benefit Analysis of Shoreline Protection Projects in California," prepared for the California Dept. of Boating and Waterways, Spring 2000. "The Fiscal Impact of Beaches in California," prepared for the Public Research Institute, San Francisco State University, Fall 1999, available at http://online.sfsu.edu/—pgking/beaches.htm. "An Economic Analysis of Coastal Resources on the Majuro Atoll," prepared for the United Nations Development Program Project MAS 95/001/DO1/99 and the Majuro Atoll Local Government, September, 1997. "The Economic Impact of California's Beaches," prepared for the Public Research Institute, San Francisco State University, Summer, 1997 (with Michael Potepan.) "The Revenue Impact of the Proposed Marine Link Pipeline System in Richmond, California," prepared for the Public Research Institute, San Francisco State University, Spring, 1997 (with Ted Rust.) "The Economic Impact of California's Ports and Harbors," prepared for the Public Research Institute, San Francisco State University, Spring, 1997 (with Ted Rust). Books: International Economics and International Economic Polio, 5th Edition, McGraw-Hill, 2009. International Economics and International Economic Policy, 4th Edition, McGraw-Hill, 2004. International Economics and International Economic Polio, 3rd Edition, McGraw-Hill, 2000. International Economics and International Economic Policy, 2nd Edition, McGraw-Hill, 1995. International Economics and International Economic Polio, 1st Edition, McGraw-Hill, 1990. Published Papers: "Potential Loss in GNP and GSP from a Failure to Maintain California's Beaches", Fall 2004, with Douglas Symes, Shore and Beach (Refereed). "Do Beaches Benefit Local Communities?: A Case Study of Two California Beach Towns," Fall 2002, Proceedings of the Conference on California and the World Oceans. "The Economic Value of California's Beaches," Fall 1997, Proceedings of the Conference on California and the World Oceans (with Michael Potepan.) "William Simon: Treasury Secretary," in Biographical Dictionanj of the United States Secretaries of the Treasure,/; 1789-1995, edited by Bernard Katz and C. Daniel Vencill, Greenwood Press, 1996. "The Multinational Corporation: Pro and Con," in International Economics and International Economic Policy, McGraw-Hill, 1990, "Negotiations over Mineral and Petroleum Contracts in Developing Countries: a new explanation," Winter 1987, Journal of Economics and International Relations. "A Political Theory of MNC-LDC Negotiations over Mineral Concessions Contracts," 1988, International Interactions. Public Testimony: Testified and prepared report to the California Coastal Commission in San Diego on the economic loss due to a proposed seawall at Las Brisas, Solana Beach, California. Dale LaForest & Associate Design, Planning & Environmental Consulting 101 E. Alma Street, Suite 100-A Mt. Shasta, California 96067 (530) 926-5016 phone/fax Law Offices of William D. Kopper 417 E Street Davis, CA 95616 phone: (530) 758-0757 fax: (530) 758-2844 COMMENTS ON FINAL ENVIRONMENTAL IMPACT REPORT: UKIAH WALMART EXPANSION PROJECT - State Clearinghouse No. 2010032042 Dear Bill, January 17, 2012 We are disappointed to report that the FEIR's responses to our comments are largely inadequate. The FEIR must analyze and respond to all comments. CEQA § 21092.5(d)(2)(A). There must be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information will not suffice. CEQA Guidelines § 15088(c). It is noteworthy though that the Project itself and the FEIR have been somewhat revised in response to our comments. Better pedestrian access to Walmart's main entrance has been added. And the FEIR now includes revised calculations of Walmart's tree shading in its parking lot which were redone and included as an unacknowledged admission that those in the DEIR are in error. But that is not good enough because it deprives the public and City officials of the facts. As shown below, the FEIR's responses to many of our comments are inadequate, do not provide a good faith and reasoned analysis, and fail to support some conclusory statements with facts. COMMENT Q-113 DEIR Must Be Recirculated For Additional Time To Review Landscaping Plans We commented that CEQA requires the DEIR to be recirculated for additional time to review the significantly modified landscaping and site plans that were not contained in DEIR. Those plans were released later and the City of Ukiah did not provide even the CEQA-required minimum of 45 days for public review. The City withheld releasing the revised "Preliminary Planting Plan" with a different parking and planting layout until after the public comment period for the DEIR began. By now releasing the FEIR instead of recirculating the DEIR, the City of Ukiah refuses to provide the public that minimum review opportunity. On this comment, the FEIR responds: "A preliminary landscaping plan was submitted: Figure 3-5 of the DEIR. CEQA does not require preparation of detailed plans in order for the impacts to be evaluated and mitigation measures crafted. A revised parking lot plan and shade calculations are included as Appendix B of this Final EIR. " Comments on FEIR for Ukiah Walmart Expansion Project -1- DL&A Comment Letter — January 17, 2012 This response to comments is inadequate because it fails to address the problem commented upon regarding inadequate public review time. That response implies that the public is not entitled to an accurate project description that is fully contained within the DEIR. Such accuracy is vital for the public to use for its limited 45 -day public review of this Project's compliance with local standards and CEQA requirements. The FEIR's response also compounds the earlier problem. It contains a newly revised parking lot plan with new shading calculations, but the FEIR again refuses to provide the public the opportunity to fully review a recirculated DEIR with this significant new information. The threshold of significance for evaluating tree shading compliance, urban heat island effects and greenhouse gas impacts should be found in Ukiah's standards that require 20% landscaping and 50% pavement shading. The public has a right to accurate information and a detailed DEIR analysis in order to independently evaluate the Project's compliance and potentially significant impacts. Withholding such calculations until the FEIR is released denies that CEQA-mandated 45 day opportunity to analyze and comment and receive a thoughtful response to our comments from the City of Ukiah. The FEIR's response continues: "Further, the issue of parking lot shading was determined not to be a significant environmental issue ... " That response is inadequate because tree shading impacts may be significant if the City's minimum standards are not met. The EIR provides no other threshold of significance standards than those in the City's zoning regulations against which to measure the Project's shading and associated greenhouse gas impacts. The FEIR claims that parking lot shading is not an environmental issue because "(I) the AIP shade requirements were not in effect at the time the original store was approved and constructed. " That response is inadequate and ignores the fact that 19 years ago the consequences of global warming and climate change were not as well known. Now California has broadened CEQA's purview to include review of greenhouse gas emissions, and shading is clearly more than an aesthetic matter. Such review is now required for reasons of lessening climate change impacts and energy waste. The FEIR also replies that "(2) compliance with current standards is a code consistency issue to be determined by the Planning Commission. " That response is inadequate and evasive. It is an attempt to shift the burden of proper environmental review to a lesser matter of code consistency. Compliance with the local standards is more importantly a measurement of whether a Project may have significant environmental impacts that exceed the City's informal threshold of significance for shading impacts. On this comment, the FEIR finally responds: "(3) the proposed Project would improve future shading of the parking lot, and thus increase the benefits of shading that the commenter describes here and in additional comments below. " This response too is inadequate. It fails to Comments on FEIR for Ukiah Walmart Expansion Project -2- DL&A Comment Letter — January 17, 2012 acknowledge that the Project poses shorter -term but worsened pavement shading problems for possibly years as some existing, medium-sized shade trees are removed and until newly planted shade trees can increase in size to someday meet the pavement shading standards. The improved tree shading will not be immediate because some of the removed trees are larger than their replacements will be when those are planted. The likelihood of long-range future benefits does not exempt the City from analyzing and mitigating short-term shading loss. Just as construction noise impacts are a short-term impact that CEQA must evaluate, so too is pavement shading loss an significant impact to be analyzed. That deficit may extend for years before a net shading improvement is realized. The DEIR and FEIR never examine or acknowledge this interim period where Walmart will have less pavement shading than now. Therefore it is untrue for the FEIR to dismiss tree shading concerns under the erroneous theory that any trees that Walmart adds from this point forward will offer more pavement shading than its previously planted trees do. COMMENT Q-114 Landscape Plan For Tree Shading Is Inadequate We commented that the tree shading as proposed will be inadequate, resulting in significant greenhouse gas impacts and urban heat island effects. We demonstrated that due to significant calculation errors and misleading methods used, Walmart will not achieve the predicted 45% pavement shading in 10 years, for its landscaping plantings may only shade 20% of pavement by that time. We also summarized a list of nine ways that the DEIR misleads the public with its calculation errors. But the FEIR failed to adequately respond to these comments. The FEIR instead repeats its previous response error: "The issue of landscaping is not a significant environmental issue, but is rather a code consistency issue, to be determined by the Planning Commission. " As stated before, a project's compliance with City standards is also a CEQA factor for examining a project's level of significance and the FEIR cannot legitimately dismiss that obligation. The FEIR also responded: "The urban heat island effect, to the extent that it exists, would be reduced under the proposed Project, as the percentage of overall shade would be increased (see Master Response #5). " However, the urban heat island effect will be increased at first until new trees can grow large enough. The DEIR and FEIR both fail to examine the length of that short- term impact, and accordingly fail to propose mitigation (such as extra tree plantings at first) to more fully mitigate the impact. The FEIR replied by stating: "The existing trees are not to be considered a potentially significant impact, but are part of the baseline conditions (see Master Response #1). " This response is inadequate because it avoids, as described below, the City's obligation under CEQA to evaluate these existing trees and their pavement shading inadequacy as a means to predict the success or feasibility of proposed tree shading requirements. CEQA requires the EIR to discuss the Project's significant effects, such as a failure to comply with local standards, "with emphasis in proportion to their severity and probability of occurrence." The DEIR is inadequate because its preparers refuse to examine the probability, based upon Walmart's track record with this same store and location, to maintain such parking lot trees. CEQA does not permit the City to merely Comments on FEIR for Ukiah Walmart Expansion Project -3- DL&A Comment Letter — January 17, 2012 set a baseline and ignore considerations all that has gone on before this point in time with Walmart's trees. The FEIR does not respond to our comments that the DEIR improperly relied upon significant calculation errors and used misleading methods to analyze pavement shading. We commented on nine different errors that the DEIR contained in that regard. But the FEIR only states: "The shade calculations have been revised to account for differences in methodology, see Master Response #S. " That response is evasive and nonresponsive. It provides the reader no understanding of those various errors so they too can examine the FEIR's conclusions that this impact is not a significant environmental issue. When the DEIR estimated that Walmart will provide 45% shading of the parking lot pavement in 10 years, but now the FEIR dramatically changes its tune and estimates that pavement shading will be as low as 8% to 15%, the public deserves to know what went wrong with the previous calculation. In the absence of a good -faith response to this comment, the public will not have the information with which to analyze the FEIR's even more exaggerated alternative claim in Appendix B that pavement shading may be 61 %. Moreover, the public has a right to review the new calculations within a recirculated DEIR. Otherwise, the EIR will have misled the public into believing that Walmart was nearly complying with shading standards, when in fact Walmart's compliance may be far from the mark. COMMENT Q-115 FEIR.pdf p. 188 Parking Lot Tree Shading Is Important In Reducing Various Environmental Impacts We commented that the Project's failure to meet Ukiah's landscaping requirements has greenhouse gas impacts, urban heat island effects and energy usage implications. Shade trees reduce parking lot temperatures, reducing the cooling requirements of the Walmart building, future neighborhood businesses, and parked automobiles. The FEIR, p. 3-79, responded: "As discussed in response to comment A-7, the landscaping guidelines for the AIP may be modified as determined by the decision making body. It is acknowledged that the existing parking lot does not meet the AIP shading goal. " This FEIR response is inadequate because the landscaping requirements of the AIP Ordinance are not subject to modification by the Planning Commission unless a variance is requested, but none was. Moreover, CEQA requires analysis and consideration of alternatives or mitigations of such inconsistency even if the agency chooses to later modify its standards. Then the FEIR continues: "However, using any of the discussed methodologies, the shading would ultimately increase under the proposed Project (see Master Response #5) as compared to existing conditions. Therefore, the indirect effects discussed by the commenter would be reduced. " This response is inadequate because the applicable threshold of significance is not whether shading will "ultimately increase", but whether the 50% pavement shading standard will be achieved within 10 years. Until a net shading increase occurs pursuant to the required conditions and schedules of the existing Walmart project and the proposed expansion, this Project would result in increased, and not reduced, shading impacts. The EIR fails to evaluate that short-term decrease in pavement shading impact. Comments on FEIR for Ukiah Walmart Expansion Project -4- DL&A Comment Letter — January 17, 2012 AERIAL PHOTO OF THE UKIAH WALMART'S PARKING SHADING —2011—Google Maps Comments on FEIR for Ukiah Walmart Expansion Project -5- DL&A Comment Letter — January 17, 2012 The 2011 aerial photo above, proving how important tree shading is, shows that motorists will even park far from this Walmart's entrances when they can find tree shading from larger trees on the edge of the parking lot. The EIR should analyze any significant environmental effects this Project might cause by bringing development and people to this site that is already inadequately shaded. Such analysis should include the greater greenhouse gas emissions and climate change impacts as even more people access this larger store and park in unshaded locations, or locations that will not be shaded sufficiently for many years until new trees gain appreciable size. COMMENT Q-116 FEIR.pdf p. 189 Walmart Failed To Comply With Previous Tree Conditions We commented that Walmart failed to follow its original tree planting requirements of one shade tree to be planted for every four parking spaces. Those were to be a minimum of 15 -gallon shade trees that by now could have been as large as 30 feet in crown diameter under ideal conditions. Walmart however planted and pruned olive trees within its parking lot, preventing them from providing their anticipated shading benefits over these last 18 years. The FEIR's response is inadequate because it states: "The existing trees are part of the baseline conditions for purposes of the EIR. See Master Response #1. See also response to comment Q- 117. " This response never addresses that