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2007-02-20 SubmittalsProvided by Development Services at the 02-20-07 CIC Meeting Re: Agenda Item #3 -A NAOMI MIROGLIO The Tennessee Theatre rehabiliation in Knoxville, completed in 2005, was the first project to benefit from the combined historic and new markets tax credits programs through the Historic Theater Financing Fund. URBAN LAND NOVEMBER /DECEMBER 2006 The two most common ways to save historic movie theaters are to adapt them for live performances or make them work for modern-day moviegoers. THE MOVEMENT TO PRESERVE American movie palaces began during the 19705, when cities started exploring options for redevelop- ment. Citizens pressured their governments to save and adapt these buildings to new uses. Sentiment as much as economics saved these structures. The hope was that movie theaters would become catalysts for down- town revitalization. In a few cities, theaters were adapted for live performances. Yet, as development efforts focused on new con- struction and moved away from historic cores, many of these buildings were shuttered, van- dalized, and abandoned. There still are historic theaters in major urban centers, as well as hundreds of smaller film houses in outlying neighborhoods and first -ring suburbs. In some cases, it has taken 30 years to bring them back to life. The desire on the part of municipalities and communi- ties is there —but the challenge is to find an economically viable strategy. Historic movie theaters represent a unique building type that does not easily lend itself to other uses. In addition, such theaters are large structures that often have significant seismic and infrastructure issues that are ex- pensive to address. Even restoring them to their original use can be a challenge, because the movie industry has changed so signifi- cantly since the early loth century. Suburban cineplexes located near freeways offer con- venience and ease of parking. Modem the- aters tend to comprise ten to 20 screens in auditoriums of loo to 200 seats. Today, movie theater operators make their money largely by selling snacks and drinks, so con- cession stands are large and prominently placed. While some historic theaters have been subdivided into multiple screening rooms, this approach sacrifices the structure's integrity and the spatial pleasure it offers, pro- viding only glimpses of the original grandeur. Despite all this, movie palaces represent one of the major architectural achievements of the loth century, with their ornate ceilings and walls, handpainted murals, and a level of architectural detail not possible in modem construction. Because each one is unique, they offer towns and cities the potential to create a distinctive destination that helps eco- nomically revitalize the downtown and serve as a source of pride for the community. How can communities save these historic resources? "There is no si ngle economic model," says Kyle Conner, president ofAlameda Enter - tainment Associates. "Each project needs to be approached individually." In some cases, when land adjacent to the theater can be acquired, a multiplexcan be added next doorto a historic single- screen building. In the city ofAlameda, Califomia, for example, municipal officials had long wanted to bring back the art deco Alameda Theatre, designed in 1932, which stopped screening movies in 1979. The city issued a request for proposals (RFP), but was unsuccess- ful in obtaining viable responses forthe rehabili- tation ofthe theater on its own. A second RFP, to develop the theater with the adjacent parcel, received only one response. Connerwas origi- nally part ofthat response, and when negotia- tions failed, he turned around and created a new development entity to make the project happen. By using city -owned land next door, Alameda EntertainmentAssociates crafted a project that restores the Alameda Theatre and adds store- front retail space, a seven - screen cineplex, and a 350 -space parking garage. The restoration will decrease the number of seats in the historic structure from 2,250 to about s,000. The city acquired the theater using its power of eminent domain, and will lease the land and use ofthe theater to Alameda Entertainment Associates. "The key at Alameda was having both a commitment from the redevelopment agency and the will of the community to rehabilitate the historic theater," says Conner. "Without the redevelopment funds, this project just wouldn't pencil out. We could build two ten- to 12- screen cineplexes in the suburbs for the combined cost of the restoration and seven - screen cineplex in Alameda." Leslie Little, director of the city of Alameda's development services department, The art deco Alameda Theatre, built in 1932, is located in a National Register historic district in downtown Alameda, California. The lobby's interior, shown in a 1943 photograph, includes plaster ornaments with original metal leaf finish. Plans for the theater include restoration of the space and the addition of storefront retail space, a seven- screen cineplex, and a 350-space parking garage by using city -owned land next door. agrees that redevelopment funds are impor- tant, but generally other investment compo- nents are required as well. 'We used HUD 1o8 funding for the Alameda parking struc- ture," she says, noting that this type of fund- ing is no longer available. "It requires a cre- ative public /private partnership to find a solution that will reuse the structure for public goals, provide an amenity that the greatest number of people can use, and establish a long -term plan to sustain the building," Little observes. "Cities simply cannot take on main- tenance of another facility — essential civic services such as fire stations and police sta- tions require all our resources ?' The Fox Theatre in Oakland, California, built in 1928 and shuttered in 1965, repre- sents another example of cities using adjacent lands to help bring back a historic building. In this case, the movie house, a national historic landmark, is planned to become a live per- formance venue, with an associated public arts school on the parcel next door, using both existing and new structures. The project is an essential part of the city's plan to estab- lish an arts district in the area. Other kinds of partnerships involve work- ing with an existing performance company in need of a permanent home. In San Jose, the 1904 Jose Theater had remained vacant since ARCHITECTURAL RESOURCES GROUP the 1989 Loma Prieta earthquake; seismic retrofitting had proven too expensive. San Jose's city council agreed to provide $5.1. million to restore the theater after striking a ten -year lease agreement with the Improv Comedy Club, a Los Angeles—based chain of comedy clubs founded in 1963. The restora- tion, completed in 2003, brings the theater back to its original use as a live performance space; it had originally hosted vaudeville acts before it was converted into a cinema during the 1920s. Other long- awaited projects become a real- ity due to a major private donor. Also in San Jose, the 1927 California Theatre was rescued after nearly three decades of disuse by a major donation from the Packard Humanities Institute, whose $21 million grant, combined with city redevelopment funds and other pri- vate donations, funded the $75 million restora- tion. Opera San Jose and other companies now perform in the space. A new three -story building with a lobby was added, and a two - story addition to the stagehouse provides the extra space needed for opera performances. (See "Historic California Theater Restored," page 55, November/December 2005) NOVEMBER /DECEMBER 2006 URBAN LAND 97 A rehabilitated Fox Tucson, completed in December 2005, is the cornerstone project of the city's Rio Nuevo district revitalization program. The theater, designed in 1929 in the southwestern art deco style, received help through the Historic Theater Financing Fund and includes rehabiliation of an adjoining building that now houses concessions, building systems, and commercial spaces. State and federal tax credits, as well as the federal new markets tax credit program, remain a valuable source of funds for historic rehabilitation projects. However, the process of obtaining tax credits is time consuming, complicated, and expensive, requiring exten- sive paperwork. (Currently, the U.S. Congress is considering legislation that will simplify the tax credit process.) "It can take $5o,00o to $6o,00o to close a simple tax credit deal, and up to $1oo,000 to close a complicated deal," says John Leith Tetrault, president of the National Trust Community Investment Cor- poration (NTCIC) in Washington, D.C. In 2004, the League of Historic American Theaters (LHA1) and the NTCIC cofounded the Historic MS URBAN LAND WILLIAM LESCH PHOTOGRAPHY Theater Financing Fund (HTFF). Through the HTFF, staff at both organizations assist mem- ber theaters in fulfilling the requirements of federal and state rehabilitation tax credit pro- grams and in marketing projects to potential tax credit investors. The HTFF offers training workshops several times a year to organiza- tions seeking help in financing. 5o far, the fund has helped three projects come to fruition: the Tennessee Theatre in Knoxville, Tennessee; the Fox Tucson in Ari- zona; and the Tumage Theaters in Washing- ton, North Carolina. 'We give theater projects the ability to get their projects done more quickly, by substituting $5 million or $6 mil- lion in federal and state historic and new markets tax credits for money they would oth- erwise have to acquire by fundraising," says Leith Tetrault. "And we try to make sure that the theater group and the city understand that we're setting this up in a way to make sure that there are five years of `wont' free' funding so they can keep going. We don't want the organization or the investors to worry about the risk of recapture ?' In many of these cases, there is an "angel," a donor who can provide collateral other than the theater itself. The NTCIC and the LHAT work closely with theater organiza- tions to make sure they have all the business plan, programming, and operations pieces in place. They also help ensure that the fund- raising plan is realistic about how much it can raise in time for the anticipated opening of the theater. "In these theater projects, the organizations often want to borrow the funds NOVEMBER/DECEMBER 2006 WILLIAM LESCH PHOTOGRAPHY upfront, through bonds or loans, to bridge the fundraising gap in order to get the project done sooner and to meet an opening date goal," says Leith Tetrault. "We're advising that these projects build in a six-month window so they can have those six months to catch up, if necessary, and not feel pressured to borrow a large amount." The Fox Tucson was the second movie the- ater to receive help through the HTFF. A group of citizens formed the nonprofit Fox Tucson Theater Foundation in 1999 to restore the his- toric 1929 structure in downtown Tucson. In 2000, the foundation purchased the theater, which had been closed for nearly three dec- ades. The foundation received a Si million fed- eral grant, followed by a $3.5 million contri- bution from the city's Rio Nuevo district. "The Tucson city council said they would only help if we could get the project done right away," says Herb