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CC - Item 3A - Complete Final EIR for Walmart Development•
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ROSEMEAD CITY COUNCIL/COMMUNITY DEVELOPMENT
COMMISSION
PUBLIC HEARING STAFF REPORT
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
CHAIRMAN AND MEMBERS OF THE COMMUNITY DEVELOPMENT
COMMISSION
FROM: BILL CRMWE, CITY MANAGER/EXECUTIVE DIRECTOR
DATE: DECEMBER 6, 2005
SUBJECT: COMPLETE FINAL EIR FOR THE ROSEMEAD COMMECIAL RETAIL
CENTER (WALMART) DEVELOPMENT
1827 WALNUT GROVE AVENUE
INTRODUCTION
This staff report pertains to the Complete Final Environmental Impact Report that has been prepared
in accordance with the order of Judge Yaffe of the Superior Court for the Wal-Mart Project. The
court order requires the City Council to consider and certifythe document and then make appropriate
findings under CEQA. If these resolutions are approved, the City's Community Development
Commission will also be required to accept the Complete Final Environmental Impact Report for the
approved Project and join in the amendments to the CEQA findings and determinations made by the
City Council as the approved project is within Project Area No. 1.
BACKGROUND
The detailed facts leading up to the Complete Final Environmental Impact Report can be found in
Section 1 of each of the proposed resolutions. Briefly, an Environmental Impact Report ("EIR") was
prepared last year for the applications submitted for the Wal-Mart development: a Development
Agreement; a General Plan Amendment changing the land-use designation from "office/light
industrial" to "commercial," a tentative parcel map; and conditional use permits("CUPs") for alcohol
sales, a mini-mall on one of the outlying pads, and a gas station.
C._L. i.
DEC 13 2005
• •
Revised Final EIR
December 6, 2005
Page 2
In September 2004, the City Council considered the EIR along with all of the requested approvals.
At the end of a lengthy hearing, the Council certified the EIR, approved the Development
Agreement, the General Plan Amendment, an alternative design to the proposed project which
included a 4 lot parcel map, and CUPs for alcohol sales at Wal-Mart and a mini-mall on one of the
outlying pads. The CUP for a gas station was denied. (The Development Agreement was later
rescinded on December 14, 2004, because of a referendum petition.) The City's Community
Development Commission ("CDC") joined in the certification of the EIR and the approval of the
Project Design Alternative. The staff reports from the City Council and CDC hearings are attached
to this staff report for purposes of background information.
Shortly after approval, a lawsuit was filed by Save Our Community, challenging the adequacy of the
EIR on the following grounds: alternative site analysis; 24-hour analysis; traffic study; light and
glare; urban decay; earthquake risks; native birds; and run-off and drainage. The court found that the
EIR was inadequate only with regard to the alternative site analysis and analysis relating to a 24-hour
operation. The court's primary objection to the alternative site analysis was that the information that
was in the administrative record, which the court stated did adequately analyze the alternative
locations, was not actually included within the EIR itself, precluding meaningful public review and
comment. The court therefore issued a judgment and writ of mandate which directed the City to
revise the EIR; these documents were previously provided to the City Council. The judgment and
writ specifically provided that the approvals remained valid unless the City Council decided not to
approve the project or modify the site of the project.*
ANALYSIS
Based on the court's ruling, the City prepared a Revised Alternative Site Analysis that was circulated
for public review from September 26, 2005 to November 10, 2005. Responses to comments
received through November 22, 2005 were responded to and final changes to the EIR are included in
the document entitled, "Revised Final EIR (December 2005)." An additional comment was received
by Save Our Community on December 6, 2005 regarding Caltrans' continents on the traffic analysis;
as stated above, the court has determined that the previous traffic analysis was adequate.
The revision did not include any analysis of a 24-hour operation as subsequent to the court's
decision, Wal-Mart provided the City with a restrictive covenant to be recorded against the property
prohibiting a 24-hour operation absent subsequent environmental review and approval by the City.
This covenant moots the issue of including an analysis of a 24-hour operation. Planning condition
number 54 has been changed from the adopted version to provide a limitation on the hours.
The entire Administrative Record that was submitted to the court, including transcripts of the
previous proceedings, is available for review at City Hall. A transcript of the court's April 6,
2005 hearing is also available. This information provides a more detailed background, but is
not necessary for certification of the Complete Final EIR.
Revised Final EIR
December 6, 2005
Page 3
Alternative Sites
The purpose of an alternative site analysis is to determine if there are any sites which would feasibly
attain most of the basic objectives of the project and would avoid or substantially lessen any of the
significant effects of the project. An EIR is not required to consider alternatives which are
infeasible, but is required to include some explanation as to why the alternatives were rejected. The
factors that can be used to eliminate alternatives from detailed discussion are: failure to meet most of
the basic project objectives; inability to avoid significant environmental impacts; or infeasibility. In
order for an alternative to be considered feasible, it must be capable of being successfully
accomplished within a reasonable period of time, taking into account economic, environmental,
legal, social and technological factors; these factors include jurisdictional boundaries (i.e., is the
location in another city) and the fact that the applicant does not own or control the location.
The EIR identified the following impacts as significant: traffic impacts on the Pomona (SR-60)
Freeway based on Caltrans' threshold criteria which states that the addition of one additional vehicle
on a freeway operating below level of service "C" is significant; short-term air quality impacts
relating to Regional Organic Gases (ROG), Oxides of Nitrogen (NOX), and Local Particulate Matter
(PM I resulting from construction; air quality impacts relating to Carbon Monoxide (CO), Regional
Organic Gases (ROG), and Oxides of Nitrogen (NO,) resulting from operations; and short-term noise
impacts relating to construction. Therefore, in analyzing the suitability of other sites, these are the
impacts that are to be reduced. Impacts relating to such matters as local street traffic, operational
noise, and light and glare were not significant and therefore did not need to be considered as part of
the criteria for finding an alternative site.
Although the court stated that the information regarding the lack of an available alternative site was
adequate, just not included in the EIR, the Revised Alternative Site Analysis went farther than the
earlier analysis and analyzed three sites that had not been previously mentioned, in addition to
discussing the Ralph's Market site. The sites discussed in the Alternative Site Analysis Revision
are: the L.A. Dealer Auto Auction site (8801 Garvey); the northeast corner of Valley Boulevard and
Temple City Boulevard; and the Robinson's-May site at the Montebello Town Center. The Final
EIR (December 2005) also addressed other locations and project designs that had been submitted as
responses to comments. These sites include: the current San Gabriel Nursery & Florist/ propagation
nursery located in Monterey Park on Potrero Grande; the proposed Monterey Park "Marketplace"
Development along the north side of the Pomona Freeway, west of Paramount Boulevard; the former
Starlight Theater on Rosemead Boulevard in South El Monte; the Triple B Shooting Range (fonnerly
the Pachmayr International Shooting Range) site in the Whittier Narrows Recreational area in Los
Angeles County; the intersection of the Pomona Freeway and Santa Anita Avenue; and a parcel of
land used by the Boy Scouts, located at the northeast corner of Walnut Grove Avenue and Mission
Drive in the City of Rosemead.
Analysis of each site supports the finding that there are no other sites within the City which are large
enough to support a Wal-Mart Supercenter, even without the outlying pads. Furthermore, the
analysis found that although there may be some perceived reduction of temporary noise impacts, the
significant traffic impacts would not be reduced below a level of significance because no matter
Revised Final EIR
December 6, 2005
Page 4
where the project was located, it would add at least one additional vehicle to either the 60 or the 10
freeways, both of which operate below a level of service "C." Additionally, no matter where the
project is constructed, the construction noise would exceed 65 decibels, the applicable threshold of
significance. Lastly, because the air impacts related to the regional air basin as a whole, and not to
any site specific "hot spots," there would be significant impacts no matter where the project was built
because all of the alternative sites are within the same air basin.
A brief summary of the individual reasons for rejecting each of the alternatives as infeasible and not
a reasonable alternative is listed below. A full analysis is found in the Alternative Site Analysis
Revision and the responses to comments contained in the Final EIR (December 2005).
A. Alternative Sites Discussed in Alternative Site Analysis
L.A. Dealer Auto Auction (Alternative Site1) - The 15.25 acre site which is not within the
applicant's control is not large enough and additional parcels that are needed to form an 18 acre
rectangular parcel are not within a redevelopment area and acquisition, if possible, would be
expensive and time-consuming; successful completion in a reasonable period of time is therefore
unlikely. The site is adjacent to sensitive receptors and none of the significant impacts would be
reduced, although the impacts for noise would switch to those persons located near that site and the
traffic impacts would switch to the 10 freeway. Noise and air impacts would actually increase as this
site would require existing buildings to be demolished.
Northeast corner of Valley Boulevard and Temple City Boulevard (Alternative Site L- The 4.0 acre
site is irregularly shaped, too small and not within the applicant's control. Even with the acquisition
of additional adjacent parcels and covering the wash, the site would total only approximately 8.75
acres. Although the site is within a redevelopment project area, many of the surrounding properties
that would have to be acquired are not within a redevelopment area and such properties are
developed with existing residences and businesses. Although suggestions were made to develop this
parcel along with the City of El Monte on adjoining property, previous attempts to jointly assemble
and develop the necessary parcels failed. Additionally, El Monte has approved development on
some of the surrounding property which would impede any joint development for a Wal-Mart
Supercenter. The site is therefore too small and it would not be possible to acquire needed property;
successful completion in a reasonable period of time is therefore unlikely. The site is adjacent to
sensitive receptors and none of the significant impacts would be reduced, although the traffic impacts
would move to the 10 Freeway. Noise and air impacts would actually increase as this site would
require existing buildings to be demolished.
Robinson's-May at Montebello Town Center (Alternative Site 3) - The existing Robinson's-May
building is located on 8.75 acres and there is no surrounding land to purchase to create the required
18 acre parcel. The City has been informed that this site is not available as Federated Department
Stores will change this to a Macy's store. Additionally, the construction noise impacts would still
exceed 65 decibels and there would still be significant air and traffic impacts.
Two-story alternative - The two-story alternative, whether located on the Montebello Town Center
site, or any of the other suggested locations, is economically infeasible. Wal-Mart has never built a
Revised Final EIR
December 6, 2005
Page 5
multi-story Supercenter as its customers do not like shopping for convenience items and groceries in
this type of setting. Additionally, the cost of designing and constructing such a facility would make
it economically infeasible. Even if it could be accomplished, Wal-Mart does not control any of the
suggested properties making successful completion in a reasonable time unlikely. For reasons set
forth above, a two-story alternative would not reduce the significant impacts that were associated
with the project.
Ralph's Market - The previously vacated Ralph's market was on an approximate 4.6 acre site across
from City Hall, which is also developed with a United States Post Office; even with the adjacent
parcel, which is developed with a bank, the total acreage is only 6.2 acres, which was much smaller
than the required 18 acres for a Wal-Mart Supercenter. Since the time that the Draft EIR was
originally circulated, the anchor grocery store tenant space was re-occupied with a new grocery
tenant (Rosemead Supermarket) and is no longer available. Even if the Project could be moved to
this site, impacts would not be reduced and there are sensitive receptors (schools) nearby.
B. Alternative Sites Raised In Continents
Greenwood Avenue - This large parcel known as the "Marketplace" Development in Monterey Park
is not under the control of the applicant nor under Rosemead's jurisdiction; it is being developed as a
retail Center with a Home Depot as the anchor tenant and the City of Monterey Park has stated that
there is not enough vacant property remaining to build a Wal-Mart Supercenter at this location. It is
therefore not possible to successfully complete the project in a reasonable period of time at this
location. Additionally, for the reasons previously discussed, none of the significant impacts would
be reduced. Development at this site would fail to meet one of the primary objectives, which is to
augment the City of Rosemead's tax base.
Potrero Grande Drive - This 10 acre parcel in Monterey Park is not under the control of the
applicant, nor under Rosemead's jurisdiction, and is not of adequate size to develop the Project. The
site is currently developed with the San Gabriel Nursery & Florist, which is also operating a
propagation nursery; the nursery has been in operation for more than 80 years, making it doubtful
that the site would even be available for development. The site is too small and it is not possible to
successfully complete the project in a reasonable period of time at this location. Additionally, for the
reasons previously set forth, none of the significant impacts would be reduced. Development of this
site would also fail to meet one of the primary objectives, which is to augment the City of
Rosemead's tax base.
Starli ght Theater - This 11.5 acre parcel in South El Monte is not under the control of the applicant,
nor under Rosemead's jurisdiction, and is not of adequate size to develop the Project. It is therefore
not possible to successfully complete the project in a reasonable period of time at this location.
Additionally, for the reasons previously set forth, none of the significant impacts would be reduced
and air and noise impacts may actually worsen because of demolition of existing structures.
Development of this site would also fail to meet one of the primary objectives, which is to augment
the City of Rosemead's tax base.
Revised Final EIR
December 6, 2005
Page 6
Triple B Shooting Range (Trap and Skeet site) - This approximately 83 acre site within the Whittier
Narrows Recreation Area is within a flood prone area; the entire Whittier Narrows, which is
operated by the Los Angeles County Department of Parks and Recreation is a valuable recreational
resource. The property would not be suitable for development of a retail commercial center and is
not under the control of the applicant. It is therefore not possible to successfully complete the
Project or meet the objectives outlined in the EIR at this location. Development of this site would
also fail to meet one of the primary objectives, which is to augment the City of Rosemead's tax base.
Additionally, for the reasons previously set forth, none of the significant impacts would be reduced.
Northeast corner of Walnut Grove Avenue and Mission Drive - This approximate 3.5 acre site is not
under the control of the applicant, and is not of adequate size to develop the Project and is currently
zoned for residential uses. It is therefore not possible to successfully complete the Project in a
reasonable period of time at this location. Additionally, for the reasons previously discussed, none of
the significant impacts would be reduced.
Pomona (60) Freeway & Santa Anita Avenue - The commenter who suggested this site did not
identify which specific corner was being referred to. Regardless of the comer, this site is located
outside of the j urisdiction of the City of Rosemead and is not under the control of the applicant and
therefore it is unlikely that there could be successful completion of the Project in a reasonable period
of time at this location. Additionally, for the reasons previously discussed, none of the significant
impacts would be reduced. Development of this site would also fail to meet one of the primary
objectives, which is to augment the City of Rosemead's tax base.
Conditions of Approval
In addition to containing the responses to comments, the Final EIR (December 2005) contains final,
revised Conditions of Approval, which are part of the EIR. The changes that are shown are from the
conditions that were approved last year. The only change is to show that the deletion of the language
that allowed for a 24-hour operation; the condition is now back to limited hours. This change
reflects the restrictive covenant that Wal-Mart has provided for recordation and moots the court's
order with respect to this issue. The other changes are non-substantive; references to the rescinded
Development Agreement have been deleted and replaced with appropriate language. None of these
changes have any impact on the environmental analysis.
CERTIFICATION OF THE COMPLETE FINAL EIR
The City Council is being asked to first decertify the previously approved Final EIR and to certify the
Complete Final EIR for the Project. The Complete Final EIR consists of: the May 2004 Draft EIR
and teclvlical appendices; the August 2004 Final EIR; the September 2005 Alternative Site Analysis
EIR Revision; and the December 2005 Revised Final EIR. Certification indicates that the documents
were prepared in accordance with CEQA, adequately describes the project, contains all of the
required elements, and reflects the independent judgment of the City Council. Resolution No. 2005-
43 is attached for the City Council's consideration to decertify the original EIR (see Resolution No.
Revised Final EIR
December 6, 2005
Page 7
2004-36 attached hereto) and certify the Complete Final EIR.
CEQA FINDINGS
In addition to certifying the Complete Final EIR, it is also necessary for the City Council to make
findings when approving a project with significant impacts. Although the approvals for the Project
Design Alternative remain in place without any further action of the City Council, the court's order
required that necessary CEQA findings be made. Since the court's order found that there were only
two deficiencies relating to the August 2004 Final EIR, Resolution No. 2005-44 making the required
findings has been drafted that amends the previous findings made in Resolution No. 2004-39. The
major amendment to the previous resolution are to add a section on the alternative sites which were
rejected, as well as clarification that each of the previous alternatives to the project that were
discussed in the Draft EIR were rejected as infeasible. Except as amended, all other provisions of
Resolution No. 2004-39 remain intact. Both Resolution No. 2005-44 and Resolution No. 2004-39
are attached hereto.
COMMUNITY DEVELOPMENT COMMISSION ACTIONS
The approved project is within the boundaries of the Rosemead Redevelopment Project Area 1. The
CDC previously adopted Resolution No. 2004-16, finding that the Project Design Alternative was
consistent with the City's General Plan and the Redevelopment Plan and approving the same. Along
with this finding and approval, the CDC also accepted the Final EIR for the Project Design
Alternative and joined in the findings and determinations and the Statement of Overriding
Considerations made by the City Council. If the City Council approves the revised Complete Final
EIR and amends the resolution making the necessary CEQA findings, then the CDC will also have to
take similar actions. Resolution Number 2005-21 is attached hereto for the CDC's consideration.
RECOMMENDATIONS
Citv Council
That the City Council: 1) Approve Resolution No. 2005-43 decertifying the original EIR, certifying
the Complete Final Environmental Impact Report; and 2) Approve Resolution No. 2005-44
amending Resolution No. 2004-39 pertaining to Findings of Fact and a Statement of Overriding
Considerations.
Communitv Development Commission
That the CDC approve Resolution No. 2005-21 accepting the City of Rosemead's certification of the
Complete Final Environmental Impact Report and joining in the City of Rosemead's amendment to
the resolution regarding CEQA findings and a statement of overriding considerations for the
approved development within Project Area No. 1 (1827 Walnut Grove Avenue).
0 0
Revised Final EIR
December 6, 2005
Page 8
Attachments:
Resolution No. 2005-43
Resolution No. 2005-44
CDC Resolution No. 2005-21
Final Environmental Impact Report (December 2005)
Letter from Save Our Community dated November 30, 2005
Executed Covenant restricting hours
E-mail from Macerich Company regarding Robinson's-May site
City Council staff report dated September 1, 2004 (without attachments)
Resolution No. 2004-36
Resolution No. 2004-39
Community Development Commission staff report dated September 1, 2004
Cormmunity Development Commission Resolution No. 2004-16
Previously Distributed Items:
Previous Final EIR consisting of 3 volumes
Alternative Site Analysis EIR Revision (September 2005)
Staff Administrative Records 1 A and 1 B (originally distributed in 2004)
la - (3- OS
s
Rosemead Commercial Retail Center
Revised Final EIR
I i
Prepared for:
December 2005
{
I , F,
I
TABLE OF CONTENTS
SECTION PAGE
1.0 INTRODUCTION 1-1
1.1 Overview 1-1
1.2 Background ...................................................1-1
1.3 Public Review/Public Comment 1-2
1.4 Document Organization 1-5
2.0 PROJECT DESIGN ALTERNATIVE DESCRIPTION 2-1
2.1 Project Design Alternative Characteristics 2-2
2.2 Project Design Alternative Operations 2-4
2.3 Project Objectives 2-4
2.4 Discretionary Approvals 2-5
2.5 Significant Impacts Associated with the Project Design Alternative 2-6
3.0 REVISIONS 3-1
3.1 Introduction 3-1
3.2 Revisions 3-1
4.0 COMMENTS AND RESPONSES 4-1
Rosemead Commercial Retail Center Table of Contents
Revised Final EIR (SCH No. 2003 1 2 1 095) Page i
LIST OF FIGURES
FIGURE
PAGE
2.1-1 Project Design Alternative Site Plan Concept 2-3
7.3-1 Alternative Site 1 3-6
7.3-2 Alternative Site 2 3-10
7.3-3 Alternative Site 3 3-13
Rosemead Commercial Retail Center Table of Conter:ts
Revised Final EIR (S CH No. 2 003 1 2 1 095) Page ii
LIST OF TABLES
TABLE
PAGE
2.1-1 Proposed Land Uses 2-2
7.3-1 CMP Highway System Peak Hour Levels of Service 3-8
1.10-2 Revised Conditions of Approval .
4-1 Revised EIR Comment Letters 4-1
Rosemead Commercial Retail Center Table of Contents
Revised Final EIR (SCH No. 2003121095) Page iii
1 1.0 INTRODUCTION
11
11
1.0 INTRODUCTION
1.1 OVERVIEW
This Revised Final EIR, combined with the May 2004 Draft Environmental Impact Report (EIR),
the August 2004 Final EIR (FEIR), and the September 2005 Alternative Site Analysis EIR
Revision (Alternative Site Analysis or EIR Revision) comprise the environmental analysis and
California Environmental Quality Act (CEQA) documentation for the Rosemead Commercial
Retail Center Project (the Project).
This Revised Final EIR presents modifications to the Draft EIR realized pursuant to the EIR
Revision, and specifically responds to comments received on the EIR Revision. All other
concerns and comments regarding the Project and related EIR analysis have been adequately
and appropriately addressed within either the May 2004 Draft EIR and/or August 2004 Final
EIR. A synopsis of the Project and EIR review/approval processes to date is presented below,
including the basis and purpose of the EIR Revision.
1.2 BACKGROUND
In September 2004, the City of Rosemead approved the "Project Design Alternative" for the
Rosemead Commercial Retail Center Project and certified the accompanying EIR, allowing for
the construction of retail and restaurant uses on a vacant, 22.35-acre site located north of State
Route 60 at the intersection of Walnut Grove Avenue and Rush Street in Rosemead. The Project
proposes development of approximately 235,815 square feet of new retail commercial uses,
including a 230,367 square foot Wal-Mart Supercenter with general merchandise and grocery
sales and two restaurant or retail uses totaling 5,448 square feet. Additional detail, including
an illustration of the conceptual site plan for the Project Design Alternative, is included in the
following Section 2.0, "Project Design Alternative Description."
Rosemead Commercial Retail Center Introduction
Revised Final EIR (SCN No. 2003121095) Page 1-1
I I Applied Planning, Inc. (Copyright © 2005)
Soon after the City's approval of the Project, a legal challenge to the EIR was heard in Los
Angeles County Superior Court. The Court's judgment, issued in August 2005, requires the
City to void its certification of the EIR, and certify a new EIR that "adequately addresses
alternative sites for the project" before allowing construction to ensue. It is important to note
that the Court only required that a revised EIR be certified and did not invalidate any of the
associated approvals.'
It is further noted that consistent with the intent and requirements of CEQA EIR alternatives
analyses, the purpose of considering Alternative Sites is to identify potential locations which
could foremost, substantially reduce the Project's significant environmental impacts. Within
this context, a potential alternative site must also be feasible in terms of its size and
configuration, and if not already under control of the Project Proponent, should be reasonably
obtainable.
1.3 PUBLIC REVIEW/PUBLIC COMMENT
CEQA Guidelines (Guidelines) section 15088.5 addresses recirculation of a Draft EIR. This
section of the Guidelines provides that when an EIR is revised and recirculation is required, the
lead agency may recirculate only the revised chapters or portions of the EIR and in such case,
the lead agency may request that comments be limited to only the recirculated portions.
Because the revisions to the Draft EIR are limited to additional analysis of possible alternative
sites, the previously circulated EIR was not recirculated along with the Alternative Site Analysis.
In this regard, CEQA Guidelines §15088.5(b) provides: "[i]f the revision is limited to a few
chapters or portions of the EIR, the lead agency need only recirculate the chapters or portions
that have been modified." As directed by the Court, the City has revised the Alternative Site
Analysis, and the revised Alternative Site Analysis has been recirculated for public review and
comment. Section 3.0 of this Revised Final EIR includes the recirculated section.
IAlthough the Coun also found that the EIR did not adequately analyze potential impacts from a 24-hour operation, this issue is no
longer relevant as Wal-Mart has provided notice to the City that it has withdrawn its request for a 24-hour operation and a restrictive
covenant will be recorded guaranteeing that no 24-hour operation of the Wal-Mart Supercenter will be allowed without further
cm inmmental re% ie« Re%i;ed Conditions of Appro al 1111111 [his document reflect this operational restriction
Rosemead Commercial Retail Center Introduction
Revised Final EIR (SCH No. 2003121095) Page 1-2
Applied Planning, Inc. (Copyright C 2005,)
Copies of the Alternative Site Analysis EIR Revision, as well as the Draft EIR and August 2004
Final EIR for the Rosemead Commercial Retail Center Project are available for review at the
City of Rosemead Planning Department, located at 8838 East Valley Boulevard in Rosemead.
1.3.1 EIR Revision Commentors
The following agencies, organizations, and individuals have provided written comments on the
EIR Revision. Comment letters, and responses to those comments are presented in Section 4.0
of this Revised Final EIR.
State Agencies
Governor's Office of Planning and Research, State Clearinghouse
California Department of Transportation (Caltrans), District 7
State Officials
Representative Judy Chu, 49`s Assembly District
Senator Gloria Romero, Senate Majority Leader, 24"' District
Regional/County Agencies
Southern California Association of Governments
Local Public Agencies/Organizations
City of Montebello
City of Monterey Park
Garvey School District
Private Organizations and Individuals
Save Our Community
Peggy and Richard Baumann
L. C. Bevington
Bruce Capucetti
Rosemead Commercial Retail Center
Introduction
Revised Final EIR (SCH No. 2003121095) Page 1-3
Applied Planning, Inc. (Copyright (C 2005)
Private Organizations and Individuals (contd.)
James I. Flournoy
Yuki Fukumoto
Ron Gay
Estelle Holtz
John Kawakami
Todd Kunioka
Germori Lavarin-Garcia
Brian Lewin
Le Don Lewin
Polly Low
Lydia Martinez
Al and Jewel Mehlman
Celia Nishimura
David Perea
Victor Ruiz
Paul Saito
Marlene Shinen
Edward Stepanian
David A. Stewart
Paul Thomson
Jeffery K. Yann, P.E.
Susan Young
Julie L. Wang
Rosemead Commercial Retail Center Introduction
Revised Final EIR (SCH No. 2003121095) Page 1-4
Applied Planning, Inc. (Copyright 2 2005)
1.4 DOCUMENT ORGANIZATION
This Revised Final EIR is presented in four (4) sections, as follows:
• Section 1.0, "Introduction," provides an overview of the document.
• Section 2.0, "Project Design Alternative Description," summarizes the approved
Project Design Alternative and its associated significant impacts.
• Section 3.0, "Revisions to Draft EIR," includes modifications to the Draft EIR
realized pursuant to the EIR Revision document. Also included within Section 3.0
are revised Conditions of Approval which reflect administrative corrections and
restrictive changes to the Project or its operations. Modifications to the EIR Revision
realized pursuant to comments on that document are also presented.
• Section 4.0, "Comments and Responses," presents comments received on the EIR
Revision as well as responses to those comments. Within Section 4.0, comment
letters have been organized by State agencies, State Officials, regional/county
agencies, local public agencies and organizations, and those comments received from
private organizations and individuals. Each letter has been assigned an identifying
designation (generally an acronym or name abbreviation), and topical items within
each letter have been numbered. Corresponding responses follow each commentor
letter.
Rosemead Commercial Retail Center Introduction
Revised Final EIR (SCH No. 2003121095) Page 1-5
2.0 PROJECT DESIGN ALTERNATIVE
DESCRIPTION
2.0 PROJECT DESIGN ALTERNATIVE
DESCRIPTION
The Project approved by the City of Rosemead in September 2004 was addressed as the
"Project Design Alternative" in the previously circulated Draft EIR. In summary, the approved
Project Design Alternative involves the site preparation and construction of a 230,367 square
foot Wal-Mart Supercenter, with associated parking and street improvements, and two
restaurant or retail uses totaling 5,448 square feet. By contrast, the project initially analyzed
in the Draft EIR contemplated development of a 230,367 square foot Wal-Mart Supercenter,
with associated parking and street improvements, an associated gas station with 900 square foot
office kiosk, two (2) retail buildings totaling approximately 19,000 square feet and one (1) fast
food restaurant use totaling approximately 3,000 square feet. The Project Design Alternative
represented a reduction in the project size by approximately 17,000 square feet of
retail/restaurant uses and elimination of the gas station. As stated in the Draft EIR,
development of the Project Design Alternative is anticipated to result in a reduction of
environmental impacts in comparison to the initially considered project. The following
paragraphs summarize the Project Design Alternative in greater detail for the reader's
convenience. A full description of the Project Design Alternative can be found in Section 7.0 of
the Draft EIR. Unless otherwise differentiated within this Revised Final EIR, the terms "Project"
and "Project Design Alternative" are understood to be equivalent.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Pmject Design Alternairve Descaiptian
Page 2-1
Applied Planning, Inc. (Copyright © 2005)
2.1 PROJECT DESIGN ALTERNATIVE CHARACTERISTICS
As shown in the following site plan concept, Figure 2.1-1, the Rosemead Wal-Mart Supercenter
would be constructed in the westerly portion of the Project site, with a primary entrance from
Walnut Grove Avenue and a secondary access from Rush Street. Delivery trucks would be
prohibited from using the secondary, Rush Street, access, and would enter the site from Walnut
Grove Avenue only. Two smaller restaurant or retail uses are planned to be located within the
eastern portion of the site, south of the primary Walnut Grove Avenue project entrance. One
of these uses is en-zsioned as a 2,448 square foot fast food use with drive-through service; while
the other is identified as a 3,000 square foot restaurant/retail facility. Table 2.1-1 identifies the
land uses proposed as part of the project, expressed in terms of Gross Leasable Area (GLA).