fewer shade trees per parking space now exist than were required. It fails to address Walmart's history at this site of an inadequate tree growth rate, of its failure to replace missing trees, and of its excessive pruning that led to inadequate shading. CEQA requires that the FEIR evaluate Walmart's future probability to be in significant noncompliance with a local standard which, in this case, is related to a threshold of significance for greenhouse gas impacts. The FEIR does not comply with CEQA when it sweeps under the carpet Walmart's history of neglect or abuse of these tree planting standards. It is inaccurate for the FEIR in its Master Response #1 to state: "The existing Walmart store operates in a manner that is consistent with its existing permits. " If the City of Ukiah now takes that position, then the likelihood is that City officials will look the other way again if Walmart fails to live up to these new tree planting conditions for its expansion Project. COMMENT Q-119 FEIR, pdf. P. 191 Walmart's Parking Lot Shade Trees Will Not Grow As Fast As The DEIR Estimates We commented that Walmart's existing Chinese Pistache trees are much smaller after the last 18 years than they should be. They average only 17.5 feet in diameter instead of the DEIR's assumed 30 -foot diameter for the newly planted Chinese Pistache trees. The FEIR replies: "As stated in the Final EIR, the existing parking lot does not comply with current AIP landscaping standards (which were not in effect at the time the original Walmart was approved). " But that reply fails to respond to the essence of this comment which primarily criticizes the DEIR's gross exaggeration of how much shade a Chinese Pistache tree will provide Comments on FEIR for Ukiah Walmart Expansion Project -6- DL&A Comment Letter — January 17, 2012 within 10 years. Such a calculation error undermines the DEIR's claim to provide substantial evidence. The FEIR also responds: "The proposed Project, while not meeting all of the standards of the AIP ordinance, would represent an improvement over the baseline conditions. It has further been acknowledged by staff that the existing parking lot trees have not provided the coverage that was anticipated. " That response is largely irrelevant to the comment though. It ignores the point that since previous Chinese Pistache trees grew much slower than Walmart's consultants now predict, that this Project's future Chinese Pistache trees may also fail to meet the DEIR's and FEIR's predictions. The public is not served well by the DEIR's mere admission that Walmart's anticipated shade coverage was deficient. Rather, the DEIR should analyze that deficiency in order to craft effective mitigations or impose conditions so that future shading will be effective. The FEIR continues: "Maintenance requirements will be included in the conditions of approval should the Project be approved. " Yet that response is also inadequate. It is insufficient to merely maintain trees better; these trees also need good soil when planted, sufficient planter surface area for air and water, and require protection from surface water pollutants also draining across the pavement and penetrating the soil from leaking vehicles parked nearby. The EIR fails to deal with this comment or the underlying problem if no mitigation is provided to require proper soil preparation and planter size before each tree's planting. The FEIR also fails to address a problem often seen in nursery -grown trees that are typically bought by Walmart at the lowest possible costs. Such trees are often selected to be sold at a discount because they are nursery stock that is less likely to thrive than healthier trees marketed at regular prices to others. The FEIR's response include this margin note beside Q-119: "Supplemental Environmental Checklist Form" but this notation is not meaningful to the reader and has no reference in FEIR elsewhere. This margin note is not adequate to comply with CEQA Guidelines § 15088(d)(2) because it is too cryptic to actually inform the public that the EIR is revised in response to this particular comment. Essentially, the FEIR preparer is hiding from the public that it made substantial errors in overestimating how fast Walmart's parking lot trees would grow. The FEIR is concealing the necessary information that is required by CEQA to help the public discern what changes were made in response to public comments. We commented that Walmart's existing trees have only about one third the actual shaded area as the predicted area discussed in the DEIR, even though the existing trees been growing for nearly twice that future 10 -year period. But the FEIR completely ignores and fails to respond to this comment. This is a violation of CEQA which requires the FEIR to analyze and respond to all comments. Instead, the FEIR (see FOR .pdf, page 192) does not even add the typical designation line in the right border to label our comment's paragraph as part of Q-119; that is further evidence that the FEIR did not respond to this part of this comment Q-119 and arguably does not want to draw the reader's attention to that fact. Comments on FEIR for Ukiah Walmart Expansion Project -7- DL&A Comment Letter — January 17, 2012 COMMENT Q-120 FEIR .pdf, p. 192 The DEIR and FEIR Inconsistently Describe How Many Trees Will Be Removed We commented that the DEIR inconsistently identifies either 5 or 6 Chinese Pistache trees will be removed. The FEIR responded and fixed that inconsistency by stating that 6 Chinese Pistache trees will be removed. But at the same time, and this is much more of a serious discrepancy, the FEIR now claims on its revised Preliminary Planting Plan L4.0 that twenty (20) of these existing Chinese Pistache trees will be removed. An EIR must contain a consistent project description if it is to comply with CEQA. But this FEIR does not comply because it, at the last moment and without providing a 45 -day public review opportunity to discover and challenge these changes, now reveals that more than three times the number of these trees which have been growing for 18 years are proposed for removal. We also commented that the DEIR calculated the shaded area from 44 of these Chinese Pistache trees when only 38 will remain, and thus it exaggerated the amount of tree shading. The FEIR violates CEQA because it provided absolutely no response to this comment. The FEIR should have acknowledged that the DEIR's predicted shading for those six trees was mistakenly included in its shading calculations as if they were to remain. Now that the FEIR plans propose removing 20 of these Chinese Pistache trees, the EIR's shading calculations are even more exaggerated. COMMENT Q-121 FEIR.pdf, p. 192-193 Walmart Could Have Met Ukiah Tree Shading Standards If It Had Tried We commented that the City of Ukiah should hold Walmart to its tree shading standards. And we noted that the DEIR fails to provide adequate data, analysis and correct conclusions regarding these tree shading impacts. The FEIR, p. 3-80 to 81, responds: "The ability of Walmart to have improved its tree planting practices in 1993, and the currently resulting shade coverage is not relevant to the EIR. Please refer to Master Response #1. " This response is inadequate. The FEIR is incorrect to claim that Walmart's history of tree planting and maintenance is not relevant to the EIR. Noncompliance may be a significant effect and it should be discussed with emphasis in proportion to its severity and probability of occurrence. (see CEQA Guidelines § 15143.) The DEIR is inadequate because its preparers refuse to examine the probability, based upon Walmart's track record with this same store and location, to maintain such parking lot trees. Such analysis is reasonably feasible, given that the data about existing tree sizes is already known and that aerial photos showing such tree shading are readily available. We commented that the DEIR fails to identify a threshold of significance for shading impacts, does not double-check Walmart's claims, and concludes that 45% of the parking lot's shading is good enough. But by first failing to recognize that non-compliance with Ukiah's current tree Comments on FEIR for Ukiah Walmart Expansion Project -8- DL&A Comment Letter — January 17, 2012 standards is evidence of a significant environmental impact, the DEIR then fails to provide a mitigation requiring a specific tree shading ratio in 10 years. Such mitigations which are publicly enforceable are needed when Walmart has not privately complied with conditions it signed. Had Walmart planted and maintained the trees it agreed to plant in 1993, there would now be sufficient shading to meet current standards. Compliance is feasible and should be required. The FEIR responds: "Regarding the threshold of significance, compliance with the AIP landscaping standards, in and of itself, is not a potentially significant effect, therefore it is not addressed as such and a threshold of significance is not provided (see CEQA Guidelines Section 15143). The proposed Project, regardless of meeting the AIP standards, would represent an improvement in existing shade coverage. In addition, the AIP standards include specific procedures for modification of the landscaping standards by the decision making body. " The FEIR fails to adequately respond to the comment that the DEIR did not identify a threshold of significance for tree shading -related greenhouse gas impacts. The City's minimum landscaping standards for tree shading are functionally equivalent to a threshold of significance, even if Ukiah has not formally adopted them as such. Ukiah must rely on some kind of explicit or implicit threshold of significance for its pavement shading if it intends to comply with CEQA when preparing this EIR. However, the FEIR's response is confused, evasive and irrelevant on this point. Moreover, § 15143 itself' mandates that the EIR focus on the probability of occurrence of significant environmental effects. COMMENT Q-122 FEIR.pdf, p.195 The DEIR Ignores Significant Errors In Wahnart's Landscaping Predictions We commented that overlapping tree canopy areas should not be double -counted as the DEIR did. The FEIR, p. 3-81, states: "At the City's request, revised shade calculations have been prepared and are included in Appendix B of the Final EIR. Please see Master Response #5. " But this is not an adequate response to this comment. This response inadequately admits or addresses the calculation errors and essentially refuses to recirculate the DEIR for additional public comment. The reader may likely falsely believe that the DEIR's calculations are still accurate, and that the FEIR only presents two more, equally valid methodologies for calculating tree shading areas. We raised a concern that those trees with crowns that overlap cannot achieve full growth if their limbs and roots are intertwined and they have to compete for limited sunlight and nutrients. When planted so close together, it is unlikely they will reach the size that Walmart predicts. The DEIR and the landscape plan calculations need to be corrected to reduce the exaggerated shaded 15143: The EIR shall focus on the significant effects on the environment. The significant effects should be discussed with emphasis in proportion to their severity and probability of occurrence. Effects dismissed in an Initial Study as clearly insignificant and unlikely to occur need not be discussed further in the EIR unless the Lead Agency subsequently receives information inconsistent with the finding in the Initial Study. A copy of the Initial Study may be attached to the EIR to provide the basis for limiting the impacts discussed Comments on FEIR for Ukiah Walmart Expansion Project -9- DL&A Comment Letter — January 17, 2012 area from Walmart's various closely -planted trees. But the FEIR completely fails to address the comment that trees with overlapping canopies and root systems do not achieve the same size as the single trees do and which the DEIR bases its calculations on. Instead, it continues with its new calculations in Appendix `B" making that same error of overestimating tree canopy shading area from trees it proposes to replant again too close together. Our comment that this Project's shade trees will not grow in 10 years to the size predicted by the DEIR was also totally ignored, at least as far as CEQA requires with a good faith, reasoned analysis in response. Repeating that error, the FEIR now provides an even more exaggerated calculation in Appendix B predicting that the trees will achieve 61% pavement shading, and uses figures for the tree sizes that are clearly unreasonable. We commented that the DEIR does not even describe what area (measured in square feet) of the parking lot will be shaded. The FEIR again completely fails to respond to this comment. We commented that the DEIR completely fails to predict when in time that its predicted 45% parking area shading will occur. The FEIR completely fails to respond to this comment too. We questioned why can't Walmart at the same time plant twice as many new trees within its parking rows so they will achieve the City's desired shading coverage sooner in time? It does not cost much more to plant two trees in a tree planter instead of just one, so this would be a feasible mitigation even if eventually the two trees' canopies overlap. In the early years they will provide more shading and reach the City's goal sooner in order to comply. The FEIR again completely fails to respond to this comment. We commented that neither the Shade Calc chart, the Preliminary Planting Plan, or the DEIR identifies which existing shade trees and new shade trees are predicted to grow to these sizes it relies upon. The FEIR completely fails to respond to this comment too. And we noted that the DEIR must be revised and recirculated once these errors were remedied. Again, the FEIR has no response to this comment. These must be sensitive issues that the FEIR preparers wanted to downplay or even hide from the readers, and in so doing, violated CEQA's mandate to provide a good -faith reasoned response. The FEIR, in response to literally seven pages of our different and detailed comments, ignored most and merged them into just one short response, missing many points, and concluded instead by reporting only that some revised shade calculations are added to the FEIR. COMMENT Q-127 FEIR.pdfp 214 DEIR fails to analyze the two-story project alternative We complained that the DEIR fails to analyze the two-story project alternative — an alternative that would have allowed more of the property to remain landscaped and therefore comply with the City of Ukiah standards. We commented that CEQA requires actual analysis and not unsupported conclusions such as the DEIR offered of [t]his alternative would not avoid or Comments on FEIR for Ukiah Walmart Expansion Project -10- DL&A Comment Letter — January 17, 2012 substantially lessen any of the significant unavoidable GHG emission... impacts. " To the contrary, paving less of the otherwise landscaped site would actually lessen GHG impacts. However the FEIR, p. 3-82, responded: "The DEIR includes a reasonable range of alternatives. The range of alternatives considered in an EIR is determined by their ability to avoid or reduce one or more significant effects, and to feasibly achieve most of the Project objectives. " This response is inadequate. The DEIR does not evaluate a reasonable range of alternatives to avoid the significant impact of inadequate landscaping percentage of the site. Paving or building on less of the otherwise landscaped site would actually lessen greenhouse gas impacts. Those alternatives that are part of the "reasonable range" of alternatives must include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project. We commented that the DEIR claims without any analysis that "adding a second story is much more expensive than constructing an addition to an existing building, raising issues of economic feasibility. " If indeed economic feasibility is an issue that is raised, where is it discussed in the DEIR? Nothing in the DEIR supports that statement. Without any explanation however, the DEIR dismisses this two-story project alternative out of hand without any analysis of its potential environmental benefits and its feasibility. The FEIR responds: "The two-story alternative was considered, but rejected for failing to meet those two basic criteria. As discussed on page 6.3.1, this alternative would not avoid or reduce significant impacts, could create new impacts (aesthetic), and raises issues of feasibility. " That response is also inadequate. The DEIR's rejection of this two-story alternative was not based upon analysis or studies of its infeasibility. The DEIR includes no finding of infeasibility of this two-story project alternative. Walmart has built other two-story Walmart buildings elsewhere .2 There is also a two-story Walmart in La Mesa, CA. Shoppers access the separate retail floors using standard escalators along with cart escalators. 