Stratford, executive director of the Fox Tucson. "5o we leamed that with tax cred- its, we could do that" Last year, with the help of the HTFF, the group garnered $2.8 million in historic tax credits and new markets tax cred- its. Subsequently, the city council lent the foun- dation $5.6 million, raised by selling bonds, so the project could be completed swiftly. Other private funds helped close the gap. The res- toration included rehabilitation of the adjoin- ing property, a commercial building connected to the theater that now houses concessions, building systems, and commercial spaces. Establishing a vision early on is crucial. The Fox Tucson Theater Foundation surveyed local and regularly visiting performing arts groups to see what they wanted in a perform- ance venue. The only 1,200 -seat theater in town, the theater reopened as a live perform- ance venue a year ago. "We expected to do go events in our first year, and so far we are doing 120," Stratford says. While urban cores, with their newfound popularity among young professionals and empty nesters, have larger populations to sustain specialty performance venues, subur- ban towns can have more difficulty finding a sufficient audience base. Nevertheless, some suburbs have made these projects work. In Park Ridge, Illinois, for instance, the art deco Pickwick Theatre, built in 1928 and listed on the National Register of Historic Places in 1975, saw the addition of three more screens in an adjacent building by the Pickwick The- atre Council in 1990. The theater has contin- ued to draw sizable audiences, both with movies and live performances. Another suburb, the town of Torrington, Connecticut, is working on restoring the 1,765 - seat Wamer Theater, built in 1931. A group of citizens established the not - for - profit North- west Connecticut Association for the Arts during the early 198os to save the edifice from demolition. So far, the group has raised more than $15 million of its $19 million goal. The first phase of the project, completed in 2002, upgraded infrastructure, renovated the facade and public areas, and installed state- of-the-art lighting and sound systems. The second phase includes building a new 200 - seat studio theater, a. stage house, and expanded art education facilities, as well as reworking the movie theater to better support live performances. As much as they benefit communities, however, historic theaters also can require strong community support to survive over the long term. In Orinda, California, preservation of the historic 1941 Orinda Theater came about during the 19705, when the owner pro- posed razing the landmark to construct a 116,000- square -foot (1o,790 -sq -m) office and shopping complex. Citizens organized to save the structure, along with its distinctive mar- quee, which had served as a beacon for the downtown, and its omate murals. The conflict went all the way to the state's supreme court, which ruled against demolition at the last moment. The developer built a 9o,000- square -foot (8,372 -sq -m) project instead, keeping the theater and adding retail and office space and a parking garage. The project was dubbed Orinda Theater Square, and eventually two smaller screens were added in an adjacent building. However, the retail por- tion has not performed well, and competition from area cineplexes has been strong. Cur- rently, city officials and local residents are reviewing options, including the possibility of converting it for use for live events and estab- lishing a nonprofit organization to manage it. The two most common ways to save his- toric movie theaters are to adapt them for live performances or make them work for modem - day moviegoers. For the former approach, tax credits are generally crucial. The latter approach Return to Grandeur The 1931 Warner Theater in Torrington, Connecticut, Is working toward the second phase of its restoration and expansion. The interior, with 1,765 seats, was completed in 2002 as part of the first phase., most often requires the acquisition of adjacent parcels to accommodate contemporary con- cession stands and the addition of multiple smaller screens. Ironically, the-demands of the list- century film industry often mean that updating historic cinemas to show movies again requires more intervention and additions than changing them to live performance venues, where the major alteration may involve only expansion of the stage house. As a result, conversions to performance venues may be more likely to qualify for his- toric preservation tax credits. For either use, however, financial support from the city, par- ticipation and strong interest from local citi- zens, and private fundraising efforts are essential—as are parking structures. However, just as each historic movie theater is a one-of- a-kind building, every preservation of a his- toric cinema is unique, requiring a different — and sometimes creative —mix of financing solutions as well as programming strategies that respond to the specific needs and aspira- tions of the local community. Both LHAT and NTCIC express optimism about the future of historic theaters. Together, they anticipate working with cinemas on three new rehabilitation projects in the next year, and interest in the program is growing. The suc- cess of their recently completed projects recon- firms that restoring historic theaters can have a powerful effect on downtown revitalization. "Having a theater closed for so many years is such a negative thing and when you bring [it] back, it creates a sense of pride in the community and a sense of history, and it brings people together to make it a reality," says Stratford. "I keep saying, We started out wanting to save a building, but in the end we may save downtown.' " LL N A O M 1 M 1 R o G 110 is a principal at Architectural Resources Group, an architecture firm specializing in preservation with offices in San Francisco, Pasadena, and Seattle. NOVEMBER/DECEMBER 2006 URBAN LAND 99 CHRISTOPHER BUCKLEY 1017 SAN ANTONIO AVENUE ALAMEDA, CA 94501 February 20, 2007 Community Improvement Commission City of Alameda 2263 Santa Clara Avenue Alameda, CA. 94501 Subject: Value Engineering and Street Trees for Civic Center Parking Garage and Alameda Theater Cineplex (Item 3 -A on 2-20-07 CIC agenda) Dear Commissioners: I have the following comments on the Construction Update report that is included in your agenda packets plus comments on the proposed street tree selections: 1. Changes to parking garage north wall.. As part of the value engineering items discussed at the January 16, 2007 CIC meeting, the shear wall that covered the three center bays of the garage has been deleted, which will expose the sloping garage ramps. In addition, two of the north wall's columns are proposed for deletion and some of the formerly horizontal railings will now be sloped, presumably to match the slope of the floor levels. Neither of these two changes appear to be called out in either the 1 -16 -2007 or 2 -20 -07 staff reports. These changes will make the north wall look even more unattractive than the previous design. The sloped ramps will be skew to the level ground surface and to other elements of the garage. This overall treatment seems disorderly, excessively horizontal and gives the impression that the garage is in a state of collapse. Unfortunately, the revised north elevation was not presented at the 1 -16 -07 CIC meeting, so it was difficult at that meeting to fully understand the visual impact of elevation's design changes. I have attached a copy of the previously approved north elevation. By comparing this with the proposed elevation in your packets, you can easily see the visual impact. The north wall treatment would be of less concern if another building were to be erected next to the garage in the reasonably foreseeable future that would hide the north wall, but there appears to be no indication that this is going to happen. 1 Agenda Item #3 -A CIC 02 -20 -07 Although there are major budget constraints, the visual prominence of the north wall demands some form of mitigation. Here are some suggestions, which are all less than ideal, but which should be relatively affordable: a. Provide some kind of curtain wall covering as much of the north wall as possible, perhaps with an architectural trompe d'oil treatment that would present a series of building facades that are architecturally compatible with the garage's west elevation and with the neighboring Civic Center structures (Carnegie Building, City Hall, etc.). A mural was previously proposed as a public art project on the now - deleted shear wall. b. Provide a solid row of dense, closely spaced evergreen trees that will grow tall quickly, such as coast redwood. c. Plant evergreen vines, such as creeping fig, at the base of the north elevation. This will probably be less satisfactory than Option (b), since the vines will probably take more time to cover the wall than would redwood trees. 2. Deletion of solid granite slabs at the base of the garage AND Cineplex. As noted at previous meetings, 12" x12" granite tiles rather than the previously approved large granite slabs are now being proposed on the Oak Street side at the base of the garage and only at the base of the pilasters rather than as a continuous band along the sidewalk. This change will also be made on the Cineplex. At a minimum, the tiles or some other high quality material should be applied as a continuous band along the base of both structures to provide pedestrian interest. 3. Identify the material to be used under the Cineplex storefront windows. Related to Item 2 above, the partial Cineplex elevation attached to the staff report shows a brick -like material under the storefront windows: This material needs to be identified. 4. Street Trees, a. Central Avenue. The City's Street Tree Master Plan provides for London Plane Sycamore (Platanus acer fo1ia) on Central Avenue where P. acerifolia is now the predominant tree. However, staff has informed me that a smaller tree, Trident Maple (Acer buergeranum), is being proposed because of concern that sycamores will become too large and block visibility of the Cineplex. The existing sycamores make Central Avenue one of Alameda's outstanding streetscapes and should be maintained along all portions of Central Avenue, including the Cineplex and Alameda Theater frontage. 2 The sycamores have a relatively open, transparent canopy so the Cineplex facade will be visible through the canopy. Since the sycamores are deciduous, they will have virtually no blocking effect on the facade during the winter. The existing sycamores on Central are widely spaced, generally 35'-60' apart. This wide spacing should be continued along the Cineplex and theater frontage to further minimize facade blockage and streetscape clutter. I suggest a 40' -50' minimum spacing. Trident maple, on the other hand has a mature height of about 20' -25', which will conflict with store signage (which is typically 15'-20' above the ground) and interfere with trucks and other tall vehicles parked along the curb. Sycamores, on the other hand, grow to about 40'-50' and can easily be limbed up to 15' or more so that they branch above signage and tall vehicles. b. Oak Street. Staff has told me that Quercus robur `Skyrnaster' or 'Fastigiata' ('Skyniaster' and `Skyrocket' English Oak) is being proposed along Oak Street, I assume because their narrow, columnar growth form is well suited to the relatively narrow 10' sidewalk and their verticality would compliment the verticality of the Cineplex and parking garage. Unfortunately, Q. robur is very subject to aphids in Alameda and the attendant honeydew drip and sooty mold. If a fastigiate tree is desired, the following possibilities could be considered, among others: o jyrus calletyana `Chanticler' ('Chantic1e' Flowering Pearl Gingko biloba `Princeton Sentry'. 