Table 2.1-1
Rosemead Commercial Retail Center
Proposed Land Uses-Square Feet of Gross Leasable Area (GLA)
Parcel
Land Use
Parcel Area
Building Area
Comments
No.
General merchandise/grocery sales
1
Retail
20,34 acres
230,367 s. f.
(Wal-Mart).
Retail or restaurant; may be
2
Retail/Restaurant
1.21 acres
3,000 s.f.
developed as two (2) facilities with
multiple tenants
Retail/restaurant uses; restaurant
3
Retail/Restaurant
0.80 acres
2,448 s.f.
may include drive-through and
outdoor play area
N/A
Develop
Project
22.35 acres
235,815 s.f.
N/A
Site
1
4 Not a Part 1.30 acres N/A To be retained by SCE
N/A TOTALS [23.65 acres 235,815 s.f. N/A
Source: Rosemead Commercial Retail Center "Project Design Altemative" Site Plan Concept (Development Resources
Consultants, Inc.) Apri12004.
Rosemead Convnercitdl Retail Centel"
Revised Final EIR (SCH No. 2003121095)
Prrject Design Alterni tke Description
Page 2-2
N ~ ~
NO, ,O fUIF
Source: Development Resource Consultants. Inc.. April 2004
2004 Applied Planning, Inc.)
Figure 2.1-1
Project Design Alternative Site Plan Concept
Applied Planning, Inc. (Copyright ~Q,, 2005)
2.2 PROJECT DESIGN ALTERNATIVE OPERATIONS
The proposed uses and activities of the Wal-Mart Supercenter store would include the sale of
general merchandise, liquor, groceries and food, pharmacy and vision care, a food service
center, a photo studio, a photo finishing center, a banking center, outdoor sales including but
not limited to pumpkin patch, Christmas tree lots, seasonal outdoor sales events, garden sales,
truck docks and loading, rooftop and proprietary satellite communication, and parking. The
store may, among other things, carry pool chemicals, petroleum products, pesticides, and paint
products.
It should be noted that, following the previous public hearings on the Project, the proponents
have agreed to limit the Wal-Mart Supercenter's hours of operation by recording a restrictive
covenant that limits the hours of operation unless and until additional environmental review is
conducted. Please refer also to Revised Planning Department Condition of Approval (COA)
presented in Section 3.0 of this Revised Final EIR. As stated under revised COA No. 54, which
now reflects the "no 24-hour operations" restrictive covenant:
The hours of operation of the major tenant shall be limited to 8:00 a.m. to 10:00
p.m., except during Christmas season, in which case the hours of operation may
be extended to midnight.
2.3 PROJECT OBJECTIVES
The objectives of the project are as follows:
1) Create anew mix of retail/commercial uses responsive to City and regional markets.
2) Provide retail/commercial uses to service the needs of residents.
3) Increase economic benefits to the City through job creation.
4) Augment the City's economic base by providing a variety of tax generating uses
Rosemead Commercial Retail Center Project Design Alternative Des~
Revised Final EIR (SCH No. 2003121095) Page 2-4
Applied Planning, Inc. (Copyright :c- 2005)
5) Provide retail/commercial development compatible with vicinity land uses.
6) Ensure development of the project site in a manner consistent with policies,
objectives, and requirements of the City's General Plan, Redevelopment Plan and
Zoning Ordinance (Title 17 of the Municipal Code).
2.4 DISCRETIONARY APPROVALS
Approval of the following discretionary actions have already been made in the City's approval
of the Project Design Alternative:
1) Certification of the Environmental Impact Report;
2) Approval of a General Plan Amendment to revise General Plan land use designations
for the site from "Office/Light Industrial" to "Commercial;"
3) Approval of a development agreement between the City of Rosemead and Wal-Mart
Real Estate Business Trust (note: this approval was later rescinded by the City
Council);
4) Approval by the Planning Commission of Conditional Use Permits allowing the sale
of alcoholic beverages and the creation of parcels less than 45,000 square feet that
could be developed with multiple uses, and therefore could be considered to allow
for establishment of a "mini mall" as defined within Chapter 17.04 of the Zoning
Ordinance;
5) Approval of a tentative parcel map;
6) Approval of construction within the slope easement located along Rush Street;
7) City Council determination of public convenience and necessity for liquor sales;
Rosemead Conmercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Project Des g AlternaliUe Description
Page 2-5
Applied Planning, Inc. (Copyright C 2005)
8) Approval by the Planning Director of outdoor storage (e.g., bale and pallet storage)
as defined by Section 17.44.070 of the City Zoning Ordinance; and
9) Community Development Commission approval of the architectural, landscape, and
site plans to ensure the project creates an attractive and pleasant environment and
consists of good design, open space, and other amenities to enhance the aesthetic
quality of the project area.
As noted previously, following recirculation of this document, if it finds it appropriate, the City
is to re-certify the Rosemead Commercial Retail Center EIR before permitting construction of
the Project.
2.5 SIGNIFICANT IMPACTS ASSOCIATED WITH THE PROJECT DESIGN
ALTERNATIVE
The following were identified as unavoidable significant impacts associated with the Project
Design Alternative:
• Increased vehicle densities on the Pomona (SR-60) freeway;
• Short-term, construction-related air quality impacts;
• Long-term, operational air quality impacts;
• Short-term, construction-related noise impacts; and
• Cumulative impacts relating to traffic on the Pomona freeway, air quality, and
construction-related noise.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Project Design Alternative D tion
Page 2-6
3.0 REVISIONS
11
11
1 3.0 REVISIONS
3.1 INTRODUCTION
This Section presents modifications to the Draft EIR realized pursuant to the EIR Revision
document. Also included in this Section are revised Conditions of Approval which reflect
administrative corrections and restrictive changes to the Project or its operations.
Modifications to the EIR Revision realized pursuant to comments on that document are
also presented. Additional text incorporated in the Draft EIR is identified by bold,
italicized text, and deletions are indicated by strikeou font. Subsequent modifications to
the EIR Revision which respond to comments on that document are indicated by double
underlined text and strikeout font.
3.2 REVISIONS
3.2.1 Additions to Draft EIR Section 1.0, Introduction
1.9.6 Alternatives Considered but Rejected
Three alternative Project sites in the City were considered for construction and
operation of the Project, but rejected as either infeasible, not capable of attaining
basic project objectives, and/or not able to reduce or avoid the significant impacts
of the Project. Additional detail on alternative sites is provided in the following
Section 7.3.1.
Rosemead Commercial Retail Center Revisions to Draft EIR
Revised Final EIR (SCH No. 20031211095) Page 3-1
Applied Planning, Inc. (Copyright © 2005)
1.9.7 Locations Outside of the City
One of the requirements for the consideration of an alternative is that it must meet
most of the basic objectives of the project. (CEQA Guidelines §15126.60.)
Relocation of the Project Design Alternative outside the City would thwart one of
the primary objectives of the Project which is to augment the City's economic base.
Additionally, even if located outside of the City, the project may not contribute to
any localized air quality impacts, but would still contribute to air pollutant loads
within the affected air basin and would still cause significant impacts on the
region's freeways because of Caltrans' threshold level of one additional vehicle
creating a significant impact. For these reasons locations outside of the City were
rejected as alternatives.
3.2.2 Revisions to Draft EIR Section 7.0, Alternatives Analysis
7.3.1 Consideration of Alternative Sites
As stated in the CEQA Guidelines §15126.6(f)(1)(2)(A), the "key question and first
step in [the] analysis [of alternative locations] is whether any of the significant
effects of the project would be avoided or substantially lessened by putting the
project in another location. Only locations that would avoid or substantially lessen
any of the significant effects of the project need by considered for inclusion in the
EIR." Subsection (B) goes on to provide that "fi]f the lead agency concludes that no
feasible alternative locations exist, it must disclose the reasons for this conclusion,
and should include the reasons in the EIR." A feasible alternative is one which can
be "accomplished in a successful manner within a reasonable period of time, taking
into account economic, environmental, social, and technological factors." (Pub.
Resources Code, § 21061.1.) Feasibility also includes factors such as site suitability,
jurisdictional boundaries and whether the proponent can reasonably acquire,
control or otherwise have access to the alternative site. (CEQA Guidelines §
15126,60(1).)
--p- 1,~~!Ioeated otrht --e of tile City the pte~%!A-L ITTZT
Rosemead Commercial Retail Center Revisions to Draft EIR
Revised Final EIR (SCH No. 2003121095) Page 3-2
Applied Planning, Inc. (Copyright D 2005)
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7.3.1.1 Project Requirements
A Wal-Mart Supercen ter is a discount retail store that can be compared to a typical
neighborhood or community level shopping center within a single building. The
product line and the development size are similar to a traditional neighborhood
center with a supermarket, drug store, and discount retail shopping. The proposed
Wal-Martstore consists of 230,367square feet including thegarden center area, and
requires a minimum of 922 parking spaces to meet the City's standards.
Based on civil engineering estimates, and a survey of similar Wal-Mart stores
throughout California, a Wal-Mart Supercenter would typically require a minimum
of 18 acres of land. Additionally, the site would need to be flat and have a square
or rectangular configuration with a minimum dimension of 600 feet.
7.3.1.2 Potential Alternative Sites
The City of Rosemead is essentially a built out, urban community. There is a
minimum of vacant orunderutilized land available to accommodate a development
the size of the proposed Project. Based on current knowledge of available land
within the City of Rosemead, City Planning and Redevelopment staff have
identified the following locations as the only possible alternative development sites
within the City.
11
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Revisions to Draft EIR
Page 3-3
11
Applied Planning, Inc. (Copyright @ 2005)
• Alternative Site 1: L.A. Dealer Auto Auction property on Garvey Boulevard,
• Alternative Site 2: The area on the northeast corner of Valley Boulevard and
Temple City Boulevard; and
• Alternative Site 3: The existing Robinson's-May site at the Montebello Town
Center Mall.
One additional site was considered and rejected as a possible alternative. At the
time the Draft EIR was being prepared, the Ralph's Grocery Store on Valley
Boulevard had recently been vacated, and this site was suggested as an alternative
during public hearings on the Project. The grocery store use accounts for
approximately three (3.0) acres and is sited among other viable commercial and
service uses along the Valley Boulevard commercial district. The store is no longer
available, and is currently operating as the "Rosemead Supermarket" under a long-
term lease. Based on the re-opening of the supermarket, and the vitality of other
existing uses, this site has not been considered further within this analysis. Even
without the reuse of this site, it was not a feasible alternative due to its limited size
and inability or impracticability for site expansion due to the existence of
surrounding residential and school uses to the north, west, and east.
The following paragraphs describe each of the three identified alternative sites in
greater detail.
Alternative Site 1
a. Sitc Description
The L.A. Dealer Auto Auction site, located at 8001 Garvey Boulevard between Del
Mar Avenue and San Gabriel Boulevard, is approximately 15.25 acres in size. This
alternative site is bounded to the south by Garvey Avenue, to the west by Denton
Avenue, to the north by existing single family residences and to the east by an
existing mobile home park.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Revisions to Draft EIR
Page 34
Applied Planning, Inc. (Copyright @ 2000
b. Potential Feasibility Site
As seen in the following Figure 7.3-1, the purchase of several parcels adjacent to, but
excluded from the ownership of the L.A. Dealer Auto Auction, would be required to
create a rectangular site of adequate size. These additional properties would
include a commercial use at 7951 Garvey Avenue, and numerous residential
properties, some of which include more than one residential unit, located to the
north and south of Virginia Avenue. If these parcels were included, a site of roughly
19 acres could be assembled. Denton Avenue, an existing public street which
provides access to the residences on Virginia Avenue, currently bisects the westerly
portion of the site. The relocation of this street to the west, where it will align with
Strathmore Avenue, has already been planned and approved by the City.
The L.A. Dealer Auto Auction is a thriving commercial operation, well known
throughout Southern California. None of the identified properties within this
alternative site location are currently listed forsale, nor is itreasonably foreseeable
that any of these properties will become available for sale in the near future.
Wal-Mart, as a private developer, has a limited ability to assure that a developable
site can be assembled through the successful purchase of specific identified parcels
of private property. Land owners not willing to sell their property or requesting
exorbitant prices can influence the overall site configuration, particularly once the
landowner realizes the importance of his/her parcel in the site development process.
Negotiations with multiple property owners in such a manner have been known to
take years to complete and the costs have exceeded market cost when finally
completed. Based on these factors, this site has been determined to be infeasible.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Revisions to Draft EIR
Page 3-5
N
0
HOT 10 SCAT E
Source City of Rosemead. August 2005
Figure 7.3-1
Alternative Site 1
L.A. Dealer Auto Auction Property Boundary Potential Site Boundary
Applied Planning, Inc. (Copyright G 2005)
c. Comparison of Environmental Impacts
Even if the purchase of the properties was feasible and the adjacent Virginia Avenue
residents were relocated, the site is located adjacent to extensive tracts of existing
single-family residential uses to the north, and two mobile home parks to the east.
Two community parks (Garvey Park and Zapopan Park) are located approximately
one-quarter mile from the site to the north and east, respectively. Additionally,
Duff Elementary School is located adjacent to Garvey Park, less than one-half mile
from the site. The proximity of the homes adjacent to Virginia Avenue and the
mobile home park to this potential alternative site is similar to the proximity of the
homes on Delta Street to the proposed project site. Accordingly, impacts from
construction noise would not be significantly reduced when compared to the
impacts anticipated to be caused by the Project, or even the Project Design
Alternative. Moreover, even if the Project was developed at this alternative site, air
quality impacts would not be significantly reduced. Construction activities would
be similar at either site, thereby resulting in similar short-term construction air
quality impacts. Locating the Project at this alternative site would still result in
similar numbers of daily traffic trips resulting in similar mobile air emissions. In
fact, due to the need for demolition of existing structures onsite, airquality impacts
would be greater if the Project were placed in this location.
Freeway access to this site would be provided via Interstate 10 (I-10), which is
located less than one mile to the north. The distance between the freeway and this
alternative site is similar to the distance between the proposed project site and the
SR-60 freeway. Accordingly, Project trips would utilize the I-10 facilities to access
the site. A detailed analysis of the I-10 and the interchanges at San Gabriel Avenue
and Del MarAvenue has not been conducted; however, a review of the2004Congestion
Management Plan for Los Angeles County (MTA, April 2004) reveals that the 1-10 has
heavier evening peak hour traffic than the SR-60 on the segments located between the 605
and 710 Freeways, as illustrated in the following Table 73-1.
Rosemead Commercial Retail Center Revisions to Draft EIR
Revised Final EIR (SCH No. 2 003 12 1 095) Page 3-7
Applied Planning, Inc. (Copyright © 2005)
Table 7.3-1
CMP Highway System Peak Hour Levels of Service
Segment
AM Peak Hour
PM Peak Hour
Westbound SR-60
F
D or Better
Eastbound SR-60
D or Better
F
Westbound 1-10
F
E
Eastbound 1-10
D or Better
F
Source: 2004 Congestion Management Program for Los Angeles County, Exhibits 2-5 and 2-6, April 2004.
As seen in Table 7.3-1, the P.M. peak hour level of service on the westbound I-10 is
LOS "E," compared to LOS "D" or Better on the westbound SR-60. In a general
sense, this indicates that traffic conditions are worse on the I-10 than on the SR-60
in the primary evening commute period (4:00 p.m. to 6:00 p.m.). As indicated in
Section 4.3 of the Draft EIR, due to the significance criteria utilized by the
California Department of Transportation in determining impacts to State Freeway
facilities, a project will cause a significant impact by adding any vehicular trips to
freeways that are already operating at degraded levels of service. Just as the
Project is anticipated to result in a significant impact to SR-60, development of the
Project at this site would result in a similar, if not worse, impact to the I-10. On
this basis, it appears unlikely that use of this alternative site would result in
reduced impacts to freeway facilities.
Because of the infeasibility of this alternative site, and because this location would
not avoid or substantially lessen any of the significant effects of the Project or the
Project Design Alternative, this site was rejected as a potential alternative site for
EIR purposes.
Rosemead Commercial Retail Center Revisions to Draft EIR
Revised Final EIR (SCH No. 2003121095) Page 3-8
Applied Planning, Inc. (Copyright © 2005)
Alternative Site 2
a. Site Description
A vacant area designated for redevelopment exists on the northeast corner of Valley
Boulevard and Temple City Boulevard in the extreme northeasterly corner of the
City. The site is approximately four acres in size, and is considered "blighted,"
pursuant to the City's redevelopment plan. As shown in the following Figure 7.3-2,
the property is located between light industrial uses fronting on Temple City
Boulevard to the west, single-family residential uses to the north, the channelized
Eaton Wash to the east, and additional light industrial/commercial uses and a
mobile home park to the south, across Valley Boulevard. High-density, single-
family residential uses are located east of the channel in the City of El Monte.
b. Potential Feasibility of Site
Because the existing vacant site is only approximately 4 acres in size, additional
property would have to be assembled to accommodate development of the Project.
Project development would require obtaining possession of five (5) parcels located
along the south side of Abilene Street and one (1) along Temple City Boulevard
which are currently improved with residences. Development of the project would
also require obtaining property along Temple City Boulevard currently used for
office, commercial and light industrial uses. None of these parcels are located
within a redevelopment project area. Accordingly, extensive relocation of
businesses and homes would need to be negotiated before additional, adjacent
parcels could be assembled to provide a roughly rectangular project site.
With the inclusion of the parcels identified in Figure 7.3-2, the site would total
approximately 7.5 acres. If the adjacent wash were covered to provide parking, a
total of approximately 8.75 acres would result, which is considerably less than the
18 acres required.
This alternative site is therefore considered infeasible due to its limited size, as well
as the time consuming process that would be required in relocation and the
problems in assembling parcels under multiple ownership.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Revisions to Draft EIR
Page 3-9
11
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Source: City of Rosemead, August 2005
AL,
rE
Figure 7.3-2
Alternative Site 2
Applied Planning, Inc. (Copyright © 2005)
c. Comparison of Environmental Impacts
Even if development of this alternative was feasible, none of the significant
environmental impacts would be avoided or substantially reduced by developing
the Project at this location. Given the proximity of residential uses to the north,
south and east, the potential fornoise impacts to nearby sensitive receptors would
not be significantly reduced when compared to the impacts associated with the
Projector Project Design Alternative. The proximity of the residences located along
Abilene Street to this alternative site resemble the proximity of the residences
located along Delta Street to the Project site. Accordingly, construction noise
impacts would not be avoided or substantially reduced in comparison to
construction noise impacts anticipated to be caused by the Project or the Project
Design Alternative.
Additionally, this site is located approximately three-quarters of a mile north of
the I-10 freeway. As noted in the preceding analysis of Alternative Site 1, traffic
conditions on the I-10 appear to be worse than those on the SR-60. For this reason,
it appears unlikely that use of this alternative site would reduce impacts to freeway
facilities when compared to the Project or the Project Design Alternative; it would
only relocate these impacts. Finally, development of the Project at this location
would not avoid or substantially reduce air quality impacts anticipated to be
caused by development of the Project or the Project Design Alternative. If this
alternative site could provide enough area to develop the Project, the construction
air quality impacts would be similar due to necessary grading and site preparation
activities. Demolition of the existing structures to the west and north of the site
would add additional air emissions not realized with development of the current
site. As stated previously, the Project is anticipated to generate a similar number
of daily traffic trips regardless of its location. Accordingly, mobile air emissions
will not be avoided or substantially reduced by developing the Project at this
alternative site.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Revisions to Draft EIR
Page 3-11
Applied Planning, Inc. (Copyright (D 2005)
Because of the infeasibility of Alternative Site 2, and because this location would
not avoid or substantially lessen any of the significant effects of the Project or the
Project Design Alternative, the use of this site was rejected as a potential
alternative site for EIR purposes.
Alternative Site 3
a. Site Description
Alternative Site 3, located on the eastern edge of the Montebello Town Center Mall,
was identified as a possible alternative due to the recently announced corporate
merger between the May Department Stores Company and Federated Department
Stores, Inc. The closure of the Robinson's-May store is anticipated by the City,
although this store was not identified in the latest list of locations planned for
divestiture, issued by Federated Department Stores on July 28, 2005. The Federated
announcement notes that "a small number of stores are being studied for potential
conversion to the Bloomingdale's nameplate," which would result in these stores
remaining in operation rather than being vacated. There is no indication, however,
that the Montebello Town Center location would be included in this plan.
b. Potential Feasibility o Site
The existingRobinson's-May store is approximately 140,100 square feet in size, and
is located on an 8.75 acre parcel that provides shared mall parking, as shown in the
following Figure 7.3-3. In order to accommodate the proposed Wal-Mart
Supercenter, substantial re-design of the Project would be required, resulting in the
construction of a multiple-story facility with additional, at-grade parking provided
under the store.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Revisions to Draft EIR
Page 3-12
i . *Alwl-al
Figure 7.3-3
Alternative Site 3
Applied Planning, Inc. (Copyright © 2005)
Beyond the obstacles of site availability and project design, compatibility between
the proposed Wal-Mart and the existing mall is an additional concern. The
Montebello Town Center is an upscale, regional mall. As such, retailers within this
mall seek to draw consumers from a different market sector than that of the
discount retailer and grocery seller, and the introduction of a discount
retaillgrocery use within the existing mall could be incompatible and have a
detrimental economic effect on adjacent retailers. Accordingly, this alternative site
was determined to be infeasible.
c. Comparison of Environmental Impacts
The primary advantage of this alternative site is that it is located away from
existing residential and school uses. While noise and air quality emissions during
construction and operation of the Project would not be as likely to affect nearby
sensitive receptors, they would remain significant impacts. Because air emissions
thresholds are set for the region's air basin as a whole, the exceedances anticipated
to result from development of either the Project or Project Design Alternative
would remain significant unless the Project was moved outside the 'air basin.
Similarly, construction-related noise would likely still exceed the City's maximum
CNEL thresholds, which allow no more than 65 dBA exterior exposure for all land
use types, including commercial as well as residential, institutional, and open space
uses.
Traffic impacts would also be similar to those of the Project. Since regional access
to the mall is provided directly by San Gabriel Boulevard from the SR-60 freeway,
significant impacts to freeway facilities would remain unchanged.
Because Alternative Site 3 has not yet been identified as available, and because the
size and configuration of this location would not accommodate a Supercenter and
would thereby fail to meet one of the primary objectives of providing additional
retail uses, such as a supermarket, for residents, and because the use of this
alternative site would not eliminate any of the permanent significant impacts of
Rosemead Commercial Retail Center
Revised Filial EIR (SCH No. 2003121095)
Revisions to Draft EIR
Page 3-14
Applied Planning, Inc. (Copyright © 2005)
the Project or Project Design Alternative, the use of this site was rejected as a
potential alternative site for EIR purposes.
7.3.1.3 Alternative Sites Summary
If located atan alternative site, the significant impacts associated with the Project,
as well as the Project Design Alternative, would not be realized at the specific
location identified in the previous EIR. However, these impacts would not be
substantially reduced, only relocated. Pursuant to CEQA Guidelines §15126.6
(f)(1)(2)(A), "Only locations that would avoid or substantially lessen any of the
significant effects of the project need be considered for inclusion in the EIR."
Because significant effects would not be avoided or substantially lessened by
putting the Project in another location, the use of an alternative site is not justified.
3.2.3 Modifications to the EIR Revision
Comments on the EIR Revision provided by the City of Montebello have effectively
removed the Robinsons-May/Montebello Town Center site from consideration as a
potential location for the Project. Based on the City of Montebello's comments, Pages 3-11
and 3-12 of the Revised Alternative Site Analysis are amended to read as presented below.
Text changes to the EIR Revision document, presented below, are indicated by double
underlining and strikeout font.
a. Site Description
Alternative Site 3, located on the eastern edge of the Montebello Town
Center mall, was identified as a possible alternative due to the recently
announced corporate merger between the may Department Stores Company
and Federated Department Stores, Inc. The closure of the Robinsons-May
store is anticipated by the City, although this store was not identified in the
latest list of locations planned for divestiture, issued by Federated
Department Stores on July 28, 2005. In response to the Revised Alternative
Site Analysis, the City of Montebello has provided information that this site
will not be available as the store will remain open as a Macy's store providing
women's apparel. children's apparel, and household furnishings. The
Rosemead Commercial Retail Center
Revised Final EIR (SCN No. 2003121095)
Revisions to Draft EIR
Page 3-15
Applied Planning, Inc. (Copyright © 2005)
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,
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ontebe
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own
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b. Potential Feasibility of Site
The existing Robinsons-May store is approximately 140,100 square feet in size,
and is located on an 8.75 acre parcel that provides shared mall parking, as
shown in the following Figure 7.3-3. In order to accommodate the proposed
Wal-Mart Supercenter, substantial re-design of the Project would be required,
resulting in the construction of a multiple-story facility with additional, at-grade
parking provided under the store.
Based on the information from the City of Montebello, as well as problems
relating to project design, the site is considered unavailable and the alternative
rejected as infeasible.
Beyond the obstacles of site availability and project design, compatibility
between the proposed Wal-Mart and the existing mall is an additional concern.
The Montebello Town Center is an upscale, regional mall. As such, retailers
within this mall seek to draw consumers from a different market sector than that
of the discount retailer and grocery seller, and the introduction of a discount
retail/grocery use within the existing mall could be incompatible and have a
detrimental economic effect on adjacent retailers. Accordingly, this alternative
site was determined to be infeasible.
3.2.4 Revised Conditions of Approval
The following table includes the final Project Conditions of Approval; changes shown are
from those final conditions which were approved and incorporated into the August 2004
Final EIR as Exhibit A to the certifying resolution. The only substantive change from the
previously approved conditions is the deletion of language in Condition No. 54 allowing
the Wal-Mart to operate as a 24-hour Supercenter. In order to satisfy the Court's order
regarding this issue, Wal-Mart has rescinded its request to operate on a 24-hour basis, and
Rosemead Commercial Retail Center Revisions to Draft EIR
Revised Final EIR (SCH No. 2003121095) Page 3-16
Applied Planning, Inc. (Copyright © 2005)
has agreed to allow a covenant to be recorded against the property prohibiting a 24-hour
operation absent additional environmental review of the potential impacts of such an
operation. This condition has been amended to be consistent with the restrictive covenant.
The other changes made from those previously-approved conditions are technical changes
to delete references to the Development Agreement, which has been rescinded.
Appropriate language is reflected under these revised conditions as required. As the only
substantive change is more restrictive than the previously- approved conditions, and the
other changes are technical in nature, the analysis and conclusions of the EIR and all its
component parts are not affected.
Table 1.10-2
Revised Conditions of Approval
PLANNING DEPARTMENT CONDITIONS
Condition No. 1
The Site shall be developed and parcelized in accordance with the Tentative Par
Map for the Project Design Alternative marked Exhibit "D" dated August 05, 200.='
the Development Plans (Site Plan, Floor Plans, Elevations, and Landscape Plans)
marked Exhibit "E" and submitted colored elevations and color and material sample
boards, marked Exhibit "F". Any revisions to the approved plans must be
resubmitted for review and approval by the Planning Department.
Condition No. 2
Approval of , Tentative Parcel Map 26827 and
Conditional Use Permits 02-882 and 03-939 shall not take effect for any purpose until
the Developer has filed with the City of Rosemead an affidavit stating that they are
aware of and accept all of the conditions set forth in this list of conditions.