2 See article, "A two-story Walmart store is proposed for Route 1 north..."; http://articles.boston.com/2011-07- 21 /news/2979 8660_ 1 _site-plan-water-mains-new-walmart Comments on FEIR for Ukiah Walmart Expansion Project -11- DL&A Comment Letter — January 17, 2012 Escalator and cart -escalator in two-story Walmart in California The DEIR on page 6.3.1 or elsewhere does not adequately support dismissal of this alternative with evidence that it could create a new, significant aesthetic impact. All its states on that subject is: "In addition, the two-story alternative would be more visible from the U.S. 101 corridor, which is identified as a Scenic Corridor in the City's General Plan. " Two-story buildings are not necessarily visually impacting, and are allowed in that zoning district. The General Plan Open Space Element, page 25, has a scenic corridor section 1.08 but it has but one goal to visually enhance Highway 101 with implementation measures that only require landscaping. Two story buildings are not restricted. The City of Ukiah could require more landscaping and trees along the freeway side of Walmart if it truly believed a two-story alternative might have an aesthetic impact, for tree planting is certainly a low-cost, feasible mitigation. This FEIR response is therefore inadequate and misleading if not outright false. COMMENT Q-128 FEIR.pdf p. 214 The DEIR Must be Recirculated For Additional Public Review We commented that CEQA requires the revision and recirculation of this DEIR before this Project's application can be again considered. The FEIR p. 3-82 inadequately responds: "As discussed in the specific responses to comments above, the commenter has not identified significant new information pertaining to new, or substantially greater impacts, that would require recirculation (see CEQA Guidelines Section 15088.5(a)). " That response is not adequate. Recirculation need not only be triggered by identification of new or substantially greater environmental impacts. It is also required where the DEIR was so fundamentally inadequate as to tree shading of Walmart's parking that comment on the DEIR was essentially meaningless. If significant new information is added to the EIR by the responses to comments after the public review period has begun, the City of Ukiah is required to recirculate Comments on FEIR for Ukiah Walmart Expansion Project -12- DL&A Comment Letter — January 17, 2012 the relevant parts of the document for further review and comment. The purpose of the recirculation is to give the public an opportunity to review the new data and the validity of the conclusions drawn from it. Newly revised site plans and tree shading calculations that appear for the first time in the FEIR are evidence of significant new information that requires recirculation. The newly predicted pavement shading ratio that is reduced from the DEIR's previously predicted 45% to the FEIR's now predicted lows of 8% to 15% is considerably different. Such information shows a substantial increase in the severity of this Project's greenhouse gas impacts and urban heat island effects. There is no substantial evidence that the previous shading calculations were adequate. These changes in the FEIR do not merely clarify or amplify existing information in an otherwise adequate EIR as would be necessary to avoid recirculation. The new information, dumped at the end of the FEIR, deprives the public of a meaningful opportunity to comment on a substantial pavement shading and greenhouse gas impact of the Project or feasible ways to mitigate those shading deficiencies. By the City of Ukiah having included an incorrect site plan in the DEIR, then omitting the corrected Landscaping Plan from the DEIR and not recirculating it then, and now revising it again at the end of the FEIR, the City has deprived the public of a meaningful opportunity to review that aspect of this Project. And even a brief review of that new information reveals that it too is significantly flawed. NEWLY REVISED SITE PLAN AND PRELIMINARY PLANTING PLAN Rather than respond to comments about exaggerated tree shading predictions, the FEIR instead refers the reader to some new exhibits in the FEIR, "Appendix B", as if those constitute an adequate response to comments. They do not. Those exhibits are also grossly misleading and filled with errors. The FEIR provides nearly no explanation of the revised tree shading calculations to accompany these exhibits other than some conclusory statements in its Master Response #5. Moreover, this Appendix B does not constitute an adequate response to comments because many comments remain unanswered by its new exhibits. City of Davis Standard Calculation Method The FEIR includes a new Project -related site plan labeled: SHEET L4.2 "Shade Calculation Exhibit (City of Davis Std.)" with graphic tree shading area representations and what are purported to be calculations of shading area. This drawing contains a legend labeled "Shade Calculations" that misrepresents the facts as presented in the DEIR. As a result, the purported calculation of shading area is essentially a sham and is in significant error. If provided adequate time (a minimum of 45 days, as required by CEQA), we would demonstrate how significantly in error this calculation exhibit is. But in the limited time provided, the following observations show that this exhibit does not constitute substantial evidence to support the FEIR's conclusions. 1. These "calculations" claim to exclude the area of all planter areas, as if only the asphalt pavement to be shaded was calculated. But this exhibit's plan of the parking area Comments on FEIR for Ukiah Walmart Expansion Project -13- DL&A Comment Letter — January 17, 2012 graphically indicates that some planters, some landscaping, and even some sidewalks where cars cannot park are included in the total shading area. The pavement shading calculations improperly take credit for shading some landscaping area but miscount it as if it is paved area. The lack of assumptions and data to back up these "calculations" makes it nearly impossible for the public to review this exhibit's conclusions. 2. The estimated 10 -year diameter of the newly proposed trees and their shaded areas are also grossly exaggerated as to their scale and area on this drawing. The new Chinese Pistache trees are assumed in these "calculations" to achieve a shading area of 962 s.f. each in 10 years. That typically represents shading from a circular tree crown diameter of 35 feet. While the City of Davis uses a maximum canopy or shading area of 962 sq. ft. for the Chinese Pistache at 15 years of age, that may be too large for actual, harsh parking lot growth circumstances in Ukiah, even if Ukiah's standards were lengthened to 15 years. A study of those Davis trees with a warmer climate found that tree canopy diameters didn't reach the theoretical size due to problems with parking lots. Elsewhere the City of Davis estimates a smaller 30 -foot diameter crown diameter for Chinese Pistache at 15 years with a full growth rate for this "moderate growth rate" tree. With that lesser diameter, the Chinese Pistache tree would have a canopy area of about 706 sq. ft. The City of Sacramento, after actually measuring this particular tree species in parking lot situations, also uses a smaller crown area of 706 sq. ft. for a Chinese Pistache tree at 15 years. 3. Trees' summer boughs do not entirely block sunlight penetration. Fully leafed trees will block varying amounts of sunlight. Walmart's proposed Chinese Pistache parking lot shade trees would likely allow approximately 15% sunlight penetration and reduce the true shaded area to about 85% of the crown area. By the FEIR's exaggerating how much shade these trees can provide like this, the entire calculation and conclusion is in error. 4. This drawings' calculations also are based on a 15 -year growth period for Chinese Pistache trees, not Ukiah's 10 -year requirement, as is evident by the note at the bottom of the "shade calculations" box. At most, those Chinese Pistache trees would have a crown diameter of only 25 feet in 10 years. In fact, the average diameter of those trees on Walmart's site after an even longer period of 18 years is only about 17.5 feet. That is only one half the size that Walmart's landscape architects now estimate. Walmart's architects are therefore estimating their new Chinese Pistache trees will have four times the shading area in 10 years than the existing ones attained in 18 years. That incredible and unreliable estimation is simply not likely nor even possible on this site, planted amidst pavement in undersize planters, as historical evidence shows. 5. That drawing's predicted 962 s.f. area for new trees is also inexplicably the same numerical area that is described for the existing Chinese Pistache trees that will have been growing for 28 years (in another 10 years) at that site. It is impossible for the shading area of the new Chinese Pistache trees to catch up to the shaded area of the older Chinese Pistache trees in that 10 -year period. The FEIR's estimated area in this "calculation" is obviously in error as a result. 6. The shade "calculations" add shading for a total of 44 Chinese Pistache trees (19,252 s.f. + 13,236 s.f.), yet the "Preliminary Plant Legend" only proposes that this Project will have 42 such trees. (24 existing + 18 to be planted = 42 total Chinese Pistache trees.) Comments on FEIR for Ukiah Walmart Expansion Project -14- DL&A Comment Letter — January 17, 2012 7. Similarly, the estimated diameter of the new Coast Live Oaks and London Plane Trees are also grossly exaggerated. They too are predicted by Walmart's landscape architects to grow to a shaded area of 962 s.f. in presumably 10 years, yet nowhere in the FEIR is there any substantiation for that excessive shading area claim. For that matter, the FEIR fails to describe when (i.e. 10 years? 15 years? or maturity?) these other two species of trees will achieve a 962 s.f. shading area. That shaded area per tree figure — if it represents growth in 10 years -- certainly does not come from any City of Davis standards. 8. No reduction in the parking lot's total shaded area is included for the inevitable tree damage, death, and necessary replacement with smaller trees. 3 9. The previous plans described that of the existing 44 Chinese Pistache trees, that 6 would be removed and 38 would remain. Now however many more of these trees which have been there for about 18 years are indicated for removal. This new drawing indicates that 20 Chinese Pistache trees will be removed and only 24 existing ones will remain, not including the new small ones to be planted. This previously undisclosed change will remove a significant amount of pavement shading from some of those existing larger trees that have the most shade to offer. US Forest Service Calculation Method The FEIR also includes a new Project -related site plan labeled: SHEET L4.3 "Shade Calculation Exhibit (US Forest Service)" with graphical tree shading representations and what are purported to be calculations of shading area. Other than a restatement of this calculation's conclusions in Master Response #5, nowhere in the FEIR is there any analysis of the calculations pertaining to this drawing. The FEIR inadequately supports those mere conclusions without providing any substantial evidence and data that this drawing is meant to convey. The HLA Group's landscape architect however added a note stating "In accordance with the Ordinance provided by the City of Ukiah, the area calculated for shading "All paved areas within 10 years of planting" we have provided an estimate of the shade at the 10 year mark." The [summary of] calculations on this drawing concludes, though without providing any meaningful data or detailed calculations, that the total pavement shading area is estimated to be 15%. Comparison of Calculation Methods Undermines the Credibility of the Walmart EIR: The note on the City of Davis calculation method claims that the parking lot shade percentage will be 61% s.f. (sic). On the next page, the U.S. Forest Service calculation method claims that the parking lot shade percentage will be 15% in 10 years. The FEIR fails to reconcile these huge estimation differences between 61% and 15%. It is as if the FEIR and Walmart's landscape 3 In 15 years, about a third of these proposed shade trees may not have survived and will need replacement, assuming that the City actually monitors the tree shading mitigation measure after years have passed. Replacement trees will not be as large and will accordingly provide less shade than if the original trees had remained healthy. The Sacramento Municipal Utility District estimates only 66% of such shade trees will have survived after 15 years. This Walmart Project's EIR does not discuss this issue where these trees in their initial half-dozen years will be more vulnerable to loss. Perhaps a third of them will have to be replaced with smaller trees in order to fit them into existing landscape planters. An aerial photograph of the trees in the existing Ukiah Walmart parking lot reveals that many of its original parking lot trees have not grown to anticipated size in 18 years since installation. Comments on FEIR for Ukiah Walmart Expansion Project -15- DL&A Comment Letter — January 17, 2012 architects are just blindly throwing darts if they can't prepare a more consistent or narrow target for evidence than this. This wild variation entirely calls into question the credibility of the tree shading evidence that has been presented. As shown above, it is clear that Walmart's landscape architects have misused the City of Davis method and exaggerated how much tree shading may occur. But there is no indication on their drawing, Sheet 1-4.2, whether that purported 61% shading estimation will occur in 10 years, in 15 years, or in a longer period of time. As such, it is not credible information upon which the EIR can determine that proposed parking lot tree planting will adequately comply with the City of Ukiah's standards and will not contribute to this Project having a significant greenhouse gas impact. Conclusion: For the foregoing reasons, the Ukiah Walmart Expansion Project's Final EIR and Walmart's newly proposed site or landscaping plans are inadequate in describing, analyzing and mitigating this Project's significant parking lot tree shading impacts, landscaping impacts, greenhouse gas emission impacts, and energy impacts. CEQA requires the revision and recirculation of this EIR before this Project's application can be again considered. Thank you for reviewing these comments. If you have any questions about this comment letter, please feel free to contact my office. Sincerely, Dale La Forest Professional Planner and Architectural Designer Dale La Forest & Associates Comments on FEIR for Ukiah Walmart Expansion Project -16- DL&A Comment Letter — January 17, 2012 SMITH ENGINEERING & MANAGEMENT 9 January 17, 2012 Mr. William D. Kopper Attorney at Law 417 E Street Davis, CA 95616 Subject: Ukiah Wal-Mart Expansion Project FOR P11005 Dear Mr. Kopper: Per your request, in support of the appeal to the City Council of the Planning Commission approval, I have reviewed the traffic and transportation aspects of the Final Environmental Impact Report (the "FEIR") for the proposed Ukiah Wal- Mart Expansion (the "Project") and subsequent disclosures such as oral and written testimony or later written responses related to the Planning Commission hearings on the FEIR dated November 9, 2011 and December 14, 2011. Previously, I reviewed and commented on the Draft Environmental Impact Report (the "DEIR") for the Project in a letter dated August 15, 2011. My qualifications to perform these reviews were thoroughly documented in my letter of August 15, 2011. Those credentials, as well as the entirety of substantive comment in that letter are incorporated herein by reference. My comments on the FEIR and subsequent disclosures follow. The FEIR's Approach to Responses To Comments Has Several Critical Flaws That Render the Responses Inadequate Critical flaws in the response to comment include the following: • The FEIR does not respond directly to the comments. Instead, it only responds to its own selective, usually very brief, summarization of the comments. This enables it to superficially appear responsive while actually evading addressing substantive issues in the actual comment. • In several instances, the FEIR attempts to characterize difference between the substance of the comment and the conclusions of the DEIR as a difference of opinion between experts. Where reasonable differences of opinion exist, the FEIR's obligation is to simply note of the difference of opinion without obligation to deal with it further. However, where analysts preparing the DEIR traffic study make assumptions or data interpretations highly