0 Acer rubrum `Armstron ' or `Bowhall' (`Armstrong' and `Bowhall' Red Maple). Whatever tree is selected for the theater/parking garage's Oak Street frontage should probably eventually be used for all of Oak Street from Central Avenue (or possibly Encinal Avenue) north to Lincoln Avenue to help unify the Civic Center and articulate Oak Street as the Civic Center spine. 1 believe that any of the above three tree selections would generally work well for this purpose, but there are a variety of alternatives. It is unfortunate that Alameda has still not prepared a Civic Center Specific Plan as called for in the 1 991 General Plan, which could, among other things, establish the street tree treatment for Oak Street. Note: I provided street tree comments similar to those above to staff last November, with more detailed comments on alternative street trees for Oak Street. 3 Thank you for the opportunity to comment. Please call me at 523 -0411 if you would like to discuss these comments. s. istophe Buckley cc: Deborah Kurita, City Manager (by electronic transmission) Leslie Little, Development Services (by electronic transmission) Doreen Soto, Development Services (by electronic transmission) Jennifer Ott, Development Services (by electronic transmission) Matt Naclerio, Public Works (by electronic transmission) Cathy Woodbury, Planning and Building (by electronic transmission) Kyle Conner (by electronic transmission) T. J. Towey (by electronic transmission) 4 Ztie'RIP'Otg :r4 gree.1- D$g *A ts..e v7 1QNV-.31V0 ia211J/11 HINas4Arno3 WIC moo, ,- snoaoNo)I NOLL i4113uN o Q t�- i[ _ '-- - -- rgiaall111.11011 r1F3 cc laweW ia ARO u) Truo WNW RAM 0 cif LLOf I LS ONININd C1 W X31dBNiO VO3WV1V I tie A q ci C\J 0 w W W Z W :Lc U Q Z f F. tt t. Submitted by Richard Rutter at the 02 -20 -07 CIC Meeting Re: Agenda Item #3-A BY ECONOMIC SEGMENTS /SALES TAXES/YEAR Highest Year ECONOMIC SEGMENT Sales Tax Year 2005 Differences CO C) Q d' Q o Co Q Q Q r- r- LO N a 1- '1' Eft 0) LC) CO Ef} 69. Ef} Ea- Eft d' CY) CD N r 0 Ea. LO cv a CO N C4 0 Ea Q N. 0) Ca Q ov ce ti Ln r- CD ea- en- ea ea- . u} E LO rte- r �r-- N CD CO d' LC) N- Q - Q CY) Ea Ef} Ef} Ef. CO 07 LC) 11) N r r N L{7 CO I` LC] CO- Cr] • r N_ Liz CZ! 69- N CN r '- E taEaEa6F}Ef}Ef� E03 to Ea- Ea CD ILO C3 c'7 CO IL] LO r[7 ILO ILO CO N p CO N. • vavasoacvva,oC oa)a) • NNNnNNNN� C r NCI C\I L[] Cfl Q CO LO 03 N C0 N d' Q LO N. Q Q C0 r CO N CO C0 Cr LO N. LO CY) Lf ) r Q {f} LC) L!7 CT) N LO C3? Q r r N LC) Q 037 CO Ea- Q N. 0) '1 N. C37 033 .c-r C3? f` C1! LC3 a7 �- - Q 0 Co 0) C) LO CD L(7 N r Ef} r Ef- ea CO CY) N e-- r r CFI Ea E Ea- Ea Ef} Ea. Ea Ea Eft Ea. J � W � w W = u3 F- ❑Q w— of Ju) 0 u) zo— ()mil 0) <z 1 u) w oC u) >wwCO _>-u)0 D rZ u)n2 o-0_ W0 CrDu.a�. z�wzw�z�wcn�wu)u3�Q WIZ U) 0�- w���ZZJ ❑- w~ Q❑ Q �<ZW �2—,m u)wLI_F- wa_(r) - >U_ < ❑wF_<o0cKzoz0 L7~ '5 �_ 0cou)a_DLT -0 Pu)i-- o° ❑ =�� wo_WwLl.ClCi1 -W o ❑ ❑2— ❑ <O0C(. L...3m<U -2co o) f •.c } a ,77 Source: City of Alameda Sales Taxes (10 year comparison) Provided by Councilmember deHaan at the 02 -20 -07 City Council Meeting Re: Agenda Item #4 -E TTE October 5th, 2006 Mr. Patrick Lynch, President City of Alameda Planning Board Alameda City Hall 2263 Santa Clara Avenue Alameda, California 95401 Reference: Target Store—Draft Environmental Impact Report (DEIR) Subject Comments Related to Traffic and Parking Dear President Lynch and Members of the Board: This letter and the comments that follow represent a true grassroots appeal to the City of Alameda Planning Board on two fronts. The first and most immediate appeal is a petition to the Board to undertake a new, reality - based study of the traffic impacts of the proposed Target store at Alameda Towne Centre. The second, underlying appeal is a plea for the Board to adopt an open, transparent process when analyzing proposed developments on Alameda Island ---a process that places citizens squarely at the center of every development debate; a process that recognizes that the very purpose of city government is to respond to the concerns of its citizens; a process that emphasizes the "public" in the term "public servant." Like most people, I think you will agree that plain talk is where truth resides. Instinctively, we are wary of what we don't understand. We are cautious about accepting as truth that which we cannot confirm for ourselves. Most of us know that, when the facts are on our side, there is no need to bury them in complexity. The truth can withstand the sunshine of public scrutiny. At the request of a group of Alameda citizens, I have just completed an exhaustive review of the Traffic Study embodied in the Draft Environmental Impact Report (DEIR) for the proposed Target - Alameda Towne Centre store. Why was I asked to evaluate this document, which supposedly was created for public consumption? Quite simply, I was asked because the citizens themselves were stymied by the sheer volume and intricacy of this daunting, two -inch- thick, techno -speak volume. Even as a licensed civil and traffic engineer, understanding the basis for the report's conclusions required three full days of intense scrutiny to fully understand the traffic impacts on neighborhood streets. The citizens who asked me to review the Traffic Study were motivated by one, simple, common -sense question: How can a project of this magnitude have zero impact on traffic in the surrounding area, as the report concludes? H :ITTEServerlProposals12681 Alameda Target1Package to CitylLtr to Alameda Planning Board re Target --Oct 5. 2006.doc Last saved: ! 0/5/2006 3:41 PM Thomson Transportation Engineers, Inc. • 2969 Johnson Ave • Alamed Telephone (510) 865 -1959 • Fax (866) 302 -6657 • E -Mail: general(diTT: Submitted by Eugenie Thomson at the 02 -20 -07 City Council Meeting Re: Agenda Item #4-E October 2, 2006 There is a simple answer to that question: The Traffic Study in the DEIR did not evaluate the traffic impacts of a 145,000 square-foot Target store, as proposed by the developers. That's right—the DEIR incorrectly considered only the traffic and parking impacts associated with 49, 100 square feet of generic shopping center area, which accounts for only one -third the actual size of the proposed Target store. The report rationalizes using this absurdly low figure by stating that the City already approved an additional 95,900 square feet of shopping area for the center in 2003. The problem with this rationale is that the 2003 Traffic Study did not involve a Target store, which is a major regional draw. In fact, the addition of the Target store would bring the total area of the shopping center to 706,000 square feet At that size, Alameda Towne Centre would no longer be a neighborhood shopping center, but a regional mall. According to Target's own consultants, nearly two-thirds of the proposed Target store's customer base is located in Oakland, and one -third in Alameda. The fact is that there is no mall comparable within five miles of the proposed Target-Alameda Towne Centre. The Traffic Study included in the 2006 DEIR is not reality- based. In fact, many of the assumptions that were used to form its conclusion of zero traffic impact are flatly wrong. As traffic engineers, we cannot foretell the future with absolute accuracy, so we base our projections on a variety of assumptions about potential traffic impacts. Each of these assumptions involves a range of values that we assign, based on the nature of the project. The vast majority of the time, the values fall in the middle of the range. Time after time, the consultants who conducted the 2006 Traffic Study assigned the lowest possible value to the assumptions used for the proposed Target store project. They did this with respect to defining the project type and size, baseline conditions, traffic counts, trip generation, trip distribution and impact analyses. With respect to trip generation alone, the consultants used the lowest available trip rates, while other rates were 100% higher. For traffic counts, the consultants plugged in numbers taken at a time when the shopping center's sales were down 30 %. Thomson Transportation Engineers (TTE) and Traffic Data Services (TDS) conducted engineering field surveys at the key intersection of Otis Drive and Park Street These engineering field surveys illustrated an amazing finding. The Traffic Study grossly underestimated the congestion that the proposed Target store would generate in future years. This finding illustrates perfectly how misleading the results can be when minimal assumptions are used. One has to wonder. Why were the lowest -range assumptions used repeatedly? Was it simply that neither the consultant engineer who prepared the Traffic Study, nor the engineer from the City, were licensed civil engineers with experience in traffic engineering, as required by California state law? Neither 1, nor the citizens who asked me to review the Traffic Study, are against having a Target store on Alameda Island. A retail store of the magnitude of the proposed Target should not be located on the beach, however, where vehicles must travel through surrounding neighborhoods to get to their destination. Typically, Target stores are located on four- to six -lane arterials near freeways. Preferable locations for a Target store would be nearer the estuary, or closer to either Interstate 880 or Interstate 580—all of which would be more central locations within the Target trade area. The simple truth is that the Target - Alameda Towne Centre project has not been evaluated properly. A new, reality -based Traffic Study is needed in order to give the citizens of Alameda a clear picture of the traffic impacts H:ITTEServer\Proposals12681 Alameda Target\Paciage to CitylLtr to Alameda Planning Board re Target —Oct 5, 2006.doc - 2 - Last saved: 10/5/2006 3:41 PM October 2, 2006 of the project on our community, particularly those who live along Broadway and in the neighborhoods adjacent to the project. In a larger sense, it simply should not be this difficult for the public to get accurate information and straightforward answers about a proposed development project. The process of evaluating projects such as this one should facilitate public involvement, not obstruct it. Reports like the Traffic Study in the Target - Alameda Towne Centre DEIR breed distrust. The DEIR and other professional reviews need not be convoluted and overwhelming, as the DEIR is at more than 465 pages. They should not require an engineering degree to understand. Reports like this one can and should be simple, direct and concise. They should reduce complex technical terms to layman's language. They should be fact -based and reality- based. The citizens of Alameda deserve no Tess. They believe, and rightfully so, that plain talk is where truth resides. The bottom line is that traffic