Condition No. 3
The rights granted by Tentative Parcel Map 26827 and Conditional Use Permits
02-882 for the Mini-mall and 03-939 for the sale of alcohol shall be exercised within
two years. The applicant shall make progress towards initiation of the proposed
uses or request an extension 30 days prior to expiration from the Planning
Commission, otherwise these approvals shall become null and void. the time -set
Condition No. 4
The Developer shall comply with all Federal, State and local laws relative to the
approved use including all requirements of the Planning, Building, Engineering,
Fire, Sheriff and Health Departments and obtaining all operating permits from State
and local agencies prior to issuance of a Certificate of Occupancy.
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Revised Final EIR (SCH No. 2003121090
Revisions to Draft EIR
Page 3-17
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Table 1.10-2
Revised Conditions of Approval
Condition No.5
A final Certificate of Occupancy will notbe granted until all improvements required
by this approval have been completed, inspected, and approved by the appropriate
department(s); except for off-site improvements for which bonds are acceptable as
approved by the Planning Department. However, a temporary certificate of
occupancy may be issued so interior work can be completed. Nothing herein
requires all improvements to be built at the same time, nor does it prohibit the
phasing of the major tenant anchor store, provided that the landscaping and parking
lot improvements are installed with the first phase.
Condition No. 6
The Developer shall develop and implement a Site and Facilities Security Plan which
is to be approved by the Sheriff's Department, in its reasonable discretion, prior to
the issuance of building permits for Parcel 1. At a minimum the plan shall include
private security guards, or other as approved by the Sheriff's Department, parking
lot patrols, videotaping of the parking lot with signs informing the public of such,
and security cameras inside the major anchor store.
Condition No. 7
The Developer shall obtain a Certificate of Occupancy permit and any applicable
City of Rosemead business licenses prior to beginning business operations. The
Planning Director may issue a temporary Certificate of Occupancy to allow the store
to be setup and stocked prior to opening if all safety conditions have been satisfied.
A final Certificate of Occupancy shall be required prior to the store being opened to
the public.
Condition No. 8
Building permits will not be issued in connection with any project until such time
as all plan check fees, and all other applicable fees are paid in full for improvements
on each parcel.
Condition No. 9
The Developer shall be required to complete all of the parking and landscaping on
Parcel 1 with the first phase of construction.
Condition No. 10
Prior to issuance of building permits for improvements on each parcel, all school
fees shall be paid. The Developer shall provide the City with written verification of
compliance from the Garvey School District.
Condition No. 11
The hours of construction shall be limited from 7 a.m. to 8 p.m. Monday - Saturday.
No construction shall take place on Sundays or on any legal holidays without prior
approval by the City.
Condition No. 12
Developer and its successors shall be required to meet with staff for a
pre-construction meeting prior to the beginning of any site work.
Condition No. 13
City staff shall have access to the subject property during construction hours to
monitor progress.
Condition No. 14
These conditions of approval listed on this Exhibit A hall be copied directly onto
development plans submitted to the Planning and Building Departments for review.
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Revised Final EIR (SCH No. 2003121095)
Revisions to Draft EIR
Page 3-18
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Table 1.10-2
Revised Conditions of Approval
Condition No. 15
Driveways and parking areas shall be surfaced and improved with asphalt cement
and thereafter maintained in good serviceable condition. Driveway entrances shall
be improved with a decorative, stamped, colored concrete surface, subject to the
review and approval of the Planning Director.
Condition No. 16
Sufficient off-street parking shall be provided on-site to meet the requirements of the
Rosemead Municipal Code, including parking for persons with disabilities (in
accordance with the most current edition of the Americans With Disabilities Act
Accessibility Guidelines).
Condition No. 17
A wall and fence plan will be required if any perimeter fencing or walls are
proposed. The colors and materials of the proposed fence shall be consistent or
compliment the submitted color and material board and first be approved by the
Planning Department prior to installation.
Condition No. 18
Prior to issuance of building permits, a detailed landscape and irrigation plan
prepared by a licensed landscaped architect shall be submitted to the Planning
Department for review and approval for the Parcel being improved; said plan shall
reflect the landscape and site plans contained in Exhibit C.
a. The plan shall include automatic timers and rain shutoff valves;
b. Landscaping irrigation systems shall be designed for high efficiency and
irrigation timers programmed for minimized water usage;
c. All landscape planters shall be surrounded by 4 - 6 inch high curbs.
d. A landscape edge treatment of approximately 32 feet shall be provided along the
westerly Delta St. project boundary.
e. Perimeter landscaping along Walnut Grove Avenue and Rush Street shall
continue the landscaping themes of those corridors.
f. Additional landscape and hardscape features shall be developed along the Rush
Street perimeter to provide additional visual interest and enhancement.
Condition No. 19
All landscaping and irrigation shall be installed and completed prior to final
Planning Department approval. Perimeter landscaping shall be installed concurrent
with the development of Parcel 1; landscaping on the interior of Parcels 2 and 3 need
not be implemented until building permits are taken out for the improvements on
each of those parcels.
Condition No. 20
All ground level mechanical/utility equipment (including meters, back flow
preservation devices, fire valves, A/C condensers, furnaces and other equipment)
shall be located away from public view or adequately screened by landscaping or
screening walls so as not to be seen from the public right-of-way. The Director of
Planning shall approve said screening prior to installation.
Condition No. 21
All loading areas, mechanical equipment and trash disposal areas shall be screened
from view with materials approved by the Planning Department.
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Revisions to Draft EIR
Page 3-19
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Table 1.10-2
Revised Conditions of Approval
Condition No. 22
All trash enclosures shall be constructed to City Standards.
Condition No. 23
There shall be no roof mounted equipment extending above the parapet wall of the
building. A line of sight analysis to ensure zero visibility of roof top equipment shall
be submitted to the Planning Division for review and approval.
Condition No. 24
There shall be no outside storage of shipping containers, other than in screened areas
indicated on the approved site plan. All trash and debris shall be contained within
a trash enclosure or compactor.
Condition No. 25
There shall be no outdoor sales activity on the site except as allowed by temporary
sales as set forth in condition 26 below; no outside vending machines shall be
allowed.
Condition No. 26
Except for the outside display and storage of Christmas trees and pumpkins which
is a permitted use under the Municipal Code, the outdoor seasonal and/or
promotional sales displays shall only be allowed when issued a temporary outdoor
sales license by the City (an over-the-counter administrative approval). All
requirements of the temporary outdoor sales ordinance shall be followed.
Condition No. 27
Electronic Shopping Cart wheel locks shall be installed on all carts that are utilized
on the site to contain all carts within the perimeter property lines of the shopping
center.
Condition No. 28
"No overnight camping" and "No Loitering" signs shall be installed throughout the
parking lot area on signs acceptable to the Planning Department.
Condition No. 29
Developer shall post signs stating "possession of open alcoholic beverages on the
premises prohibited by law", along sidewalks and parking lots. Size, location and
material of signs shall be to the satisfaction of the Planning Department.
Condition No. 30
Conditional Use Permit No. 03-939 is for the issuance of an Off Sale alcohol license
for a Type 21 (general alcohol). The appropriate license from the California
Alcoholic Beverage Control shall be maintained and all conditions of the ABC
license are hereby incorporated as conditions of this CUP approval. Violation of
either the conditions of this approval or the ABC conditions shall be grounds for
revocation of the CUP approval.
Condition No. 31
A uniform sign plan shall be submitted for review.
Condition No. 32
Any proposed signage must be reviewed and approved by the Planning Division
and must comply with City Sign Regulations.
Condition No. 33
Signs shall reflect material and design elements of the project and shall be
compatible with the streetscape elements of adjoining areas.
Condition No. 34
The numbers of the address signs shall be at least 6" tall with a minimum character
width of 1/4", contrasting in color and easily visible at driver's level from the street.
Materials, colors, location and size of such address numbers shall be approved by
the Director of Planning prior to installation.
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Revised Final EIR (SCH No. 2003121095) Page 3-20
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Table 1.10-2
Revised Conditions of Approval
Condition No. 35
All utilities shall be placed underground including facilities and wires for the supply
and distribution of electrical energy, telephone, cable television etc. The
underground conversion of these utilities shall consider all future connections to the
satisfaction of the Director of Planning.
Condition No. 36
Violation of the conditions of approval may result in citation and/or initiation of
revocation proceedings.
Condition No. 37
Minor modifications of the approved plans, except for the plans for the mini-mall
on Parcel 2, may be approved by the Planning Director. The Rosemead Planning
Commission must act on any substantial changes to the approved plans, to any
changes of these conditions of approval and to any changes of plans approved for
the mini-mall on Parcel 2.
Condition No. 38
The Developer shall pay the required "Document Handling Fee" in order to file the
Notice of Determination with the County of Los Angeles.
Condition No. 39
The Developer shall install the type of lights identified in the mitigation monitoring
program. Downlit fixtures shall be used to shield light emissions onto adjoining
properties. The overall height of the light pole and fixture shall not exceed 24 feet.
The poles shall be steel, aluminum, or other similar approved material. The style of
the poles shall compliment the fixture design. All wall pack fixtures must be cutoff
(shielded) fixtures.
Condition No. 40
A lighting plan (photometric.plan), addressing parking lot security lighting on-site,
shall be submitted in conjunction with the Final Site Plan application for review and
approval by the City Planning Department.
Condition No. 41
A 14-foot high decorative block wall shall be constructed along the northern and
western boundary and along the southern boundary to the depth of the truck well
with the development of Parcel 1.
Condition No. 42
All mitigation measures set forth in the Mitigation Monitoring Program are
incorporated as conditions of approval. Unless otherwise specified, any mitigation
measure listed in the EIR which was not included in the Mitigation Monitoring
Program shall be deemed to have been included as a mitigation measure as though
included in the Mitigation Monitoring Program and incorporated as a condition of
approval. In the case of any conflict between the mitigation measures and these
conditions, the wording that provides the most protections to the City shall apply.
Mitigation Measure 4.4.9 is specifically excluded as the CUP for the gasoline station
is not approved.
Condition No. 43
Truck deliveries shall not occur between 10 p.m. to 6 a.m. the following day and
routing shall be approved by the Planning Department.
Condition No. 44
No portion of the parking lot area, shall be used by or sublet for any other business
activity not associated with general merchandise/grocery activities.
Rosemead Commercial Retail Center Revisions to Draft EIR
Revised Final EIR (SCH No. 2003121095) Page 3-21
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Table 1.10-2
Revised Conditions of Approval
Condition No. 45
CC&Rs requiring maintenance of the parking lots, landscaped areas and parkway
landscaping on parcels 1, 2 and 3 shall be recorded. The CC&Rs shall be submitted
for review and approval by the City prior to recordation of the parcel map. These
provisions of the CC&Rs may not be amended or deleted without the prior written
consent of the City. The City shall be a third party beneficiary to the CC&Rs and
shall have the right to enforce these requirements.
Condition No. 46
No access to the site shall be provided from Delta Avenue.
Condition No. 47
Bollards shall be located adjacent to all pedestrian service doors in locations
approved by the Building Division in order to prevent vehicles from blocking access.
Condition No. 48
During construction, all roads shall be kept free of nails or other construction debris
that may pose a hazard to emergency and other city vehicles.
Condition No. 49
An as-built set of plans shall be submitted upon completion of the project.
Condition No. 50
The walls on the outside of the Project Site shall be coated with graffiti-resistant
materials or landscaping treatments such as wall-climbing vines shall be planted to
help deter graffiti. Tenants shall be responsible for cleaning graffiti on their
buildings within 48 hours of notification of such graffiti; the major tenant shall be
responsible for cleaning graffiti on the perimeter walls of the Project Site within this
same time period. Complaints regarding graffiti on the perimeter walls or on the
major tenant's building may be made to the customer service department of the
major tenant.
Condition No. 51
Developer shall file a Notice of Intent with the State Regional Water Quality Board.
Condition No. 52
In the event of any administrative, legal or equitable action or other proceeding
instituted by any person, entity or organization challenging the validity of the
project approvals to which these conditions attach or challenging the sufficiency of
any environmental review, the Developer shall cooperate with the City in the
defense of any such challenge. Developer agrees that City may, at its sole option,
tender the complete defense of any such third party challenge to the Developer, and
upon acceptance of such tender by Developer, Developer shall indemnify and hold
harmless City against any and all fees and costs arising out of the defense of such
challenge and shall control the defense. Should Developer refuse to accept such a
tender by the City, City may defend such action or proceeding and if City so
defends, Developer shall indemnify and hold City harmless from all attorneys' fees
related to such defense.
Rosemead Commercial Retail Center
Revised Final EIR (S CH No. 2003121090
Revisions to Draft EIR
Page 3-22
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Table 1.10-2
Revised Conditions of Approval
1
1
Him as the grarety store evirtporient is opened, tit, maiv, ..,.y OF-ate Of, 8
24 hour basis.
1
1
1
1
Rosemead Commercial Retail Center Revisions to Draft EIR
Revised Final EIR (SCH No. 2003121095) Page 3-23
Condition No. 53
The Developer shall pay for all of the City's costs, including the costs of outside
consultants, incurred in working on the CEQA and project entitlement review and
shall pay for all costs related to the Mitigation Monitoring Program. Prior to
beginning construction, the Developer shall pay all fees incurred to date and shall
deposit $10,000 toward the Mitigation Monitoring Program. The City shall keep
track of the actual costs of the Mitigation Monitoring Program and in the case of a
difference between the deposit and the actual cost, the Developer shall either pay for
any additional costs or the City shall refund the difference.
Condition No. 54
,The hours of operation
of the major tenant shall be limited to 8 a.m. to 10 p.m., except during Christmas
season, in which case the hours of operation maybe extended to midnight. ~ttavcir
Condition No. 55
The parking lot lights shall be dimmed two hours after closing.
Condition No. 56
No single can sales of alcohol shall be allowed; the liquor department shall not be
located near an entrance.
Condition No. 57
All references to the "Developer" shall include any successors in interest.
Condition No. 56
The cart storage area in front of the stores shall be fully screened from view.
Condition No. 59
The Planning Commission shall conduct an annual review of the major tenant'.
operation to insure that it is complying with all conditions of approval. The fir-,t
review shall take place one year after a certificate of occupancy, or temporary
certificate of occupancy, is issued.
Condition No. 60
No guns, handguns, rifles, or other types of firearms or ammunition shall be soli!
from any business on the Project Site.
CITY ENGINEER'S CONDITIONS
Condition No. I
Details shown on the tentative map are notnecessarily approved. Any details which
are inconsistent with requirements of ordinances, general conditions of approval, or
City Engineer's policies must be specifically approved in the final map or
improvement plan approvals.
Condition No. 2
A final parcel map prepared by, or under the direction of a Registered Civil
Engineer authorized to practice land surveying, or a Licensed Land Surveyor, must
be processed through the City Engineer's office prior to being filed with the County
Recorder.
Condition No. 3
A preliminary subdivision guarantee is required showing all fee interest holders and
encumbrances. An updated title report shall be provided before the final parcel map
is released for filing with the County Recorder.
Condition No. 4
Monumentation of parcel map boundaries, street centerline and lot boundaries is
required for a map based on a field survey.
Applied Planning, Inc. (Copyright © 2005)
Table 1.10-2
Revised Conditions of Approval
Condition No. 5
Final parcel map shall be filed with the County Recorder and one (1) mylar copy of
filed map shall be submitted to the City Engineer's office. Prior to the release of the
final map by the City, a refundable deposit in the amount of $1,000 shall be
submitted by the developer to the City, which will be refunded upon receipt of the
mylar copy of the filed map.
h
Condition No, 6
T
e developer
shall comply with all requirements of the Subdivision Map Act.
Condition No. 7
Developer shall obtain a public works permit for all work in or adjacent to the public
right-of-way.
Condition No. 8
Developer shall install and complete all necessary public improvements, including
but not limited to street, curbs, gutters, sidewalks, handicap ramps, and storm
drains, along the entire street frontage of the development site as required by the
City Engineer.
Condition No. 9
The project proponent shall dedicate appropriate right-of-way or easements to
accommodate improvements adjacent to and on the project site, if applicable.
Condition No. 10
A precise grading and drainage plan, prepared by a civil engineer registered in the
State of California, shall be submitted to the Building Department for approval prior
to the issuance of building permits, which shall conform to all requirements of the
City of Rosemead Grading Ordinances. The grading plan shall include, but not be
limited to:
a. Prior to the recondition of the final map, grading and drainage plans must be
approved to provide for contributory drainage from adjoining properties as
approved by the City Engineer, including dedication of the necessary easements.
b. The grading and drainage plan must provide for each lot having an independent
drainage system to the public street, to a public drainage facility, or by means of
an approved drainage easement.
c. Historical or existing storm water flow from adjacent lots must be received and
directed by gravity to the street, a public drainage facility, or an approved
drainage easement.
d. The proposed drainage system shall be constructed and connected to the existing
storm drain in Walnut Grove Avenue. Developer shall process the storm drain
plans through Los Angeles County Department of Public Works.
e. Surface water generated from each lot shall not drain over the sidewalk or
driveway into the gutter on Delta Avenue, Rush Street and Walnut Grove
Avenue.
f. Developer must comply with the City's storm water ordinance and SUSMP
requirements.
Condition No. 11
For parcels 1, 2 and 3 only, Developer shall prepare and record a covenant, subject
to City Engineer's approval, to allow cross lot drainage.
Rosemead Commercial Retail Center Revisions to Draft EIR
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Table 1.10-2
Revised Conditions of Approval
Condition No. 12
For parcels 1, 2 and 3 only, Developer shall prepare and record a covenant, subject
to City Engineer's approval, for ingress and egress, utility and drainage easement,
fire lane, to the extent no provided on the parcel map, and maintenance of the
private driveways.
Condition No. 13
Developer shall prepare and record a covenant, subject to City Engineer's approva:,
for reciprocal vehicular and pedestrian access between parcels 1, 2 and 3.
Condition No. 14
Roadways shall be improved as required by the City Engineer.
Condition No. 15
The final layout and site driveway design shall be subject to the review and approval
of the City Engineer.
Condition No. 16
New drive approaches shall be constructed at least 5' from any above-ground
obstructions in the public right-of-way to the top of 'Y' or the obstruction shall be
relocated.
Condition No. 17
Drive approaches shall be at least 20' wide.
Condition No. 18
Clear unobstructed sight distances shall be provided at all unsignalized site
driveways.
Condition No. 19
Clear visibility of pedestrians approaching on-site intersection crosswalks shall b+
provided; signage and other objects shall not obstruct clear views between drivel
and pedestrians.
Condition No. 20
The project proponent shall coordinate with the City of Rosemead and the County
Fire Department during the development review process to ensure the adequacy of
the proposed: (1) driveway vertical profiles, to ensure a smooth transition between
the roadway and the driveway change in grade, (2) designation of the curb at the
building face as a fire lane, to ensure that emergency vehicles have access to all
building faces, and (3) the internal circulation system relative to emergency access.
Condition No. 21
The project proponent shall comply with the requirements of the applicable
transportation agencies regarding the public transit facilities required on or off-site,
as set forth by the City Engineer.
Condition No. 22
Damaged curb, gutter and sidewalk along Delta Avenue, Rush Street and Walnut
Grove Avenue shall be reconstructed.
Condition No. 23
Developer shall construct handicapped access ramps at all on-site intersections and
site driveways.
Condition No. 24
Developer shall modify the existing traffic signal at the intersection of Walnut Grove
Avenue and Rush Street to include north/south left-turn phasing in conjunction with
the proposed development. Pedestrian crossing improvements at this intersection
shall be provided to the satisfaction of the City.
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Revisions to Draft EIR
Page 3-25
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Table 1.10-2
Revised Conditions of Approval
Condition No. 25
The north site access on Walnut Grove shall be signalized in conjunction with the
construction of the initial phase of the proposed commercial center. At the
construction stage, the developer shall provide signal timing plans and interconnect
the closely adjoining signalized intersections to provide adequate coordination.
Pedestrian crossing improvements at this intersection shall be provided to the
satisfaction of the City.
Condition No. 26
Developer shall provide two (2) entering, and two (2) exiting lanes at the north site
access driveway on Walnut Grove. To provide efficient signal operation at the north
site access on Walnut Grove, separate sensing of the driveway's right-turn and left-
turn exit lanes shall be provided. The left turn exiting lane at this location shall be
a minimum of 100 feet in length.
Condition No. 27
A median break with a minimum 225-foot recessed left-turn bay shall be provided
for NB Walnut Grove at the north Walnut Grove driveway access.
Condition No. 28
The customer entrance on Rush Street shall be signalized in conjunction with the
construction of the initial phase of the proposed commercial center and provide
separate right-turn and left-turn lanes for vehicles leaving the site. At the
construction stage, the developer shall provide signal timing plans and interconnect
the closely adjoining signalized intersections to provide adequate coordination.
Condition No. 29
The existing eastbound left-turn bay on Rush Street at Walnut Grove shall be
lengthened to a minimum of 325 feet.
Condition No. 30
A left-turn bay shall be provided at the median openings for the customer access on
Rush Avenue.
Condition No. 31
There shall be no delivery truck driveway on Rush Street; delivery trucks shall take
access off of Walnut Grove Avenue.
Condition No. 32
The developer shall install all street name signs, stop signs, and all other
miscellaneous signage as deemed necessary by the City Engineer, regardless of
whether such signs are shown on the street improvement plans. All signs must be
installed to City of Rosemead, County and/or Caltrans standards, as applicable,
prior to utility clearances and occupancy certification of the first development phase.
Condition No. 33
The developer shall be responsible for installing or repairing all centerline striping,
traffic legends, raised reflective pavement markers and other traffic delineation
required by the City Engineer, including signal loops damaged or required to be
installed as a requirement of the project.
Condition No. 34
All on-site parking and circulation areas shall be paved as required by a pavement
engineering or geotechnical report prepared by a civil engineer, subject to review
and approval of the City Engineer.
Condition No. 35
Developer shall construct handicapped access ramps per City standards at the
corners of Walnut Grove Avenue and Rush Street, and Rush Street and Delta
Avenue.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Revisions to Draft EIR
Page 3-26
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Table 1.10-2
Revised Conditions of Approval
Condition No. 36
Vehicle storage space in all left-turn bays associated with site access points and the
adjacent intersection shall be provided to the satisfaction of the City Engineer.
Condition No. 37
The site design shall provide the facilities necessary to safely integrate alternate
transportation modes such as bicycle usage, pedestrian access, and transit operations
into the site access and circulation system on-site and minimize the area where
vehicle conflicts with bicyclists and pedestrians can occur.
Condition No. 38
Bicycle rack(s) shall be installed pursuant to Chapter 12.32 of the Rosemead
Municipal Code.
Condition No. 39
Left-turn site egress shall be prohibited at the proposed southern site access on
Walnut Grove Avenue.
Condition No. 40
Street trees sized at a minimum of 24 inch boxed, shall be installed within the
setback areas adjacent to the parkway of all streets. The type, size and location of the
street trees shall be approved and inspected prior to planting by the City Engineer.
Condition No. 41
Prior to issuance of a certificate of occupancy for Phase 1 Improvements, Developer
shall deposit an amount determined by the City Engineer for the costs of installing
a flashing beacon at school crossing and funding a school crossing guard program
at the corner of Rush Street and Delta Avenue for a minimum of 20 years.
Condition No. 42
The Walnut Grove Avenue entry shall be 58 feet, providing four (4) 12-foot lanes,
two inbound and two outbound, and a 10-foot wide landscaped median.
Condition No. 43
Approval of the land division is contingent upon the installation of local 8-inch
(minimum) main line public sewer within a dedicated (10 feet minimum) easement
to the City. Separate house laterals shall be constructed to serve each lot of the land
division.
Condition No. 44
The developer shall send a print of the sewer plans to the City and to the Los
Angeles County Department of Public W orks for review. Approval mustbe assured
prior to filing the land division map.
Condition No. 45
The developer shall consult the City Engineer to determine the sewer location and
design requirements.
Condition No. 46
Any utilities that are in conflict with the development shall be relocated at the
developer's expense.
Condition No. 47
All lots shall be served by adequately sized water system facilities, which shall
include fire hydrants of the size, type and location as determined by the Fire Chief.
Condition No. 48
The water mains shall be of sufficient size to accommodate the total domestic and
fire flow required for the land division. Domestic flows required are to be
determined by the City Engineer. Fire flows required are to be determined by the
Fire Chief.
Rosemead Commercial Retail Center
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Table 1.10-2
Revised Conditions of Approval
Condition No. 49
Plans and specifications for the water system facilities shall be submitted for
approval to the water company serving this land division. The subdivider shall
submit an agreement and other evidence, satisfactory to the City Engineer,
indicating that the subdivider has entered into a contract with the servicing water
purveyor guaranteeing payment and installation of the water improvements.
Condition No. 50
Prior to the filing of the final map, there shall also be filed with the City Engineer,
a statement from the water purveyor indicating subdivider compliance with the Fire
Chief's fire flow requirements.
Condition No. 51
Any fast food restaurants proposed with drive-through facilities shall be designed
to provide safe on-site traffic circulation which does not conflict with entering or
exiting traffic to the site, on-site parking or pedestrian movements. Sufficient
reservoir space shall be provided to store four vehicles between the order board and
the pick-up window (not including the car at the order point or the car at the pick-
up window). Storage for at least four vehicles shall also be provided in advance of
the menu board.
Condition No. 52
If any oil, gas or injection wells are discovered within the Project Boundaries, the
Developer shall notify the Department of Conservation (Cypress office) and comply
with any necessary closure/remedial actions required by DOC.
Condition No. 53
Sidewalks shall be installed on the easterly side of Delta immediately adjacent to the
street frontage of the Project site; Delta shall be fully improved to City standards to
the satisfaction of the City Engineer.
FIRE DEPARTMENT CONDITIONS
Condition No. 1
An engineered automatic sprinkler system is required to be installed pursuant to
applicable Building and Fire Codes to the satisfaction of the County Fire
Department. Plans for such a system shall be submitted for review and approval by
the County Fire Department prior to the issuance of building permits.
Condition No. 2
The use or storage of any hazardous or flammable materials shall comply with the
requirements of the Fire Department and must be in compliance with the Uniform
Fire Code.
Condition No. 3
Underground fuel storage tanks and any associated tank connections shall be
submitted to the Los Angeles County Department of Health Services for approval
prior to review/approval by the County Fire Department. Contractors performing
said work shall obtain a Fire Department Permit prior to commencement of work.
Access roadways shall be provided as per the current edition of the Uniform Fire
Code and property marking designating "No Parking" where necessary to ensure an
unobstructed clear width.
Condition No.4
A water supply system shall be installed, capable of providing the required fire flow
for the proposed type of development as per requirements of the applicable Fire
Code.
Rosemead Commercial Retail Center Revisions to Draft EIR
Revised Final EIR (SCH No. 2003121095) Page 3-28
Applied Planning, Inc. (Copyright © 2005)
Table 1.10-2
Revised Conditions of Approval
Condition No. 5
Where access to or within a structure area is restricted because of secured openings
and immediate access is necessary for life saving or fire fighting purposes, a Knox
Box is to be installed in an accessible location as approved by the Fire Department.
The Knox box shall be of a type approved by the Fire Department.
Condition No. 6
Fire apparatus access roads shall be required for any building constructed where any
portion of an exterior wall is located more than 150 feet from Fire Department
vehicle access point. Fire apparatus roads shall have an unobstructed width of not
less than twenty (20) feet and an unobstructed vertical clearance of not less than
thirteen (13) feet, six (6) inches.
Condition No. 7
All streets and access roadways as approved on the final tract map shall be
maintained in such a manner as to provide access for emergency vehicles at all times
during construction phase. All streets and/or access roadways shall be constructed
and maintained as to provide a smooth driving surface of not less than twenty (20)
feet of unobstructed width, capable of supporting the imposed load of Fire
Department apparatus and/or emergency rescue equipment to within seventy-five
(75) feet of all structures. Failure by the developer and the persons responsible for
the project site to comply with this provision or any of the other requirements
outlined in Rosemead Municipal Code and the applicable Fire Code, will be cause
for the Fire Chief to require that all activity be discontinued pending compliance.
Condition No. 8
If temporary fencing is used to enclose the construction site, at least two (2) meal-
of unobstructed access must be installed and maintained each of which is to b,
located as to give maximum access to all parts of the site. Locking devices shall be
of materials which can be readily forced by equipment used by the Los Angeles
County Fire Department.