favorable to the Project rather than equally plausible assumptions SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 2 and data interpretations less favorable to the Project, this is not a difference of opinion among experts. It is a failure on the part of the DEIR analysts to make the good faith effort to disclose impact that the California Environmental Quality Act (CEQA) demands. Moreover, in several instances on traffic matters in this FEIR, we ourselves, the traffic experts from the State of California Department of Transportation, the Mendocino County Department of Transportation and the traffic experts for COSTCO have, though phrased differently, made essentially the same comments. When multiple experts independently raise essentially the same comment, this is an issue of substance that must be responded -to in depth and cannot be noted and dismissed as the FEIR response has done as if these were separate one-on-one differences between the FEIR's traffic analyst and the individual commenters. • A number of comments by multiple independent commenters involve the need for more detailed definition of the design of the traffic mitigation measures. There is substantial doubt that the vaguely described mitigation measures would be functionally feasible (that is, actually mitigate the traffic impacts) and doubt that the proposed mitigations, if developed at a scale and with required design features that would actually result in functional mitigation, would be physically feasible within the constraints of right-of-way and existing structures. The FEIR's response to these comments is to the effect that these are design details that will be worked out between the City and Caltrans later on. In this DEIR and FEIR, the City has not fulfilled its obligation to define feasible mitigation measures for the Project's traffic impacts (since there is substantial doubt as to whether the inadequately described mitigation proposals would actually be functionally mitigative and/or physically feasible). Moreover, the effort to postpone defining the mitigation details until later constitutes a deferral of mitigation that is improper under CEQA. With this overview regarding generalized inadequate responses to comments on traffic impact matters, we now turn to the inadequacies of specific responses to individual comments. The DEIR Understates Existing, Consequently Future Traffic Volumes. This Leads To Understatement of Severity of Traffic Impacts and Unreliable Expectations Regarding Performance of Purported Mitigations. The FOR Does Not Provide Reasonable Response to These Issues. In a comment the FEIR labels Comment W-2, Caltrans representatives point out that the DEIR analysis is based on traffic counts taken in February, a month which tends to have below average traffic, and suggests that the study should have been based on months exhibiting more typical peak traffic or that the SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 3 February counts should have been adjusted based on seasonal factors. We concur in this Caltrans comment. The FEIR response on this issue is nonsense. We explore it in detail as follows with sections of the response highlighted in indented italic: The normal baseline for purposes of an EIR analysis is the existing conditions at the time of the NOP or when the environmental analysis is begun. This statement is true, but there is no mandate under CEQA that baseline traffic counts be taken in the exact month that the Notice of Preparation (NOP) is filed or analysis initiated as implied in the response. Anyway, the NOP in this matter was issued on March 11, 2010, not in February. Seasonal adjustment factors may introduce uncertainty and would require additional justification under CEQA. The preparers of the DEIR/FEIR are or should be well aware that ample justification for seasonal adjustment of February counts is supplied in the authoritative trip generation source document they have relied upon in this matter, Trip Generation, 8th Edition. Table 4 on page 14991 of Trip Generation, 8th Edition indicates that February shopping center traffic totals only 78.1 percent of annual monthly average shopping traffic, and is the absolutely lowest month of the year. Caltrans maintains permanent traffic count stations at locations throughout northern California. The preparers of the DEIR/FEIR know or should know that data from the most relevant stations can be readily accessed and used to seasonally adjust counts of overall traffic from the clearly low month of February to be representative of an average month or a peak month. In fact, the data from a nearby Caltrans permanent count station on US 101 shows that general traffic on the freeway in February is 7 percent lower than the average annual month, 12.4 percent lower than the average of the busiest 6 months of the year and 18 percent lower than the busiest month of the year. The DER in this matter was not released until June of 2011, more than 16 months after the February, 2010 counts were taken. The preparers could easily have taken counts in any of several more representative months when no adjustment would have been necessary and still had ample time to complete the work by June, 2011. ' The table is reproduced as Attachment A to this letter. SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 4 In addition, concerns were raised at the DEIR public hearing regarding peak hour traffic when school is in session which would make August - early September problematic. As noted above, there was plenty of time between when the NOP was issued in March, 2010 and June 2011 when the DER was circulated to have performed traffic counts in a month when school was in session that is more representative of an average or peak traffic month than February. Apparently the comments about `school in session' were made at the public hearing on the DER, about the same time as Caltrans comments of August 18, 2011 were filed. The FEIR was not circulated until very late October, 2011. We have reviewed the calendar of the Ukiah Unified School District. Elementary, middle and high schools started session in Ukiah on August 22, 2011. There was ample time in late August, September or early October of 2011 for the FEIR preparers to have performed representative verification counts to substantively prove or disprove whether the February 2010 counts are adequate or not. The City and its consultants made no such attempt. There is no substantial evidence that an increase in the baseline level would alter the findings of significance or the feasibility of the proposed mitigation measures. This statement is simply untrue. As we document further in subsequent sections, the feasibility of developing the proposed mitigation measures at a scale sufficient to functionally mitigate traffic impacts has been called to question by multiple competent parties, including Caltrans, COSTCO and ourselves. It is obvious that increases in baseline traffic would require greater scale facilities (particularly more throughput capacity and/or greater queue storage capacity on the 101 southbound — Talmage ramps, the ramp intersection with Talmage, at the Talmage — Airport Park intersection, and between the Talmage -101 ramps intersection and the Talmage — Airport Park intersection). The need for greater scale facilities increases the doubt that such facilities of the nature proposed can be developed within the constraints of the subject location. A central issue here is whether or not the queuing on the 101 southbound off - ramp to Talmage does or would stack back into the high speed deceleration area of the ramp or even onto the freeway mainline lanes under existing traffic or if lust Project traffic were added. In testimony at the December 14, 2011 Planning Commission hearing Mr. Steve Weinberger, the principal analyst of the DER traffic analysis, stated that in the existing condition and with Project traffic added, traffic on the southbound -to -westbound traffic would queue past the point where it shares the exit ramp with southbound to eastbound traffic but that the combined traffic would not queue so far as onto the freeway mainline. He also stated that all of the other scenarios studied for the Baseline (short range future) SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 5 and Future (long range future) conditions would cause queues onto the freeway mainline. In a December 7 mem02 responding to issues raised in your own letter of November 9, 2011, Brian Grattidge of ESA states in Comment Response 48- 49 as follows: "Based on our further review of the queuing analysis, the combined queues would be contained within the freeway/ramp gore point for only the Existing and Existing plus Project condition. In all other cases, the combined queue would extend onto the freeway." These statements seem to reflect an additional queuing analysis which, we note, has never been documented on record for public review. They also tend to convey an errant impression that it might somehow be OK to approve the Project now and work on mitigation of future conditions later. But the critical problem is that the above conclusions only relate to low February traffic. If the analysis considered an average month, there would be 7 percent more traffic than analyzed; if it considered the average of the busiest 6 months of the year, there would be 12.4 percent more traffic; if it considered the busiest month of the year, there would be almost 19 percent more traffic. And if it considered the peak shopping season, one component of peak traffic, shopping traffic, would be about 63 percent higher than in February. If traffic corresponding to these other time period scenarios were considered, the queues would be much, much longer than the DEIR estimated and the Existing plus Project queue would extend onto the freeway mainline. Traffic backing onto the freeway is, as Weinberger himself stated in his December 14, 2011 testimony to the Planning Commission, "the more significant safety issue". So, contrary to the FEIR response, there is substantial evidence that an increase in the existing traffic counts would alter the findings of significance or the feasibility of the proposed mitigation measures. Further to the point about the traffic volumes on which the entire traffic analysis is based, when the City's traffic consultants analyzed existing traffic at Redwood Business Park, they found that the Business Park as a whole was generating traffic at only about 71.6 percent of ITE Trip Generation 8th Edition rates in the PM peak. They chose to assume that the Walmart component was generating traffic at full ITE rates and that the rest of the Business Park was generating traffic at only 59.5 percent of ITE rates3. Carrying through application of the rates, this implies that the Business Park is generating 810 trips less than ordinary norms, evidently due to vacancy and decreased trip attraction as a consequence of the depressed economy. However, per the Court's ruling in Sunnyvale Neighbors vs. Sunnyvale City Council, the analysis should have adjusted the existing baseline to account for such trips not observed due to a temporarily depressed economy. Adjustment to account for the temporarily 2 Memo from Brian Grattige, ESA, to Kim Jordan, December 7, 2011, hereinafter "the December 7, 2011 ESA memo. 3 See DEIR Appendix B, Traffic and Circulation Report, page 37. SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 6 missing 810 existing trips would make an enormous difference in the entire traffic analysis findings. Factors described by the commenter could be used in the design process for mitigation options. As described below, this level of design is not required under CEQA. The lead agency will coordinate any such design work with Caltrans. This part of the response, which defers definition of feasible mitigation and attempts to shift responsibility for defining feasible mitigation from the Project applicant to the public, via Caltrans, is improper under CEQA and inadequate. In summary, this is one of several situations where the FEIR response denies the obvious, and continues to rely on data or assumptions favorable to the Project when other data is more representative. Hence, the FEIR fails to make the good faith effort to disclose impact that is demanded by CEQA. FEIR Admits Traffic Queuing On Southbound US 101 Exit to Talmage Road Will Be Significantly Longer than Disclosed In DEIR But Claims, Without Foundation or Logic, that Longer Queues No More Consequential Than Those Disclosed Our comment, now labeled Comment Q-85 documented how the DEIR Traffic Study failed to properly disclose the extent and significance of traffic queues on the US 101 southbound exit to Talmage Road. We point out that the flaw in the analysis is that it failed to consider that once the queue on the southbound to westbound ramp reaches a length of 600 feet (which the DEIR projects it does), the queue length becomes significantly greater instantly because traffic on the southbound to eastbound movement is obstructed at that point and that traffic becomes additive to the queue. This additive queue length, which is not analyzed in the DEIR, creates a situation significantly more hazardous than the queue lengths that are predicted in the DEIR. The FEIR response admits that the queues on the southbound to westbound exit movement "could interfere with the southbound to eastbound traffic", but claims, without foundation that this is not a new or substantially greater impact than is discussed in the DEIR. This conclusory claim of the response does not withstand the test of reasonableness because it attempts to isolate the fact that the DEIR understates queue lengths from the consequences of those significantly longer queue lengths that are discussed in what is now labeled Comment Q-86. And in fact, the SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 7 subsequent oral testimony of Weinberger at the December 14 Planning Commission meeting and the December 7 ESA Memo both subsequently admit that their analysis for all scenarios other than the Existing and Existing plus Project conditions, the subject off -ramp traffic would queue onto the freeway mainline. The FEIR Improperly Dismisses Our Comment that the Much Longer Queues than the DEIR Discloses Will Significantly Increase Traffic Safety Hazard on the Southbound 101 Exit to Talmage Those traffic safety consequences of the queues significantly longer than disclosed in the DEIR are explained in detail in what the FEIR now labels our comment Q-86. The FEIR's response to Comment Q-86 is essentially, `So what if the queue is really in excess of 1200 feet; we said it would be a little over 600 feet and anything over 600 feet is a problem.' In fact, the consequence of DEIR's underestimate of queue lengths, as revealed in our comment Q-86 is that the character of collision hazard inherent in the considerably longer queue lengths changes from the character of collisions with shorter queues. Shorter undesirable queues that the DEIR disclosed engender minor low -speed rear -enders. The longer queues that actually would result engender much more serious high- speed -differential and compound chain -reaction and avoidance -attempt collisions that involve greater personal injury and property damage. The failure to disclose and make this distinction clear to the public renders the FEIR response inadequate. The subsequent December 14 testimony of Weinberger and the December 7, 2011 ESA memo Response to Comment 48-49 now admit that the queues would extend onto the freeway mainline in most scenarios and the testimony of Weinberger agrees that this is a more significant safety issue. However, the ESA memo inexplicably continues to incorrectly maintain that "these conditions have already been identified as significant impacts in the DEIR,. 4 The FEIR response opines that "the increase in the rate of traffic collisions cannot be adequately forecasted." While it is correct that traffic collision rates are not typically forecast with precision, this response is an evasion. It is a matter of fundamental traffic engineering principles that if the queues extend into the high traffic speed operating area, the frequency and severity of collisions will increase. Hence, the response is an improper denial of the obvious consequences of queues significantly longer than those estimated in the DEIR. In his subsequent December 14, 2011 testimony to the Planning Commission evidently agrees with our comment that extension of the queues into the high speed traffic operating area is, in his words "the more significant safety issue". 