doesn't impact roadways; it impacts people. It impacts quality of life. The attached comments clearly indicate the need for a new reality based Traffic Study for the entire Target Project. Respectfully, Eugenie P. Thomson P.E., PTOE Consulting Civil and Traffic Engineer ept/ept Attachments: Comments to the Traffic Study and Exhibits H:1TiE5erverlProposals12681 Alameda Target\Package to City\Ltr• to Alameda Planning Board re Target—Oct 5, 2006.doc - 3 - Last saved: 10/5/2006 3:41 PM October 2, 2006 COMMENTS BY THOMSON TRANSPORTATION ENGINEERS (TTE) Traffic Study for Proposed Target Store Alameda Towne Centre (formerly South Shore Shopping Center) I. A Target store is not evaluated in this DEIR. Factual Data: Although the total area of the proposed Target store would be approximately 145,000 square feet, the Draft Environmental Impact Report (DEIR) considers only traffic and parking impacts associated with 49,100 square feet of shopping center area. The DEIR states that the 49,100 square -foot figure was used because an additional 95,900 square feet ( 145,000 minus 49,100 ` 95,900) of shopping area was already approved by the City in 2003. Also, the new gas station proposed for the site of the now - vacant U.S. Bank building, was excluded from the DEIR. The DEIR does not evaluate the environmental impact of the entire "project" (emphasis added). The required analysis must take into account the entire Target store, the three -story parking garage, two new restaurants, renovation of the "smaller structures," the proposed gas station and any other "reasonably foreseeable future expansion" of the "project." The 2006 DEIR merely looks at the effects of bits and pieces of the "project." The California Environmental Quality Act (CEQA) regulations define the term "project" to mean "the whole of...the underlying activity being approved." (14 Cal. Code Regs., Sec.15378 (a), (c)- (d)). 1 understand the courts have interpreted the term "project" broadly in order to maximize protection of the environment. I do not believe that CEQA regulations can be avoided by chopping up proposed projects into bite -sized pieces that, when considered separately, might indicate no significant effect on the environment. Those who prepared the 2006 DEIR attempted to justify the exclusion of 1 12,000 square feet from their analysis on the basis that this square footage had already been considered and mitigated to a "less than significant level" in the 2003 Mitigated Negative Declaration. This is an attempt at impermissible "tiering" or "piggy- backing." When appropriate, tiering allows agencies to analyze broad environmental issues in a "first- tier" environmental impact report (EIR), followed by a detailed examination of specific, limited issues in a "second- tier" environmental document. The first -tier document must be an EIR. (Pub. Res., Sec. 21094 (a); 14 Cal. Code Regs., Sec. 15152(d)). In this case, the first document is a Negative Declaration, not an EIR. Further, as shown in the following pages, the 2003 proposal (112,000 square feet of shopping center space) did not use the correct traffic criteria for a Target store and grossly underestimated the base conditions. When the 2003 study is corrected, it reveals an impact at the major intersection of Otis Drive and Park Street that may not be possible to mitigate. Recommended Corrective Action: In order to measure traffic and parking impacts accurately, the DEIR H:ITTEServer\Proposals12681 Alameda Target\Package to CitylLtr to Alameda Planning Board re Target -Oct 5, 2006.doc - 4 - Last saved: 1015/2006 3:41 PM October 2, 2006 must evaluate the entire Target store's proposed total area of 145,000 square feet, plus parking garage, restaurants, gas station and renovations of smaller structures. 2. The current Traffic Study builds on previous work, however, the DEIR did not include a copy of the previous Traffic Study for public review and comment. Further, the DEIR did not include the traffic intersection levels -of- service analyses for the current Traffic Study. Factual Data: The Traffic Study in the DEIR's Appendix states, `This analysis builds on previous transportation work already completed for the previous expansion proposal in 2003." (Omni Means Consultant's Report on the Transportation and Parking Impacts for the Proposed South Shore Shopping Center Expansion, City of Alameda, 2003).' Missing Data: A DEIR that bases its conclusions primarily on data from a previous study should include those data in the DEIR or make the previous data available to the public, along with the DEIR. Also, the Traffic Study in the April 2006 DEIR excludes both the levels -of- service analyses sheets and the traffic counts. An interested citizen, Dorothy Reid, obtained a copy of the 2003 Draft Traffic Study from the City and in ty provided it to TTE. The pages in the study that should have provided the above data were blank, making it impossible for TTE to perform a review of the traffic volumes associated with the 2003 proposal. The failure to disclose pertinent information in an EIR usually is considered prejudicial? Correction of Data The City: (a) failed to include the 2003 Traffic Study in the DEIR; (b) failed to p rovide a complete copy to the public when it was requested; and (c) failed to include the traffic counts and traffic intersection levels -of- service analyses in the publicly distributed copy of the April 2006 DEIR's Traffic Study. Accordingly, the City should re- circulate the DEIR and re- notice the DEIR for another 45-day public review period. 3. More Oakland residents than Alameda residents are likely to shop at the proposed Target store. P � Keyser Marston Associates' Urban Decay Report (Appendix D of the DEIR) states that 1 8,500 Alameda households and 32,100 Oakland households (with household incomes consistent with Target's customer demographics) are located within the Target trade area of three to five miles from the proposed Target- Alameda Towne Centre. According to those figures, as much as 64% of the new Target store's traffic could come from across the estuary. Page 1, first paragraph, Appendix B Traffic Study. 2 See Protect the Historic Waterways v. Amador Water Agency (2004) 1 16 Cal. App. 4th 1099, 1106. An EIR must include underlying technical data so readers can evaluate the conclusions; technical data may relegate to appendices. (Guidelines Section 15147; San Franciscans for Reasonable Growth v. City and County of San Francisco [ 1987] 193, App. 3d 1544.): Source: William Kopper, Attorney at Law, letter to Kraig Tambornini of City of Santa Rosa, comments to Draft EIR for Wai -Mart Store, dated February 8, 2006. Copy of letter can be obtained from City of Santa Rosa website. H:ITTEServer\Proposals1268I Alameda TargetTackage to CitylLtr to Alameda Planning Board re Target —Oct 5, 2006.doc - 5 - Last saved: 1015/2006 3:41 PM October 2, 2006 Number of Households within the Target Income range in Oakland and Alameda and within 3 to 5 miles of a Target at Towne Center • Alameda • Oakland Keyser Marston Associates, which prepared the Urban Decay Report for the DEIR, defined the Target trade area as including Alameda Island and (for areas off of Alameda Island) 1 -980 to the west, 1 -580 toward the hills, and Hegenberger Road to the south. Using MSN Maps software, TTE checked travel times from various locations in both Alameda and Oakland. We found that it would take consistently less time to travel from the Oakland locations to the proposed Target - Alameda Towne Centre, as opposed to the Target store in San Leandro. Thus, it is reasonably foreseeable that the 32,100 households in Oakland account for approximately two- thirds of the customers who will shop at the proposed Target store at Towne Centre. 4. a cji rayon Target Trade area in Oakland= 32,100 households (S Developers H:1 posals1268I Alameda Target\Package to CitylLtr to Alameda Planning Board re Target —Qct 5, 2006.doc - 6 - Last saved: 10/5/2006 3:41 PM October 2, 2006 Correction of Data The DEIR should address the traffic impacts assuming that up to 67% of the traffic traveling to and from the proposed Target -Towne Centre will originate off- island. 4. The traffic impact assessment is based on existing traffic counts that were obtained at a time when the shopping center's sales were low. Factual Data: The Traffic Study states that 2002 existing traffic counts were used for four intersections,' three of which are on Otis Drive and one on Park Street. For the remaining nine intersections selected for the study, traffic counts were taken during 2005. In 2002, the shopping center was not fully occupied due to the anticipated renovation. In 2005, the center was under construction and only partially occupied. City of Alameda sales tax data illustrates clearly that the shopping center's sales were 22% and 31% lower in 2002 and 2005 than during the g center's peak periods. For example, no gas station was onsite in 2005. (See the table below, which uses City of Alameda data to compare sales tax receipts for South Shore Center over a ten -year period.) SOUTH SHORE CENTER HIGHEST SALES TAX COMPARISON BY ECONOMIC SEGMENTS/SALES TAXES/YEAR Highest Year ECONOMIC SEGMENT Sales Tax Year DEPARTMENT STORES FOOD MARKETS MISCELLANEOUS RETAIL RESTAURANTS APPAREL STORES DRUG STORES OFFICE EQUIPMENT RECREATION PRODUCTS FURNITURE /APPLIANCE LIQUOR STORES BUSINESS SERVICES AUTO PARTS /REPAIR FLORIST /NURSERY MISCELLANEOUS OTHER BLDG.MATLS -WHSLE LIGHT INDUSTRY MISC. VEHICLE SALES SERVICE STATIONS $300,562 1996 $204,915 2005 $197,266 2000 $139,570 2003 $159,923 1996 $61,065 2005 $59,168 2005 $27,142 2005 $12,256 2005 $5,577 2005 $19,044 1998 $950 2002 $1 ,635 1997 $57 2000 $1,010 1996 $704 1997 $0 $69,954 1996 2002 $235,377 $168,830 $182,337 $123 838 $1 09,377 $57,222 $54,953 $22,678 $8,772 $5,025 $2,033 $950 $684 $42 $0 $0 $o $56,428 $1,028,546.: Differences 2002 to Highest Percent Year Change - $65,185 -$36,085 -$14,929 -$15,732 -$50,546 - $3,843 - $4,215 - $4,464 - $3,484 -$552 - $17,011 $o -$951 -$15 - $1,010 -$704 so 413,526 diff 2005 Differences 2005 to Highest Percent Year Change $223,614 $204,915 $1 46,576 $121,516 $96,243 $61,065 $59,168 $27,142 $12,256 $5,577 $2,303 $719 $570 $35 $0 $0 $o $o - $76,948 $o - $50,690 - $18,054 - $63,680 $o $o $o $o $o - $16,741 -$231 - $1,065 -$22 - $1,010 -$704 $o - $69,954 diff $961 , Source: City of Alameda Sales Taxes (10 year comparison) 1 The 2002 traffic volumes used in the study encompassed the following four intersections: Otis/Office Max driveway, Otis/Trader Joe's driveway, Otis Drive/Park Street, Park Street/northern project driveway. H:ITfEServerlProposals12681 Alameda TargettPackage to CitylLtr to Alameda Planning Board re Target ---Oct 5, 2006.doc - 7 - Last saved; 1W5/2006 3:41 PM October 2, 2006 5. The existing traffic counts from the year 2002 are more than four years old, and the P eak hour selected may not reflect peak traffic on a typical Saturday. The 2002 traffic count is more than four years old and does not represent the through travel on streets adjacent to the center that occurs today. The counts were obtained for the period between 4:00 P .m. and 6:00 p.m. on weekdays, and between 1 1:00 a.m. and 1:00 p.m. on Saturdays, when shopping in activities are not always at their peak. Taking traffic counts during the time of the day when shopping icall is tYP Y slow would produce a very low existing traffic data condition —not a true representation of the existing conditions. The graph from the Institute of Transportation Engineers (ITE) Trip Generation Manual clearly illustrates that the Saturday peak occurs mid- to Tate- afternoon, not between Noon and I :00 P .m. Unlike many years ago, Saturdays today generate very high traffic conditions. Because of the proliferation of families in which both adults are employed outside of the home, Saturdays have become the rims P rY time when many households run errands and perform day -to -day tasks. As a result, traffic peaking characteristics are different from years past. Whereas Noon to 1:00 p.m. once was the eak, today, the P Y peak occurs later on Saturday afternoon. ' Percent of Peak Period 16.0 14.0 12.0 10.0 8.0 6.0 4.0 2.0 0.0 Shopping Trip Distribution throughout a Saturday Percent Exiting Traffic of Total 24 Hour Entering Traffic for S.C. More than 300,000 sf of Gross Leasable Area (Per ITE) 10:00 11:00 12:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 AM AM PM PM PM PM PM PM PM PM PM PM Hour Beginning ' Target's own manual indicates that the peak operation on a Saturday is between 3::00 and 4:00 p.m. H:1TTEServerlProposals1268I Alameda TargetkPackage to CitylLtr to Alameda Planning Board re Target --Oct 5, 2006.doc - 8 - Last saved: 1015/2006 3:41 PM October 2, 2006 Correction of Data: At minimum, given the size and potential impact of the Target proposed et store, new P g traffic counts must be completed. 