Condition No. 9
The storage or stacking of lumber, fabricated components or other combustible
materials is not permitted nor shall the storage of structure framing lumber be
initiated within the City limits until all water lines and hydrants, as set forth on the
approved water map for the project, have been installed and approved by the Los
Angeles County Fire Department.
Condition No. 10
To the extent not already covered by the conditions 'set forth therein, The
development shall conform to the regulations of the California State Fire Marshal as
contained within Title 19 and Title 24 of the California Code of Regulations.
Condition No. I l
The developer shall submit a list of hazardous or flammable materials used or stored
and the quantities of each to the Building Division prior to plan check. A hazardous
material management plan (HMMP) per UBC 307.1.6 shall be prepared and
submitted prior to plan check submittal. Additional fees incurred by Building
Division shall be paid for the analysis and review of the HMMC.
Condition No. 12
When required, permits from County Department of Health Services for use,
storage, or disposal of hazardous materials shall be obtained prior to final approval
of the project Certificate of Occupancy.
I Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Revisions to Draft EIR
Page 3-29
I I
Applied Planning, Inc. (Copyright © 2005)
Table 1.10-2
Revised Conditions of Approval
Condition No. 13
The final development plans shall comply with all applicable code and ordinance
requirements for construction, access, water mains, fire flows, and hvdrants and
shall meet the following minimum requirements:
a. Development may require fire flows up to 5,000 gallons per minute at 20 pounds
per square residual pressure for up to a five-hour duration; final fire flows will
be based on the size of buildings, its relationship to other structures, property
lines, and types of construction.
b. Fire hydrant spacing shall be 300 feet and shall meet the following requirements:
i. No portion of lot frontage shall be more than 200 feet via vehicular access from
a public fire hydrant
ii. Additional hydrants shall be required if hydrant spacing exceeds specified
distances;
c. Turning radii shall be not less than 32 feet;
d. A Fire Department approved turning area shall be provided for all driveways
exceeding 150 feet in length; all on-site driveways shall provide a minimum
unobstructed width of 28 feet, clear-to-sky. The on-site driveway is to be within
150 feet of all portions of the exterior walls of the first story of any building.
Condition No. 14
Specific fire and life safety requirement for the construction phase will be imposed
during building fire plan check.
Condition No. 15
All buildings shall be accessible to Fire Department apparatus by way of access
roadways, with an all weather surface of not less than the width prescribed by the
Fire Department, unobstructed, clear-to-sky. The roadway shall be extended to
within 150 feet of all portions of the exterior walls when measured by an
unobstructed route around the exterior of the building.
Condition No. 16
Fire sprinklers shall be required in all buildings.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121090
Revisions to Draft EIR
Page 3-30
4.0 COMMENTS AND RESPONSES
4.0 COMMENTS AND RESPONSES
The following section presents written comments received during the public review period
for the Rosemead Commercial Retail Center Alternative Site Analysis EIR Revision (EIR
Revision). Responses to these comments are provided within this section of the Revised
Final EIR. Comment letters have been organized by State agencies, regional agencies, and
those comments received from other individuals. Each letter has been assigned an
identifying designation (generally an acronym or name abbreviation), and topical items
within each letter have been numbered. The comment letters and corresponding responses
are presented on the following pages. Table 4-1 lists all comment letters received on the
EIR Revision, and the designation assigned to each.
Table 4-1
EIR Revision Commentor Letters
State Agencies
SCH Governor's Office of Planning and Research, State Clearinghouse
SCH2 Governor's Office of Planning and Research, State Clearinghouse
CT Department of Transportation (Caltrans), District 7
State Officials
CHU State Representative Judy Chu, 49`h Assembly District
ROM State Senator Gloria Romero, Senate Majority Leader, 24`h District
11
11
County and Regional Agencies
SCAG Southern California Association of Governments
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-1
11
11
11
Applied Planning, Inc. (Copyright @ 2005)
Table 4-1
EIR Revision Commentor Letters (contd.)
Local Agencies/Organizations
MON City of Montebello
MP City of Monterey Park
GSD Garvey School District
Private Organizations and Individuals
SOC Save Our Community
PRB Peggy and Richard Baumann, 8305 Scenic Drive, Rosemead
LCB L.C. Bevington, 8372 Rush Street, Rosemead
BC Bruce Capucetti, Post Office Box 1760, Rosemead
JF James I. Flournoy, 8655 Landis View, (no location provided)
JF2 James I. Flournoy, 8655 Landis View Lane (no location provided)
YF Yuki Fukumoto, 1807 Delta Avenue, Rosemead
RG Ron Gay, 4106 Encinita Avenue, Rosemead
EH Estelle Holtz (no address provided)
JK John Kawakami, 8346 Elsmore Drive, South San Gabriel
TK Todd Kunioka, 8400 Wells Street, Rosemead
GL Germori Lavarin-Garcia, 2443 Charlotte Avenue, Rosemead
BL Brian Lewin, 9442 Ralph Street, Rosemead
LL La Don Lewin, 9442 Ralph Street, Rosemead
PL Polly Low, 1039 La Presa Avenue, Rosemead
LM Lydia Martinez, 1921 N. Delta Avenue, Rosemead
AJM Al and Jewel Mehlman, 1055 Walnut Grove Avenue, Rosemead
CN Celia Nishimura, 1634 N. Delta Street, South San Gabriel
DP David Perea, 2434 Charlotte Avenue, Rosemead
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCN No. 2 003 1 2 1 095) Page 4-2
11
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Applied Planning, Inc. (Copyright © 2005)
Table 4-1
EIR Revision Commentor Letters (contd.)
VR Victor Ruiz, 9703 Olney Street, Rosemead
PS Paul S. Saito, 8361 Sierra Bonita, South San Gabriel
MS Marlene A. Shinen, 8447 Drayer Lane, South San Gabriel
ES Edward Stepanian, 1813 Delta Avenue, Rosemead
DS David A. Stewart, (no address provided), Rosemead
PT Paul Thomson, 8320 Scenic Drive, South San Gabriel
JW Julie L. Wang, 1012 S. Marengo Avenue, No. 1, Alhambra
JY Jeffery K. Yann, P.E. (no address provided)
SY Susan Young, 1836 Rosebrook Lane, Rosemead
In reviewing the comments provided on the EIR Revision, several topical areas of concern
or consideration were common to multiple letters. Those topical concerns, and responses
to those concerns are summarized below.
Topic: Several commentors reiterated issues which have been previously addressed in the Draft EIR
and August 2004 Final EIR.
Response: The lawsuit challenging the EIR raised multiple issues; only two (2) of which
were found to have merit. In this regard, when the EIR was challenged in Court, it was
determined by the Court that:
Petitioners criticism of the treatment in the EIR of traffic impact, light and
glare, urban decay, earthquake risks, runoff and drainage, are also without
merit. The EIR adequately considers and discusses those problems, and the
City's decision to proceed with the project in spite of them is supported by
substantial evidence.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2 003 1 2 1 095)
Comments and Responses
Page 4-3
Applied Planning, Inc. (Copyright © 2005)
The focus and purpose of the EIR Revision is to respond to the two (2) Court-identified
deficiencies in the Draft EIR. Specifically, the Court determined that the potential for 24-
hour operations was not properly considered, and secondly that the Draft EIR inadequately
addressed potential alternative sites for the Project.
Regarding the potential for 24-hour operations, Wal-Mart has rescinded its request to
operate on a 24-hour basis and has agreed to allow a covenant to be recorded against the
property prohibiting a 24-hour operation absent additional environmental review of the
impacts of such an operation in order to satisfy the court's order regarding this issue.
Provisions of this covenant are reflected in Project Condition of Approval No. 54 which
now states:
The hours of operation of the major tenant shall be limited to 8 a.m. to 10 p.m.,
except during Christmas season, in which case the hours of operation may be
extended to midnight.
The second Court-identified issue regarding consideration of alternative sites is the focus
of the EIR Revision. The purpose of an alternative site analysis is to consider potential
alternative locations that may reduce or eliminate significant impacts of the Project, not to
reopen every environmental impact discussion included in the original EIR. Furthermore,
when alternatives are rejected, CEQA does not require a full evaluation of the alternative;
all that is required is an explanation underlying the lead agency's determination as to why
the alternative was rejected. These reasons can include: failure to meet most of the basic
project objectives, infeasibility, or inability to substantially reduce significant environmental
impacts.
Many of the comments go beyond the Revised Alternative Site Analysis and take issue with
the Draft EIR analysis, and reiterate previous comments on that document. Responses
were provided to these comments in the 2004 Final EIR. Comments and concerns
regarding environmental topics or areas of concern already addressed in the Draft EIR and
August 2004 EIR are beyond the scope of the EIR Revision. Applicable portions of the
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-4
Applied Planning, Inc. (Copyright © 2005)
Draft EIR and August 2004 Final EIR are summarized or cited within responses provided
in this Revised Final EIR, and commentors are directed to the previous EIR analyses for
detailed information regarding these topics.
Topic: Several commentors stated opinions or offered explanations why the Project should be
relocated to the site occupied by the Robinsons-May store within the Montebello Town Center.
Response: This alternative site (Alternative Site 3) was specifically assessed and rejected
as discussed within the EIR Revision on Pages 3-11 through 3-14. The EIR Revision
analysis substantiates the infeasibility of this site, and the fact that relocation of the Project
to the site would not substantially reduce significant Project impacts. In addition to these
considerations, comments on the EIR Revision provided by the City of Montebello have
ultimately removed the Robinsons-May/Montebello Town Center site from consideration
as a potential location for the Project. Based on the City of Montebello's comments, Pages
3-11 and 3-12 of the Revised Alternative Site Analysis are amended to read as follows:
a. Site Description
Alternative Site 3, located on the eastern edge of the Montebello Town
Center mall, was identified as a possible alternative due to the recently
announced corporate mergerbetween the May Department Stores Company
and Federated Department Stores, Inc. The closure of the Robinsons-May
store is anticipated by the City, although this store was not identified in the
latest list of locations planned for divestiture, issued by Federated
Department Stores on July 28, 2005. In response to the Revised Alternative
Site Analysis. Rosemead has learned that this site will not be available as
the store will remain open as a Macy's store. The Federated annotincement
notes that '~a smaH number of stores are being studied thr pote
of the Bloominqdale~s ,nameptate,, which would Fesult in these
inciuded in this plan.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-5
Applied Planning, Inc. (Copyright © 2005)
b. Potential Feasibility of Site
a. The existing Robinsons-May store is approximately 140,100 square feet
in size, and is located on an 8.75 acre parcel that provides shared mall parking,
as shown in the following Figure 7.3-3. In order to accommodate the proposed
Wal-Mart Supercenter, substantial re-design of the Project would be required,
resulting in the construction of a multiple-story facility with additional, at-grade
or subterranean parking. Based on the information from the City of Montebello,
as well as problems relating to project design, the site is considered unavailable
and the alternative reiected as infeasible.
Beyond the obstacles of site availability and project design, compatibility
between the proposed Wal-Mart and the existing mall is an additional concern.
The Montebello Town Center is an upscale, regional mall. As such, retailers
within this mall seek to draw consumers from a different market sector than that
of the discount retailer and grocery seller, and the introduction of a discount
retail/grocery use within the existing mall could be incompatible and have a
detrimental economic effect on adjacent retailers. Accordingly, this alternative
site was determined to be infeasible.
Topic: Multiple commentors proffered alternative designs for the Project on the presumption that
the Project could then be relocated to an alternative (usually smaller) site.
Response: CEQA does not require that an EIR consider multiple combinations of Project
configurations and alternative sites within the Alternatives Analysis, only that a reasonable
range of alternatives be considered, as determined by the Lead Agency. The EIR Revision
document considers (and rejects) three (3) potential alternative sites, and further discusses
the reasons for the original rejection of the prior Ralph's Market site. Additionally, within
the Draft EIR, three (3) alternatives were considered (and rejected), and six (6) additional
alternatives (including the CEQA-mandated "No Project Alternative") were assessed and
compared with the Project. The City of Rosemead, as the Lead Agency, has determined
that this analysis satisfies CEQA's requirements to examine a reasonable range of
alternatives, with supporting reasoning for rejection of potential alternative sites from full
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-6
Applied Planning, Inc. (Copyright © 2005)
consideration. Evidencing available information to permit an informed choice, the City
rejected the initially proposed Project, and adopted the Project Design Alternative.
Further, the Project is that proposal described and assessed in the EIR, not some variation
or redesign not agreed to by the Project proponent and Lead Agency. Lastly, with specific
regard to suggested multiple-story configurations for the Project's major tenant (Wal-Mart),
such a design is infeasible and would not be considered by the Project proponent. More
specifically:
• The cost of designing, engineering and construction such a store would be prohibitive,
particularly if it involved subterranean parking.
• The Project Major tenant described and assessed in the EIR is a Wal-Mart Supercenter,
which includes a general merchandise component and a supermarket component.
There are no multi-story Wal-Mart Supercenters in California. This is a function of
customer convenience. Supermarkets are generally not multi-story (if there are any
at all). Wal-Mart has determined that customers generally dislike shopping in multi-
level stores for convenience items such as groceries and household products.
Therefore, the multi-story format would put Wal-Mart at a competitive disadvantage
in comparison to its competitors. There is not the same concern with a Wal-Mart
general merchandise (only) store. This is evidenced by the existence of several multi-
story general merchandise stores in California.
These general responses are incorporated by reference, and are cited where applicable,
within specific responses to comments on the EIR Revision, which comments and responses
follow.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-7
State Clearinghouse, Page 1 of 2
M rW...
STATE OF CALIFORNIA a
Governor's Office of Planning and Research
State Clearinghouse and Planning Unit ep UL
Sear, wabb
Arnold Dveaeor
Sdhww2aaegper
Gowmar Nwmmber 10, 2005
Mr. Brad Johnson
City of Rosemead
8638 Este Valley Boulevard
Rosemead CA 91770
NOV 1, t, 2005
Sub) ect Rosemead Coaanercial Rend Center EIR - Revised Alternative Site Analysis
SCHrt; 2003121093
Dear Mt. Brad Iobnson!
The State Clearinghouse vabadrnd the above earned Draft EM to selected state agencies for ravrew. The
review period closed on November 9, 2005, and no ease agencies subained coumvmn by that date. Thu
Letter aclmowiedres that you bane complied v+tth she SUM Ckar mgbouse review requi worts for draft
eavirormseatal documents, pursuant to the Califorwa EnviroammW Quality Act
Please call the State Clearinghom at (916) 4454613 if you have any questions reaardiaB the
enviranmensl review Process. If you have a question about the above-named project, Please refer to she
tea-digit State Clearinghouse nambcr when consaconP this offue.
Sincerely,
•r'i~
Terry Robeits
Direetor, Stag CkannShoute
SCH-1
1400 Tl rM STMT P.Q. BU 3044 SAORAl1i8T17'0, OAI.a►t)itN1A M11-W"
State Clearinghouse, Page 2 of 2
Document Details Report
State Clearinghouse Data Base
SCHO 2003121095
Project Tide Rosemead Commensal Retell Center EIR • Revised Altsmethre Site Ana"Is
Lead Agency Roswrwad, My of
Type MR Draft SIR
Dwcr(ptNOa The Rosemaaad Commercial Retail Canter Propct proposes estabEishmerv of a new rebOoommerctei
center. Incorporetin0 a major anchor laws and esaociewd Gas station. and lilies smamr'outpad'
buMdirtgs. Site access, internal vehicuisr cirwta0on. Pedestrian access, PS", WrdsCOPWV. and
supporting Oftsbucture wilt be ►mpleteenled wxyor rsoontrGund to accommodate the Prom.
w
Lead Agency Contact
Noma Mr. Brad Johnson
Agency CMy of Rosenwad
Phone (626) 589-2100 Fax
wm,7
Address MM East Valley Boulevard
city Rosemead SssOe CA DO 91770
Prooct Location
County Los Aripeles
City Rosemead
Region
Cross Sveets Rush Sweat I Walnut Grove Avenue
Parcel No.
Township Range Section ease
Proximity to:
NVhways 1.10. SR-OD, 19
Airports
RaMvays
waarways
Schools
Land Use vacant
G3, Madk n Commercial
Project issues 0a w Issues
Rovlewlnp Resourgs Agency; Regional Waver QuaRy Control Board. Region <; Depa wwo of Parks and
Agencies ROMMion; Native Arnwicsn Heritage Commission; Department of Heafth Services: Office of Hiatonc
Preserve . Department of Fish and Game, Region 5; Depamment of Water Resources; Deparoneni
of Caruervelion; C40OMW Highway Patrol: Caltrsns. District 7
Dose Received MAIMS Sant o/ Rorie" 09r26r1005 End of Review 1110912005
Applied Planning, Inc. (Copyright © 2005)
STATE OF CALIFORNIA
GOVERNOR'S OFFICE OF PLANNING AND RESEARCH
STATE CLEARINGHOUSE
SCH No. 2003121095
Letter Received November 16, 2005
Response 1-1
SCH receipt of the Rosemead Commercial Retail Center EIR-Revised Alternative Site
Analysis is acknowledged, as is distribution of the EIR Revision to the listed State Agencies.
SCH identifies that review requirements of that agency (SCH) have been complied with,
and that as of the SCH-assigned close of comments date, none of the reviewing State
agencies had provided comments to SCH. The State-assigned review period, September
26, 2005 through November 9, 2005 is also acknowledged.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-10
State Clearinghouse, Letter 2, Page 1 of 1
STATE OF CALIFORNIA
Govatraar's Offine of Plaaniag and Research
State Clearinghouse and Planning Unit It
Ataotd son, w"
Director
schwalzmew Govstaor
November 16, ZOOS
/ r
W BradIobnson
City of Rosemead
9935 East Valley Boulevard
Rosemead, CA 91770
Subject aaaemead Caamoucial Retail Canter M - Rr vised Alternavve Site Analysis
SCHM 2003121095
Dar Mr. Brad Johnson:
The enclosed comiroent (s) on your Dtaf! EIR .nos (vaece) received by the State Clearuighoax idler the and
of the sate review period which closed on November 9. 2005. we are forwarding these com nentr to you
beaux dwy provide Wormatioo or raise boa dat should be addressed in your foal euvaownemal
document.
The Callforma Faviraaraental Quality Act does not require Lead Agencies to respond to late comments. SCI-12-1
However, we encourage you to incorporate these additional counwn into your final euvirottmeatel
document and to eonsidei tbem pr orto taking 5aa1 action on the proposed project.
Please contact the Scam Clesrioghoute at (9167 "S-0613 if you bave say quettiom concerning the
eavirnmmcatal review process. If you bave a question regarding the above-awned project, pleue rr(ar to
the ten-digit Staae Ciariaghonae aumbef (2003121095) wben coaincting this office.
Sincerely,
,Pe-'tz-
"erry Robe*
Senior Pilo, State Claringbouse
&naosutes
cc: Resources Agency
lfoo Tom eTBSE'f P.O. Box so" SACRAMMM. CALIFORNIA O N12-3044
TEL (919)44d-MIJ TAX (M) 3 MIS aw*.epr-ca.p.
Applied Planning, Inc. (Copyright © 1005)
STATE OF CALIFORNIA, Letter No. 2
GOVERNOR'S OFFICE OF PLANNING AND RESEARCH
STATE CLEARINGHOUSE
SCH No. 2003121095
Letter Dated November 16, 2005, Received November 21, 2005
Response SCH 2-1
The State Clearinghouse indicates that late comments (comments submitted after the
noticed close of comment period-November 9, 2005) were received on the Revised Site
Alternative Site Analysis. SCH further notes that Lead Agencies are not required to
respond to comments submitted after the noticed close of comments, but suggests their
inclusion and consideration in final environmental documentation. The referenced
comments, provided by Caltrans, and responses to those comments, are included within
this Revised Final EIR. Please refer to comment letter CT-1 and corresponding responses.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Comments and Responses
Page 4-12
Caltrans District 7, Page 1 of 3
STATFOF CA1.11OR N..A-B1`J_NtSs rRANSPORIA[ION _AN_L)IP)USING.,5rFNCY ARNOU1SCHWAR7.ENF.(_QFR Gi_crw.
DEPARTMENT OF 'T'RANSPOR'T'AT'ION 4 _
DISTRICT 7, REGIONAL PLANNING
IGR/CEQA BRANCH
100 MAIN STREET, ms # 16 LOS ANGELES, CA 90012-3606 nev vwin /over'
PHONE: (213)897-1747 U(- rnel yx i ffi(irrrr'
FAX: [213) 897-1337
IGR/CEQA No. 050953AL. EIR Revision
Referenced to IGR/CEQA No. 040806AL. FEIR
and IGR/CEQA No. 040526AL
Rosemead Commercial Retail Center
Wal-Mart Shopping Center
Vic. LA-60 / PM R8.54
S C H 2003121095
Novemher 8. 200
Mr. Brad Johnson
City of Rosemead
8838 E. Valley Boulevard
Los Angeles, CA 91770
Dear Mr. Johnson:
Thank you for including the California Department of Transportation (Caltrans) in the
environmental review process for the above referenced project. This revision to draft E1R
provides alternative site analysis for developing, Wal-Mart shopping center.
Due to the fact that the traffic pattern and distribution will be different than the original
site, a traffic study should be prepared. We wish to refer the project's traffic consultant to
our traffic study guideline Website:
lhttp•//www clot ea aovllicl/u-al'fupsldevelopserv/operationalsvstemslreports/tisL,uide.pdf
and we list here some elements of what we generally are expecting in the traffic study:
1. Presentations of assumptions and methods used to develop trip generatiull, trip
distribution, choice of travel mode, and assignments of trips to State Routes.
2. Consistency of project travel modeling with other regional and local modeling
forecasts and with travel data. The IGR/CEQA office may use indices to check
results. Differences or inconsistencies must be thoroughly explained.
3. Analysis of ADT, AM and PM peak-hour volumes for both the existing and future
conditions in the affected area. This should include freewavs, intercharives, and
intersections, and all HOV facilities. Interchange Level of Service should he specified
CT-1
Cultrnns unprnrr, urwbif h-at rnvt C(domiiu'
Caltrans District 7, Page 2 of 3
(HCM2000 method requested). Utilization of transit lines and vehicles, and of all
facilities, should be realistically estimated. Future conditions would include build-out
of all projects (ree. next item) and any plan-horizon years.
4. Inclusion of all appropriate traffic volumes. Analysis should include traffic from the
project, cumulative traffic generated from all specific approved developments in the
area, and traffic growth other than from the project and developments. That is.
include: existing + project + other projects + other grog+~th.
5. Discussion of mitigation measures appropriate to alleviate anticipated traffic impacts.
These mitigation discussions should include, but not be limited to, the following:
• Description of Transportation ]nfrastructw-c improvements
• Financial Costs, Funding Sources and Financing
• Sequence and SchedulinL_' Considerations
• Implementation Responsibilities. Controls, and Monitoring
Any mitigation involving transit. HOV, or TDM must be rigorously justified and its effects
conservatively estimated. Improvements involving dedication of land or physical
construction may be favorably considered.
6. Specification of developers percent share of the cost. as well as a plan of realistic
mitigation measures under the control of the developer. The following ratio should he
estimated: additional traffic volume due to project implementation is divided by the
total increase in the traffic volume (see Appendix "B" of the Guidelines). That ratio
would be the project equitable share responsibility.
We note for purposes of determining project share of costs, the number of trips from
the project on each traveling segment or element is estimated in the context of
forecasted traffic volumes which include build-out of all approved and not yet
approved projects, and other sources of growth. Analytical methods such as select-
zone travel forecast modeling ought be Used.
The Department as commenting agency under CL-QA has jurisdiction supereeding that
of MTA in identifying the freeway analysis needed for this project. Caltrans is
responsible for obtaining, measures that will off-set project vehicle trip generation that
worsens Caltrans facilities and hence, it does not adhere to the CMP guide of 150 or
more vehicle trips added before freeway analysis is needed. N1TA's Congestion
Mana~_ement Program in acknowledging the Department's role, stipulates that
C'altrans must he consulted to identify specific locations to be analyzed on the State
Highway System. Therefore State Route(s) mentioned in item #1 and its facilities
must be analyzed per the Department's 'T'raffic impact Study Guidelines.
We look forward to reviewing the traffic study. We expect to receive a copy from the
State Clearinghouse when the DEIR is completed. However, to expedite the review
process, and clarify any misunderstandings, you may send a copy in advance to the
undersigned.
CT-1
(cont'd)
Caltrans District 7, Page 3 of 3
It' you have any quc~tions. please feel free to contact me at 13) 897-3747 or AI,tn Lin CT-1
the project coordinator at (213) 897-8391 and refer to IGR/CF,QA No. 050953) AL. (cont'd)
Sincerely,
e U
CHERYL J. POWELL
IGR/CEQA Branch Chief
cc: Sett Morgan. State Clcaringhouse
Applied Planning, Inc. (Copyright (D 2005)
STATE OF CALIFORNIA, DEPARTMENT OF TRANSPORTATION, DISTRICT 7
Letter Dated November 8, 2005
Response CT-1
The comments provided by Caltrans appear to misinterpret the findings of the Alternative
Sites Analysis provided within the EIR Revision Document. The EIR Revision finds that
the use of an alternative site is not justified because significant environmental effects would
not be avoided or substantially lessened by putting the Project in another location. On this
basis, no changes to traffic patterns or distribution will result, and no additional traffic
study is required. It is further, noted that when the EIR was challenged in Court, it was
determined by the Court that criticism of the treatment in the EIR of traffic impacts was
without merit. And further, that the EIR adequately discusses this issue, and the City's
decision to proceed with the Project in spite of identified traffic impacts is supported by
substantial evidence.
In the future, should the City Council choose to pursue development on an alternative site,
the Traffic Study guidelines provided will be used as part of a more comprehensive
environmental review process specific to the recommended site. The commentor's
statements and opinions will be forwarded to the decision-makers. Analysis and
conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-16
1] 13 2005 FAN 9163192149 -SRI Judi Citu .1(to2 ou=
Representative Judy Chu,
1vo~~erriner 9 '_0(1-
c, SE11[~T ltT
(f~fifjarffizt sl~~ltrl'
JUDY CHU
ASSEMBLYMEMBER. FORT-1 141N'Y DISTRICT
Mr. Brad Johnson
City of Rosemead
sS )R East Vatic-, Biva.
Rosemead CA 91 ? I
Dear NI:. Jonn,un
v1t ,'05
Page 1 of 1
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FAX 16:6145C-61'r
I art? e~:arc" ~Oncer-Lis rrLard ing iriadequac~ Of The revised Envtron.-rer.tal Impact Repor. (EIR) for
,he cerk,c C i ricrcla. -'C: a; Ccn:cr
The revise d EIR :at:s to prn icie ar. adegLate const6erarion Of Ll-.CManve sites for the proposed project. There arc
numerous aspects o-' the alternative sites that were ignored or omitted frorn the revised EIP. that would have
rr.::ieatcd the cnyconmertal impact of the project. SpCCif1Cally, the revised FIR failed to adequately consider
aspects of .hc alternative sites that would protect the heelth of " senslttvr receptors" and access to public
tratt_;DOnation tat would mitigate the iong-term environmental impact of fne projeci.
T'ne rcv,!,cd EUI also fails io acimowledge or address rattigauon measure for the lone-term eavironrnental impact
of die project. The Te'yised EI contains mitigation proposais for the uonstructlon phase of the project, but faits -LC
iIrovi de rmn-puon proposals for lone-term, chronic an, and noise poautinn produucd by transport truck and
~onsuriel vincle an'vitn- _
CHU-1
.Am emzronmental unnact report i~ reouired to be a dctaf.ed report .written by the lead agency deseribtne and
~uia:vz.ng the significant environmental erects ofa proposed proj--ct. idenuiying alternatives and discussing..ays
:o reduce or avoid the possible environmental damage. Stenificant effect on the em•irorimci t means a substant.aL CHU-2
it poten*.ta'Av subsianna.. adversc- change in arty of the physical conditions within the area affected by the proicc-
,ncludtng land. air. water, TTlinerais. aora. sauna, ambien: nose. and objects of historic or aesmetic ,tmtGcarce
The Les Angeles COUMV Superb- Court issued a judgment to requ.rc the Cary of Rosemead to cerify a new ;r 1R
that -adeouately addresses nice=-t'.ve sites for -he Dr'01CCT' et07e" allowing contraction :o c-sue. 'T-hts EIR. 10
'aueouatc?): address alternative sites for the xucct- and ther.Core should be re;ectec. CHU-3
T 2ni v0:- for :mane the nric :c1 . orisi6er sir: cxicurm5 reganiim, -.hu uiadedaacv of :hc rc%-!scd UP, 'or the
Rusen-r.ad i:orrure%131 R;tail r-enter.