4 Response to Comment 56 in the December 7, 2011 ESA memo is a circular reference to its' Response 48- 49 and adds no enlightenment to these issues. SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 8 The Proposed Mitigation Measures to the Queuing Problem at the US 101 — Talmage Interchange Would Be Disfunctional Due To Geometric Constraints Our comment now labeled Q-87 documented in detail the physical and operational and constraints that impaired the ability of the mitigation measures proposed at and near the interchange ramps of US 101 and Talmage Road to be feasible and mitigate the impacts of the Project. The FEIR response simply asserts that "the preparers of the EIR have determined that options described in the DEIR are potentially feasible' (emphasis added). The use of the term "potentially feasible" means that the preparers are not certain the mitigation options are feasible and that there is a reasonable possibility that they may not be feasible. This is simply not good enough. CEQA demands that feasible mitigation be defined. Speculative measures do not qualify as mitigation. Response Q-87 continues: "The options have yet to go through conceptual design (a step which is beyond the scope of this project level EIR)." This statement is nonsense. Unless a modicum of conceptual design at a level sufficient to demonstrate the facilities needed to provide a functional operational mitigation will fit within the physical constraints of the site, feasible mitigation has not been defined and the FEIR is deficient. Response Q-87 continues: "At such time, the geometric issues raised by the commenter, and other design and construction issues, will be further examined, in consultation with Caltrans, and it will be determined which mitigation option will be carried forward." This part of the response has several flaws. Because the mitigation remains indefinite, this constitutes a deferral of mitigation that is improper under CEQA. Because the mitigation remains indefinite, it is impractical for the City to condition the Project applicant to pay a fair share of an unknown cost of an unknown mitigation. And the notion that the City will work it out later in consultation with Caltrans is belied by the fact that Caltrans comments, now labeled W-3 through W-11, echo our own doubts about the feasibility of the mitigation options and the insufficiency of the conceptual engineering definition of the mitigation measures. We also note that the comment of COSTCO, now labeled 0-3 in the FEIR, reinforces our own comments as well as those of Caltrans regarding the insufficiency of demonstrating the feasibility of mitigation in the US 101 interchange area and the intersection of Talmage with Airport Park. The FEIR response evades any substantive response to this comment by simply referring the commenter to the traffic impact study that constitutes Appendix B to the DEIR as if there were something in there, which there is not, that demonstrates the geometric feasibility of the purported mitigation options. SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 9 A striking aspect of the FEIR responses to our comments, those of Caltrans and those of COSTCO on this same subject is that the response dismisses each as if it were the only comment on this particular matter. The response does not even acknowledge that three very competent parties, reviewing the DER from independent perspectives, have reached the same conclusion and concur that there is insufficient definition of the mitigation measures to demonstrate that what is needed to mitigate the traffic impacts can feasibly be fit within the physical constraints. The dismissive nature of the response is shockingly arrogant and improper under CEQA. However, in response to your letter of November 9, 2011, the ESA memo of December 7, 2011 belatedly provides limited significant new information — it discloses the inscribed circular diameter (ICD) of proposed roundabout mitigation Alternatives A and B5. Although the ESA mitigation claims that this is not significant new information, it undeniably is significant and new because it enables the public, for the first time, to see at scale how large the roundabouts and their required geometric features will be, to determine whether or not they will fit within the site's constraints and to determine whether they will interfere with the performance of other purported Project traffic mitigations. The new information enables corroboration of the comments on the DER by Caltrans, Costco and this commenter that the proposed roundabout mitigations don't fit and won't work. The fact that the information about the dimensions of the circles is significant and new means that the entire traffic component and any related component of the environmental document should be re -circulated in "draft" status. What the new disclosure about the dimensions of the proposed mitigation roundabouts reveals when considered at scale is discussed in detail in this writer's oral and PowerPoint presentation to the Ukiah City Council on January 18, 2012. The narrative script of that presentation and its' PowerPoint slides are appended hereto as Attachments B and C and incorporated herein by reference. In brief, when considered at scale, the newly disclosed dimensions of the roundabout alternatives reveals the following: For Roundabout Mitigation Alternative A: • The roundabout, with an ICD of 150 feet, will be considerably larger than depicted in the not -to -scale DER Appendix A, Figure 3-13 and with additional space required for replacement of sidewalks and slopes or retaining walls, will require taking of property and building demolition or relocation to the northwest of the roundabout. 5 Op. Cit., Response to Comment 52 SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 10 With properly dimensioned splitters (raised islands required to define and channelize the entries and exits on each two -direction leg) and bay tapers (the transitions between through lanes and left or right turn lanes, Roundabout A will constrain the left turn lanes from Talmage westbound to Airport Park southbound well below the lengths assumed in the analysis for the proposed traffic mitigation of the Talmage — Airport Park intersection. As a consequence, overflows from the left turn lanes will back-up the westbound through lanes on Talmage into Roundabout A and neither intersection, gridlocking it. The attached table (also duplicated in the referenced PowerPoint presentation, documents the extent of the serious left turn lane overflows that would occur in all scenarios analyzed. 6 When required lengths of lane transitions (the distance required to merge two or more lanes into one) are considered, the eastbound lanes emerging from Roundabout A would require transitions of 600 to 840 feet to merge down to a single lane 7. This puts the merge point well east of the US 101 freeway. Since the Talmage freeway overcrossing only has width for one lane in each direction, this means that Roundabout A would necessitate widening of the freeway overcrossing, a significant fact not disclosed in the DEIR or FEIR or subsequent disclosures. These considerations render the design of Roundabout Alternative A infeasible. In addition to the foregoing, the inscribed circle diameter of Roundabout A, 150 feet, is considerably less than recommended for 2 -lane roundabouts where overlapping heavy truck movements are likely (180 feet). The larger recommended ICD would compound all of the problems noted above. 6 We also note for the record that the December 7, 2011 ESA memo Response to Comment 50 misrepresents the situation. The response states: "The study intersections in the area of the Talmage Road interchange and the Airport Park Boulevard (sic) were evaluated using Synchro and Simtraffic which analyzes the intersections as a system, and not independently. The Synchro model has been set up to include all of these intersections, so that the impacts of excessive queuing on one intersection may impact the queuing and operations at an adjacent intersection. " The problem with this response is that, when the size of Roundabout A and its required splitters and turn bay tapers are plotted at scale, this reveals that the lengths of the westbound left turn pockets assumed in the DEIR's Synchro and Simtraffic calculations are far greater than the lengths that actually would be possible. Hence, what the output of the DEIR's Synchro and Simtraffic reveals is extensive queue overflows from these left turn lanes and blocking of the through lanes back into the roundabout rather than sufficiency. The same is true of the SIDRA analysis referenced in December 7, 2011 ESA memo Response to Comment 51. The response discusses only the satisfactory results for effects of bunching of traffic platoons on the eastbound approach to the roundabout and the adequacy of eastbound queue storage between Airport Park and the roundabouts. However, because the analysis assumes vastly more queue storage length in the westbound Talmage left turn lane approaches to Airport Park than what could actually be developed with Roundabout A and its required related geometric features, the SIDRA analysis does not properly reflect the queues that would extend back into the roundabout due to the inadequacy of these left turn storage lanes. ' The December 7, 2011 ESA memo discloses that design speeds at the roundabout were assumed to be 15 to 20 miles -per -hour at the roundabout. However, for movements away from the roundabout, a design speed minimum of 25 mph must be assumed and on at the existing 35 mph speed limit should be assumed. The lane transition distance requirements cited reflect these latter respective design speeds. SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 11 Left Turn Queues At Airport Park Overflow Their Storage Scenario II7 rn DEIR Lt. Tu StorageM Actual Lt. Turn Storage [3) Est. 95th %ile [41 95'h %ile Overflowl5l Est. Avg. Queuel'l Overflow hI B+P 450 192 _Queue 380 188 260 68 B+DC 450 192 403 211 293 101 B+DC+ P 450 192 457 265 343 151 F+P 450 192 387 195 286 1 94 F+DC 450 192 379 187 287 95 F+DC+P 450 192 451 259 334 142 0] All scenarios are for PM peak hour for westbound left turn lanes on Talmage at Airport Park under proposed mitigation for this intersection and with Roundabout A mitigation at Talmage with southbound US 101 ramps. B= Baseline, F= Future, +P= plus Project, +DC = plus Discount Club R) Combined queue storage length of both westbound left turn lanes with proposed Talmage -Airport Park intersection mitigation as assumed in DEIR traffic study calculations. All storage and queue values in feet. 131 Actual available storage in both westbound left turn lanes with proposed Talmage -Airport Park intersection mitigation and Roundabout Option A. 141 Per DEIR Appendix B, Appended Queuing & Blocking Reports. The 951h %ile queue ordinarily defines the queue length to be accommodated for design purposes and is often referred -to as the "design queue". 151 Length of 956i %ile queue in excess of actual queue storage with Roundabout A. 161 Average length of all queues that build in the subject left turn lanes, considering each signal cycle occurring in the peak hour per DEIR Appendix B, Appended Queuing & Blocking Reports. 171 Length of Average queue in excess of actual queue storage with Roundabout A. For Roundabout Mitiaation Alternative B: Roundabout B, with an ICD of 142 feet, would be considerably larger than depicted in the not -to -scale DEIR Appendix A, Figure 3-C. The DEIR's Roundabout B design assumes there will be right turn "bypass lanes on the southbound and eastbound approaches to it. Caltrans comment on the DEIR (Letter W, Comment 9 in the FEIR response) states that these bypass lanes are "non-standard features not typically permitted by Caltrans". The FEIR response on this item states: "Issues with constructability and design would be addressed in finalizing the design for this mitigation plan if the City and Caltrans agree on that concept". This response is merely an evasion. The true implication of Comment W-9 is that the design of Roundabout B simply is infeasible. The DEIR Appendix B Traffic and Circulation Report's SIDRA calculations showing purportedly satisfactory overall operations on Roundabout B are dependent on the assumption of bypass lanes on the southbound and eastbound approaches to this 1 -lane roundabout. If the bypass lanes are not there, Caltrans simplified capacity calculation procedures documented in Roundabout Geometric Design Guidances show that Roundabout B will 'Roundabout Geometric Design Guidance, California Department of Transportation, June, 2007 SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 12 have grossly insufficient capacity as a single lane roundabout. Hence, to provide sufficient capacity, Roundabout B would have to be enlarged to a two-lane roundabout. If this were done, it would have two lanes exiting eastbound. In that case, it would suffer from the same critical problem as Roundabout A — the necessary to -standard lane transition to a single eastbound lane could not be completed until east of the freeway overcrossing. Since the existing freeway overcrossing has room for only one eastbound lane, this renders Roundabout B infeasible.9 Summary Dismissal of Suggested Alternative Mitigation Is Inadequate In our comment that the FEIR response now labels Q-88, we suggest alternative mitigation measures for the US 101 — Talmage interchange. Although the FEIR preparers are unwilling to provide an adequate demonstration of the feasibility of the DEIR's proposed mitigation options, they are quick to claim our suggestions lack demonstration of feasibility. It is obvious, considering our comments, those of Caltrans and of COSTCO, that in regard to the 101 — Talmage / Airport Park area, the City is, in metaphor, trying to jam 4 pounds of clay into a 2 pound box and it just doesn't fit. The suggestion that the City look to broader solution to the issue is well founded and its' summary dismissal in the FEIR is inadequate. What the City really needs to mitigate both the near term situation and the cumulative long term situation properly is to widen the Talmage freeway overcrossing to at least 4 lanes, configure the southbound on and off ramps in a tight diamond, and develop as many through and turning lanes at the intersection of Talmage and the southbound ramps as necessary to solve level -of -service and queue storage problems. The FEIR Fails to Respond to the Demonstration that the DEIR Traffic Study's Computation Results Are Illogical Our comment, now labeled Q-89 in the FEIR documented in detail that in the future traffic scenarios, differing increments in traffic resulted in wildly disproportionate changes, and even in wrong -direction changes in queue lengths on the US 101 southbound ramp to Talmage. The FEIR response attempts to evade this disclosure of the lack of credible logic in the forecasts by resorting to a smokescreen of technical jargon. The response states as follows: "Queuing results were obtained using the Simtraffic software as discussed in the report on page 11 of the DEIR section. An average of random runs was used to obtain the queuing result, therefore queuing conditions don't necessarily follow a logical linear computation. 