6. The consultant applied a reduction of 10% in the calculation of vehicle project. s for the ro'ect. According to the study, this was done to account for "passerby" trips. A "passerby" tri is P defined as a vehicle already traveling west on Otis Drive and being diverted to the store by the project. What is "passerby" h misleading is that many, if not a majority, of these vehicles P Y actually would add trips to the intersections and would not reduce the number of trips, as stated in the report. Consider the following Rather than traveling west on Otis Drive, straight through the intersection of the Office Max driveway and Otis Drive, a passerby vehicle stopping at the proposed Target store would make a westbound left turn at the Office Max driveway /Otis Drive intersection—and then travel into the Target parking lot or garage. When leaving the store, this vehicle would make a northbound left turn out of the shopping center at the Office Max driveway /Otis Drive intersection and continue traveling westbound on Otis Drive. Thus, in TTE's opinion, the proposed project would add two new left -turn vehicle trips to this intersection P ntersection that do not occur today, and would eliminate a westbound through trip at the intersection. It should be noted that these left-turn movements are more significant than a through movement due to the limited capacity of left -turn lanes. This project would add these passerby vehicles to the critical volume at these intersections. Therefore, we do not understand how the vehicle trips in the area can be reduced for this project as a result of passerby vehicles going into the new store. Clearly, the passerby P Y reduction should not have been applied to the project driveway or nearby intersections. H:ITfEServer\ProposaIs12681 Alameda TargettPackage to CitylLtr to Alameda Planning Board re Target —Oct 5. 2006.doc - 9 - Last saved: 10/5/2006 3:41 PM October 2, 2006 Correction of Data: TTE recommends that the consultant modify the traffic generation accordingly for intersections gY the ntersections contiguous to the project site. 7. The Traffic Study grossly underestimates trip rates that were used in the calculations to estimate the traffic to and from the proposed Target store. Factual Data: Due to only estimating traffic generation for 49,100 square feet and using very low traffic trip g ry trip generation rates, the Traffic Study states that 127 vehicle trips per hour' would be added midday on a typical Saturday. At the same time, Keyser Marston Associates projects that the proposed Target store g would produce a very high level of sales ($45 million per year) and would serve 900,000 customers per year. 2 P Clearly, there is a disconnect between the Keyser Marston Associates Urban Decay Report estimates Y P (DEIR Appendix D) and the Traffic Study estimates (DEIR Appendix B). First, the consulting firm that produced the DEIR drastically reduced the actual square footage, using only g g Y 49,100 square feet of gross leasable area upon which to perform the impact assessment. Second, the firm used an extremely low existing traffic count database. Third, the consultant applied an invalidated, extremely low trip rate to project the total trips to be generated by the proposed Target store. In essence, at each step of the traffic analysis, the consultant used very low values. For example, for the weekday afternoon peak hour, the consulting firm used the lowest trip rate for shopping centers from the ITE Trip Generation Manual (2.9 vehicle trip ends per 1,000 square feet of floor area for the 49,100 gross square feet of area, and 2.25 vehicle trip ends per 1,000 square feet for the previous 1 12,000 gross square feet of area and used in the baseline condition). The study did not indicate that this ITE rate for shopping centers varies from a low 0.68 to a high of 29.27 vehicle trip ends per weekday afternoon peak hour per 1 ,000 square feet of gross floor area (GFA). Neither did the study indicate that this ITE vehicle trip rate has a high standard deviation of 2.75. Finally, the study did not consider the ITE Trip Generation Manual's trip generation rates for discount stores. (Please refer to the graph below for a comparison of trip generation rates.) 1 The additional 49,100 square feet of retail space would add 67 vehides entering and 60 vehicles exiting during the peak hour on a Saturday, Source Table 4, page 25, Traffic Study in Appendix B. 2 See page 4, Urban Decay Study, Appendix D, DEIR. H :ITTEServerlProposals12681 Alameda TargettPaekage to CitylLtr- to Alameda Planning Board re Target—Oct 5, 2006.doc - 10 - Last saved: I W5/2006 3:41 PM October 2, 2006 35 30 25 20 15 10 5 0 Comparison of Trip Rates Target Store- Alameda Towne Center to Free - Standing Discount Stores, Wal -marts and Shoppping Centers (Vehicle Trip ends! Weekday PM Peak Hour /1000 Square Feet of Gross Floor Area ) Minimum Average Or Used Maximum -- Previous 112,000 Sq Ft of Retail at Town Center, Table 2 Estimates for Baseline, DEIR —.-- Target Store at Alameda Town Center DEIR —.— Institute of Transportation Engineers, Freestanding Discount Stores —A— Five Walmarts (2003) —)K— Institute of Transportation Engineers, Shopping Centers Correction of Data: The standard of care in the traffic engineering industry is to validate the Institute of Transportation Engineers research by factoring focal characteristics and specific types of stores into the traffic analysis. For example, a Target store impacts shopping center traffic much differently than does a Macy 's store. Moreover, adjustments need to be made for the fact that many of the ITE shopping in center rates were collected during the 1960s and 1980s. In addition, ITE's discount store rate should be considered. In order to validate the trip generation rates to be used, the consultant must perform actual field surveys of l existing Target stores to determine the vehicle trip generation rate and perform surveys of the existing g shopping center. H:17TEServer\Proposals12681 Alameda Target\Pacage to City\Ltr to Alameda Planning Board re Target—Oct 5, 2006.doc - 1 1 - Last saved: 1 0/5/2006 3:41 PM October 2, 2006 8. A comparison of existing traffic counts with future traffic counts illustrates another unusual finding: The existing traffic entering and exiting the shopping center is as much as 30% Tess than the Traffic Study projects at full build -out of the shopping center. How is that possible? Factual Data: Figure 2B illustrates that the total traffic entering and leaving the shopping center at some point between 2002 and 2005 equals 3,936 vehicles per hour on a Saturday midday peak. Table 4 illustrates the total traffic entering and leaving the shopping center at 706,647 square feet (i.e., full build - out with Target) equals 1777 vehicles per hour on a Saturday midday peak. Correction of Data The consultant should re -count all the intersections and verify the rates for the existing shopping center to correct this significant error. (See graph below and Attachment A for figures and tables from the Traffic Study.) Vehicles Per Hour 45W 4000 3500 3000 2500 2000 1500 1000 500 0 Comparison of Traffic Data in Traffic Study for Saturday Midday Peak hour. Existing Total Traffic Entering and Exiting Shopping Center derived from 2005 and 2002 counts, Figure 2B Build Out Total Traffic Entering and Exiting Shopping Center With Project, Towne Center at 706,647 sq. ft., Table 4 HATTEServeriProposals12681 Alameda TargetTackage to CitylLtr to Alameda Planning Board re Target —Oct 5, 2006.doc - 12 - Last saved: 1015t2006 3:41 PM October 2, 2006 9. The report states that vehicle access patterns would not change from the previous 2003 proposal.' TTE was unable to review this, however, due to the lack of traffic data from the previous Traffic Study in the DEIR. Fact It is likely that traffic patterns will change dramatically with multi -level parking versus a large, one - level parking lot. Also, parking space beneath the proposed Target would increase the entries and exits at the west end of the shopping center significantly. Missing Data: The consultant should demonstrate that the new traffic generated by the proposed Target and the new garage across from Office Max, would not dramatically change traffic patterns as stated in the DEIR. 10. The Traffic Study does not consider impacts along Otis Drive, Broadway, Willow Street, Bayview and other residential streets that customers would use to access the shopping center. Fact: The Traffic Study performs levels -of- service or impact analyses at only the intersections contiguous to the shopping center site, plus the four Otis Drive intersections with Broadway, Willow, Grand and High Streets. No impact assessment is included with respect to the difficulties residents could encounter when backing out of their driveways or, for example, waiting for a gap in traffic to make a left turn off of westbound San Jose Avenue onto southbound Broadway (i.e., toward Otis Drive). Also, residents living along Otis Drive between Willow Street and High Street could have difficulties backing out of their driveways with the increased traffic. Neither the 2003 Traffic Study nor the 2006 Traffic Study addressed potential impacts to these residents. Missing Data: All streets leading to and from the shopping center need to be considered for potential delays due to the likely increase in traffic volumes. 