J1CCTCh',
17''X CIIL. ?h[U.
49" :lsse-nb!v Dtstrnc:
i -N1-.-
Prnrao on Feci>>eo f'aac-
Applied Planning, Inc. (Copyright © 2005)
REPRESENTATIVE JUDY CHU, CALIFORNIA STATE ASSEMBLY, 49h DISTRICT
Letter Dated November 9, 2005
Response CHU-1
The commentor incorrectly implies that the Project-related air emissions would result in
health risks to sensitive receptors, which health risks could be reduced or eliminated
through relocation of the Project. This assertion is not borne out by, nor substantiated
through, facts or analysis. Subsequent statements by the commentor based on this
unsubstantiated assertion are similarly invalid. Consequently, there is no requirement for
the EIR Revision to "adequately consider aspects of the alternative sites that would protect
the health of 'sensitive receptors' and access to public transportation that would mitigate
the long-term environmental impact of the project."
The EIR does conclude and disclose that, even after the application of all feasible mitigation
measures, the Project will result in certain exceedances of South Coast Air Quality
Management District (SCAQMD) emissions thresholds. In this regard, additional
pollutants generated by the Project will generally affect regional air quality conditions.
However, such effects do not equate to localized health risks. As a point of fact, due largely
to ambient air pollutant conditions within urban Southern California, it is not uncommon
for new development projects to exceed SCAQMD emissions thresholds.
Consistent with the provisions of CEQA, the City may decide to proceed with the Project
in spite of its significant air quality impacts. In this regard, the previous Project approval
included the adoption of a Statement of Facts, Findings and Overriding Considerations
which acknowledged that certain impacts could not be avoided, but found that the benefits
of the Project outweigh those impacts.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-18
Applied Planning, Inc. (Copyright © 2005)
More specifically, potential air quality impacts of the Project are discussed within Draft EIR
Section 4.4, "Air Quality," and the detailed technical Air Quality Impact Study presented
within Draft EIR Appendix D, "Air Quality and Noise Impact Study." Air quality impacts
significance thresholds applicable to the Project are based on criteria pollutant thresholds
established by the SCAQMD, and subsequently adopted by the Lead Agency. And it is on
this basis, when evaluated against established SCAQMD criteria, that certain air quality
impacts of the Project are determined to be significant. The Project's significant air quality
impacts are area-wide or regional in nature, and the SCAQMD thresholds are the accepted
criteria to quantify the Project's relative individual contribution to basin-wide air quality.
These significant impacts are not however, a specific indicator of localized health risks.
With the exception of certain adopted localized criteria and standards, discussed below,
SCAQMD thresholds are not location-specific within the South Coast Air Basin (Air Basin).
On this basis, air quality exceedances that are generated by the Project would result
irrespective of its location within the Basin.
With specific regard to the commentor's expressed concerns regarding potential air
pollutant health risks that may result from the Project, potential localized air quality
impacts and related health risks for sensitive receptors (not to be confused with numeric
exceedances of SCAQMD thresholds for area-wide Basin criteria pollutants) are addressed
at Draft EIR Pages 4.4-41 through 4.4-48. The Project's potential localized air emissions
impacts as discussed it the Draft EIR are associated with the [previously] proposed gas
station [subsequently removed under the adopted Project Design Alternative], and
potential localized CO concentrations at Study Area intersections. As discussed in the
Draft EIR, the Project would not result in significant localized air quality impacts either
through operations of the previously considered gas station, nor would the Project result
in or cause CO exceedances at Study Area intersections.
Relevant responses to the commentor's concerns regarding potential health effects of
Project-related criteria pollutant emissions have also been previously provided at Pages 3-
110 and 3-111 of the August 2004 Final EIR:
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-19
Applied Planning, Inc. (Copyright © 2005)
If approved, the operation of the Project will exceed the South Coast Air Quality
Management District (SCAQMD) thresholds of significance for three of the five
criteria pollutants, including reactive organic gases (ROG), oxides of nitrogen
(NOx), and carbon monoxide (CO). Based on these exceedances, the decision-
making body will need to adopt a Statement of Facts, Findings, and Statement
of Overriding Considerations that acknowledges the exceedances and makes
findings that essentially declare that certain benefits of the Project outweigh the
environmental impacts for the Project.
The SCAQMD advises the lead agency in addressing and mitigating the
potential adverse air quality impacts caused by projects both during and after
construction. The SCAQMD has established short-term construction-related and
long-term operational thresholds of significance which they recommend for use
by lead agencies in considering both primary or direct impacts and secondary
or indirect impacts on air quality.
The SCAQMD emissions thresholds are basically indicators of potential air
quality impacts. They do not indicate whether or not State or federal clean air
standards will be exceeded in the Project vicinity and provide no information
regarding the presence or absence of sensitive receptors. In essence, the
thresholds provide an indication of whether or not the air pollutant emissions
expected to accompany a project are substantial enough to warrant analysis in
an EIR and the application of mitigation measures.
Ambient air quality is determined from data collected at air quality monitoring
stations located throughout the South Coast Air Basin. Ambient air quality data
is given in terms of state and federal standards. These standards represent air
pollutant concentrations which are considered safe (with a reasonable margin of
safety) to protect the public health and welfare. As such, they represent
objectives for acceptable concentrations of specified pollutants in outdoor air.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-20
Applied Planning, Inc. (Copyright © 2005)
Ambient air quality standards are designed to protect public health and that
segment of the population that is most sensitive and susceptible to
respiratory distress or infection such as: asthmatics, the very young, the
elderly, people weak with illness or disease, or persons engaged in heavy
work or exercise (i.e. sensitive receptors). Healthy adults can tolerate periodic
exposures to air pollutant levels well above these standards before adverse
health effects are observed.
. . . The pollutant modeling demonstrates that future carbon monoxide
concentrations adjacent to the most heavily used intersection in the Project
vicinity will be one-half of the State standard and one-third of the Federal
standard during weekday peak hours.
Localized effects of Project-related construction air emission impacts may be less
perceptible if the Project were implemented within a commercial or industrial context.
However, area-wide air quality impacts of the Project would remain significant as
determined by applicable SCAQMD significance threshold criteria. As demonstrated in
the EIR Revision, there are no feasible alternative sites that would substantially reduce the
extent or magnitude of Project's significant air quality impacts.
The commentor also states that "access to public transportation would mitigate the
long-term environmental impact of the project." In this regard, available public
transportation systems are discussed at Pages 4.3-15 and 4.3-16 of the Draft EIR, and the
Project's estimated transit demands (593 daily trips) are presented at Draft EIR Page 4.3-43.
Even assuming full use of transit systems, including transportation systems that may be
available at some unnamed alternative site, this would account for less than five (5) percent
of the Project's total daily traffic. As such, no substantial reductions in traffic or air quality
impacts would result based on potential use of transit services.
It is further noted that speculative reductions in traffic impacts and air quality impacts
based on assumed use of transit systems and transit facilities is inconsistent with
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-21
Applied Planning, Inc. (Copyright © 2005)
assessment and disclosure of the Project's probable maximum traffic and air quality
impacts, and would be similarly inconsistent with environmental assessment and
disclosure provisions of CEQA and related policies and procedures adopted by the Lead
Agency.
Potential operational noise impacts of the Project, including noise from transport trucks are
determined to be less-than-significant [Draft EIR at Section 4.51, and are therefore not
considered in the assessment of alternative sites. The commentor's statements and
opinions will be forwarded to the decision-makers. Analysis and conclusions of the EIR
Revision are not affected.
Response CHU-2
The commenter is directed to the Initial Study for the Rosemead Retail Commercial Center,
the Draft Environmental Impact Report for the Rosemead Commercial Retail Center, the
August 2004 Final Environmental Impact Report for the Rosemead Commercial Retail
Center (including the comments and responses contained therein), and the EIR Revision
for the Rosemead Commercial Retail Center containing the Alternative Site Analysis. The
totality of the information contained within these documents identifies the substantial,
adverse change in any physical conditions within the area affected by the Project.
The previous approval included the adoption of a Statement of Facts, Findings and
Overriding Considerations which acknowledged that certain impacts could. not be avoided,
but found that the benefits of the Project outweigh those impacts.
Response CHU-3
The commentor is expressing an opinion regarding the EIR Revision for the Rosemead
Commercial Retail Center. These comments will be forwarded to the decision-makers for
consideration during their deliberations on the Revised Final EIR. The analysis and
conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-22
Senator Gloria Romero, Page 1 of 1
La fornt•I t•ttr ~Irit'ltr
SENATOR =r E.
GLORIA ROMERO
ec y -V;EN`,.=QURTH =Et-.ATE ZI15 iR1C-
Ut, , /U0( .
The I lonorable Jay Imperial. Mayor
CIty of Rosemead
X%--K l=ast \ alle% Bouievard
Rosemead- CA 91-10
-Nncnuor. Brad Johnsen. Plannmt Department
Dcar Mayor impcnal.
am wnime this letter to the Ro,ericad Cny C~;uncil for submission as a written zomment to the revised
mironmcntal Impact Report I FIR ~ for the proposed Ruiemcad Commercial Retail Center and U ai-Man project
After rrvtt.-wvng the revised EIR. 1 question the soundness of the conclusions fut the report because is determines that
all three proposed alternative cites are unfeasible hecause of either tratlic conditions or proximity to residences and
IOi:al <:!tiK~ls
Howercr, the current proposed site on Walnut Grove and Rush is alsc within close proxuntt-, to a public school.
residence and the Pomona Frerw•ay. which had airead% determined previously in the onginal Environmental
Impact Ren0r, as extreme[, coneested Are you employing a double .t: ndard" Can you explain w'h} the Walnut
tirv%c and Rush site is much more preferable to the other cites despite similar conditions"
ROM-1
The revised FIR also tndicairs that althouch Wal-Mart has withdrawn its request for a _'4 hour operation of its stun.'
and that a restrictive covenwit will be recorded. the report continua or. r., ;-,i\ that am future onsideration of ROM-2
ailow•ine a 24 hour operation would requuc further envuorintemal ie%'w% 1)- 'h-. 0--
future you will consider allowinc the store to operate for 24 hours'
Be aware that 1 will conunuc to oppose bnneinc a Thal-Hart to die CttA- Rosemead becausr for evet store List
opens. oohs SR lost to the :ommutim the tax oast .hr.nio, the numi~rr of worker. with hcalthwrc hcnefi ducimc.. ROM-3
ane the numoer of w•orken cliphtc for welfare in.r_s_ses.
You! failure to prcxiuce a revised FIR that rr.es detinittxc assurances that no _4-hour operation bti Wal-P-lan will
allowed and adequatch explain, w'h± the current pr< powd site is preferable to the altemative_; is. a disregard to the
concerns and views of your zonstituentc :n Rosemead
ROM-4
1 thunk thr Cav Council and ( ommu=m Rcdcxciopmcr.! C. r.:ru>.;i.::. ivr hc:rtr.r mx ..vmmeni and look forwarc to working with v_ ou on sound econonni dex"elc~pntci:[ t;-'r :hc t l:.•sc!::e.::. sfl.Ul~f ~ n: C --n% uucstwns,
you may zontac: me at t321►
(0.0RIA ROMERO
`talc ,enaty Majorit., Leader. 24" District
Applied Planning, Inc. (Copyright © 2005)
SENATOR GLORIA ROMERO, CALIFORNIA STATE SENATE MAJORITY LEADER, 24'h
DISTRICT
Letter Dated November 11, 2005
Response ROM-1
The commenter is misinterpreting the findings of the EIR Revision. No alternative sites
were dismissed due to their traffic concerns or proximity to residences or local schools.
Each alternative site was assessed consistent with the applicable provisions of the CEQA
Guidelines, which state in pertinent part:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the Project. Of those
alternatives, the EIR need examine in detail only the ones that the lead agency
determines could feasibly attain most of the Project Objectives.
[CEQA Guidelines, §15126.6 (f)].
CEQA also provides guidance in assessing feasibility of alternative sites. "Feasibility
includes factors such as site suitability, jurisdictional boundaries and whether the
proponent can reasonably acquire, control or otherwise have access to the alternative sites."
f CEQA Guidelines, §15126.6 (f)(1)]. The alternative sites included in the EIR Revision were
assessed based on these codified factors.
The conclusion that the project is the preferred to the alternatives that were evaluated
within the Revised EIR was based on the guidance provided by the CEQA sections cited
above and the complete alternatives analysis that is presented within the Revised EIR. The
commentor is directed to pages 3-1 through 3-15 of the EIR Revision.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-24
Applied Planning, Inc. (Copyright 0 2005)
Response ROM-2
As stated on page 1-1 of the EIR Revision, the issue is no longer relevant as Wal-Mart
has provided notice to the City that it has withdrawn its request for a 24-hour operation
and a restrictive covenant will be recorded guaranteeing that no 24-hour operation of the
Wal-Mart will be allowed without further environmental review." Please refer also to
Revised Planning Department Condition of Approval (COA) presented in Section 3.0 of
this Revised Final EIR. As stated under revised COA No. 54, which now reflects the "no
24-hour operations" restrictive covenant:
The hours of operation of the major tenant shall be limited to 8:00 a.m. to 10:00 p.nt,,
except during Christmas season, in which case the hours of operation may be extended
to midnight.
Further environmental review will be provided to the extent determined necessary by the
Lead Agency, and consistent with the provisions and requirements of CEQA. At this
juncture, given that 24-hour operations of the Project are not proposed, nor defined, to
comment on the format and content of such an environmental analysis would be
speculative at best.
Response ROM-3
Potential economic impacts of the Project are summarized at Draft EIR Pages 4.1-14
through 4.1-23, and discussed in detail in Draft EIR Appendix E, "Economic Analysis."
CEQA specifically states that economic or social effects of a project shall not be treated as
significant impacts on the environment. However, physical changes that could result from
economic or social effects of projects are within the scope of CEQA considerations. The
Project will not result in, nor create significant economic impacts that would result in
adverse physical change.
Please refer to the discussion of potential Project-related economic impacts presented at
Draft EIR Section 4.1, "Land Use," the Project Economic Analyses presented at Draft EIR
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-25
Applied Planning, Inc. (Copyright © 2005)
Appendix E, and relevant responses presented in Final EIR Section 3.0, "Comments and
Responses."
Beyond these issues, the commentor is expressing an opinion regarding Wal-Mart business
practices. These comments will be forwarded to the decision-makers for consideration
during their deliberations on the Project. The analysis and conclusions of the EIR Revision
are not affected.
Response ROM-4
Please refer to Response ROM-2 for 24-hour considerations, and the analysis presented at
Section 3.0 of the EIR Revision, as well as responses presented herein, for the basis of
rejection of alternative sites.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-26
Southern California Association of Governments, Page 1 of 1
S' UI HE RN C/11 II C)t'NIA
ASSOCIATION of
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October 11 r 2005
Mr. Brad Johnson
Planning Director
City of Rosemead
8838 E. Valley Boulevard
Rosemead, CA 91770
RE: SCAG Clearinghouse No. 1 20050622 Rosemeand Commercial Retail
Center EIR - Revised Alternative Site Analysis
Dear Mr. Johnson:
Thank you for submitting the Rosemead Commercial Retail Center EIR-
Revised Alternative Site Analysis for review and comment. As areawide
clearinghouse for regionally significant projects, SCAG reviews the consistency
of local plans, projects and programs with regional plans. This activity is based
on SCAG's responsibilities as a regional planning organization pursuant to state
and federal laws and regulations. Guidance provided by these reviews is
intended to assist local agencies and project sponsors to take actions that
contribute to the attainment of regional goals and policies.
We have reviewed the Rosemead Commercial Retail Center EIR - Revised
Alternative Site Analysis, and have determined that the proposed Project is not
regionally significant per SCAG Intergovernmental Review (IGR) Criteria and
Califomia Environmental Quality Act (CEQA) Guidelines (Section 15206).
Therefore, the proposed Project does not warrant comments at this time. Should
there be a change in the scope of the proposed Project, we would appreciate the
opportunity to review and comment at that time.
A description of the proposed Project was published in SCAG's September 1-30,
2005 Intergovernmental Review Clearinghouse Report for public review and
coo niilenL.
The project title and SCAG Clearinghouse number should be used in all
correspondence with SCAG conceming this Project. Correspondence should be
sent to the attention of the Clearinghouse Coordinator. If you have any questions,
please contact me at (213) 236-1851. Thank you. _
Sincerely,
BRIAN WALLACE
Associate Regional Planner
Intergovemmental Review
Doc+11477_'
SCAG-1
!1
Applied Planning, Inc. (Copyright © 2005)
SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
Letter Dated October 11, 2005
Response SCAG-1
The Southern California Association of Governments (SCAG) has determined that the
Project is not regionally significant per SCAG Intergovernmental Review (IGR) Criteria and
California Environmental Quality Act (CEQA) Guidelines (Section 15206). SCAG findings
in this regard are acknowledged, no further response is required.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-28
City of Montebello, Page 1 of 2
aNT E 9 ESC
OPPORT UNITY
M
O
~9E~BJ' ~WEr*~
October 5, 2005
Brad Johnson, Director of Planning
City of Rosemead Planning Department
8838 E. Valley Boulevard
Rosemead, CA, 91770
Re: Comments on the revised site analysis for the Rosemead Commercial Retail
Center
Dear Mr. Johnson:
The City of Montebello appreciates the opportunity to comment on the Rosemead
Commercial Retail Center. The City has had the opportunity to review the draft and has a
few comments. The following is a list of comments related to the Notice of Availability related
to the Rosemead Commercial Retail Center EIR - Revised Alternative Site Analysis.
Section 3.2.1 Additions to Draft EIR Section 1.0. Introduction
Subsection 1.9.7 Locations Outside of the City
Although the City of Montebello understands that one of the primary objectives of the
project is to augment the City's economic base, it appears that there are two
alternative sites just outside Rosemead that could be alternative site locations. The
two sites are addressed at:
1. 2015 Potrero Grande Drive and Edison right-of-way to the west
2. 2300 Greenwood Avenue
The City of Montebello is suggesting that Rosemead consider these as possible
alternative sites as part of the revised analysis.
Section 7.3.1.2 Potential Alternative Sites
• Alternative Site 3: The City of Montebello does not consider this a viable alternate
site. Of the three alternative sites, this is the least likely to be redeveloped.
On pages 3-11 and 3-12 under the "Site Description", please be advised that th
description of what is going to happen with the Robinson's May store based on th
MON-1
MON-2
e
e
1600 best Beverly Boulevard • Montebello. California 90640-3932 • ( 3231 887-1200
City of Montebello, Page 2 of 2
merger of Rob/May and Macy's is not accurate. The Rob/May will remain open as
a Macy's store providing women's apparel, children's apparel, and household
furnishings. Please contact Kathy Arndt at the Montebello Town Center for the
correct description of the changes for Macy's and Rob/May.
Based on the fact that Macy's is going to covert Rob/May into a second Macy's MON-2
store, it is the City's opinion that this is not an appropriate alternative to use in the (COnt'd)
analysis.
If you have any questions or concerns regarding this letter or the City's comments, please do
not hesitate to contact me at (323) 887-1475.
Sincerely, r
ichael A. F~untley
Director of Planning
Xc: 2005 Letter File
Applied Planning, Inc. (Copyright © 2005)
CITY OF MONTEBELLO
Letter Dated October 5, 2005
Response MON-1
As presented in the CEQA Guidelines:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the Project. Of those
alternatives, the EIR need examine in detail only the ones that the lead agency
determines could feasibly attain most of the Project Objectives.
[CEQA Guidelines §15126.6 (f)].
The selection and scope of potential alternative sites presented within the Alternative Site
Analysis EIR Revision is as determined by the Lead Agency, and the Alternative Site
Analysis is presented consistent with CEQA Guidelines §15126.6. Further, and as noted by
the commentor, the two referenced sites are outside of the City limits, and are therefore
beyond control of the lead agency. In this respect, as noted within the CEQA Guidelines:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
[emphasis added] and whether the proponent can reasonably acquire, control
or otherwise have access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
At face value then, the two referenced sites fail to meet feasibility criteria in that they do
not achieve a primary objective of the Project which is to increase City tax revenues.
Further, the subject sites are not under jurisdiction of the Lead Agency. Nor is it
considered likely that the Project Proponent could reasonably acquire the referenced
properties.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-31
Applied Planning, Inc. (Copyright © 2005)
Notwithstanding the above considerations, which would effectively eliminate the 2015
Potrero Grande Drive and 2300 Greenwood Avenue sites as potential alternative locations
for the Project, the following discussions expand on aspects of these sites which render
them infeasible.
2015 Potrero Grande Drive; Monterey Park, CA - This address is a commercially- zoned
property, located adjacent to residential units. Detracting from this site's potential as a
location for the Project, the subject property is not under control of the Project proponent
and is not within the jurisdiction of the City of Rosemead. The site is currently occupied,
and owned in part, by the San Gabriel Nursery & Florist which has been in operation there
for more than 80 years and therefore, the site is unlikely to be available. Any acquisition
would also require demolition and removal of all facilities that exist on the subject site
(such demolition is not required at the current site). The site is also encumbered by several
high-tension electrical lines and associated Southern California Edison (SCE) easements,
which lines and easements traverse the rear of the property, acting to constrain the
buildable area and limiting this area to approximately 10 acres, which is too small for a
Wal-Mart Supercenter.
Furthermore, locating the Project in this area would at best only relocate the Project's
impacts, not reduce them, as is the primary intent and purpose of the alterative site
analysis. Significant traffic impacts would still occur due to mainline freeway traffic
volume increases and applicable SCAQMD thresholds would still be exceeded. Transient
and temporary construction noise impacts would be reduced in that the City of Monterey
Park noise standards exempt construction noise. However, the actual level of construction
noise would not be reduced, and noise generated during construction activities would
result in annoyance of vicinity residential uses.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-32
' Applied Planning, Inc. (Copyright © 2005)
' 2300 Greenwood Avenue; Monterey Park, CA.- The size and zoning of this property
appear appropriate for the Project; however, a retail center anchored by a Home Depot has
been approved for this site and the City of Monterey Park has stated that there is not
' sufficient space to also develop a Wal-Mart at the same location.'
t Additionally, and as noted for other locations considered herein, locating the Project in this
area would not substantially reduce Project's impacts, as is the primary intent and purpose
' of the alterative site analysis. Significant traffic impacts would still occur due to mainline
freeway traffic volume increases, and applicable SCAQMD thresholds would still be
' exceeded. Transient and temporary construction noise impacts would be reduced in that
the City of Monterey Park noise standards exempt construction noise and the site is not
' proximate to sensitive receptors. However, the actual level of construction noise would not
be reduced.
' Lastly, it is reiterated that the purpose of the Alternative Site Analysis is to identify
potential locations which could foremost, substantially reduce the Project's significant
environmental impacts. The commentor's opinions will be forwarded to the decision-
makers. Analysis and conclusions of the Alternative Site Analysis are not affected.
1
' 1 Telephone conversation of Brad Johnson with Monterey Park Planning Department on November 29, 2005.
' Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-33
Applied Planning, Inc. (Copyright @ 2005)
Response MON-2
The EIR Revision acknowledges that the status of the Robinsons-May/Montebello Town
Center site for future redevelopment is questionable. In this regard, comments on the EIR
Revision provided by the City of Montebello have removed the Robinsons-
May/Montebello Town Center site from consideration as a potential location for the Project.
Based on the City of Montebello's comments, Pages 3-11 and 3-12 of the Revised
Alternative Site Analysis are amended to read as follows:
a. Site Description
Alternative Site 3, located on the eastern edge of the Montebello Town Center
mall, was identified as a possible alternative due to the recently announced
corporate mergerbetween the May Department Stores Company and Federated
Department Stores, Inc. The closure of the Robinsons-May store is anticipated
by the City, although this store was not identified in the latest list of locations
planned for divestiture, issued by Federated Department Stores on July 28,
2005. In response to the Revised Alternative Site Analysis. Rosemead has
learned that this site will not be available as the store will remain open as a
Macy store.
stones aFe being studied fbt- potential convemion of the Bloomingdale~s
then being vacated. Them is mo indication, howevet-, that the Momtebefic T-own
eenteF location would he inciuded in this plign.
b. Potential Feasibility of Site
a. The existing Robinsons-May store is approximately 140,100 square feet
in size, and is located on an 8.75 acre parcel that provides shared mall parking,
as shown in the following Figure 7.3-3. In order to accommodate the proposed
Wal-Mart Supercenter, substantial re-design of the Project would be required,
resulting in the construction of a multiple-story facility with additional, at-grade
or subterranean parking. Based on the information from the City of Montebello,
as well as problems relating to project design, the site is considered unavailable
and the alternative reiected as infeasible.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-34
Applied Planning, Inc. (Copyright © 2005)
Beyond the obstacles of site availability and project design, compatibility
between the proposed Wal-Mart and the existing mall is an additional concern.
The Montebello Town Center is an upscale, regional mall. As such, retailers
within this mall seek to draw consumers from a different market sector than that
of the discount retailer and grocery seller, and the introduction of a discount
retail/grocery use within the existing mall could be incompatible and have a
detrimental economic effect on adjacent retailers. Accordingly, this alternative
site was determined to be infeasible.
Because the EIR Revision already acknowledges that the status of the Robinsons-
May/Montebello town Center site for future redevelopment is questionable, the additional
information does not change any analysis or conclusions in the Revised Alternative Site
Analysis. Alternative 3 was also rejected within the EIR Revision due to its inability to
significantly avoid or lessen the Project's permanent impacts.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-35
CITY Or: MONTEREY PARK
we ftew ne."wo weave • A*mft v nr.. ram "w Af,"P.M6
~
November 10. 2005
M-r. Brad Johnson, Planning Director
City of Rosemead
6638 E. Va!lev Boulevard
Rosemead. CA 91770
RF- COMINIEN"I'S ON THE ROSFNIFAD COMN- fF;RUT 81. RETAIL CENTER- EtR
REVISION-ALTE+WNATIVE SITE ANALYSIS
Dear Mr. Johnson
Thank you for providing the City of Monterey Pa; K the opportunity to comment on the revised
FIR Alternative Site Analysts for the Rosemead Commercia' Retx Center prepared ty Applied
Pluming, Inc.
City S:a'f has reviewed the document regarding the proposed project. and have the following
Seeing that the revised EIR only addresses Alternative Site Analysis and no changes were made
to the traffic portion of the project the City of Monterey Park reiterates it's original concern and
has no further comments.
As previously stated, during the review of the Notice of Preparuion, the City of Monterey Park
raised potential local concerns regarding traffic impacts on streets and the 60 Freeway In
response, the Draft EIR and Traffic Analysis, "Rosemead Retail Center Traffic Impact Study"
(Endo Engineering) April 2004, has msponded to those concerns. The study notes that potential
mcmased traffic volume and traffic congestion has begat deemed lass-than-significant because
project4niuated traffic improvements and related trafficlcireulabon nequtrements identified
within the City of Rosemead's Conditions of Approval will result to acceptable levels of service
at the anticipated build-out of the project.
The Traffic Impact Study further identifies that i»ereased vehicle densities on certain 60-
Freeway segments that currently operate below level of service (LOS) "C" (low restricted flow)
have been deemed significant and unavoidable. According to Caltrans, traffic is predicted to
increase with or without the build-tut of the proposed project Additionally. the study noted that
on and off-ramps at the 60-Freeway appear to operate at below capacities.
City of Monterey Park, Page 1 of 2
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City of Monterey Park, Page 2 of 2
Comments to Revised 19IR-Alternative Site Analysis
Rosemead Commercial Retail Center
November 14, 2005
Page 2 of 2
It is the City of Monterey Park's understanding that Caltrans has responded to the Draft EIR.
Caltrans notes that, "additional current and future weekend traffic counts for westbound Route
60 and San Gabriel off-ramp, and the traffic analysis should include the intersection of
Paramount Boulevard and the eastbound Route 60 off-ramp." As noted, this analysis should be
undertaken. Caltrans further specifies that mitigation measures may be necessary for these
intersections. if the results of the analysis warrant improvement.