9 Roundabout B would also have significant problems with grading and sight distance as discussed in the appended Council presentation. SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 13 This commenter is well aware that the Simtraffic software used to project queues relies on a probability distribution in estimating individual vehicle arrivals and that the projected queue lengths are the average of several runs of the simulation and that, consequently, the resultant queue length predictions are not absolutely linearly proportionate to the actual forecast changes in traffic volume. However, the queue length predictions are ultimately based on volume of approaching traffic, the results should show a reasonable rough proportional correspondence to the changes in traffic volume. Such a rough proportional correspondence between queue length and traffic volume is overwhelmingly lacking in the results disclosed in the DEIR and described in the comment. A large increase in traffic generated in the area subject to analysis should never result in a decreased queue length. However, in the DEIR analysis the huge increase in traffic that would result when trips from the 464,872 square foot gross floor area Redwood Business Park results in a purported decrease in queue length. Such a result is simply not credible, and since the fundamental traffic mitigation issues relate to queues on the southbound 101- Talmage ramps and queues between the ramp intersections and Talmage -Airport Park, this credibility is fundamental to the adequacy of the traffic analysis supporting the DEIR and FEIR. The December 12, 2011 ESA memo response to Comment 57 repeats the FEIR response smokescreen of technical jargon and adds a self-righteous assertion that the methodology is an accepted methodology, that this commenter did not suggest an alternative methodology and that the answers in the DEIR are right. This response again evades the fundamental point of our original comment, which is: if the analysis applies the accepted methodology, but the results are clearly nonsensical, then there must be something wrong with the inputs to the methodology or the way it was applied. What the preparers of the DEIR traffic study should be doing is rechecking their work and correcting the illogical and errant result, instead of trying to evade the uncomfortable lack of credibility in that result by raising a smoke screen of technical jargon and self-righteous assertion. The December 12, 2011 LSA memo response to Comment 57 continues, asserting that the PM peak hour analysis of queuing on the southbound off ramp is always the worst case condition for all the scenarios analyzed in the DEIR. We concur in that statement, but it completely misses and fails to respond to our point. That point is that comparison of the AM and PM traffic volumes for the various scenarios presented in the DEIR leads to the reasonable deduction that the AM queuing impacts on the southbound off ramp would be similarly significant as those in the corresponding PM ones, though somewhat less severe, and that acknowledging those significant queuing impacts would not just be limited to the PM peak hour would be a useful disclosure to the public. The City has not adequately responded to this issue. SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 14 We also note here, for the record, that because, as discussed previously herein, the initial counts understate traffic, and because the DEIR traffic analysis considers no scenarios that apply seasonal adjustments to traffic or adjustments for temporarily low traffic due to depressed economic conditions, all of the traffic analysis procedures that were performed in the DEIR understate the severity of traffic impacts and overstate the likely mitigative performance of proposed mitigation measures. Discount Club Analysis In our original analysis, we believed that the basic DEIR traffic analysis, as documented above, was so severely flawed that the Discount Club analysis merely constituted an `over -the -top' scenario that compounded and added intensity to the initial flaws. We commented to that effect. We now have the benefit of seeing COSTCO and COSTCO's traffic consultants' comments on the DEIR and the FEIR's response and are compelled to augment our comments. Through their traffic consultants, COSTCO has provided compelling evidence that the DEIR traffic analysis considerably underestimates the proposed COSTCO store's trip generation potential — COSTCO's data shows that their proposed store's trip generation would be nearly 50 percent greater than considered in the DEIR analysis. The implication of this added traffic is that the mitigation options identified in the DEIR are still more likely to be insufficient or infeasible to be developed at the scale needed within the geometric constraints. We find deeply disturbing the fact that the City and its' consultants, instead of embracing the higher trip generation data volunteered by COSTCO (which would have the effect of increasing COSTCO'S fair share of whatever mitigation measure is ultimately determined necessary), have chosen to posit contrived hypothetical reasons why this particular COSTCO site might have lesser trip generation than the composite of COSTCO's experience, and thereby, to avoid revising the traffic analysis to reflect the COSTCO data. Central to the FEIR response's denial of the superiority of the COSTCO data is the unsubstantiated presumption that because this proposed COSTCO site is internal to a business park, it would somehow have different trip generation characteristics than most COSTCOs in Northern California. In specific, the response claims that it would attract more than a normal percentage of its' customers from people already in the Redwood Business Park and that, because it is not right next to the freeway, the COSTCO gas station would not attract travelers from the freeway (as though it were true that most COSTCO gas stations derive a substantial share of their business by attracting significant numbers of long range freeway travelers to stop for gas as if they operated like SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 15 just another freeway interchange area gas station). However, these presumptions are contrary to the nature of a 'discount club' store, particularly when set in a small, relatively remote urban area that serves as the 'market town' for a large rural hinterland. When a discount club store opens, particularly in such an area, the members will come and shop regardless of whether the store location is next to a freeway interchange, internal to a business park, next to the dump or alongside the sewage disposal plant. There is simply no basis for claiming this COSTCO will attract more than a normal percentage of its patrons from nearby establishments. Similarly, there is no basis for assuming the COSTCO gas station will attract a less -than -normal number of freeway travelers. Because of highly competitive pricing, COSTCO gas stations involve long lines at the pumps and relatively inconvenient waits. Hence, even when placed close to freeway interchanges, they are unlikely to be very attractive to long range freeway travelers, who may not be members anyway, and whose priority is getting gas quickly and getting back on the road. In dismissing the COSTCO data and maintaining the analysis based on typical rates derived from Trip Generation, 8th Edition, the City and the FEIR preparers contravene a fundamental principle articulated in Trip Generation, 8th Edition itself. That principle, articulated in Trip Generation, 8th Edition, Volume 1, page 2 states that: "When practical, the user is encouraged to supplement the data in this document with local data that have been collected at similar sites." Clearly, this is the opposite of what the FEIR responders have done. Quite evidently, the FEIR response is nonsense, put forward in the pretense of reasoned argument so that the FEIR can be certified without further analysis, with the COSTCO data dismissed under pretext of disagreement among experts. In choosing to continue to base the analysis on data favorable to the Project, rather than relying on the at least equally credible if not more credible data less favorable to the Project, the City and its consultants fail to make the good faith effort to disclose impact demanded by CEQA. Belatedly, in his December 14, 2011 testimony to the Planning Commission, Steve Weinberger takes a different approach. He states that if one considers the passerby attraction rate at COSTCO stores, the difference between the COSTCO data in the comment, as adjusted for attracted passers-by, and what was assumed in the DER analysis is less than 5 percent. But this facile explanation ignores the particular circumstances of the proposed COSTCO site. It is on a loop street, Airport Park Boulevard, that just returns drivers to the same intersecting street they came in from — there is no through traffic. So all the assumed passers-by would have to be attracted from the existing traffic on Airport Park Boulevard. SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 16 COSTCO stated its' PM peak generation should be 925 trips, the Walmart DEIR estimated them at 630 and Weinberger in his testimony says the difference from the DEIR number is only 5 % due to accounting for attracted passers-by. This works out to assuming 263 attracted passersby in the PM peak hour. Only 1763 vehicles enter or leave Airport Park Boulevard in the PM peak hour according to the DEIR. But of those, 720 would be Walmart trips. Since few shoppers visit Walmart and Costco on the same trip except in the Thanksgiving -to -New Year holiday shopping season which isn't analyzed at all in the DEIR, if the 263 trips are really attracted passers-by, they would be from the remaining 1043 PM peak hour trips on Airport Park Boulevard. That is to say, slightly over 25 percent of the non-Walmart travelers would have to be attracted. Since many of the non- Walmart travelers are daily users, this is like saying these other users would stop at Costco in the PM peak once every four or five days, an entirely unrealistic presumption. The traffic on Airport Park Boulevard is not sufficient to sustain the purported attracted passerby rate the Weinberger testimony assumes for Costco. Presumably, Weinberger was using the term "passers-by" loosely, really meaning trips diverted from the broader pool of trips on Talmage and the 101 freeway, not just directly from existing traffic on Airport Park. But such diverted trips would add critical turning movements at the Talmage -Airport Park intersection and to critical queues on the 101- Talmage ramps and between on Talmage between the Airport Park and 101 ramp intersections that is not properly accounted for in the DEIR analysis. Hence, the Weinberger Planning Commission testimony fails to reasonably explain the discrepancy between the DEIR trip estimate for the Discount Club and the COSTCO data. In end result, the failure to properly account for COSTCO traffic compounds the DEIR's understatement of initial traffic in scenarios involving the Discount Club, thereby compounding the DEIR's understatement of the severity of traffic impacts and its' overstatement of mitigative effects of purported mitigation measures. Conclusion The foregoing demonstrates that in its' traffic component, the FEIR repeatedly stonewalls responsible comment, fails to make the good faith effort to disclose impact demanded by CEQA and defers definition of feasible mitigation. Critical flaws in the DEIR analysis remain uncorrected despite oral and written responses of the DEIR/FEIR preparation consultants during the Planning Commission review process. Hence, the FEIR is inadequate and cannot be certified. Remedy of the deficiencies of the FEIR and DEIR would involve substantial new information about impacts and mitigation. Hence, the revised document should be recirculated in DEIR status. SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 17 Sincerely, Smith Engineering & Management A California Corporation Daniel T. Smith Jr., P.E. President LCL' �� , �'`�� `"• SL . CO � V `0 • M ZZ w :o No. 0)938 Exp.. �j ' • Th'�4 F F�G•',�N +��• OF CAS-`�0��,,0 a...........��tio SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Mr. William D. Kopper January 17, 2012 Page 18 Attachment A Sample size: 2 Average gross leasable area: 938,000 square feet The sites were surveyed between the 1960s and the 2000s throughout the United States and Canada. Source Numbers 1, 2, 3, 4, 5, 6, 13, 14, 18, 19, 22, 26, 40, 42, 48, 49, 54, 59, 60, 61, 64, 65, 72, 73, 75, 76, 77, 78, 79, 87, 89, 90, 98, 99, 100, 10.5, 110, 124, 156, 159, 172, 186, 193, 194, 195, 196, 197, 198, 199, 202, 204, 211, 213, 260, 263, 269, 295, 299, 300, 301, 304, 305, 307, 308, 309, 310, 311, 312, 313, 314, 315, 316, 317, 318, 319, 358, 365, 376, 385, 390, 400, 404, 414, 420, 423, 428, 437, 440, 442, 444, 446, 507, 562, 563, 580, 598, 629, 658 Trip Generation, 8th Edition 1499 Institute of Transportation Engineers SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Table 4 Monthly Variation in Shopping Center Traffic Percentage of Average Month Month Percentage Month Percentage January 85.3 July 100.8 February 78.1 August 102.1 March 92.0 September 94.8 April 93.2 October 98.9 Mav 105.4 November 101.5 June 106.0 December 141.8 Sample size: 2 Average gross leasable area: 938,000 square feet The sites were surveyed between the 1960s and the 2000s throughout the United States and Canada. Source Numbers 1, 2, 3, 4, 5, 6, 13, 14, 18, 19, 22, 26, 40, 42, 48, 49, 54, 59, 60, 61, 64, 65, 72, 73, 75, 76, 77, 78, 79, 87, 89, 90, 98, 99, 100, 10.5, 110, 124, 156, 159, 172, 186, 193, 194, 195, 196, 197, 198, 199, 202, 204, 211, 213, 260, 263, 269, 295, 299, 300, 301, 304, 305, 307, 308, 309, 310, 311, 312, 313, 314, 315, 316, 317, 318, 319, 358, 365, 376, 385, 390, 400, 404, 414, 420, 423, 428, 437, 440, 442, 444, 446, 507, 562, 563, 580, 598, 629, 658 Trip Generation, 8th Edition 1499 Institute of Transportation Engineers SMITH Engineering & Management • 5311 Lowry Road, • Union City, CA 94587 - Attachment B Testimony of Daniel T. Smith Jr., P.E. To the Ukiah City Council January 18, 2012 Members of the City Council: My name is Dan Smith, Smith Engineering & Management, 5311 Lowry Road, Union City, CA. I'm a registered civil and traffic engineer in California. I'm here on behalf of the appellants. I commented on the DEIR for the Project. In those comments, like those of Caltrans' and the Costco" representatives, I noted that the proposed traffic mitigations was not sufficiently detailed to know whether, with proper geometric requirements, they were physically feasible within the site constraints and whether they would be capable of creating the traffic operational improvements claimed in the DEIR's theoretical traffic analysis. The final EIR failed to provide details about key improvements. Finally, last month there was an ESA memo stating that the inscribed circle diameter —that's the diameter to the outside edge of the traffic lanes in the circle - would be 150 feet for Option A and 142 feet for Option B. That's it as far as detail. The concerns are these: (show slide 1). If the geometrics are done right, the mitigations won't fit or won't perform as claimed. Secondly, we believe the analysis of impacts is understated and the effectiveness of mitigations is over-estimated because everything is based on unrealistically low traffic counts and because of another major flaw in the traffic analysis — it failed to consider that a second traffic flow joined the queue once the queue on the southbound to westbound movement reached a certain length and failed to consider the consequences of that compound queue. Lets consider the geometric issues; (show slide 2) • What is the actual to -scale size of the roundabout circles? • What more space is needed for sidewalks, sideslopes and retaining walls? • What are the requirements for lane transitions, the distances to merge down from multiple lanes to a single lane, and the number of lanes needed at the exits to the roundabout? • What space do splitters take up, the size of the islands that channel traffic in and out of the roundabouts? • What space do bay tapers take up, the transitions to get into extra turn lanes • Particularly with regard to Roundabout alternative B, we are going to be talking about bypass lanes — lanes that avoid coming into the roundabout, and limitations on the steepness of grade on which the roundabout is placed and sight distance limitations. So lets see what happens when you place actual geometric requirements at scale on the roundabouts, starting with Traffic Study Figure 313, which shows Roundabout A. Here is the DEIR traffic study sketch.