1 Last paragraph on page ! , Traffic Study, Appendix B. H :ITTEServerrProposals1268I Alameda TargetTackage to CitylLtr to Alameda Planning Board re Target —Oct 5, 2006.doc - 13 - Last saved: 1 015/2006 3:4I PM October 2, 2006 11. The High Street/Otis Drive intersection is excluded from the 2003 Traffic Study and Mitigated Negative Declaration. The 2003 Traffic Study does not check for project impacts at the intersection of High Street and Otis Drive. Neither this omission, nor other impacts and needs, were addressed as part of the Mitigated Negative Declaration. They require a reassessment of the 1 1 2,000 gross floor area approved in 2003. Levels of Service Comparison at key Intersections between 2006 and 2003 Traffic Study Intersection Willow Otis Drive Otis Drive Otis Drive Otis Drive Park St Broadway High St April 2006 Traffic Study Saturday Midday Peak Baseline 26.4/C 24.5/C 23.1/C Baseline plus Project 26.7/C 35.7/0 * Yr 2025 Cumulati ve without Project 28.2/C 41.6/D 24.5/C 30.3/C 23.2/C 25.8/C Yr 2025 Cumulati ve with Project 28.4/C 43.9/D 30.5/C 26.2/C Existing 15.8/B 45.9/0 9.8/A n/a , 4' x r * - +=:d 7 ne ' vrti7cs ^1i^f' Saturday Midday Peak Baseline 15.9/C 46.0/D 18.6/0 n/a Baseline plus Project 16.0/B Yr 2020 Cumulati ve without Project 16.21E 45/D 18.9/B n/a 19.2/B n/a n/a Yr 2020 Cumulati ve with Project 48/D n/a not available, intersection not evaluated. * page 44 of 2003 Traffic Report, the mitigation is a dedicated southbound right turn lane, 150 feet long Source: Omni Means Traffic Study, April 21,2006 and Traffic Study, April 10, 2003 12. The 2003 Traffic Study states, incorrectly, that the intersections of Otis Drive and Willow Street, and Broadway and Otis Drive, would have shorter delays in the year 2020 than today, as determined in the 2006 Traffic Study. Fact: According to the current DEIR, the existing delay at the intersection of Otis Drive and Willow Street is 26.1 seconds per vehicle. This is 59% greater than the delay predicted for this intersection for the Year 2020 Cumulative with Project condition in the 2003 Traffic Study. Similarly, according to the g current 2006 Traffic Study, the Otis and Broadway intersection has more delay today than the Year 2020 Cumulative scenario in the 2003 Traffic Study. That cannot be correct considering that today, Towne Centre has only 300,000 square feet of shopping area, while it will have 706,000 square feet total at build - out. Clearly, this invalidates the previous study. (See table above and Attachment B for tables from both studies.) Correction of Data These errors indicate that the base data on which the project of 1 12,000 square feet was assessed in 2003 is incorrect. H :ITTEServer\Proposals1268I Alameda TargettPackage to CitylLtr to Alameda Planning Board re Target —Oct 5, 2006.doc - 14 - Last saved: 10/5/2006 3:41 PM October 2, 2006 13. TTE field- measured delays at the shopping center today, with only 300,000 square feet of occupied space, reveal congestion at higher levels than those projected by the 2003 and 2006 traffic studies for total build -out of the center. This is the inevitable result of the consultants and city staff having used exclusively lowest -range assumptions in their analyses. Under the City's own CEQA criteria, it is likely that any increase in occupancy will result in significant impact at the intersection of Otis Drive and Park Street. Further, due to the right -of -way constraints and roadway geometry, it is unlikely that any significant impact could be mitigated at the major intersection of Otis Drive and Park Street. Corrective Action: A new Traffic Study must be conducted to correct mistakes in both the 2003 and 2006 studies. 14. The Traffic Study in the DE1 R illustrates that the existing shopping center has a parking demand rate of 3.01 parking spaces per 1 ,000 square feet of floor area for one day in December 2002. Fact: The parking demand rate of 3.01 parking spaces per 1,000 gsfa for a December peak, is not necessarily reasonable, for high traffic- generating stores such as grocery stores, Trader Joes, Targets and Wal- Marts. TTE's surveys of Wal -Mart stores illustrate parking rates of more than four spaces per 1.000 gsfa for non- December peak and supply rates of approximately six parking spaces per 1,000 gsfa. This is not to say that a Target store's parking demand and parking supply requirements are similar to those of a Wal- Mart store. The point is that existing Wal -Mart stores are experiencing parking demand rates that are significantly higher than four parking spaces per 1,000 gsfa for non - December days. Further, Wal -Marts are providing parking at much higher supply rates to accommodate peaks that occur around holidays such as December. Missing Data: The 2006 Traffic Study relies on one survey conducted on one day in December 2002. This is insufficient multiple surveys should be conducted on multiple days. The industry standard of care is to verify the parking demand and supply rates from research documents via field surveys at several comparable -sized Target stores during both non - December and December periods. In addition, multiple field surveys should be performed at the existing shopping center to verify current peak parking demand rates. Sales records should be checked to determine whether the days selected for the surveys would represent a reasonable activity level for the shopping center. The intent of this assessment is to determine whether any spillover parking or other parking impact would occur in the surrounding neighborhoods during peak traffic times at the shopping center. Currently, the demand at the beach illustrates heavy usage of the curbs along Shoreline Drive and other streets, as well as additional parking burden on Willow and in the neighborhoods to the west. Potential impacts in these areas should be evaluated as part of a comprehensive traffic analysis. H:ITTEServerPProposais12681 Alameda TargetlPackage to CitylLtr to Alameda Planning Board re Target—Oct 5, 2006.doc - 15 - Last saved: 1 0/5/2006 3:41 PM October 2, 2006 15. The roadways to the site and the site plan need review, and modifications need to be made for pedestrian, bicycles, bus and truck access and circulation. Fact: Sidewalks and bicycle lanes should be provided within the roadways to the site and on the site. For example, bicycle access via Otis Drive and Park Street is cumbersome due to a lack of bicycle lanes and narrow road widths near the intersection of Park and Otis. As a result, most bicyclists traveling to and from the east via Otis Drive, and north via Park Street, ride their bicycles on the sidewalks where children and senior citizens typically walk. This could result in potential conflicts and should be resolved. Pedestrian and bicycle access from all directions and on the site should be evaluated and accommodated accordingly. Driveways are too narrow and result in total blockage when a bus or truck turn occurs. For example, at the intersection of the Whitehall driveway and Park Street, neither a bus nor a truck can make a right turn into the shopping center while a car is at the stop bar waiting to exit. Corrective Action: Roadway and site geometry needs to be modified for the implementation of sidewalks and bicycle lanes, and to accommodate the truck/bus turning movements. Decision sight lines should be checked for clear visibility for all pedestrians and bicycle traffic crossings. 16. The consultant who prepared the Traffic Study and the City of Alameda engineer who is referenced in the study do not have civil engineering licenses, as required by state law. Fact The unlicensed consultant engineer and unlicensed public works engineer provided study and recommendations of roadway modifications and performed signal warrant analyses. The California Business and Professions Codes for Professional Engineers requires that individuals who make recommendations for fixed works within a cites infrastructure must be licensed in civil engineering by the California Board of Professional Engineers and Land Surveyors, a division of the California Department of Consumer Affairs. Pertinent sections of the code are provided below: California Professional Engineers Act, as amended January I. 2000. Section 6730, states the following In order to safeguard life, health, property and public welfare, any person, either in a public or private capacity, except as stated in this chapter... who practices, or offers fern to practice, civil engineering. .. sha116e registered accordingly as a civil engineer... Section 6731 of the Act provides the definition of civil engineering: Civil Engineering embraces the following studies or activities in connection with fixed works for irrigation, drainage, waterpower, water supply, flood control...municipal improvements...highways. Section 6731 states. further: Civil engineering also includes city and regional planning insofar as any of the above features are concerned therein. Section 6787 states the following: Every person is guilty of a misdemeanor... a) Who... practices civil engineering ...without a license (See California Board for Professional Engineers and Land Surveyors website.) Correction: All study and recommendations for changes in roadway configurations and traffic control devices must be performed under the responsible charge of a licensed civil engineer with experience in traffic engineering. The engineer(s) in charge must sign all reports. H:ITTEServerlProposals12681 Alameda Target\Package to Cityltr to Alameda Planning Board re Target —Oct 5, 2006.doc - 16 - Last saved: 10!5/2006 3:4I PM January 20, 2007 Honorable Mayor and Councilpersons: I am Claire Risley and I live in Alameda. I urge you not to approve the requested contract revisions because the scope of work fails to remedy the most basic problem with the DEIR, that is, its failure to analyze the environmental impacts of the entire `Target' building. Instead, it purports to analyze only 49,000 square feet of retail, shopping center space. That space will not be built in a vacuum. It will be part of one 161,000 square foot building, the proposed Target. CEQA requires that the environmental effects of the entire building be analyzed, as part of one CEQA "project ". What is happening here is an impermissible tactic called 'piecemealing'. The time to correct this is now. The scope of work that you are being asked to authorize doesn't do that. Piecemealing is the "chopping up (of) proposed projects into bite -sized pieces which, individually considered, might be found to have no significant effect on the environment...". It is not permitted under the provisions of CEQA for the obvious reason that all these `bit sized pieces' can add up to a very significant total impact. Association For a Cleaner Env't v Yosemite Community College Dist. (2004) 116 CA4th 629, 638, 10 CR3rd 560. The California courts have made it very clear that a public agency may not divide a single project into smaller subprojects to avoid responsibility for considering the environmental impact of the project as a whole. Orinda Ass'n v Board of Supervisors (1986) 182 CA3d, 1145, 1171, 227 CR 688. This is precisely what is being proposed here in the contract provisions before you. I have pointed this defect out by letter dated October 9, 2006. A copy of that letter is appended and incorporated herein. Neither the Planning Department nor the City Attorney has responded to that letter. Please don't approve the proposed contract amendments until they include a reasonable and legal scope of work Thank you. Claire Yeaton - Risley Attorney at Law 1101 Grand Street Alameda, CA 94501 510 864 -1103 Submitted by Claire Risley at the 02 -20 -07 City Council Meeting Re: Agenda Item #4 -E z1/76/ CLAIRE YEATON..RISLEY Attorney at Law 1101 Grand Street Alameda, CA 94501 510 864 -1103 October 9, 2006 CERTIFIED MATURETURN RECEIPT REQUESTED Mr. Patrick Lynch, President City of Alameda Planning Board Alameda City Hall 2263 Santa Clara Avenue Alameda, California 94501 Ze„.