The City of Monterey Park does recognize that it would not be feasible for any new individual
development to undertake freeway lane expansions. The traffic impact study indicated that
Caltrans has been considering the addition of new freeway lanes to the Pomona Freeway in the
Study Area within the next two to three years. It is understandable Caltrans' goals for freeway
land expansions are beyond the scope of traffic improvements that the proposed project can
achieve.
Seven categories were discussed in the cumulative impacts Section 4.8 of the Draft EIR. The
seven categories include Land Use, Earth Resources, Traffic and Circulation, Air Quality, Noise
Public Services, and Aesthetics 1 light and Glare. Of the seven, three categories are considered
less-than-significant- These three categories include Land Use, Public Services, and Earth
Resources. Traffic will have a significant impact, as discussed earlier, along with Air Quality,
Noise and Aesthetics / Light and Glare. The City.of Monterey Park understands that mitigation
measures will be implemented to address these impacts.
The City of Monterey Park may consider providing commenu on the project at any future public
meeting on the matter. Please forward the Final MR. and Mitigation Monitoring Program
Should you have any further questions, please contact this office at (626) 307-13I5.
Sincerely,
' Samantha Duong
Acting Associate Planner
e: Adolfo Reta, Development Services Director
Ray Hamada, Planning Manger
Margarita Crux, Economic Development Director
Planners
L
rl
MP-1
(cont'd)
Applied Planning, Inc. (Copyright © 2005)
CITY OF MONTEREY PARK
PLANNING DEPARTMENT
Letter Dated November 10, 2005
Response MP-1
The City is providing an overview of the Project and their understanding of the facts as
presented within the environmental documentation prepared for the Project. No response
is necessary. Analysis and conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-38
Garvey School District, Page 1 of 1
6ARVEY SCHOOL DISTRICT
L' ' i•. ,sill North Del Mar Avenue. Rosemead. C:% 917'0 (626) 307-344-1
lit ) BRI EM *H. Pr;;el,ierrr Board of EdUCCIMM
tinverriber 1U. 24G`
IMARD OF UJI'r'aT10'1
Bob 13ruesch
Irrue Flores
licnr, I o
foiin 1 uen
~itfl~
Rosemead Cm Council
Ry S, F Valk, Blvd.
Rosemead. CA 917-0
Re Addendum: e! 11t, A.11`tarl 1 1 R
Thank :ou tbi the upaurtutur.° to respond to thr analysts of alternate sites to the %k'al!.larr protect to be located on Walnut
Grr„ -v A•,e (The E I R Re,.tcwni .you mo,,. last tear uur Board of Educauort passed a resolution itating+ that the 1)Ismcl
wa nnpo5cd n. ;stahh;flu e <.uch a lar::' :u;nmeri ial •_enter across the spree: from one of,wr schooiS and two blocks awa) :;„ni GSD`1
IWil nth,.. 0 ar,~itu :!a. f1.•! ,i!a ..in.. i~•:. :h.~ ;i: ~,i!,.. ,it ..l:• ~..:!ir..... a.•• .!r1. .:.t.. !i..
report
I I
Although the report ;tats, that the ciwironmental impacts ufihc protect to the area. snecificall, the caflic and air quairty,
cannur b: mitiuated b, nwwing the site. we reel that the report dealt wnh the impact on rite region.. not the specific area of our
schools True piacirie of the WaMart protect at dry of the other sties will not impro.e the air pollution or traffic congestion In
Snuthem California. the mo, ine +,f thr protect awa} from our schools would. ho,re%,er. have a pnsm%c :ffcci on the health and
~atetn of Our students. It is a proven to t that %oumg :hildren are more acutely affened by the Irutahna ot'vehicle -tmssions. GSD`2
particularly carbon monoxide. ROi7s and Particulate Manor. Since all schools are do,alwind from the site the poor qualm o!
the air nreathr.u h, children wili cr:;ail;ly hie ezacrrbat::d, putting the most vulnerat+te of our a117enc in grcatei danger of
coniractm lung diseases
Increased traffic to the vicinity of any schonl IF. al..•avs a d3nf:er to children traveling to and from school, In the morning.
children are ualkim. to school at the height of the traffic tlo.m, and after school tile, would hase to v.-atch for increased traffic
flow caused by the massn-r ize of the proposed de%ciopmrnt. Add to that equation a major Youth athieuc field on ate cangvw GSD`3
of one school i.iesse oorizwer Sports Complex I. the almost universal aner-,,chooi ?rugrams tboth academic and recreational: i :it
each scuooi site. and the construction of a iarvr c:lmmuni , gymnasium a: Fcmple School to Marco. •Jou can see that chiiurci':
will be !oing to and cnmtrg from those schools fratn -:30 m the morning to °!2ttt or nine o Clock In the -%ening.
It secmi nxirr io ical to piace the N alMa r prulrn u; an ahrad% ngtahlished commercial-industrial zone. such as the Valle} a;!d
T°nmle Cir: Blvd vvher- there alrcadc tti a,veli established hi,_h Volume iraili: corridor i Valley Bkd.I and is far an-ay from
~Chticlls ithe nearest beinu six blocks a,va% I :\n idc;j evvii more appeahn_` %%ould be the inte,raune of dud ;tore Into an alread'. GSD-4
-StahLshed shopping genre:. like the `ufunt-)ciio ruwti c enter. thus separat:n it from our residential neighborhoods,
1-haui.:ou for lentil- w express uur concerns re ardln this man
S tncerel, .
v . rucsct:. 'rryidcai
4 ;at-, e•: ~chuoi L)istrict
Board o!' E:aucanun
Equai (triorturim Emplover • Non-Discrinntiation on Basis of Race. Color. Atlcest?). Rt11210us greed Sex. Handicap. Ape
Applied Planning, Inc. (Copyright © 2005)
GARVEY SCHOOL DISTRICT
Letter dated November 10, 2005
Response GSD-1
The commentor expresses opinions regarding the Project, and preference for consideration
of alternative sites. These opinions and statements will be forwarded to the decision-
makers.
Response GSD-2
The EIR does conclude and disclose that, even after the application of all feasible mitigation
measures, the Project will result in certain exceedances of South Coast Air Quality
Management District (SCAQMD) emissions thresholds. In this regard, additional
pollutants generated by the Project will generally affect regional air quality conditions.
However, such effects do not equate to localized health risks. As a point of fact, due largely
to ambient air pollutant conditions within urban Southern California, it is not uncommon
for new development projects to exceed SCAQMD emissions thresholds.
Consistent with the provisions of CEQA, the City may decide to proceed with the Project
in spite of its significant air quality impacts. In this regard, the previous Project approval
included the adoption of a Statement of Facts, Findings and Overriding Considerations
which acknowledged that certain impacts could not be avoided, but found that the benefits
of the Project outweigh those impacts.
More specifically, potential air quality impacts of the Project are discussed within Draft EIR
Section 4.4, "Air Quality," and the detailed technical Air Quality Impact Study presented
within Draft EIR Appendix D, "Air Quality and Noise Impact Study." Air quality impacts
significance thresholds applicable to the Project are based on criteria pollutant thresholds
established by the SCAQMD, and subsequently adopted by the Lead Agency. And it is on
this basis, when evaluated against established SCAQMD criteria, that certain air quality
impacts of the Project are determined to be significant. The Project's significant air quality
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-40
Applied Planning, Inc. (Copyright © 2005)
impacts are area-wide or regional in nature, and the SCAQMD thresholds are the accepted
criteria to quantify the Project's relative individual contribution to basin-wide air quality.
These significant impacts are not however, a specific indicator of localized health risks.
With the exception of certain adopted localized criteria and standards, discussed below,
SCAQMD thresholds are not location-specific within the South Coast Air Basin (Air Basin).
On this basis, air quality exceedances that are generated by the Project would result
irrespective of its location within the Basin.
With specific regard to the commentor's expressed concerns regarding potential air
pollutant health risks that may result from the Project, potential localized air quality
impacts and related health risks for sensitive receptors (not to be confused with numeric
exceedances of SCAQMD thresholds for area-wide Basin criteria pollutants) are addressed
at Draft EIR Pages 4.4-41 through 4.4-48. The Project's potential localized air emissions
impacts as discussed in the Draft EIR are associated with the [previously] proposed gas
station [subsequently removed under the adopted Project Design Alternative], and
potential localized CO concentrations at Study Area intersections. As discussed in the
Draft EIR, the Project would not result in significant localized air quality impacts either
through operations of the previously considered gas station, nor would the Project result
in or cause CO exceedances at Study Area intersections.
Relevant responses to the commentor's concerns regarding potential health effects of
Project-related criteria pollutant emissions have also been previously provided at Pages 3-
110 and 3-111 of the August 2004 Final EIR:
If approved, the operation of the Project will exceed the South Coast Air Quality
Management District (SCAQMD) thresholds of significance for three of the five
criteria pollutants, including reactive organic gases (ROG), oxides of nitrogen
(NOx), and carbon monoxide (CO). Based on these exceedances, the decision-
making body will need to adopt a Statement of Facts, Findings, and Statement
of Overriding Considerations that acknowledges the exceedances and makes
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Comments and Responses
Page 4-41
Applied Planning, Inc. (Copyright © 2005)
findings that essentially declare that certain benefits of the Project outweigh the
environmental impacts for the Project.
The SCAQMD advises the lead agency in addressing and mitigating the
potential adverse air quality impacts caused by projects both during and after
construction. The SCAQMD has established short-term construction-related and
long-term operational thresholds of significance which they recommend for use
by lead agencies in considering both primary or direct impacts and secondary
or indirect impacts on air quality.
The SCAQMD emissions thresholds are basically indicators of potential air
quality impacts. They do not indicate whether or not State or federal clean air
standards will be exceeded in the Project vicinity and provide no information
regarding the presence or absence of sensitive receptors. In essence, the
thresholds provide an indication of whether or not the air pollutant emissions
expected to accompany a project are substantial enough to warrant analysis in
an EIR and the application of mitigation measures.
Ambient air quality is determined from data collected at air quality monitoring
stations located throughout the South Coast Air Basin. Ambient air quality data
is given in terms of state and federal standards. These standards represent air
pollutant concentrations which are considered safe (with a reasonable margin of
safety) to protect the public health and welfare. As such, they represent
objectives for acceptable concentrations of specified pollutants in outdoor air.
Ambient air quality standards are designed to protect public health and that
segment of the population that is most sensitive and susceptible to respiratory
distress or infection such as: asthmatics, the very young, the elderly, people
weak with illness or disease, or persons engaged in heavy work or exercise (i.e.
sensitive receptors). Healthy adults can tolerate periodic exposures to air
pollutant levels well above these standards before adverse health effects are
observed.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-42
Applied Planning, Inc. (Copyright © 2005)
. . . The pollutant modeling demonstrates that future carbon monoxide
concentrations adjacent to the most heavily used intersection in the Project
vicinity will be one-half of the State standard and one-third of the Federal
standard during weekday peak hours.
Localized effects of Project-related construction air emission impacts may be less
perceptible if the Project were implemented within a commercial or industrial context.
However, area-wide air quality impacts of the Project would remain significant as
determined by applicable SCAQMD significance threshold criteria. As demonstrated in
the EIR Revision, there are no feasible alternative sites that would substantially reduce the
extent or magnitude of Project's significant air quality impacts.
Response GSD-3
The Project will not result in, nor create significant traffic safety impacts, including
potential traffic safety issues that may affect student populations. Please refer to the
discussion of potential Project-related traffic impacts presented at Draft EIR Section 4.3,
"Traffic and Circulation," within Draft EIR Appendix C, "Traffic Impact Study," and
relevant responses presented in the August 2004 Final EIR Section 3.0, "Comments and
Responses." Potential traffic impacts that may affect pedestrian traffic in general, and Rice
Elementary School students in specific, are addressed at Draft EIR Pages 4.3-43 through 4.3-
46. Based on applicable threshold criteria, potential Project impacts related to pedestrian
safety (including pedestrian students) are determined to be less-than-significant. Further,
as provided for in the Project Conditions of Approval, COA No. 41:
Prior to issuance of a certificate of occupancy for Phase 1 Improvements, Developer shall
deposit an amount determined by the City Engineer for the costs of installing a flashing
beacon at school crossing and funding a school crossing guard program at the comer of
Rush Street and Delta Avenue for a minimum of 20 years.
Implementation of the above Condition of Approval will act to ensure safety of pedestrians
using the school crossing on Rush Street.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-43
Applied Planning, Inc. (Copyright © 2005)
It is further noted that when the EIR was challenged in Court, it was determined by the
Court that criticism of the treatment in the EIR of traffic impacts was without merit. And
further, that the EIR adequately discusses this issue, and the City's decision to proceed with
the Project in spite of identified traffic impacts is supported by substantial evidence.
Response GSD-4
As presented in the CEQA Guidelines:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the Project. Of those
alternatives, the EIR need examine in detail only the ones that the lead agency
determines could feasibly attain most of the Project Objectives.
[CEQA Guidelines §15126.6 (f)].
Pages 3-11 through 3-14 of the EIR Revision substantiate that the Robinsons-
May/Montebello Town Center site fails at several levels within the context of the CEQA
"rule of reason" criteria and standards for identification and consideration of alternatives
to the Project. Foremost, selection of the Robin sons-May/Montebell o Town Center site
alternative would not substantially reduce permanent significant environmental impacts
of the Project. At best, these impacts would be transferred from one locale to another.
The Robin sons-May/Montebello Town Center site also fails in terms of its feasibility. In this
regard, CEQA provides guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site.
[CEQA Guidelines §15126.6 (f) (1)].
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-44
Applied Planning, Inc. (Copyright @ 2005)
As presented in the EIR Revision, the referenced Robinsons-May/Montebello Town Center
site is not currently under control of the Project proponent (and for that matter is not
known to be available). In this regard, the EIR Revision acknowledges that the status of
the Robinsons-May/Montebello Town Center site for future redevelopment is questionable.
And in point of fact, comments on the EIR Revision provided by the City of Montebello
have removed the Robinsons-May/Montebello Town Center site from consideration as a
potential location for the Project. Based on the City of Montebello's comments, Pages 3-11
and 3.12 of the Revised Alternative Site Analysis will be modified to read as follows:
a. Site Description
Alternative Site 3, located on the eastern edge of the Montebello
Town Center mall, was identified as a possible alternative due to the
recently announced corporate merger between the May Department
Stores Company and Federated Department Stores, Inc. The
closure of the Robinsons-May store is anticipated by the City,
although this store was not identified in the latest list of locations
planned for divestiture, issued by Federated Department Stores on
July 28, 2005. In response to the Revised Alternative Site Analysis.
Rosemead has learned that this site will not be available as the store
will remain open as a Macy's store. The Federated amnotmeemen
notes that '~e small numbeF of stoms are beimvy studied for potentiB
w0did be included in this ptan.
b. Potential Feasibility of Site
a. The existing Robinsons-May store is approximately 940,100 square feet
in size, and is located on an 8.75 acre parcel that provides shared mall parking,
as shown in the following Figure 7.3-3. In order to accommodate the proposed
Wal-Mart Supercenter, substantial re-design of the Project would be required,
resulting in the construction of a multiple-story facility with additional, at-grade
or subterranean parking. Based on the information from the City of Montebello.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Comments and Responses
Page 4-45
Applied Planning, inc. (Copyright © 2005)
as well as problems relating to project design, the site is considered unavailable
and the altemative rejected as infeasible.
Beyond the obstacles of site availability and project design, compatibility
between the proposed Wal-Mart and the existing mall is an additional concern.
The Montebello Town Center is an upscale, regional mall. As such, retailers
within this mall seek to draw consumers from a different market sector than that
of the discount retailer and grocery seller, and the introduction of a discount
retail/grocery use within the existing mall could be incompatible and have a
detrimental economic effect on adjacent retailers. Accordingly, this alternative
site was determined to be infeasible.
Because the EIR Revision already acknowledges that the status of the Robinsons-
May/Montebello town Center site for future redevelopment is questionable, the additional
information does not change any analysis or conclusions in the Revised Alternative Site
Analysis.
Please refer to EIR Revision at Pages 3-8 through 3-11 for the basis of rejecting the Valley
Boulevard at Temple Boulevard site.
As summarized above, and supported by information and findings presented within the
EIR Revision, selection of the Robinsons-May/Montebello Town Center site would not
realize any substantive environmental relief or benefit when compared to the current
Project site. Nor is the Robinsons-May/Montebello Town Center site considered to be a
feasible location for the Project based on its lack of availability and physical constraints.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No, 2003121095) Page 4-46
Save Our Community, Page 1 of 3
SAVE OUR COMMUNTIY
YES ON RECALL
8324 Rush St.
Rosemead, CA 91770
October 28. 2005
Mayor and City Council
City of Rosemead
8838 E. Valley Blvd.
Rosemead, CA 91770
Subject: Public Hearing
Rosemead Commercial Retail Center
Alternative Site Analysis
EIR Revision - September 2005
Mayor and City Council
The first objection is to the misstatement of this report title. This project has always been known
as the Wal-Mart Discount Supercenter The change in title is obviously an effort to make the
project eligible to be rated - for traffic and other items - as a commercial center that has different
projected traffic and several other items, than has a Discount Supercenter. SOC-1
The project is a Discount Supercenter and it is an obvious lie to title or pretend it is anything
else. In the following statement, we will continue to use the proper description.
COMME.NT #1 P 3-4 `Based on the reopening of the supermarket (at the Rosemead
Supermarket site) and the vitaliq, of the other existent uses this site was not considered....
Obviously this consultant did NOT do his homework. A lease study of this property will prove
that there has been an inordinate number of leasehold changes within the past fifteen years with,
now, ALL the leases (except the post office) changing hands at least two times. In addition there
have been several owners of the properties (two separate lots, two separate owners). There has
been constant litigation concerning original covenants being broken with each succeeding
ownership. Due to this litigation, one tenant - "Valley Grill" - has been vacant for nearly five
years and arson was suspected in the fire at another restaurant site. The two owners of the
property have fought each other with rival development plans for several years, never being able
to agree on anything, while the city sat back as an unconcerned observer.
COMMENT #2 AL TERNA TE SITE I (pp 3-4 - 3-8)
First, the claim that, to make this a viable alternative they would have to increase the Auto
Auction site size (15.2 acres) to 19 acres by including residential properties on Virginia Ave.,
this is the old scare tactic to include residential property condemnations to kill the idea. In
reality, the Auto Auction owns three lots to the south of Garvey Ave that they use for parking
and storage (the old Boys Club site and the telephone building) that, if included in this alternate
site would increase developable area to over 20 acres, 'l3 acre less than the proposals current
need for the Wal-Mart store -
SOC-2
SOC-3
Save Our Community, Page 2 of 3
On p 3-6 they claim that "...none of the identified properties are listed for sale ...land it is not/
reasonably foreseeable that any of these properties will come available.for sale in the near
future " This is a real stretch of the truth Each time the Auto Auction has changed hands in the
past twenty years (four times) they have threatened to move out of Rosemead, usually looking SOC-4
toward the Inland Empire with direct freeway access. The truth is they want to expand and have
all of their functions on site and would willingly accept the moving plan that is required under
redevelopment law
Finally, their LOS figures on p 3-7 lead one to believe that the 60 Freeway is less congested than
the 10 Freeway at "peak hours." Traffic planners consider any freeway LOS of "D;" "E" or -F
unacceptable. Forgotten in this equation, also, is the fact that Garvey Ave. is already a SOC-5
frequently used alternative to both the 10 and 60 Freeways in the p.m. peak times. Having Wal-
Mart on Walnut Grove would divert a significant portion of this "overflow" traffic onto that less
used city street.
COMMENT #3 ALTERNATE .SITE 2 (pp 3-8 - 3-11)
This is the most egregious misstatement of history and fact. First they state, in reference to the
commercial and light industrial properties along Temple City Blvd., "None of these parcels are
located within a redevelopment zone" (p 3-10). Though this is true of some of the lots, some of SOC-6
them ARE in the Redevelopment Zone, and a city is allowed to use its redevelopment powers to
ensure the integrity of a project, including obtaining property outside but contiguous to a current
redevelopment zone. Further, the referred to extensive relocation of businesses... " that
would be needed is a vital part of the redevelopment process.
Additionally, they state that, with all those parcels and the covering of the wash, the total area
would be "...8.75 acres ...which is considerably less than the required 18 acres" (p 3-10).
Obviously this consultant did NOT study the history of this site because the City
CounciURedevelopment Agency seriously considered a joint development plan with El Monte
for this site just four years ago. The plan included parcels on the east side of the wash that lie
within a redevelopment zone in El Monte, thus extending the site to nearly 18 acres - the area
required by the project. Right now, the old Howard's warehouse site and a trucking concern -
both situated on the El Monte side adjacent to the wash - are for sale. Add these two sites to the
two corner sites in Rosemead for sale plus the two lots on Abilene already owned by the City,
and most of the acquisition problems could be solved with a direct sale of property to Wal-Mart.
Of course, such a development plan would demand a great amount of cooperation between the
two cities and a sharing of tax revenues. Again, the City Council seems so enamored with the
Walnut Grove site they are either unable or unwilling to make the concerted effort to make this
site a viable alternative.
COMMENT 94 ALTERNATE .SITE 3 (pp 3-11 - 3-14)
It is true, as the Addendum states, that there has not been a definitive decision on what will be
done with the Robinson's-May store. Many rumors are flying - Macy"s will expand there,
BloominL_>>dale's will take it over - but the assertion that the Town Center Mall "...is an upscale
regional mall.../that] seeks to draft, a different market sector than that of a discount
SOC-7
SOC-8
Save our Community, Page 3 of 3
- 3 -
retailer... "(p 3-12) is ludicrous. Penney's and Mervyn's certainly do not aim at the high-end
markets. Further, many modern suburban malls are aiming their marketing appeals at a broader
cross-section of customers to increase their sales, Insisting that "...the intrrduction of a
discount retail/grocer), store could be incompatible livith other mall businessesl and lmgyj
have a detrimental economic effect on adjacent retail businesses" (p 3-12) shows that this
consultant has not visited the upper Midwest lately where several Wal-Mart's are located in
regional malls. Further, this argument refutes the City's original argument that locating a Wal-
Mart in the south end of the City would have "negligible" effect on local, smaller businesses.
Finally, I challenge the consultant to name a Wal-Mart that has been built in the San Gabriel
Valley that HAS NOT been built in a commercial zone with already established stores or a
shopping center.
CONCLUSION
This Alternative Site Analysis shows the same sloppy research and analysis that called the
original EIR into question. It does not show a thorough understanding of the actual business
activity within the city or a complete knowledge of marketing trends within the commercial
business world. It bases its conclusions on partial (at best) real estate information and a
complete lack of consideration of past city development plans. Again, the City, through using
this report to justify their desired Wal-Mart plan, shows us a Council unwilling to exert the effort
to grapple with the REAL issues of development - a business vision, an in-depth knowledge of
local business trends, and an inability to use their redevelopment powers to bring about
acceptable changes within our City's business sector.
The placement of Wal-Mart should be used to strengthen the existing troubled commercial areas
in the City of Rosemead - not to place a commercial development a mile or more from the
current struggling Rosemead commercial area and imposed on a residential area.
Sincerely,
SAVE OUR COMMUNITY
YES ON RECALL
SOC-9
SOCA 0
L. C. Bevington
Chairperson
Applied Planning, Inc. (Copyright © 2005)
SAVE OUR COMMUNITY
Letter Dated October 28, 2005
Response SOC-1
There has been no change in titling of the Environmental Impact Report. The title of the
original Environmental Impact Report (EIR) is "Rosemead Commercial Retail Center Draft
Environmental Impact Report," City of Rosemead, April 2004. The title of the Final
Environmental Impact Report is "Final Environmental Impact Report for the Rosemead
Commercial Retail Center," City of Rosemead, August 2004. Consequently, the title of the
Alternative Site Analysis EIR Revision is "Rosemead Commercial Retail Center, Alternative
Site Analysis, EIR Revision," City of Rosemead, September 2005.
Response SOC-2
The commenter is directed to the site selection criteria outlined within Section 7.3.1.1 of the
EIR Revision. Any potential site would have to be approximately 18 acres in size, and have
the ability to accommodate a 230,000 square foot building and associated parking. The
discussion at Page 3-4 of the EIR Revision correctly points out that the existing grocery
store accounts for 3 acres of land and even with the addition of the Valley Grill site, the site
is still inadequate to accommodate the Project. In fact, the supermarket and the Grill site
would barely accommodate the footprint of the building (230,000 square feet equals
approximately 5.2 acres). In addition, the site would still need to provide in excess of 900
parking aisles, ingress and egress roads, setbacks, and landscaping. As concluded in the
EIR Revision, the site is inadequate to be considered as a potential alternative site.
Response SOC-3
The commentor has identified additional properties that are located south of Garvey, a
major east/west arterial highway. The addition of these properties would require the use
of remote parking and crossing a highway to access a retail store is not a realistic
suggestion. The discussion within the EIR Revision is accurate as presented.
Roseinead Coinmercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-50
Applied Planning, Inc. (Copyright © 2005)
Response SOC-4
To assemble anything larger than four acres would require that multiple property owners
be engaged and encouraged to sell their property. Some of these are within RDA #2,
however many of them are not. Such an assemblage would further require the
displacement of residents that are unwilling to sell their property. Additionally, the owner
of the central 2-acre parcel within this suggested assemblage of properties has been
meeting with the City to discuss development opportunities for another mixed-use project
or a mini-mall type of commercial retail design. Regardless of the disposition of the
parcel(s), as discussed at page 3-8 of the EIR Revision, the relocation of the Project site to
this site would not substantially lessen, nor avoid any of the significant impacts identified
within the Draft EIR.
Response SOC-5
The commentor provides unsubstantiated assertions regarding traffic conditions and traffic
patterns, with no clear relevance to the EIR Revision. These comments are included for
consideration by the decision-makers.
As discussed in the EIR Revision, impacts to the freeway mainline system (Interstate 10 or
State Route 60) would not be reduced or significantly lessened through implementation of
the Project at Alternative Site 1. As such, location of the Project at the considered
alternative site will not substantially alter or alleviate vehicle densities along Caltrans
freeways, and Caltrans vehicle density significance thresholds would still be exceeded.
Response SOC-6
The commentor is inaccurately interpreting the discussion. The preceding sentence
explains, "Development of the Project would also require obtaining property along Temple
City Boulevard currently used for office, commercial, and light industrial uses. None of
these (referring to properties other than the focal alternative site) are located within a
redevelopment area." Please refer also to Response SOC-4.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-51
Applied Planning, Inc. (Copyright © 2005)
Response SOC-7
The commentor speculates on the ability to acquire and assemble the properties and reach
a tax-sharing agreement between two adjacent municipalities. In point of fact, the City's
efforts to assemble 18 or more acres at Temple City and Valley was ultimately deemed
infeasible, and was abandoned. Subsequent development activity in El Monte presents
even further barriers for such an assemblage. Please refer also to Responses SOC-4 and
SOC-6.
The commentor is further directed to the EIR Revision at Page 3-10, Section C, Comparison
of Environmental Impacts. As discussed therein, even if development of the alternative
was feasible, none of the significant environmental impacts would be avoided or
substantially reduced by developing the Project at this location.
Response SOC-8
The Montebello Town Center represents an upscale regional shopping mall within the San
Gabriel Valley. The contents of the discussion presented within the EIR Revision are
accurate. The boutiques and retailers located in the Mall depend on the synergy that is
created by having upper-end retailers and anchors within the Mall.
Irrespective of the mix of users within the Mall, the Robinsons-May/Montebello Town
Center site also fails in terms of its feasibility. In this regard, CEQA provides guidance
when assessing the feasibility of alternative sites: "Feasibility also includes factors such as
site suitability, jurisdictional boundaries, and whether the proponent can reasonably
acquire, control, or otherwise have access to the alternative site" [CEQA Guidelines §15126.6
(f) (1)]. As presented in the EIR Revision, the referenced Robinsons-May/Montebello Town
Center site is not currently under control of the Project proponent (and for that matter is
not known to be available), and is not configured to reasonably accept the Project building
footprint and facilities plans.