(show slide 3) The mitigation measure is not to scale; fortunately, the underlying aerial photo is. The typical range of inscribed circle diameter for 2 -lane circles is 150 to 200 feet. The diameter needed to facilitate side-by-side heavy truck movements is 180 feet, not a bad idea for a roundabout at a freeway interchange near a major shopping area and business park"'. But let's just stick with the proposed size of Roundabout A, 150 feet, recognizing that this is close to minimally sized. Here is the space a 150 foot roundabout would take. (show slide 4). There is a 5 foot sidewalk along the north side of Talmage that probably must be maintained. The right of way along the north side of the circle would have to extend another 5 feet beyond the circle diameter plus whatever additional space would be needed for utilities, slopes or retaining walls. So, a circle with an inscribed circle diameter of 150 feet, would extend into the long rectangular vehicle maintenance building to the north, and would actually extend another 5 or 10 feet allowing for sidewalk and retaining walls. That building is a goner. If it isn't already public property, there has to be a right- of-way acquisition. This is clearly different than what is in the DEIR. A design objective is to minimize merges within the roundabout. So if two or three lanes enter the roundabout, two or three lanes respectively should come out'v. This affects roadway width at the eastbound exit from the roundabout. The DEIR shows three lanes coming in from the south to only two lanes on the roundabout and two lanes coming in from the west. Clearly, there needs to be a third lane going out to the right, to the east side of the roundabout. When merging from two or more lanes to one, a considerable distance must be allowed for the merge. This distance is given by the width of the lane(s) being eliminated times the design speed in miles per hour. At a design speed on 35 miles per hour (the current speed limit), the merge distance from 3 lanes to one would be 840 feet; if design speed were compromised to 25 miles per hour, the merge distance would be 600 feet. Both these distances place the merge point to a single lane well on the east side of the freeway. The eastbound lanes coming off the roundabout simply cannot merge down in time to rely on the single available eastbound lane on the existing freeway overcrossing. In short, this roundabout design necessitates a widening of the freeway overcrossing. Roundabouts require raised islands called "splitters" on all two -direction legs. The part of the sketch on the east side is what a normal splitter looks like. The splitter island should be a minimum of 50 feet long although 100 feet is recommended". Because this design can't allow chaotic, unchannelized movements from the two lanes on the roundabout to the four lanes on the westbound approach to the Talmage -Airport Park intersection, the splitter on this leg in Figure 3B must be unusually wide to initially limit exits from the circle to the two through lanes. Cars and trucks don't move abruptly laterally as depicted in the DEIR sketch. Movements from through lanes to left turn lanes are defined by S-curved entry tapers. Entry tapers in California are normally 60 or 90 feet in urban areas, longer in rural areas'. So the entry tapers to the left turn lanes from Talmage westbound to Airport Park would go 60 feet from end of the splitter for the lane adjacent to the through lane and 60 feet further for the leftmost one. Because of the splitter and the entry tapers to the left turn pockets west of the roundabout, the effective length of the left turn lanes will be considerably less than depicted in the DEIR. The leftmost which would only have an effective length of less than 80 feet, will be difficult to enter, and at times blocked by traffic queues in the rightmost of the left turn lanes. Operations at the Talmage -Airport Park intersection will be worse than the DEIR estimated for the mitigated condition because the analysis overestimated queue storage based on the DEIR sketch. We can see from the queuing and blocking reports appended to the DEIR Traffic report that the left turn queues will overflow into the through lanes and spill back into the roundabout in all scenarios, not just at the 95`h percentile design queue but at the average queue as well in all scenarios where queuing was analyzed. (Slide 5) Here is a comparison of the DEIR's analysis to the queue storage actually available with required geometric features. Here it is more readable without all the footnotes (show slide 6). The table shows the queue storage the DEIR assumed, the actual queue storage with the right geometry, the values for the "design queue" and for the average queue the DEIR predicts, and the overflow back into the through lanes because the storage in the left turn lanes is too short. In all cases the DEIR analyzed in queuing and blocking reports, Baseline plus Project, Baseline plus Discount Store, plus both, Future plus Project, plus Discount Store, plus both, the queues will overflow and block the through lanes that will cause gridlock back into the roundabout. But not just the design queues. Even the average queues overflow and block in all scenarios. The SIDRA analysis of the roundabout operation does not take into account the backspill of queues from the inadequate left turn lanes on Talmage at Airport Park and the too abrupt merge of lanes between the roundabout and the freeway overcrossing. That analysis is invalidated by those conditions. However, even as performed, the SIDRA analysis shows the freeway off -ramp approach to this roundabout would operate at LOS E. Caltrans standard for this freeway segment is LOS D. Now lets discuss Roundabout Option B that was sketched in DEIR traffic Study Figure 3C (show slide 7). At scale, this 142 foot, single lane circle is slightly larger than shown on Figure 3C. (Show slide 8) Additional area will be required to the northwest of the circle to accommodate the sidewalk and necessary sideslopes or retaining walls. This proposed roundabout incorporates "bypass lanes" on the southbound and eastbound approaches. This is what a bypass lanes look like(show 9). One with a long acceleration and transition lane. (Show 10) One with a Yield sign that is almost like a separate intersection. The problem is that "Bypass lanes are not typically permitted by Caltrans"." Without the bypass lanes, the single lane roundabout would have insufficient capacity in all scenarios analyzed. Based on deterministic methods calibrated for California by Caltrans research, the capacity of a single lane roundabout would be exceeded for all scenarios analyzed from the Baseline (% over capacity) through the Future + Project + Discount store (% over capacity If the roundabout were made a 2 -lane roundabout, it might have sufficient capacity but would suffer from the same problem of insufficient distance to merge down to a single eastbound lane before reaching the freeway overcrossing structure as Roundabout Option A. Grade issues: Roundabouts should not be built on grades that exceed 4 % and are better if limited to grades of 3 percent or less""'. Available topographic data indicates the vertical curve on which this roundabout would be located averages about 5 percent. It would require extensive regarding of the north, south and east legs of the intersection to enable this roundabout to be constructed on a slope of 3% or less. This could necessitate right of way takes for side slopes or retaining walls. Sight distance issues: The grades on westbound Talmage pose sight distance issues for this roundabout. Stopping sight distance to the near limit of the roundabout, to the left half and to legs merging on the left (from the approaching drivers view), is required'x. The DEIR needs to demonstrate that these sight distance requirements are met for this proposed mitigation option rather than speculate. So here is the summary (show slide 10). Need a little more space than shown, especially with the north sidewalk and slopes. The assumed bypass lanes won't be approved by Caltrans, so the circle needs two lanes to work which means it would have to be even bigger. That also means the lanes can't merge down quickly enough to use the existing overcrossing so it would have to be widened. And there are massive grading and potential sight distance issues. We believe the right and necessary solution is to widening the freeway overcrossing to 4 lanes, put the west side ramps in a diamond configuration with as much separation from the Airport Park intersection as practical, signalize it, with as many approach lanes as necessary to make the intersection operate at LOS D or better. Now lets talk about those counts of existing traffic conditions taken in February of 2009. (Show slide 11) Caltrans permanent monitoring counts on 101 in the area show that for overall traffic, February traffic is 7 percent less than in the average annual month and 12 percent less than the average of the top 6 months. And for shopping centers, (show slide 12) the Institute of Transportation Engineers says February shopping traffic is only 78 percent of the average annual month and is the lowest shopping traffic month of the year. Further, in attempting to justify that trips of the existing Walmart should be assumed to be at full ITE Trip Generation 8rh Edition rates in crediting, that is deducting them from the proposed Walmart Superstore trip generation, the DEIR concludes that the rest of Airport Park Center is only generating traffic at % of ITE rates. This is further corroboration that the February counts are low, that traffic in the rest of the Center is depressed by economic conditions (which should be adjusted for in the base per the Court in Sunnyvale Neighbors vs City of Sunnyvale City Council), or both. There is no doubt that the DEIR's counts of existing traffic, from which the whole rest of the analysis flows, significantly under -represent existing traffic. Consequently, the traffic analysis understates traffic impacts and overestimates the effectiveness of purported mitigations. Moreover, COSTCO points out that the analysis significantly understates the Discount Club traffic. This feeds into and compounds a major flaw in the analysis. The DEIR analyzes the queue on the southbound 101 off ramp to westbound Talmage. It acknowledges that queues may build up past the point where the southbound to eastbound traffic splits on the off -ramp from the southbound to westbound traffic but it doesn't analyze that event at all. What happens when the southbound to eastbound traffic hits the back of the southbound to westbound queue is that the queue quickly gets much longer than the DEIR predicts. If ordinary traffic is 7 percent higher on the average than the February counts, and 12 percent higher in the busiest 6 months, that queue will be much, much longer than the DEIR analyzes. During peak shopping season traffic, far more than February, that queue will be much, much, much longer than predicted. And if the economy turns around, full trip generation of the rest of existing Airport Park Center will make it longer yet. If COSTCO has more traffic than accounted for, the queue is longer yet. When this happens, it puts the tail of the queue into the high-speed deceleration area or even onto the freeway mainline —something the Transportation comments forwarded by the County Board of Supervisors indicates happens already. This is a very hazardous condition, a serious public safety condition that responsible government cannot ignore. It would be irresponsible and negligent to approve the project without having feasible and effective mitigation measures identified and on track to be put in operation by the time the project would be occupied. Such measures are not in the works right now. Based on all of this, we believe you should uphold this appeal and direct staff to rework the EIR traffic study along the lines suggested herein. Thank You 'FEIR Letter W " FEIR Letter O "' Roundabout Geometric Design Guidance, California Department of Transportation, June, 2007. '° Roundabout Geometric Design Guidance, California Department of Transportation, June, 2007. "NCHRP Research Report 672 Highway Design Manual, Caltrans °" FEIR Letter W, Comment W-9. "' Roundabouts: An Information Guide 'X Roundabout Geometric Design Guidance, California Department of Transportation, June, 2007. Attachment C Concerns With Traffic Impact Analysis • Mitigation Sketches Omit Required Geometric Details • Sketches Omit Geometric Constraints • Mitigations Assume Unapproved Geometrics • When Above Is Considered, Mitigations Won't Fit Or Won't Perform As Claimed • Base Traffic Counts Taken In Low Traffic Month and Study Omits Impacts of Compound Queue Geometric Concerns • Actual scale size of roundabouts • Splitters • Bay tapers • Lane transitions and needed lanes • Sidewalks, sideslopes or retaining walls • Bypass Lanes • Grade w•tran )-P Nll. Watmart Expansion EIR Figure 3B Proposed Interchange Reconstruction Option A - City of Ukiah New US 101 Southbound Ramps Intersection (Roundabout) A North Left Turn Queues At Airport Park Overflow Their Storage Scenario Itl DEIR Lt. Turn Storagel'I Actual Lt. Turn StorageM Est. 95th %ile Queue['] 95th %ile Overflowl'I Est. Avg. QueueM Overflow hl B+P 450 192 380 188 260 68 B+DC 450 192 403 211 293 101 B+DC+ P 450 192 457 265 343 151 F+P 450 192 387 195 286 94 F+DC 450 192 379 187 287 95 F+DC+P 450 192 451 259 334 142 In All scenarios are for PM peak hour for westbound left turn lanes on Talmage at Airport Park under proposed mitigation for this intersection and with Roundabout A mitigation at Talmage with southbound US 101 ramps. B= Baseline, F= Future, +P= plus Project, +DC = plus Discount Club (2) Combined queue storage length of both westbound left turn lanes with proposed Talmage -Airport Park intersection mitigation as assumed in DEIR traffic study calculations. All storage and queue values in feet. I3) Actual available storage in both westbound left turn lanes with proposed Talmage -Airport Park intersection mitigation and Roundabout Option A. 141 Per DEIR Appendix B, Appended Queuing & Blocking Reports. The 95th %ile queue ordinarily defines the queue length to be accommodated for design purposes and is often referred -to as the "design queue". 151 Length of 95th %ile queue in excess of actual queue storage with Roundabout A. Isl Average length of all queues that build in the subject left turn lanes, considering each signal cycle occurring in the peak hour per DEIR Appendix B, Appended Queuing & Blocking Reports. l71 Length of Average queue in excess of actual queue storage with Roundabout A. Scenario[ DEIR Lt. Turn Storagel'i Actual Lt. Turn StorageM Est. 95th %ile QueueH, 95`h %ile Overflowl'I Est. Avg. QueueM Overflow [71 B+P 450 192 380 188 260 68 B+DC 450 192 403 211 293 101 B+DC+P 450 192 457 265 343 151 F+P 450 192 387 195 286 94 F+DC 450 192 379 187 287 95 F+DC+P 450 192 451 259 334 142 w-tr a r7 IV A North �o x >c X x Roundabout (Lanes to ba, i — determined)' Talmage Road x x3001 '1" I X y x @ z5mph i 1 X ac><5• i 74 i a ' -� 1 7 m T 1 1 `x, X. 0. i 1 a 4 i A North Exhibit 0.42. Configuration of right -tum bypass lane with acceleration lane. I - I Acceioratlon Tepee lennggth loregth bas0d on MHn O guidelines s Taper length based on local or state criteria (typically 401. Ate m (130 to 300 n)i Roundabouts: An Informational Guide - 6: Geometric Design Exhibit 6.43. Configuration of right-tum bypass with yield at exit leg. February Traffic Count Base Understates Traffic Impacts • Caltrans Northern California US 101 Data Shows Feb Traffic 7% Below Annual Avg. & 12.4% Below Avg. of Busiest 6 Mos. • Trip Generation, 8t" Edition Shows Feb Shopping Center Traffic Is Only 78.1 % of Annual Avg. and Is Lowest Month of Year Sample size: 2 Average gross leasable areas 938,000 square feet The sites were surveyed between the 1960s and the 2000s throughout the United States and Canada. Source Numbers 1, 2, 3, 4, 5, 6, 13, 14, 18, 19, 22, 26, 40, 42, 48, 49, 54, 59, 60, 61, 64, 65, 72, 73, 75, 76, 77, 78, 79, 87, 89, 90, 98, 99, 100, 105, 110, 124, 156, 159, 172, 186, 193, 194, 195, 196, 197, 198, 199, 202, 204, 211, 213, 260, 263, 269, 295, 299, 300, 301, 304, 305, 307, 308, 309, 310, 311, 312, 313, 314, 315, 316, 317, 318, 319, 358, 365, 376, 385, 390, 400, 404, 414, 420, 423, 428, 437, 440, 442, 444, 446, 507, 562, 563, 580, 598, 629, 658 Table 4 Monthly Variation in Shopping Center Traffic Percentage of Average Month Month Percentage Month Percentage January 85.3 July 100.8 February 78.1 August 102.1 March 92.0 September 94.8 April 93.2 October 98.9 May 105.4 November 101.5 June 106.0 December 141.8 Sample size: 2 Average gross leasable areas 938,000 square feet The sites were surveyed between the 1960s and the 2000s throughout the United States and Canada. Source Numbers 1, 2, 3, 4, 5, 6, 13, 14, 18, 19, 22, 26, 40, 42, 48, 49, 54, 59, 60, 61, 64, 65, 72, 73, 75, 76, 77, 78, 79, 87, 89, 90, 98, 99, 100, 105, 110, 124, 156, 159, 172, 186, 193, 194, 195, 196, 197, 198, 199, 202, 204, 211, 213, 260, 263, 269, 295, 299, 300, 301, 304, 305, 307, 308, 309, 310, 311, 312, 313, 314, 315, 316, 317, 318, 319, 358, 365, 376, 385, 390, 400, 404, 414, 420, 423, 428, 437, 440, 442, 444, 446, 507, 562, 563, 580, 598, 629, 658 Concerns With Traffic Impact Analysis • Mitigation Sketches Omit Required Geometric Details • Sketches Omit Geometric Constraints • Mitigations Assume Unapproved Geometrics • When Above Is Considered, Mitigations Won't Fit Or Won't Perform As Claimed • Base Traffic Counts Taken In Low Traffic Month and Study Omits Impacts of Compound Queue Geometric Concerns • Actual scale size of roundabouts • Splitters • Bay tapers • Lane transitions and needed lanes • Sidewalks, sideslopes or retaining walls • Bypass Lanes • Grade w -'t r" a t" 1 S Tig1(I Walmart Expansion EIR Figure 3B Proposed Interchange Reconstruction Option A - City of Ukiah New US 101 Southbound Ramps Intersection (Roundabout) tG . Rondabout g� { i;Larm to to �e "Orminedt i I � T*^zgc Hoed Q; I Tig1(I Walmart Expansion EIR Figure 3B Proposed Interchange Reconstruction Option A - City of Ukiah New US 101 Southbound Ramps Intersection (Roundabout) A North Left Turn Queues At Airport Park Overflow Their Storage Scenario 1 DEIR Lt. Turn Storage Actual Lt. Turn StoragePI Est. 95th %ile Queuel'I 9511 %ile Overflow! Est. Avg. Queue` 1. Overflow i.'l B+P 450 192 380 188 260 68 13+13C 450 192 403 211 293 101 B+DC+ P 450 192 457 265 343 151 F+P 450 192 387 195 286 94 F+DC 450 192 379 187 287 95 F+DC+P 450 192 451 259 334 142 III All scenarios are for PM peak hour for westbound left turn lanes on Talmage at Airport Park under proposed mitigation for this intersection and with Roundabout A mitigation at Talmage with southbound US 101 ramps. B= Baseline, F= Future, +P= plus Project, +DC = plus Discount Club [2' Combined queue storage length of both westbound left turn lanes with proposed Talmage -Airport Park intersection mitigation as assumed in DEIR traffic study calculations. All storage and queue values in feet. Actual available storage in both westbound left turn lanes with proposed Talmage -Airport Park intersection mitigation and Roundabout Option A. HI Per DEIR Appendix B, Appended Queuing & Blocking Reports. The 95th %ile queue ordinarily defines the queue length to be accommodated for design purposes and is often referred -to as the "design queue". `51 Length of 95th %ile queue in excess of actual queue storage with Roundabout A. P1. Average length of all queues that build in the subject left turn lanes, considering each signal cycle occurring in the peak hour per DEIR Appendix B, Appended Queuing & Blocking Reports. Length of Average queue in excess of actual queue storage with Roundabout A. Scenario[ I t DEIR Lt. Turn Storage« Actual Lt. Turn Storagel3J Est. 95th %ile Queue! 