„---Mr. Douglas Garrison, Planner 111 City of Alameda Planning and Building Department 2263 Santa Clara Avenue, Room 190 Alameda, California 94501 ALArs4E0A, 94S0 RE: Comments on the Draft Environmental Impact Report for the Alameda Towne Centre Expansion/ Target Dear President Lynch, Members of the Board, and Mr. Garrison: � live in the City of Alameda. 1 hereby in comments of - � corporate by reference all of the other individuals and agencies who comment on the Draft Environmental Impact Report ("DEIR") far the Alameda Towne Centre/Target Expansion_ It is m opinion that the DEIR must be withdrawn, rewritten my xtten and recirculated. The DEIR is fatally flawed because it fails to evaluate the environmental �'onrnental impact of the entire "project". It merely ����5 y at the effects of bits and pieces of the � " roect " "project The definition of the 'Proposed Project' Po � contained in the DEIR includes the construction of a new three level arki P ng structure, two new restaurants, a new approximately 145,000 square foot Target, ` g � and the renovation of smaller structures l orated in the northwest corner of the shopping pp ng center. A new gas station, proposed to be constructed on the site of the now vacant US Bank building, bu�ld�ng, should also have been included in this definition since it's a "reasonably foreseeable future expansion" of the project. Lauh is In1 rovement Ass'n � n �� gegents of the Uni versi of Cal. (1988) 3 d 3 7 � 2 5 � CR �.26 . But the trafli cana�ys�s�ntheDEl.R,aswellas part of the noise analysis, excludes from its examination p �nat�on the effects of 112,000 square feet of the proposed 145,000 square foot Target! � The effects � s of the new gas station are also excluded from. analysis in most sections of the CE - DEIR with the explanation that "a separate A evaluation is being prepared for this p p P hrs project. This is legally impermissible. An EIR is required required to look at "all significant effects on the environment of the proposed p raj ect' Cal Pub Res Code Sec. 21,100(b)(1) )- The CE QA regulations define the term 'project' to mean `the whole of .. _ . _ the underlying activity being approved." 14 Ca l Code Regs Sec. 1 53 78 (a ), (c)-(d). The Courts have interpreted the term "project" broadly in order to maximize rotection of environment. Friends of mamma p the Mammoth v. Board of Supervisors (1972) rd 7'6 1 _ Thcy have mad 8 Cal 3 259, l �4 CR made it clear that a public agency may not divide a smaller subprojects ects to avoid �' single project into j responsibility for considering the environmental the project as a whole. Orinda A impact of ss'n v Board of Supervisors (1986) l 82 CA3 1 1 71, 227 CR X88. CE t� d, l 145, "cannot be avoided by chopping up proposed pieces which, individually pp � P P oposed projects into dividually considered, might be found to have significant on the environment or to be e na s�gn�f cant only ministerial ". Association For a Cleaner Env't Corr�muni Colle e Di r env t Yosemite st. (2004) 116 CA4th 629, 638, 10 CR3rd 560. v The preparers of the DEIR attempt to . frarr� the` • p o the exclusion of � I2,0�� square feet their analysis on the basis that it was already q than significant �� - y considered and mitigated to a "less level" in the 2003 mitigated negative This impermissible "tiering-. g g declaration. This is an attempt at p Tiering or " i to "piggy-backing", when appropriate, allows agencies analyse broad environmental issues in a 'first first tier" EIR, followed by a detailed examination of specific, limited issues in a 'second tier' environn1ental document. The first tier document must be an EIR. Pub Res S ec2 1 094 (a); 14 Cal Code 15152(d). In this case the first tier Regs Sec r document is a negative declaration, not an EIR. The DEIR also fails to include in its' on s appendices several documents that it relies n in its' body. These include, but are not limit ed to, Planning and unning Board resolution No. pB_ PDA05-0004 . PB-03-40 was originally on inally requested on September 5th, 2006. y neighbor, fall Se llers, and made two additional visits to the Planning Department before we finally obtained it, but not its' attachments. It • • . . meeting with Mr. t toad three additional visits plus a g Garrison before we received, on October e attachments. PD � ber 2, most, but not all of the AO5 --004 was originally requested on September 15, 2006. We were g iven a cd on October 2, 2006 that we were told contained this document. It 2 doesn't.The failure to include relevant documents in the appendix to the DEI with the failure to make the doc � couple readily available at the Plannin and Build' Department is a violation of the Public Ong blic Participation Policies of CE A. with the case of �Itram � In accordance ar�ne v. South coast Air ualit Dana eruent C�. App -4 689. the Planning District (1993) I � Ong and Building Departtnent is required to recirculate DEIR and renotxce another 4�- � �rculate the dad review period. Sincerely, Claire Yeaton- Paisley Attorney at Law Good Evening - My name is Holly Sellers and I live in Alameda. I've come here tonight to ask you to delay amending these existing professional contracts until some clarifications can be made. I believe that the scopes of work as presented fall short of requested studies and questions submitted by Local Agencies and Alameda residents. For instance, the Lamphier 1 Gregory Agreement is deficient as follows: omPndmer174 There is no mention of a budget for Noise analysis or Air quality in their -met. Comments submitted in response to the DEIR ask that air and noise levels be taken within Alameda to know the actual existing conditions. Actual noise & air quality levels should be taken so that a comparison can be made, especially along the Otis truck route. 15t- Their response to comments line item should have copies of those comments attached here. I believe it would eliminate any confusion if re of the comments are shown. In that way Planning Staff and Alameda Residents are sure that all written comments have been received by our consultant and are being included in the final document. Omni - Means Agreement is deficient as follows: On 2/16/06 the Alameda County Congestion Management Agency said the Program "requires the City to conduct a traffic analysis of the project using the Countywide Transportation Demand Model for projection years 2010 and 2025 conditions." They also requested a much broader analysis of MTS roadway and transit systems. To my knowledge neither of these tasks were performed. In October the ACCMA reiterated the requirement for the TDM, but it does not look like these items are included in this budget. Omni -Means is a consultant to the City of Alameda. They should prepare the studies requested by the local Agencies. It would be in the best interest of the City. Please make sure these items are included. Also, this amended contract needs to spell out where and how the gas station is being included in the EIR. Omni -Means supposedly included the proposed gas station in their DEIR calculations, however the numbers were never revealed. Mr. Nickelson needs to specifically state in this amendment where the gas station is included and provide the traffic calculations used. it Omni -Means made a serious error in their 2003 draft traffic report (see note by planning staff). However, when Mr. Nickelson issued the final report, it went uncorrected. It seems that this is an appropriate time to correct that error. A line item in this amendment should ask for a corrected report or separate table showing the increase in daily traffic for the 112,000 sq ft as well as the _ 49,000. Right now we have never been given correct daily traffic figures for the 112,000 sq fitti expansion so we cannot be sure that the CEQA requirement for analyzing "the combined impacts of the project and past, present and reasonably foreseeable future projects" has been done. Submitted by Claire Risley on behahlf of Holly Sellers at the 02- 20-07 City Council Meeting Re: Agenda Item #4 -E .drew Thomas - Bann -zn p g staff- has assured Alameda residents « fQr the DEIR will be addressed" sidents that "every comments ' that sled" so I take the comment submitted vide a " " . on page of Mr. Nickelson's amen onse to the majority amendment Mr. Nickelson needs to respond j ty of written comments" is not appropriate. pond to all comments per lam noth r reason to attach the comments p planning staff 'wishes. Here then is an he will be addressing other time and materials. g and his agreement on . �' n this item become., I guess what this boils down to is that 1 don't believe that the ca written comments from the DEIR consultants have received all of IR and we need to be sure that the these agreements. Lately, hat all are included prior to • in p amending y, in many instances the written comments is are either lost or not forwarded AC Transit D'eciror ALAN/FDA CONQEST1QN VANAGEN/ENT 1333 BROADWAY, SUITE 220 • OAKLAND, CA 94612 • PHONE: (510) 836 -2560 • FAX: (510) 836 -2185 E -MAIL: mails @accma.ca.gov • WEB SITE: accma.ca.gov Coiores Jaquer February 1 6, 2006 Alameda County Supervisors Nate Miley Mr. Douglas Garrison Scott Haggerty Planner III 'lice Chairperson Planning and Building Department City of Alameda Mayor city or Alameda Beverly Johnson -"63 Santa Clara Avenue, Room 19 0 City of Albany ; .A I a ii o d a, CA 94501 Mayor Allan Maris BART Director Thomas Blalock HECEIVEL5 FEB2,2006 SUBJECT: Comments on the Notice of Pr aration of a Draft ft Environrnenta mpact Report for the Alameda Towne Centre (formerly South Shore Shopping Center) Project City of Berkeley • Councilmember KrissWorthington Dear Mr. Garrison: City of Dublin Mayor Thank you for the opportunity to comment on the City of Alameda's Notice of Preparation Janet Lockhart (NOP) of a Draft Environmental Impact Report (DEIR) for the proposed expansion and City of Emeryville renovation o t' the Alameda Towne Centre (formerly South Shone Shopping nlg Center) Project. Mayor t Ruth Akin The proposal includes: construction of a new three -level parkin{4 structure: two new City of Fremont restaurants and associated public open space improvements along Shoreline Drive. a new Mayor approximately 145,000 sq.ft. discount department store (Target) along with other- related Robert Wasserman improvements. If approved, the total gross leasable area (GLA) for the Alameda Towne City of Hayward Centre will be approximately 706,650 sq.ft. Mayor Roberta Cooper City of Livermore rr'lie ACCMA respectfully submits the following comments: Mayor Marshall Kamena City of Newark Councilmember Luis Freilas City of Oakland Caunc ;,member Larry Reid Chair ,cr ,on City of Piedmont Counc,l'.rember ;etf Weler City of Pleasanton ..ennifer 1-'CSlerman City of San Leandro Mayor Shelia Yrung City of Union City Mayrgr Mark G9,en Executive Director R. F ry The City of` Alameda adopted Resolution 12308 on August 18, 1992 establishing revieik:in c 'i: paris or local land use decisHiis consistent with the Alameda County Congestion Management Program (CMP). Based on our i c view NOP and the land uses that are being considered, the proposed project •appears to generate at least 100 p.ni. peak hour trips over existing conditions. If this is the case, the CMP Land Use Analysis Program requires the City to conduct a traffic analysis of the project using the Countywide Transportation Demand Model for projection years 2010 and 2025 conditions. Please Ilute the following paragraphs as they discuss t!ic responsibility for modeling. 