Lastly, based on comments to the EIR Revision provided by the City of Montebello, the
Robinsons-May/Montebello Town Center site has been ultimately removed from
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4 -52
Applied Planning, Inc. (Copyright @ 2005)
consideration as a potential alternative location for the Project. Based on the City of
Montebello's comments, Pages 3-11 and 3-12 of the Revised Alternative Site Analysis are
amended to read as follows:
a. Site Description
Altemative Site 3, located on the eastern edge of the Montebello Town Center
mall, was identified as a possible alternative due to the recently announced
corporate mergerbetween the May Department Stores Company and Federated
Department Stores, Inc. The closure of the Robinsons-May store is anticipated
by the City, although this store was not identified in the latest list of locations
planned for divestiture, issued by Federated Department Stores on July 28,
2005. In response to the Revised Alternative Site Analysis. Rosemead has
learned that this site will not be available as the store will remain open as a
Macy's store.
tham being vacated. Them is no imdieation, howevet,, that the MonteheHo Town
b. Potential Feasibility of Site
a. The existing Robinsons-May store is approximately 140,100 square feet
in size, and is located on an 8.75 acre parcel that provides shared mall parking,
as shown in the following Figure 7.3-3. In order to accommodate the proposed
Wal-Mart Supercenter, substantial re-design of the Project would be required,
resulting in the construction of a multiple-story facility with additional, at-grade
or subterranean parking. Based on the information from the City of Montebello,
as well as problems relating to oroiect design. the site is considered unavailable
and the alternative rejected as infeasible.
Beyond the obstacles of site availability and project design, compatibility
between the proposed Wal-Mart and the existing mall is an additional concern.
The Montebello Town Center is an upscale, regional mall. As such, retailers
within this mall seek to draw consumers from a different market sector than that
of the discount retailer and grocery seller, and the introduction of a discount
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-53
Applied Planning, Inc. (Copyright © 2005)
retail/grocery use within the existing mall could be incompatible and have a
detrimental economic effect on adjacent retailers. Accordingly, this alternative
site was determined to be infeasible.
Response SOC-9
The commentor proffers an opinion regarding the environmental work conducted for this
Project. These comments will be provided to the decision-makers for consideration during
their deliberations.
Response SOC-10
Please refer to Responses SOC-1 through SOC-9.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-54
l,Ar Brad Johnson
' Rosemead City Hall
8838 Valley Blvd
Rosemead. CA 91770
November 8 2005
Mr Johnson.
Peggy and Richard Baumann, Page 1 of 1
6305 Scenic Drive
Rosemead CA 9
In reviewing the Revised Draft Alternative Site Analysis of the Environmental Impact Report (EIR) for
the Rosemead Commercial Retail Center we have many concems regarding section 1 1 that refers
to the 24 hour operation
In the final EIR of 2004 in Table 1 10-2. Conditions of Approval. Condition No 53. reads the hours of
operation of the mayor tenant shall be limited to 8 a.m to 10 p m., except during the Chnstmas
season. At the Public Heanng and City Council Meeting of September 7. 2004. the hours were
abruptly changed to a 24-hour operation. We attended the Court hearing on April 6, 2005, where
Judge Yaffe said that was a scam and a ruse so the public wouidn t know the true hours of
operation
The EIR revision correctly states that the Court found that the EIR did not adequately analyze
potential impacts from a 24-hour operation. It further states this issue is no longer relevant as Wal-
Man has withdrawn its request for a 24-hour operation and a restrictive covenant will be recorded
guaranteeing that no 24-hour operation of the Wal-Mart Supercenter will be allowed without further
environmental review There is no definition of further environmental review in the EIR revision.
What will that encompass? Can it be a few lines created by someone appointed by the City Council
or Wal-Mart, How long is a restrictive covenant in force, One week, One year, 10 years' Who is
going to do the guaranteeing) The City) Wal-Mart? The Courts What protection are we the
people given by this document?
On August 5. 2004, about 41,,, weeks before the public hearing. we attended a South San Gabriel
Community Meeting on the proposed Wal-Mart Supercenter There was a project presentation by
Rosemead City staff I asked what Wal-Mart needed to do to if they wanted to change to a 24 hour
store since at that time, the hours were to be 8 a m to 10 p m. Their answer was that the City
Council would pass an ordinance allowing the change in hours, a very easy process Once this EIR
revision is approved by the City Council, and. if given approval by the Court, will the City Council in a
month or two decide traffic is tolerable so let's pass an ordinance changing the hours. Who will be
watching') -
Please address these issues Thank you
Peggy and P.ichare Baumann
PRB-1
Applied Planning, Inc. (Copyright © 2005)
PEGGY AND RICHARD BAUMANN
Letter Dated November 8, 2005
Response PRB-1
As correctly summarized by the commentor, Page 1-1 of the EIR Revision provides the
following discussion:
Although the Court also found that the 24-hour operation issue was not
adequately analyzed in the EIR, this issue is no longer relevant as Wal-Mart has
provided notice to the City that it has withdrawn its request for a 24-hour
operation and a restrictive covenant will be recorded guaranteeing that no 24-
hour operation of the Wal-Mart Supercenter will be allowed without further
environmental review.
Further environmental review will be provided to the extent determined necessary by the
Lead Agency, and consistent with the provisions and requirements of CEQA. At this
juncture, given that 24-hour operations of the Project are not proposed, nor defined, to
comment on the format and content of such an environmental analysis would be
speculative at best. Please refer also to Revised Planning Department Condition of
Approval (COA) presented in Section 3.0 of this Revised Final EIR. As stated under revised
COA No. 54, which now reflects the "no 24-hour operations" restrictive covenant:
The hours of operation of the major tenant shall be limited to 8:00 a.m. to 10:00 p.m.,
except daring Christmas season, in which case the hours of operation may be extended
to midnight.
Other statements and opinions expressed by the commentor will be forwarded to the
decision-makers. Analvsis and conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-56
L. C. Bevington, Page 1 of 2
Mayor and City Council
City of Rosemead
8838 E. Valley Blvd.
Rosemead. CA 911-70
Subject Proposed Wal-Mart Development
On December 13 the Rosemead City Council proposes to hold a public hearing on the possible
development of a Wal-Mart Discount Supercenter with the announced action to be a consideration
of alternative sites.
However, in light of the extremely negative information about the Wal-Mart business operation, the
hearing should be that neither the original site nor any of the alternative sites should have any
further consideration
Copies of news articles are attached.
The Wal-Mart CEO says one thing while simultaneously a Wal-Mart official memo says the
opposite - a typical Wal-Mart procedure of talking out of both sides of its mouth.
If the individual council members and staff will take the time to read and understand the articles, it
will be apparent that the City of Rosemead should quickly and quieby withdraw from any added
dealings with Wal-Mart
As quoted in one article, Wal-Mart is interested only in increasing its profit and doesn't care how it
does it
°I don't think the DNA of Wal-Mart has changed at all." said HSBC Securities
analyst Mark Husson, returning Wednesday from an analyst meeting at Wal-Mart
headquarters in Bentonville, Ark. 'It's like a religious cult - it has a low-cost gospel
to bring to the country and sees it as a divine duty to do that and nothing is going
to get in its way. It will do what it has to do and say what it needs to say to get
there '
The pledge of CEO H. Lee Scott:
On Monday, Chief Executive H. Lee Scott Jr. pledged to bring health insurance
within reach of his 1.3 million U.S. employees.
LCB-1
is totally countermanded by a memo from a Wal-Mart vice president:
L. C. Bevington, Page 2 of 2
In the healthcare memo, whose contents were first reported in the New York
Times. Executive Vice-President of Benefits Susan Chambers wrote to the
company's board of directors that Wal-Mart workers on average spent 8% of their
income on healthcare - almost double the national average. Las year, Chambers
wrote. nearly two-fifths of those enrolled in Wal-Mart health plans spent 16% of the
average Wal-Mart income on healthcare.
What's more. 46% of the children of Wal-Mart employees either are on Medicaid
or are uninsured, the memo said. That marked the first time that Wal-Mart has
acknowledged that a significant number of employee dependents rely on public
assistance.
The public knows by now that you can't believe anything that Wal-Mart says. We repeat the quote
above by Mark Husson:
`It will do what it has to do and say what it has to say....
Wal-Mart will lie when it has to in order gain what it wants.
Rosemead City Council: Please quit this unholy alliance before the city really gets burned.
46 d~2
LCB-1
(cont'd)
WA-Up Wal-Maul: Every Day Low Morith Sign the paitaon Bevington Attachment 1, Page 1 of 1 y, ,:14 PM
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This week, an investigation into Wal-Mart's sweetheart deal with
George Bush's Department of Labor revealed a shocking fact. Wal-
Mart actually helped write its own sweetheart deal for repeatedly
breaking child labor laws
For a long time, we have known Wal-Mart's policies are morally corrupt,
but now we are discovering Wal-Mart's politics are corrupting our
government too. Have we really hit the point in our nation's history
when the world's largest corporation. Wal-Mart, and the President are
willing to sell out America's children over money?
Only you have the power to take our govemment back from the multi-
billion dollar corporations like Wal-Mart and put the power in the hands
of the people where it belongs.
And don't forget the revelation last week about Wal-Mart and
Republican Congressman and former Majority Leader of the
U.S. House of Representatives Tom DeLay. Wal-Mart actually
gave Tom Delay money 2 days after he was indicted. That's
right. Wal-Mart made a $5,000 contribution to support Tom.
Delay's corruption 2 days after his indictment
It's time to tell Wal-Mart's CEO Lee Scott that Wal-Mart must
adopt a "zero tolerance policy" on child labor today. Don't let
Wal-Mart's morally corrupt political agenda destroy America
any more.
Tell Wal-Mart, its time to stand up and do the right thing and
stop exploiting child labor in the United States and abroad.
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Bevington Attachment 2, Page 1 of 12
WATCH
d. w,nrrGdltq
Reviewing and Revising Wal-Mart's Benefits Strategy
Memorandum to the Board of Directors
from Susan Chambers
The purpose of this memorandum is to update you on our efforts to review and revise Wal-
Mart's benefits strategy. In response to concerns about cost trends and growing public scrutiny,
I recently led a 15-person team, drawn from across the company, in (1) evaluating Wal-Mart's
approach to benefits and (2) developing a strategy to address any sbort-comings.
We evaluated Wal-Mart's current benefits offering through three lenses - cost trends, Associate
satisfaction, and public reputation - and are now recommending revisions to our benefits strategy
built around nine "limited-risk" initiatives and five "bold steps."
This memorandum summarizes our work and is divided into three sections:
Section 1 provides a detailed analysis of the three most significant benefits-related challenges we
face:
Growth in benefits costs is unsustainable (15 percent per year) and driven by fundamental
and persistent root causes (e.g., aging workforce, increasing average tenure). Unabated,
benefits costs will consume an incremental 12 percent of our total profits in 2011, equal
to $30 billion to $35 billion in market capitalization.
VJhiic Associates are satisfied overall with their benefits, they are opposed to most
traditional cost-control levers (e.g., higher deductibles). Satisfaction also varies
significantly by benefit and by segment of Associates. Most troubling, the least healthy,
least productive Associates are more satisfied Arith their benefits than other segments and
are interested in longer careers with Wal-Mart
Healthcare is our most pressing reputation issue because well-funded, well-organized
critics, as well as state government officials, are shining a bright light on Wal-Mart's
offering. Moreover, our offering is vulnerable to at least some of their criticisms,
especially with regard to the affordability of coverage and Associates' reliance on
Medicaid.
Section 2 discusses in detail the nine limited-risk initiatives and five bold steps we are
recommending. Given conflicts inherent in the challenges we face, any set of solutions will
require carefully balancing, and sometimes making trade-offs between, cost, Associate
satisfaction, and public reputation.
Limited-risk initiatives: We are recommending that Wal-Mart realign eligibility
t requirements for health insurance; decrease cross-subsidization of spouses; give
Associates more information about how to use healthcare and health insurance; lower
company-paid life insurance coverage levels; capture savings from current initiatives to
improve labor productivity; add a combination of best practice care management
programs; further develop high performance provider networks; offer Associates bundles
of other benefits (e.g., paid-time off) from which to choose; and continue to explore
Bevington Attachment 2, Page 2 of 12
CDNFiDE1FF~t
WATCH
adding health clinics in stores. These initiatives will reduce costs and will slightly
improve Associate satisfaction.
Bold steps: The nine limited-risk initiatives will not fully address all the benefits-related
challenges we face. To fully address these challenges, we recommend that Wal-Mart
take five bold steps that will require more explicit trade-offs between cost, Associate
satisfaction, and public reputation. The first two recommended steps primarily address
cost trends, the third addresses attracting a healthier workforce, and the last two steps
address improving our public reputation.
Move all Associates to "progressively-designed" consumer-driven health plans to
help control cost trends while allowing Associates to build up savings in Health
Savings Accounts
Restructure the retirement program (i.e., profit sharing and 401(k) program) to
reduce costs and help Associates better save for retirement
Redesign benefits and other aspects of the Associate experience, such as job
design, to attract a healthier, more productive workforce
Make some select strategic investments in our healthcare offering (e.g., lower
maximum out-of-pocket expenses) so it can better withstand external scrutiny
Improve communication of Wal-Mart's benefits offering so we get more credit
for what we provide, and, over the long-term, work to shape state and national
outcomes on healthcare
Section 3 summarizes the combined impact of the limited-risk initiatives and the bold steps. The
team believes this new strategy will bring powerful advantages to Wal-Mart, including:
Maintaining benefits spend at or below today's level as a percentage of sales
Offering a more attractive benefits package for healthy Associates
Better positioning us to fight Wal-Mart's critics
I presented this material to the Executive Benefits Steering Committee (Tom Hyde, Lawrence
Jackson, and Tom Schoewe) in late July. They received the recommendations enthusiastically
and asked that I syndicate them widely within Wal-Mart, something I have begun to do. They
also asked that the team continue to test and refine the strategy, especially with Associates and
external stakeholders. Our aspiration is to complete this work by late-September, receive
Executive Committee approval on the overall strategy by early-October, and hold a special
session with you in November for further discussion-
I Major benefits-related challenges
We analyzed the benefits-related challenges facing Wal-Mart through three lenses - cost trends,
Associate satisfaction, and public reputation.
Bevington Attachment 2, Page 3 of 12
C~FIFFOth~w• WATCH
Cost trends
From 2002 to 2005, our benefits costs grew significantly faster than sales, rising from 1.5 percent
of sales to 1.9 percent. Benefits spend grew from $2.8 billion to $4.2 billion during this period,
at a rate of 15 percent per year. Holding benefits costs as a percent of sales constant is critical
for Wal-Man's long-term economic success.
A few benefits made up the bulk of this increase: healthcare ($1.5 billion) grew by 19 percent,
paid time off ($1.4 billion) grew by 14 percent, and the profit sharing and 401(k) program ($740
million) grew by 13 percent. (Over the period, the domestic Associate base grew at 5 percent
and domestic sales grew at 11 percent.)
Increased utilization of medical services, which grew by 10 percent per year, was the primary
driver of the rapid growth in our healthcare costs (Exhibit 1). Almost half of this utilization
growth was due to three Wal-Mart-specific workforce factors (distinct from national trends):
Our workforce is aging faster (0.50 years per calendar year) than the national average (0.12 years
per calendar year).
Our workers are getting sicker than the national population, particularly in obesity-related
diseases. For example, the prevalence of coronary artery disease in Wal-Mart's population grew
by 6 percent compared to a national average of 1 percent, and the prevalence of diabetes in our
population grew by 10 percent compared to a national average of 3 percent. (That said, our
workforce is no sicker at present in absolute terms than the national population.)
A segment of our workforce consumes healthcare inefficiently, in a pattern similar to a Medicaid
population. Our population tends to over-utilize emergency room and hospital services and
under-utilize prescriptions and doctor visits. This pattern is most evident among our low-income
Associates, and the team hypothesizes that this behavior results from prior experience with
Medicaid programs.
Compounding these problems are several national trends, such as the increased use of
technological innovations, which are driving increased utilization of medical services across the
U.S. healthcare system.
The cost of Wal-Mart's profit-sharing and 401(k) program and paid time off grew faster than
overall Associate growth, due largely to increasing Associate tenure. Over the past 4 years, the
average Associate tenure has increased by 0.2 months per calendar year. As a result, more
Associates qualify for participation in benefits programs like the profit sharing and 401(k) plan
and for more paid-time off. An even more important factor is wages, which increase in lock-step
with tenure and directly drive the cost of many benefits (e.g., 401(k) is a percentage of wages).
Given the impact of tenure on wages and benefits, the cost of an Associate with 7 years of tenure
is almost 55 percent more than the cost of an Associate with 1 year of tenure, yet there is no
difference in his or her productivity (Exhibit 2). Moreover, because we pay an Associate more in
salary and benefits as his or her tenure increases, we are pricing that Associate out of the labor
market, increasing the likelihood that he or she will stay with Wal-Mart.
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We have also not effectively leveraged our benefits spend per Associate, which should be
thought of as a fixed cost for employing that Associate. We have allowed our full-time
Associates to average only 34 hours of work per week; increasing the hours worked per
Associate would enable Wal-Mart to lower our labor cost per hour by spreading benefits costs
over more hours. We also have one of the highest percentages of Ul-time Associates in the
retail industry, even though full-time Associates are more expensive per labor hour (in terms of
both benefits and wages).
Associate satisfaction
Associates are satisfied with their overall benefits package, but they have expressed significant
opposition to most traditional cost-control levers. For instance, Associates strongly oppose
higher deductibles or limits to their choice of providers. Satisfaction varies significantly,
however, by benefit and by segment of Associate, creating an opportunity to rebalance the
benefits portfolio to improve satisfaction while reducing costs. In particular, the least healthy,
least productive Associates are more satisfied with their benefits than other segments and are
interested in longer careers with Wal-Mart.
Overall, Associates are satisfied with their benefits relative to peers at other retailers. In a survey
of retail workers, Associates ranked Wal-Mart's benefits above the industry average in
availability, ability to qualify, quality, and execution (e.g., claims processing). The cost of
healthcare coverage was the only factor on which we scored poorly.
Associate satisfaction and view of importance vary significantly by specific benefit (Exhibit 3).
For example, Associates rank health insurance as the most important benefit Wal-Mart offers,
but they also say it is the one with which they are least satisfied. The stock purchase plan, the
profit sharing and 401(k) program, and life insurance are all ranked high-satisfaction, low-
importance, suggesting an opportunity to rebalance Wal-Mart's investment in these benefits into
other more important benefits. Paid time-off and the discount card are the only high-
satisfaction, high-importance benefits.
Associate satisfaction with benefits also varies significantly by segment of Associates. The team
analyzed the Associate population on a wide variety of factors (e.g., attitude, health behavior,
tenure), the most fruitful of which was annual healthcare spend. The so-called "low utilizers"
are the most attractive Associate segment because they cost Wal-Mart less in terms of hcalthcare
expenses and are more productive in their jobs. (Productivity findings were based on analysis of
individual cashier items per hour data.) Moreover, this segment also showed healthier
behaviors, specifically less prevalence of obesity. Unfortunately, the "low utilizers" were also
least satisfied with our benefits and were planning shorter careers with Wal-Mart. This segment
favors a different type of benefits package than the "high utilizers," a benefits package different
than what we offer today: a health insurance offering more closely modeled on consumer-driven
health plans - lower premiums, higher deductibles, and health savings accounts. They also
prefer certain nonmedical benefits, such as help in saving to purchase a home and help in paying
for more education, neither of which we offer in a robust way today.
Bevington Attachment 2, Page 5 of 12
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It is worth noting, however, that overall benefits only play a small role in attracting Associates to
Wal-I%Iart and in keeping Associates satisfied while at Wal-Mart. Our benefits offering played a
key role in attracting just 3 percent of our Associates. Moreover, satisfaction with benefits does
not correlate with satisfaction with Wal-Mart. A variety of factors - especially Associates'
interactions with management - are more important.
Public reputation
Healthcare is the most pressing reputation issue facing Wal-Mart. Survey work done last
summer shows that people's perception of our wages and benefits is a key driver of Wal-Mart's
overall reputation. Several groups are now mounting attacks against Wal-Mart focused on our
healthcare offering. These increasingly well-organized and well-funded critics - especially the
labor unions and related groups, such as Wal-Mart Watch - have selected healthcare as their
main avenue of attack Moreover, federal and state governments are increasingly concerned
about healthcare costs, and many view Wal-Mart as part of the problem (a view due, in part, to
the work of Wal-Mart's critics). Medicaid costs are a major priority on most governors'
agendas; already a quarter of states are spending more than 25 percent of their budgets on
Medicaid, and observers across the political spectrum assert that the current system - with
spiraling costs, a large population of uninsured, and an increasing number of medical
bankruptcies - is unsustainable (although there is little consensus on what should take its place).
In this environment, we can expect efforts like those in Maryland (which is trying to mandate
that companies spend a certain percentage of revenue on healthcare) and New Hampshire (which
requires health services to track where Medicaid enrollees are employed) to accelerate.
Proposals such as these, if successful, will bring added costs to Wal,-Mart. Moreover, these
battles with critics and governments are contributing to the decline of Wal-Mart's overall
reputation.
Our healthcare offering is also vulnerable to attack. We have not effectively communicated the
generosity of our healthcare benefits to the general public; instead, we have thus far allowed our
critics to frame the debate. For instance, only 22 percent of Americans find it very believable
that Wal-Mart provides health insurance to 900,000 people. Wal-Mart's critics can also easily
exploit some aspects of our benefits offering to make their case; in other words, our critics are
correct in some of their observations. Specifically, our coverage is expensive for low-income
families, and Wal-Mart has a significant percentage of Associates and their children on public
assistance. Consider the following:
On average, Associates spend 8 percent of their income on healthcare (premiums plus
deductibles plus out-of-pocket expenses) for themselves and their families, nearly twice the
national average. The number varies significantly by plan type, rising to 13 percent for those on
the Associate and Spouse plan.
Critics contend that the costliness of Wal-Mart's healthcare coverage causes it to enroll fewer
Associates in its health insurance plan than do most national employers (48 percent versus 68
percent) (Exhibit 4).
Bevington Attachment 2, Page 6 of 12
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Associates also face significant financial risk when a medical catastrophe occurs. On the Family
plan, an Associate must spend between 74 and 150 percent of household income on healthcare
(approximately $13,000 to $27,000) before insurance takes over completely. Though few
Associates reach this level of spending, those who do almost certainly end up declaring personal
bankruptcy. In 2004, 38 percent of enrolled Associates spent more than 16 percent of the
average Wal-Mart income on healthcare.
We also have a significant number of Associates and their children who receive health insurance
through public-assistancc programs. Five percent of our Associates are on Medicaid compared
to an average for national employers of 4 percent. Twenty-seven Percent of Associates' children
are on such programs, compared to a national average of 22 percent (Exhibit 5). In total, 46
percent of Associates' children are either on Medicaid or are uninsured.
On both of these issues - affordability and public assistance - it is important to note that our
offering and performance are on par with other retailers; Wal-Mart's critics, however, hold it to a
"large company" standard, not a retailer standard. Despite the difference in industry economics,
critics believe we should behave more like a GM or a Microsofl than a Target or a Sears. While
critics have not yet harnessed all of these facts, they are successfully exploiting those they do
have, suggesting that, when discovered, the others will also become effective ammunition.
2 Proposed revisions to benefits strategy
Against the backdrop of these challenges, the team is recommending that Wal-Mart implement
the nine limited-risk initiatives and five bold steps discussed in detail in this section.
Limited-Risk Initiatives
These nine initiatives require little or no trade-off' between cost, Associate satisfaction, and
public reputation. Exhibit 6 provides an overview of these initiatives:
1. Realign eligibility requirements for health insurance so that Associates (full-time and part-
time) and their children qualify after working 1,000 hours and spouses qualify after the Associate
works 2,000 hours. This move would simplify external communications, make Wal-Mart even
more competitive in the part-time labor market, and help align costs with the economics of the
business (in that the benefit is based on hours worked). On average, these requirements translate
into 6 months for full-time Associates (same as today) and 1 year for part-time Associates
(versus two years today).
2. Decrease cross-subsidization of spouses through higher premiums or other charges. Spouses
are by far the most expensive plan members to cover, and Wal-Mart pays more per spouse than
per Associate. This change would allow us to put more dollars towards Associates and their
children.
3. Give Associates more information about how to use healthcare and health insurance. Many
Associates are making inefficient decisions about what healthcare services to use, e.g., over-
relying on emergency rooms. We need to give Associates more information on the cost and
11
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quality of specific health services, better educate them on how best to utilize healthcare, and
develop education efforts specifically for those Associates who have previously been uninsured
or on public assistance.
4. Lower company-paid life insurance coverage levels to a maximum payout of $12,000. Life
insurance, although a small cost, is the fastest growing benefits cost. It is also a high-
satisfaction, low-importance benefit, which suggests an opportunity to trim the offering without
substantial impact on Associate satisfaction. The company-paid policy currently covers one
times an Associate's annual salary, which is slightly more generous than most retailers.
5. Capture savings from current initiatives to improve labor productivity. These initiatives
include reducing the number of labor hours per store, increasing the percentage of part-time
Associates in stores, and increasing the number of hours per Associate. These changes represent
a major cost-savings opportunity with relatively tittle impact on existing Associates. The most
significant challenge here is that the shift to more part-time Associates will lower Wal-Mart's
healthcare enrollment (even with the more generous part-time offering outlined above), which
could have an impact on public reputation.
6. Add a combination of best practice care-management programs, including utilization
management, case management, disease management, and errors and omissions programs.
These programs primarily improve quality of care, but they will also produce modest cost
savings by improving care coordination and compliance for extremely sick Associates, who
drive a disproportionate share of the cost.
7. Further develop high-performance provider (e.g., doctors, hospitals) networks so as to direct
Associates to the most efficient and effective healthcare providers. The quality of care and cost
of care vary significantly among doctors. We should be on the cutting edge of efforts to identify
the best doctors by, for instance, working with payors to find new ways to identify these doctors.
We should then create provider networks made up only of those doctors and provide Associates
with incentives for using those doctors.
8. Offer Associates bundles of other benefits (e.g., paid time off, education, discount card) from
which to choose. Our benefits package today is "one size fits all," even though different
segments of Associates value specific benefits differently. For instance, one segment would
happily give up some paid-time off in exchange for a more generous discount card. While we
believe every Associate should have a core healthcare and retirement offering, we could more
effectively spend our remaining benefits dollars by allowing Associates to choose from among
several packages of benefits.
9. Continue to explore adding health clinics in stores. Wal-Mart is starting an effort to put
clinics in stores, a strategy currently framed as a real-estate opportunity. Longer-term and with
several important modifications to the current offering (e.g., innovations to create lower cost
visits), these clinics could become an important part of our healthcare strategy, especially as a
substitute for emergency room visits.
Bevington Attachment 2, Page 8 of 12
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Taken together these nine initiatives should reduce Wal-Mart's projected healthcare costs from a
projected 2.3 percent of sales in 2011 to a projected 2.0 percent of sales, largely due to the
impact of the productivity initiatives (initiative 5). The initiatives should also slightly improve
Associate satisfaction. They will not likely have any significant impact - positive or negative -
on public reputation.
Bold steps
The following five bold steps will be more difficult to execute than the limited-risk initiatives,
but their impact will be much greater. Exhibit 7 provides an overview of these steps.
1. Move all Associates to "progressively-designed" consumer-driven health plans to help control
cost trends while allowing Associates to build up savings in Health Savings Accounts
While relatively new in the United States, consumer-driven health plans have proven to
control medical cost trends more effectively than traditional plans in both domestic (e.g.,
Logan Aluminum) and international (e.g., Singapore) settings. These plans eliminate the
traditional deductible. In its place, Associates get a Health Savings Account (HSA), a
pretax bank account for health expenses that is similar to a 401(k). An HSA is funded
from three sources: annual seed money from Wal-Mart, an annual contribution from the
Associate, and a matching contribution from Wal-Mart. The Associate uses the HSA to
cover his or her first-dollar medical expenses every year. When an Associate has used up
his or her HSA, there may be (depending on how much is in the HSA) a "bridge" the
Associate must cover, which is the difference between the amount in the HSA and the
point at which coinsurance takes over.
Consumer-driven health plans are more effective at controlling costs than traditional
plans because enrollees have greater responsibility for their healthcare spending. HSA
funds belong to the Associate, so he or she has a stake in using the money wisely. If the
Associate leaves Wal-Mart, the HSA funds go with him or her. If HSA contains money
at the end of the year, those funds roll over for use in the following year. An Associate
with high healthcare expenses may also face a bridge, which serves as a further brake on
spending. Consumer-driven health plans are particularly attractive to the healthy,
productive Associate segment, because this segment now "gets something" for enrolling
in health insurance and staying healthy - they can save money in their HSA.