951h %ile Overflow['! Est. Avg. QueueIII Overflow 171 B+P 450 192 380 188 260 68 B+DC 450 192 403 211 293 101 B+DC+P 450 192 457 265 343 151 F+P 450 192 387 195 286 94 F+DC 450 192 379 187 287 95 F+DC+P 450 192 451 259 334 142 \Aa|mu,tExpansion E|K Figure3C Proposed Interchange Reconstruction Option 8' City of Ukiah New US 10| Soud,6oun6 Ramps Intersection (Roundabout) Exhibit 6-43. COnflgUratlon of right-turn bypass with yield at exit leg. Normal Splitter Islands 3. �ZY",mN7Y C-1 A.7- W."; , fl� Rc� - fiatmdatout Infu 0 n r 0 Area I r1 Pvi,tod Spitor Taper Island Fi rare 7. A?rxoath Treinuen: vi-iffi Minimal Splitter h1and Lenth "Ou'O""', nt "".,Vea ..... . . . . . Fairried Taper Spiltiet is and FieuTe 28. A!,m)-oldi Treatment with Extended Splitter hda-e, Leiwfli Concerns With Traffic Impact Analysis • Mitigation Sketches Omit Required Geometric Details • Sketches Omit Geometric Constraints • Mitigations Assume Unapproved Geometrics • When Above Is Considered, Mitigations Won't Fit Or Won't Perform As Claimed • Base Traffic Counts Taken In Low Traffic Month and Study Omits Impacts of Compound Queue Testimony of Daniel T. Smith Jr:; P.E. To the Ukiah City Council January 18, 2012 Members of the City Council: My name is Dan Smith, Smith Engineering & Management, 5311 Lowry Road, Union City, CA. I'm a registered civil and traffic engineer in California. I'm here on behalf of the appellants. I commented on the DEIR for the Project. In those comments, like those of Caltrans' and the Costc02 representatives, I noted that the proposed traffic mitigations was not sufficiently detailed to know whether, with proper geometric requirements, they were physically feasible within the site constraints and whether they would be capable of creating the traffic operational improvements claimed in the DEIR's theoretical traffic analysis. The final EIR failed to provide details about key improvements. Finally, last month there was an ESA memo stating that the inscribed circle diameter —that's the diameter to the outside edge of the traffic lanes in the circle - would be 150 feet for Option A and 142 feet for Option B. That's it as far as detail. The concerns are these: (show slide 1). If the geometrics are done right, the mitigations won't fit or won't perform as claimed. Secondly, we believe the analysis of impacts is understated and the effectiveness of mitigations is over-estimated because everything is based on unrealistically low traffic counts and because of another major flaw in the traffic analysis — it failed to consider that a second traffic flow joined the queue once the queue on the southbound to westbound movement reached a certain length and failed to consider the consequences of that compound queue. Lets consider the geometric issues; (show slide 2) • What is the actual to -scale size of the roundabout circles? • What more space is needed for sidewalks, sideslopes and retaining walls? • What are the requirements for lane transitions, the distances to merge down from multiple lanes to a single lane, and the number of lanes needed at the exits to the roundabout? • What space do splitters take up, the size of the islands that channel traffic in and out of the roundabouts? • What space do bay tapers take up, the transitions to get into extra turn lanes • Particularly with regard to Roundabout alternative B, we are going to be talking about bypass lanes — lanes that avoid coming into the roundabout, and limitations on the steepness of grade on which the roundabout is placed and sight distance limitations. So lets see what happens when you place actual geometric requirements at scale on the roundabouts, starting with Traffic Study Figure 313, which shows Roundabout A. Here is the DEIR traffic study sketch.( slide 3) The mitigation measure is not to scale; fortunately, the underlying aerial photo is. The typical range of inscribed circle diameter for 2 -lane circles is 150 to 200 feet. The diameter needed to facilitate side-by-side heavy truck movements is 180 feet, not a bad idea for a roundabout at a freeway interchange near a major shopping area and business parka. But let's just stick with the proposed size of Roundabout A, 150 feet, recognizing that this is close to minimally sized. Here is the space a 150 foot roundabout would take. (show slide 4). There is a 5 foot sidewalk along the north side of Talmage that probably must be maintained. The right of way along the north side of the circle would have to extend another 5 feet beyond the circle diameter plus whatever additional space would be needed for utilities, slopes or retaining walls. So, a circle with an inscribed circle diameter of 150 feet, would extend into the long rectangular vehicle maintenance building to the north, and would actually extend another 5 or 10 feet allowing for sidewalk and retaining walls. That building is a goner. If it isn't already public property, there has to be a right- of-way acquisition. This is clearly different than what is in the DEIR. A design objective is to minimize merges within the roundabout. So if two or three lanes enter the roundabout, two or three lanes respectively should come oue. This affects roadway width at the eastbound exit from the roundabout. The DEIR shows three lanes coming in from the south to only two lanes on the roundabout and two lanes coming in from the west. Clearly, there needs to be a third lane going out to the right, to the east side of the roundabout. When merging from two or more lanes to one, a considerable distance must be allowed for the merge. This distance is given by the width of the lane(s) being eliminated times the design speed in miles per hour. At a design speed on 35 miles per hour (the current speed limit), the merge distance from 3 lanes to one would be 840 feet; if design speed were compromised to 25 miles per hour, the merge distance would be 600 feet. Both these distances place the merge point to a single lane well on the east side of the freeway. The eastbound lanes coming off the roundabout simply cannot merge down in time to rely on the single available eastbound lane on the existing freeway overcrossing. In short, this roundabout design necessitates a widening of the freeway overcrossing. Roundabouts require raised islands called "splitters" on all two -direction legs. The part of the sketch on the east side is what a normal splitter looks like. The splitter island should be a minimum of 50 feet long although 100 feet is recommended 5. Because this design can't allow chaotic, unchannelized movements from the two lanes on the roundabout to the four lanes on the westbound approach to the Talmage -Airport Park intersection, the splitter on this leg in Figure 3B must be unusually wide to initially limit exits from the circle to the two through lanes. Cars and trucks don't move abruptly laterally as depicted in the DEIR sketch. Movements from through lanes to left turn lanes are defined by S-curved entry tapers. Entry tapers in California are normally 60 or 90 feet in urban areas, longer in rural areas6. So the entry tapers to the left turn lanes from Talmage westbound to Airport Park would go 60 feet from end of the splitter for the lane adjacent to the through lane and 60 feet further for the leftmost one. Because of the splitter and the entry tapers to the left turn pockets west of the roundabout, the effective length of the left turn lanes will be considerably less than depicted in the DEIR. The leftmost which would only have an effective length of less than 80 feet, will be difficult to enter, and at times blocked by traffic queues in the rightmost of the left turn lanes. Operations at the Talmage -Airport Park intersection will be worse than the DEIR estimated for the mitigated condition because the analysis overestimated queue storage based on the DEIR sketch. We can see from the queuing and blocking reports appended to the DEIR Traffic report that the left turn queues will overflow into the through lanes and spill back into the roundabout in all scenarios, not just at the 95th percentile design queue but at the average queue as well in all scenarios where queuing was analyzed. (Slide 5) Here is a comparison of the DEIR's analysis to the queue storage actually available with required geometric features. Here it is more readable without all the footnotes (show slide 6). The table shows the queue storage the DEIR assumed, the actual queue storage with the right geometry, the values for the "design queue" and for the average queue the DEIR predicts, and the overflow back into the through lanes because the storage in the left turn lanes is too short. In all cases the DEIR analyzed in queuing and blocking reports, Baseline plus Project, Baseline plus Discount Store, plus both, Future plus Project, plus Discount Store, plus both, the queues will overflow and block the through lanes that will cause gridlock back into the roundabout. But not just the design queues. Even the average queues overflow and block in all scenarios. The SIDRA analysis of the roundabout operation does not take into account the backspill of queues from the inadequate left turn lanes on Talmage at Airport Park and the too abrupt merge of lanes between the roundabout and the freeway overcrossing. That analysis is invalidated by those conditions. However, even as performed, the SIDRA analysis shows the freeway off -ramp approach to this roundabout would operate at LOS E. Caltrans standard for this freeway segment is LOS D. Now lets discuss Roundabout Option B that was sketched in DEIR traffic Study Figure 3C (show slide 7). At scale, this 142 foot, single lane circle is slightly larger than shown on Figure 3C. (Show slide 8) Additional area will be required to the northwest of the circle to accommodate the sidewalk and necessary sideslopes or retaining walls. This proposed roundabout incorporates "bypass lanes" on the southbound and eastbound approaches. This is what a bypass lanes look like(show 9). One with a long acceleration and transition lane. (Show 10) One with a Yield sign that is almost like a separate intersection. The problem is that "Bypass lanes are not typically permitted by Caltrans". � Without the bypass lanes, the single lane roundabout would have insufficient capacity in all scenarios analyzed. Based on deterministic methods calibrated for California by Caltrans research, the capacity of a single lane roundabout would be exceeded for all scenarios analyzed from the Baseline (% over capacity) through the Future + Project + Discount store (% over capacity If the roundabout were made a 2 -lane roundabout, it might have sufficient capacity but would suffer from the same problem of insufficient distance to merge down to a single eastbound lane before reaching the freeway overcrossing structure as Roundabout Option A. Grade issues: Roundabouts should not be built on grades that exceed 4 % and are better if limited to grades of 3 percent or less 8. Available topographic data indicates the vertical curve on which this roundabout would be located averages about 5 percent. It would require extensive regarding of the north, south and east legs of the intersection to enable this roundabout to be constructed on a slope of 3% or less. This could necessitate right of way takes for side slopes or retaining walls. Sight distance issues: The grades on westbound Talmage pose sight distance issues for this roundabout. Stopping sight distance to the near limit of the roundabout, to the left half and to legs merging on the left (from the approaching drivers view), is required. The DEIR needs to demonstrate that these sight distance requirements are met for this proposed mitigation option rather than speculate. So here is the summary (show slide 10). Need a little more space than shown, especially with the north sidewalk and slopes. The assumed bypass lanes won't be approved by Caltrans, so the circle needs two lanes to work which means it would have to be even bigger. That also means the lanes can't merge down quickly enough to use the existing overcrossing so it would have to be widened. And there are massive grading and potential sight distance issues. We believe the right and necessary solution is to widening the freeway overcrossing to 4 lanes, put the west side ramps in a diamond configuration with as much separation from the Airport Park intersection as practical, signalize it, with as many approach lanes as necessary to make the intersection operate at LOS D or better. Now lets talk about those counts of existing traffic conditions taken in February of 2009. (Show slide 11) Caltrans permanent monitoring counts on 101 in the area show that for overall traffic, February traffic is 7 percent less than in the average annual month and 12 percent less than the average of the top 6 months. And for shopping centers, (show slide 12) the Institute of Transportation Engineers says February shopping traffic is only 78 percent of the average annual month and is the lowest shopping traffic month of the year. Further, in attempting to justify that trips of the existing Walmart should be assumed to be at full ITE Trip Generation 8`h Edition rates in crediting, that is deducting them from the proposed Walmart Superstore trip generation, the DEIR concludes that the rest of Airport Park Center is only generating traffic at % of ITE rates. This is further corroboration that the February counts are low, that traffic in the rest of the Center is depressed by economic conditions (which should be adjusted for in the base per the Court in Sunnyvale Neighbors vs City of Sunnyvale City Council), or both. There is no doubt that the DEIR's counts of existing traffic, from which the whole rest of the analysis flows, significantly under -represent existing traffic. Consequently, the traffic analysis understates traffic impacts and overestimates the effectiveness of purported mitigations. Moreover, COSTCO points out that the analysis significantly understates the Discount Club traffic. This feeds into and compounds a major flaw in the analysis. The DEIR analyzes the queue on the southbound 101 off ramp to westbound Talmage. It acknowledges that queues may build up past the point where the southbound to eastbound traffic splits on the off -ramp from the southbound to westbound traffic but it doesn't analyze that event at all. What happens when the southbound to eastbound traffic hits the back of the southbound to westbound queue is that the queue quickly gets much longer than the DEIR predicts. If ordinary traffic is 7 percent higher on the average than the February counts, and 12 percent higher in the busiest 6 months, that queue will be much, much longer than the DEIR analyzes. During peak shopping season traffic, far more than February, that queue will be much, much, much longer than predicted. And if the economy turns around, full trip generation of the rest of existing Airport Park Center will make it longer yet. If COSTCO has more traffic than accounted for, the queue is longer yet. When this happens, it puts the tail of the queue into the high-speed deceleration area or even onto the freeway mainline —something the Transportation comments forwarded by the County Board of Supervisors indicates happens already. This is a very hazardous condition, a serious public safety condition that responsible government cannot ignore. It would be irresponsible and negligent to approve the project without having feasible and effective mitigation measures identified and on track to be put in operation by the time the project would be occupied. Such measures are not in the works right now. Based on all of this, we believe you should uphold this appeal and direct staff to rework the EIR traffic study along the lines suggested herein. 1 oTM- `M 1 FOR Letter W 2 FEIR Letter O 3 Roundabout Geometric Design Guidance, California Department of Transportation, June, 2007. 4 Roundabout Geometric Design Guidance, California Department of Transportation, June, 2007. 5 NCFW Research Report 672 6 Highway Design Manual, Caltrans FEIR Letter W, Comment W-9. 'Roundabouts: An Information Guide 9 Roundabout Geometric Design Guidance, California Department of Transportation, June, 2007.