0 The C'M \ Boc,i -d amended the C vIP on March 26th, 1998 so that local j LIr!Sd k tions are now responsible for conducting the model runs themselves or through a consultant. 'IThe City of Alameda has a signed Countywide v! 1e1 Agreement with the ACCMA dated Jarluar, , 27, 1 999. The Countywide model incur: ur tiil1 ABAG's land use data for Projcctioit; ?()02 is available to the local jurisdiction~ for this 5v1 Mr. Douglas Garrison February 16, 2006 Paget purpose However, before the model can be released to you or your consultant. a letter - must be submitted to the ACCMA requesting use of the model and describing the project. A copy of a sample letter agreement is available upon request. • Potential impacts of the project on the Metropolitan Transportation System CATS) need to be addressed. (See 2005 CAP Figures E -2 and E -3 and Figure 2). The analysis should address all potential impacts of the project on the MIS roadway and transit systems. These include State Route 61, I-880, Atlantic Avenue, Broadway (Alameda), Central Avenue, Constitution Way, Fruitvale Avenue (A!anieda Street g (Alameda , Hi h } and Oakland), Main Street, Otis Drive, Park Street /23rd (Alameda and Oakland), Posey /Webster Tubes, Webster Street (Alameda and Oakland), 8th Street (Alameda), 7 th 18 th Street (Oakland), Harrison Street (Oakland) as well as BART and AC Transit. Potential impacts or the project must be addressed for 201 0 and 2025 conditions. c� Please note that the ACCMA does not have a policy for determining a threshold of significance for Level of Service for the Land Use Anasis Prligrarn of the CMP. Professional judgment should be applied to determine the significance of ect J ro� P impacts (Please see chapter 6 of 2005 CMP for more information). 0 In addition, the adopted 2005 CMP requires using 1985 Highway Capacit y Manual for freeway capacity standards. • The adequacy of any project mitigation measures should be discussed. On February 25, 1993 the CMA Board adopted three criteria for evaluating the adequacy of DEIR J ro'ect mitigation measures: P - Project mitigation measures must be adequate to sustain CMP service standards for roadways and transit; - Project mitigation measures must be fully funded to be considered adequate; - Project mitigation measures that rely on state or federal funds directed by or influenced by the CMA must be consistent with the project fundin g priorities established in the Capital Improvement Program (CIP) section of the Cf 1f?_ or the Regional Transportation Plan (RTP). The DEIR should include a discussion on the adequacy of proposed mitigation measures relative to these criteria. In particular, the DEIR should detail when proposed roadwa y or transit route i nprovernents are expected to be completed, P p , low they w i l l be funded, and what would be the effect on LOS if only the funded portions of these J ro'ects were P assumed to be built prior to project completion. • Potential impacts of the project on CMP transit levels of service must he analyzed. (See 2005 CMP, Chapter 4). Transit service standards are 15 -30 minute headways for bus service and 3.75-15 minute headways for BART during peak hours. The DEIR should address the issue of transit funding as a mitigation measure in the context of the CMA's policies as discussed above. • The DEIR should also consider demand- related strategies that are designed to reduce the need for new roadway facilities over the long terra and to make the most efficient use ol. existing facilities (see 2005 CMP, Chapter 5). The DEIR should consider the use cif~ TDM measures, in conjunction with roadway and transit improvements, as a means of Mr. Douglas Garrison February 16, 2006 Page 3 attaining acceptable levels of service. Whenever possible, mechanisms that encourage ridesharing, flextime, transit, bicycling, telecommuting and other means of reducing peak hour traffic trips should be considered. Once again, thank you for the opportunity to comment on this NOP for a DEIR. Please do not hesitate to contact me at 51 0/836 -2560 ext. 24 if you require additional information. Saravana Suthanthira Assoc fate Transportation Planner cc: Chron - file: CMP - Environmental Review Opinions - Responses - 2006 AC Transit ()sector Delores .;aquez Alameda County Sapery sors Nate Miley Scott Haggerty V:ce Chairperson City of Alameda Mayor Beverly Johnson City of Albany Mayor Allan Maris BART Director Thomas Blalock City of Berkeley Councilmember Kriss Worthington City of Dublin Mayor Janet Lockhart City of Emeryville Mayor Ruth Akin City of Fremont Mayor Robert Wasserman City of Hayward Mayor Roberta Cooper City of Livermore Mayor Marshall Kamena City of Newark Councilmember Luis Freiras City of Oakland Councilmember Larry Reid Charon City of Piedmont Ccur.ci:mcmber JO \ ele, City of Pleasanton Mayor Jennifer H;sterman City of San Leandro Mayor ',Theta Yo:;ng City of Union City Mayor Mark Green Executive Director Ucnnis R. f ay , �•, `• � � f .• .,"*_7 •,, � � ,� '�i-��•� October 10, 2006 1333 BROADWAY, SUITE 220 • OAKLAND, CA 04612 • PHONE: (510) 836 -2560 • FAX: (510) 836.2185 E -MAIL: mail@accma,ca.gov • WEB SITE: accma•ca,gov Mr. Douglas Garrison Planner III Planning and Building Department City of Alameda 2263 Santa Clara Avenue, Room 190 Alameda, CA 94501 i3EF 'a to i .ri 1 w1 r ` ■ -------i i k; c : 7 .'1106L. PE 4 ii'i' CENTER ALAM ' DA, CA 94501 • SUBJECT: Comments on the Draft Environmental Impact Report for the Alameda Towne Centre (formerly South Shore Shopping Center) Project Dear Mr. Garrison: Thank you for the opportunity to comment on the City of Alameda's Draft Environmental Impact Report (DEIR) for the proposed expansion and renovation of the Alameda Towne Centre (formerly South Shore Shopping Center) Project. The proposal includes: construction of a new three - -level parking structure; two new restaurants and associated public open space improvements along Shoreline Drive, a new approximately 145,000 sq.ft. discount department store (Target) along with other related improvements. If approved, the total gross leasable area (GLA) for the Alameda Towne Centre will be approximately 706,647 sq.ft. an increase of 49,132 sq.ft from the previously approved 657,515 sq.ft. The ACCMA respectfully submits the following comments. Where possible the DEIR page numbers ar referrAlLcd. CMP Analysis: The DEIR states (Page 25. Appendix B Traffic Study) that the net p.rn. peak hour trips generated from the proposed expansion is 95. Since this is below the trip generation threshold of 100 p.m. peak hour trips to require a CMP analysis, and therefore the DEIR did not include a CMP traffic impact analysis. Page 25, Appendix B Traffic Study- Trip Generation: The following are the comments related to trip generation estimation included in the DEIR Traffic Study: Appropriate proT�rrate Laand Use Code: : The DEAR used ITE Trip Generation rates (7`h Edition) for t! 1 Land Use # 820 `Shopping Center' to estimate the trips generated from the project. Sinc this expansion proposes to bring in .a Discount Supermarket (Target) to the shopping center, a general 'Shopping Center' trip generation rate is not appropriate. The more Mr. Douglas Garrison October 10, 2006 Page 2 appropriate land use code of either `Freestanding Discount Store (815I or 'Freestanding Discount Superstore' (813) should be used to estimate the trips for the Target store. Trip Generation Rates .for Existing and Proposed Land Use: To estimate the trips generated from the approved existing and proposed uses, two different trip generation rates have been used in the DEIR. For example, for the p.m. peak hour, for the existing use the trip generation rate used is 3.30 tripslksf, whereas for the proposed land use the trip generation rate used is 3.22 tripslksf, which is 0.08 trips /ksf less than the rate used for the existing use. Please clarify why different rates were used and how the rates were calculated. It is suggested that same trip generation rates be used for both existing and proposed land uses. In view of the above, it is requested that the project trip generation estimation in DEIR be revised. Since the current net p.m. peak hour trips estimated is only 5 trips less than the CMP threshold of 100 p.m. peak hour trips, it is anticipated that the revised trip generation will exceed this threshold, and therefore a CMP analysis should be carried out as requested in.our response to the NOP dated February 16, 2006. Once again, thank you for the opportunity to comment on this DEIR. Please do not hesitate to contact me at 51 0/836 -2560 ext. 24 if you require additional information. Sincerely, Saravana S uthanth ira Associate Transportation Planner cc: Chron file: CMP - Environmental Review Opinions - Responses - 2006 • ERRATA SHEET, IS 02 -006: SOUTH SHORE CENTER, TRAFFIC STUDY On May 12, 2003 George Nickelson of Omni Means Engineers, consultant for the traffic study for IS 02 -006, advised City staff that there is an error in reporting data at the top of page 23 of the April 10, 2003 traffic study: "28,882" weekday trips to the shopping center after project completion should be approximately 7,000 trip less than that amount, or 21, 882 +1 -. That would make the daily total consistent with the AM and PM peak hour data, as projected from actual Omni Means counts for existing conditions. This information was provided to the Planning Board with the May 12, 2003 public hearing on IS 02 -006, in a supplemental staff report which was also placed on the public counter at the entry to the hearing chamber before the meeting, and was verbally discussed prior to adoption of the Mitigated Negative Declaration. Dave Valeska Planner III G: Ipianning\pblreports1200315 soumy 12 Table 4 Proposed Project Trip Generation""' A. Weekday Daily, AM and PM Peak Hour Existing: Daily: 545,515 sq. ft. x 37.19 tripslksf AM: 545,515 sq. ft. x 0.804 trips/ksf PM: 545,515 sq. ft. x 3.526 trips/ksf Proposed: Daily: 657,515 sq. ft. x 43.93 trips/ksf AM: 657,515 sq. ft. x 0.746 trips/ksf PM: 657,515 sq. ft. x 3.31 trips/ksf New Weekday Trips: Daily: 8,589 AM: 52 (32 in, 20 out) PM: 252 (121 in, 131 out) B. Weekend Daily and Mid -Day Hour =.20,293 • 439 (268 in, 177 out) = 1,924 (924 in, 1,000 out) • 28,882 • 491 (300 in, 191 out) 2,176 (1,045 in, 1,131 out) Existing: Daily: 545,515 sq. ft. x 48.65 trips/ksf = 26,542 Mid-Day: 545,515 sq. ft. x 4.824 trips/ksf = 2,632 (1,369 in, 1,263 out) Proposed: Daily: 657,515 sq. ft. x 43.93 trips/ksf = 29,845 Mid-Day: 657,515 sq. ft. x 0.746 tripslksf = 2,972 (1,545 in, 1,427 out) Net New Weekend Trips: Daily: 3,303 Mid-Day: 340 ( 176 in, 164 out) (1) Institute of Transportation Engineers (ITE), Trip Generation, 6th Edition, Shopping. Centers, Land Use ( #820), 1997. Based on logarithmic equations. Traffic Analysis for the Proposed South Shore Shopping in Center Expansion 23