The key to achieving these advantages is to have all Associates participate. Otherwise
only the healthiest enroll and there is very little cost reduction because healthy people
spend so little on healthcare. During this year's enrollment cycle, we are offering a few
consumer-driven health plans (among many options); these existing offerings can serve
as a starting point for a complete transition over the next 1 to 2 years.
Such plans would have several advantages for Associates. More than 80 percent of
Associates would be better off financially under the proposed consumer-driven health
plans than under traditional plans. Associates can also accumulate wealth in their HSAs.
A typical Associate who is generally healthy would have $600 to $2,100 in savings after
Bevington Attachment 2, Page 9 of 12
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3 years. Associates can use this wealth both for significant health events and retirement.
Associates can also use their HSAs to cover a wide variety of health expenses, including
vision, dental, preventive care, and other spending not covered by the plan.
To make this change palatable externally, the plan design must be "progressive,"
meaning it cannot involve any cost shifting. In transitioning to consumer-driven health
plans, many companies have chosen to push more costs onto employees, a move that has
given these plans a bad reputation among progressives. The plans proposed by the team
do not involve any cost shifting. Moreover, a growing number of companies are
implementing such plans, providing Wal-Mart with more political cover. Many retailers
(e.g., Staples, Toys R Us) are offering consumer-driven health plans as one option among
many, and the ever-progressive Whole Foods recently moved all of its employees to such
a plan, to much media fanfare.
The primary reason for malting this transition would be to reduce future benefits costs,
and those savings would be significant: $400 million to $700 million in FY2011, all
from reduced trend. This change does, however, come with several challenges. Overall
consumer-driven health plans are less popular with Associates than traditional plans,
albeit not dramatically so, and are more difficult to communicate. Strong opposition is
isolated to approximately 10 percent of Associates. Wal-Mart will also face reputation
challenges in implementing this change given that progressives view such plans as a
"Republican answer." Wal-Mart will have to be sophisticated and forceful in
communicating this change internally and externally.
2. Restructure the retirement program (i.e., the profit sharing and 401(k) program) to reduce
costs and help Associates better save for retirement
We should reduce our overall investment in the profit sharing and 401(k) program from
approximately 4 percent of wages to approximately 3 percent of wages. Doing so would
bring the program more in line with retail offerings and would save Wal-Mart a
substantial sum of money. Hewitt ranks our retirement program as the best in its non-
union hourly retail benchmark set. Given the scrutiny that Wal-Mart receives on
healthcare and that retirement is a low-importance benefit for Associates, the retirement
program seems to be the wrong place for over-investment.
We should also redesign the specifies of our retirement program. In particular, we should
convert the 401(k) program from a "no-strings-attached" flat contribution to a matching
program in which Associates receive funds from Wal-Mart based on the contribution they
make to their 401(k). Such a program would help Associates better prepare for
retirement A fully participating career Associate would be able to replace 30 to 40
percent of his or her income at retirement, compared to 15 percent today, resulting in
some $0 to 90 percent of income replaced at retirement (when Social Security is
included).
Overall this proposal would save Wal-Mart a significant amount of money: $650 million
to $700 million in FY2011. With respect to Associate satisfaction, Associates reacted
Bevington Attachment 2, Page 10 of 12
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positively to a matching retirement program, although they slightly preferred the current
program. Although critics will contend that the new program is less generous than the
current one, retirement has not been a major issue in the external environment.
3. Redesign benefits and other aspects of the Associate experience, such as job design, to attract
a healthier, more productive workforce
Given the significant savings from even a small improvement in the health of our Associate base,
Wal-Mart should seek to attract a healthier workforce- The first recommendation in this section,
moving all Associates to consumer-driven health plans, will help achieve this goal because these
plans are more attractive to healthier Associates. The team is also considering additional
initiatives to support this objective, including:
Design all jobs to include some physical activity (e.g., all cashiers do some cart gathering)
Offer savings via the Discount Card on healthy foods (e.g., fruits and vegetables)
Offer benefits that appeal to healthy Associates (e.g., an education offering targeted at students).
A healthier workforce will lead to lower health insurance costs, lower absenteeism through fewer
sick days, and higher productivity. It will be far easier to attract and retain a healthier workforce
than it will be to change behavior in an existing one. These moves would also dissuade
unhealthy people from coming to work at Wal-Mart. Even a modest shift in Wal-Mart's ability
to attract and retain a healthier workforce could result in significant savings: $220 million to
$670 million in FY2011. The key tasks in implementing this fourth bold step, once the team has
developed a more complete list of actions, are to create a clear set of metrics to measure success,
to run pilots in several stores to understand each idea's effectiveness, and then roll-out the most
successful ones.
4. Make a series of strategic investments in our healthcare offering so it can better withstand
external scrutiny
The team is investigating a few potential investments:
To address concerns about affordability, offer at least one insurance plan that
covers Associates for $1/day (or $14 per pay period) and allows them to cover
their children for another $1 /day.
To further address concerns about affordability, lower an Associate's maximum
exposure to medical financial risk (premiums plus deductibles plus co-payments)
to a more manageable level, approximately 15 percent of the average income for a
full-time Associate.
To address concerns about access, help Associates access the private insurance
market after 30 days of employment and potentially provide them with limited
funding for doing so while they wait to become eligible for Wal-Mart's plan.
Bevington Attachment 2, Page 11 of 12
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These changes would give us a powerful set of messages to use in combating critics.
(For instance, "Wal-Mart offers Associates access to health insurance after they've
worked with us for just 30 days.") These kinds of changes would also make Wal-Mart's
coverage more affordable and accessible, directly addressing critics' and Associates'
most persistent arguments.
While this fourth bold step should create goodwill both internally and externally, it will
be expensive. In FY2011, the cost of these three proposals would be between $300
million and $350 million. Given this steep price, the team is rigorously testing these
ideas with the public and policymakers to determine what set of investments will most
effectively "move the needle" on Wal-Mart's public reputation.
5. Improve communication of our benefits offering so we get more credit for what we provide
and, over the long-term, work to shape the outcomes of state and national healthcare reform
efforts
We need to be more proactive in the public arena Three efforts are needed here:
Address the Medicaid issue head-on by reframing the debate (e.g., this is
everyone's problem, not just Wal-Mart's) and by offering some type of counter
proposal or compromise. This first effort is critical because Wal-Mart is under
serious attack from state governments with regard to the number of Associates on
publicly-funded health insurance. These attacks show no signs of abating - in
fact, they seem to be accelerating - and elected officials are proposing
increasingly costly solutions.
Clarify and improve messages about our healthcare offering (building on the
proposed changes outlined above) and engage in a sustained communication
campaign. This kind of communication will help us reframe public perception of
our healthcare offering, the only way for us to start winning the debate with our
critics. It will also help us build the credibility needed to weigh-in more broadly
on U.S. healthcare issues.
Become more engaged in the national healthcare debate, to position Wal-Mart as
a leader in healthcare in general and on access (e.g., individual mandates) and
affordability (e.g., bringing IT to healthcare) in particular. Establishing Wal-Mart
as a leader on this critical issue will help deflate our critics. It will also put us in a
position to help shape the outcome of the public debate about the healthcare crisis
in a way that is at least somewhat advantageous to our interests.
3 Impact of the proposed changes
Taken together the limited-risk initiatives and the bold steps create a powerful set of advantages
for Veal-Mart.
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Significant advantages
The new strategy will enable us to deal with all three of the benefits-related challenges we face.
Cost control. Benefits costs will be at or below 1.9 percent of sales (i.e., level as of FY 2005) in
2011. (The limited-risk initiatives result in about a 16-percent reduction in projected 2011
benefits costs and the bold steps yield about another 9-percent reduction.)
Associate satisfaction. Associates will have a more generous healthcare benefit with an HSA to
cover first-dollar expenses, greater protection against medical risk, and the ability to accumulate
wealth in their HSAs; a retirement benefit that helps them prepare more effectively for
retirement; and more choice, especially with regard to selecting other benefits (e.g., paid time-
off). Moreover, we will be more effective at attracting and retaining the healthy, productive
workforce Wal-Mart wants.
Public reputation. By providing Associates more affordable health coverage and responding to
concerns about Wal-Mart's Medicaid/S-CHIP enrollment, we will have addressed our critics'
most potent arguments. We will also have stepped-up our efforts to communicate the strengths
of Wal-Mart's benefits offering and counter critics' claims. Finally, we will have positioned
Wal-Mart to have a "seat at the table" in the public debate about healthcare reform.
Risks
The risks associated with these changes are worth carefully noting. Addressing them will
require, among other things, attention to implementation planning, communication, and
execution.
Cost risk If savings and investments are not properly sequenced, costs could increase before
they decrease.
Associate satisfaction risk Some of the proposed revisions to the benefits strategy (e.g., the
move to consumer-driven health plans, the changes in the retirement program) have the potential
to upset Associates, especially more tenured Associates.
Public reputation risk Healthcare enrollment will fall several percentage points due primarily to
a shift to more part-time Associates, which could draw additional attacks from Wal-Mart's
critics. Also, despite the proposed efforts, the Medicaid problem will not be "solved." A
significant number of Associates and their children will still qualify for Medicaid Because
many of these programs will offer more generous health insurance than Wal-Mart provides,
many Associates will still choose to enroll in Medicaid, leaving the door open for continued
attacks.
The team believes that the advantages of the proposed strategy outweigh these risks.
I appreciate your taking the time to engage so fully on this topic and look forward to discussing it
with you at the special Board meeting in November. In the meantime, I would welcome hearing
your reactions to our work to date.
Applied Planning, Inc. (Copyright © 2005)
L. C. BEVINGTON
Letter Received November 14, 2005
Response LCB-1
The commentor proffers opinions and statements regarding the business operations of Wal-
Mart, but provides no substantive comments related to the EIR Revision. Attachments
provided by commentor are not germane to the EIR Revision, but are included for
reference. No further response is required to these attachments. The commentor's
statements and opinions will be forwarded to the decision-makers. Analysis and
conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003 1 2 1 095)
Comments and Responses
Page 4-72
Bruce Capucetti, Page 1 of 2
November 7, 2005
CITY PLANNING DEPARTMENT
Rosemead, CA
As I read Article 3.2.2 of the EIR Revisions, 'a feasible alternative is one which
can be accomplished in a successful manner within a reasonable period of time,
`taking into account economic, environmental, social, and tecluiological factors'.
I'm left expecting that the community and Wal-Mart are striving for a WIN - WIN
result. The three alternate sites in Article 73.1.2 are all excellent WIN -WIN
possibilities. -
SITE # 1: The L.A. Dealer Auto Auction site, a `landmark' of the Rosemead
landscape for 50+ years, can lend itself as an excellent location for a Wal-Mart
location. The property east of this site and along both side of the wash has
periodically been listed `FOR SALE'. Most of this property is mobil-home parks.
If this additional land is not able to be acquired for development, and since
Rosemead is a `built-out, urban community', Wal-Mart needs to consider sub-
grade and/or roof-top areas for parking or retail space. This type of development
is common and is being designed for projects in the surrounding communities.
Besides providing a customer's vehicle some shelter from a ]lot sun or a pouring
rain, basement or roof parking areas lessen visual or audio pollution for the
immediate community. Site security can be better maintained when there is
limited access to the site's parking areas. 'T'hese are factors that any community
can appreciate fi-om a development. There also exist excellent transit service to
this site and two freeways are within two miles of this site. The nearest school,
part: or community center is located a good distance away from this site, not
across the street. Auto auction properties, though properly zoned for their
activity, do not maintain all the required 'on-site' improvements and conduct their
business more like an impound yard, a use that is only permitted in an `M' zone.
A Wal-Mart would be a more suitable development for this site and it would
complement the new retail project slated for the corner of Garvey Avenue and
Garfiels Avenue. At this site, Wal-Mart would be having to support more cost
but the development will be far more acceptable to the community that the Walnut
Grove location. And we've got to believe in WIN - WIN! _
BC-1
BC-2
SITE #2: This is another excellent location site. Adjoining residential properties
at site #2 are similar to SI'FE'l, mediunn to mediunn high densities. On grade BC-3
Bruce Capucetti, Page 2 of 2
available land is limited and will require the developer to acquire surrounding
land. A sub-grade and/or roof-top development can create additional space. This
site is within a half mile of the 10 freeway and has access to neighboring cities via
Temple City Blvd.. Baldwin Ave., and Valley Blvd., all wide major thoroughfares.
Public transportation is in place and makes this location accessible fi-om many
conununities. Though this site is noted to be located in a `blighted' area, this can
lend itself for Wal-Mart to make an immediate and positive effect on the
surrounding community. I was personally involved with a project in a `blighted'
ares, with limited vacant land, surrounded with high density housing and many
small businesses. Today this site, bordered by Union Ave., Wilshire Blvd.,
Bonnie Brae, and 6"' Street, just west of downtown LA and east of the Westlake
District, probably better known as part of the Rampart Division of the L.A.P.D., is
the location of a multistory structure that is occupied by a Home Depot, Food 4
Less, Rite-Aid, McDonald's, Pollo Loco, and parking. This development is not
only providing tax revenue to the city but more importantly is providing; jobs and
goods to a convnunity that previously had close to none of these. With minimal
regard for the `most bang for my buck' feasibility philosophy, these companies
came into this very `blighted' area, made a positive difference, and continues to
thrive in this location. This model is what I hope is envisioned when I read
Article 3.2.2 of the EIR Revisions. Site #2 is an excellent site for a Win-Win.
SITE #3: Probably the best of the alternate sites is the Montebello Town Center
Mall. Already built and located in a commercial/retail setting, this site waits in a
`MOVE -IN' condition. At least three different transit systems, the MTA -
Montebello Bus - Foothill Transit, are providing transportation to this mall from
local communities and transportation centers. This site is sufficiently located
away from homes, schools, parks, or conununity centers. Ample area is available
if an additional parking building is to be built. Vehicle access is through wide,
well built roads and two sets of freeway on/off ramps serve the mall exclusively.
An argument that a teal-Mart would not be compatible with an `upscale' regional
mall is NOT VALID. Many regional malls are now broadening their accessibity
in order to include all shoppers by adding discount retail outlets to their rosters.
Topanga Canyon Mall, an `upscale' Westfield mall, is today adding a Target Store
as one of their anchors. In the Puente Hills Mall, you can find a Pay-Less Shoes
or a Ross `dress-for-less' Store. The color of money remains green in any store.
With a minimal effort from our community or from the developer, this site has
`Welcome al-Mart' written all over it. Can Wal-Mart spell Win-Win?"?
Thank you,
Bruce Capucetti
P.O. Box 1760
Rsrnd.. CA 91770
BC-3
(cont'd)
BC-4
Applied Planning, Inc. (Copyright © 2005)
BRUCE CAPUCETTI
Letter Dated November 7, 2005
Response BC-1
The commentor's introductory remarks will be forwarded to the decision-makers. No
further response is required.
Response BC-2
Pages 3-4 through 3-8 of the EIR Revision substantiate that the L.A. Dealer Auto Auction
site fails at several levels within the context of CEQA "rule of reason" criteria for
identification and consideration of feasible alternatives to the Project. Foremost, selection
of the L.A. Dealer Auto Auction site alternative would not substantially reduce significant
environmental impacts of the Project. At best, these impacts would be transferred from one
locale to another.
The L.A. Dealer Auto Auction site also fails in terms of its feasibility. In this regard, CEQA
provides guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site.
[CEQA Guidelines §15126.6 (f) (1)].
As presented in the EIR Revision, the referenced L.A. Dealer Auto Auction site is not
currently under control of the Project proponent, and for that matter is not known to be
available. Nor is it foreseeable that the Auto Auction site or any of the other necessary
adjacent properties would be available for purchase within the foreseeable future.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 20013121095) Page 4-75
Applied Planning, Inc. (Copyright (D 2005)
With specific regard to potential multiple-story or other significant redesign(s) of the
Project as suggested by the commentor, CEQA does not require that an EIR consider
multiple combinations of Project configurations and alternative sites within the
Alternatives Analysis, only that a reasonable range of alternatives be considered, as
determined by the Lead Agency. The EIR Revision document considers (and rejects) three
(3) potential alternative sites, and further discusses the reasons for the original rejection of
the prior Ralph's Market site. Additionally, within the Draft EIR, three (3) alternatives were
considered (and rejected), and six (6) additional alternatives (including the CEQA-
mandated "No Project Alternative") were assessed and compared with the Project. The
City of Rosemead, as the Lead Agency, has determined that this analysis satisfies CEQA's
requirements to examine a reasonable range of alternatives, with supporting reasoning for
rejection of potential alternative sites from full consideration. Evidencing available
information to permit an informed choice, the City rejected the initially proposed Project,
and adopted the Project Design Alternative.
Further, the Project is that proposal described and assessed in the EIR, not some variation
or redesign not agreed to by the Project proponent and Lead Agency. Lastly, with specific
regard to suggested multiple-story configurations for the Project's major tenant Mal-Mart),
such a design is infeasible and would not be considered by the Project proponent. More
specifically:
• The cost of designing, engineering and construction such a store would be prohibitive,
particularly if it involved subterranean parking.
• The Project Major tenant described and assessed in the EIR is a Wal-Mart Supercenter,
which includes a general merchandise component and a supermarket component.
There are no multi-story Wal-Mart Supercenters in California. This is a function of
customer convenience. Supermarkets are generally not multi-story (if there are any
at all). Wal-Mart has determined that customers generally dislike shopping in multi-
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-76
Applied Planning, Inc. (Copyright © 2005)
level stores for convenience items such as groceries and household products.
Therefore, the multi-story format would put Wal-Mart at a competitive disadvantage
in comparison to its competitors. There is not the same concern with a Wal-Mart
general merchandise (only) store. This is evidenced by the existence of several multi-
story general merchandise stores in California.
As summarized above, and supported by information and findings presented within the
EIR Revision, selection of the L.A. Dealer Auto Auction site would not realize any
substantive environmental relief or benefit when compared to the current Project site. Nor
is the L.A. Dealer Auto Auction site considered to be a feasible location for the Project
based on its current lack of availability, as well as the unlikely prospect of acquiring and
assembling the numerous individual properties that would be required to create a site of
sufficient size and appropriate configuration for the Project.
Response BC-3
Pages 3-8 through 3-11 of the EIR Revision substantiate that "Alternative Site 2" fails at
several levels within the context of CEQA "rule of reason" criteria for identification and
consideration of feasible alternatives to the Project. Foremost, selection of Alternative Site
2 would not substantially reduce significant environmental impacts of the Project. At best,
these impacts would be transferred from one locale to another.
Alternative Site 2 also fails in terms of its feasibility. In this regard, CEQA provides
guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-77
Applied Planning, Inc. (Copyright © 2005)
As presented in the EIR Revision, the referenced site is not currently under control of the
Project proponent, and for that matter is not known to be available. Nor is it foreseeable
that the site or any of the other necessary adjacent properties would be available for
purchase within the foreseeable future.
As summarized above, and supported by information and findings presented within the
EIR Revision, selection of Alternative Site 2 would not realize any substantive
environmental relief or benefit when compared to the current Project site. Nor is the
referenced site considered to be a feasible location for the Project based on its current lack
of availability, as well as the unlikely prospect of acquiring and assembling the numerous
individual properties that would be required to create a site of sufficient size and
appropriate configuration for the Project.
Please refer to Response BC-2 for considerations regarding infeasibility of alternative,
multiple-story Project designs. Other anecdotal information provided by the commentor
referring to past personal experiences with redevelopment activities in other communities
will be forwarded to the decision-makers for their consideration.
Response BC-4
The commentor's opinions regarding commercial occupancy compatibilities will be
forwarded to the decision-makers. Irrespective of the mix of users within the Montebello
Town Center Mall, the Robinsons-May/Montebello Town Center site also fails in terms of
its ability to substantially reduce the Project's significant impacts. The Robinsons-
May/Montebello Town Center site fails as well under general feasibility considerations.
As presented in the CEQA Guidelines:
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003 1 2 1 095) Page 4-78
Applied Planning, Inc. (Copyright © 2005)
The range of alternatives required in an EIR is governed by a "rule of reason'
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the Project. Of those
alternatives, the EIR need examine in detail only the ones that the lead agency
determines could feasibly attain most of the Project Objectives.
[CEQA Guidelines §15126.6 (f)]
Pages 3-11 through 3-14 of the EIR Revision substantiate that the Robinsons-
May/Montebello Town Center site fails at several levels within the context of the CEQA
"rule of reason" criteria and standards for identification and consideration of alternatives
to the Project. Foremost, selection of the Robinsons-May/Montebello Town Center site
alternative would not substantially reduce significant environmental impacts of the Project.
At best, these impacts would be transferred from one locale to another.
The Robinsons-May/Montebello Town Center site also fails in terms of its feasibility. In this
regard, CEQA provides guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
As presented in the EIR Revision, the referenced Robinsons-May/Montebello Town Center
site is not currently under control of the Project proponent (and for that matter is not
known to be available), and is not configured to reasonably accept the Project building
footprint and facilities plans.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR. (SCH No. 2 003 1 2 1 095) Page 4-79
Applied Planning, Inc. (Copyright @ 2005)
In addition to the above considerations, comments on the EIR Revision provided by the
City of Montebello have ultimately removed the Robinsons-May/Montebello Town Center
site from consideration as a potential location for the Project. Based on the City of
Montebello's comments, Pages 3-11 and 3-12 of the Revised Alternative Site Analysis are
amended to read as follows:
a. Site Description
Alternative Site 3, located on the eastern edge of the Montebello Town Center
mall, was identified as a possible alternative due to the recently announced
corporate mergerbetween the May Department Stores Company and Federated
Department Stores, Inc. The closure of the Robinsons-May store is anticipated
by the City, although this store was not identified in the latest list of locations
planned for divestiture, issued by Federated Department Stores on July 28,
2005. In response to the Revised Alternative Site Analysis, Rosemead has
learned that this site will not be available as the store will remain open as a
MacL store. The Fede d announcement notes that '~a small numb
sto s are being studied for potential conversion of the Bloomingdale~s
then being vacated. Them is no indication, howevet, that the MontebeHo Town
GenteF locefion wodid he included in this plan.
b. Potential Feasibility of Site
a. The existing Robinsons-May store is approximately 140,100 square feet
in size, and is located on an 8.75 acre parcel that provides shared mall parking,
as shown in the following Figure 7.3-3. In order to accommodate the proposed
Wal-Mart Supercenter, substantial re-design of the Project would be required,
resulting in the construction of a multiple-story facility with additional, at-grade
or subterranean parking. Based on the information from the City of Montebello,
as well as problems relating to project design the site is considered unavailable
and the alternative rejected as infeasible.
Beyond the obstacles of site availability and project design, compatibility
between the proposed Wal-Mart and the existing mall is an additional concern.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-80
Applied Planning, Inc. (Copyright © 2005)
The Montebello Town Center is an upscale, regional mall. As such, retailers
within this mall seek to draw consumers from a different market sector than that
of the discount retailer and grocery seller, and the introduction of a discount
retail/grocery use within the existing mall could be incompatible and have a
detrimental economic effect on adjacent retailers. Accordingly, this alternative
site was determined to be infeasible.
As summarized above, and supported by information and findings presented within the
EIR Revision, selection of the Robin sons-Ma y/Montebello Town Center site would not
realize any substantive environmental relief or benefit when compared to the current
Project site. Nor is the Robinsons-May/Montebello Town Center site considered to be a
feasible location for the Project based on its lack of availability and physical constraints.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-81
' James I. Flournoy, Letter 1, Page 1 of 13
' Comments on Alternative Site Analysis
James 1 Flournoy
' 8655 Landis View
The Alternative Site Analysis for a superstore retailer must contain at least a comparison
' of the effect of site location upon the following assessments:
1. An assessment of the effect on shares of the local retail market.
2. An assessment of the effect on supply and demand for local retail space.
3. An assessment of the effect on wages and benefits, community income levels,
and local employment.
4. A projection of public service and facilities costs. and their incidence.
' S. .A projection of public revenues, and their incidence.
' 6. An assessment of the effect on retail operations in the same market area.
7. An assessment of the effect on implementing the City's General Plan and
' Disaster Hazards Mitigation Plan.
8. An assessment of the effect on total vehicle miles traveled by customers,
' employees and trucks.
The Alternative Site Analysis offered is clearly inadequate
' Access
Of all of the proposed sites Access is the worst to the Edison site
It is impossible to analyze the access and traffic patterns, as there is no data on where the
shoppers live or are coming from. The so called traffic study in the E1R set the scope so
narrow as to be meaningless, as will be shown.
Without data on where customers are coming from we have to guess that most customers
will be coming from the West as there are existing stores to the East on both the 60
(Industry) and 10 (Baldwin Park).
This observation is not quantified either in the EIR or this Revision.
Access to Towne Center Mall is the best of all the sites as it is served by two freeway off-
ramps with only one signal between the freeway and the site. There will be at least six
' signals between the EB 60 from the West and the Edison site via Walnut Grove Ave (4
lane). But it is obvious that there will be only five to the Edison site via Paramount/ San
Gabriel Blvd, which is the best and shortest route for traffic from West. (Six lane)
JF-1
J F-2
James I. Flournoy, Page 2 of 13
There is not enough data to properly analyze and compare the various freeways off ramps
and off ramp congestion even though they are a mitigatable factor as they are not studied
in this revision or in the EIR itself. The EIR traffic studies cleverly goes TO the San
Gabriel Blvd/ 60 WB ramps, does not discuss them, then somehow manages to skip over
them and spends pages on the mainline 60 freeway which cannot be mitigated in any
case. How do shoppers do this? Neat trick. This same set of off ramps also serve the
Towne Center site from the 60 freeway however the EB 60 ramps are not studied
Eventhough they ARE in the City of Rosemead. Traffic studies by both Montebello and
Monterey Park show traffic counts at the San Gabriel/ Walnut Grove intersection twice
what the Rosemead car counts show. This discrepancy has not been rectified. Perhaps
because any increase in car counts would require Carbon Monoxide (Co2) hotspot study
an analysis under AQMD guidelines.
A complete traffic study in conjunction with Montebello and Monterey Park and L.A.
County is needed to properly compare and make a decision on the SCE, Auto Auction,
and Montebello Towne Center sites as well as the Monterey Park Marketplace site.
Cumulative impacts exist and have not been analyzed or discussed in this or the earlier
EIR
CalTrans is on record as to the inadequacy of the traffic study. A recent letter to the City
is attached.
None of the on/off ramps on any of the freeways were analyzed in the EIR or this
Revision but it is obvious that Paramount/ San Gabriel are full cloverleaves at both the 10
and the 60 whereas Walnut Grove Ave ramps are inadequate "T"style. Access to the
Auto Auction site is therefore better than the Edison Site.
The City has recognizes the problem at Hellman/ Walnut Grove on/offEB 10 (direction
of most traffic to/ from Edison site) and has approved a signal at that site. Since Walnut
Grove is the only N-S route shown in the EIR it is obvious that this is a signal which
should have been and should be analyzed in the CEQA process. The City knew of this
problem prior to drafting the EIR. Not to have analyzed this intersection and compare it
with San Gabriel circumvents the planning process. The 10 freeway is an obvious route
for shoppers and trucks to the EdisorL East Rosemead and Auto Auction sites. It has not
been analyzed and discussed anywhere, anytime.
To customers coming from the West on the 60 the Towne Center Mall site or the Potrero
Grande site would be better. To Customers coming from the Weston the 10, from North
Monterey Park, Alhambra, and San Gabriel the Auto Auction site would be better.
Without the data it is impossible to determine time and miles saved. It is impossible to
determine the effect on pollution, on schools or any other factor.
J F-2
(cont'd)
Access to the Auto Auction site is via San Gabriel with freeway full cloverleaf off-ramps-
on both the 60 and 10 freeways. The East Rosemead site has many fewer lights between
the site and the 10 freeway and the Edison site.
t
James I. Flournoy, Page 3 of 13
East West: The Auto auction is on Garvey and the East Rosemead site is on Valley- both
major streets (MTA)
The Edison site E-W is on a "not a through street" The Edison access from the West on a
two lane residential street which dead ends into an n Elementary school. Any of the other
sites is better than this obvious school safety problem. The access problem via Graves
and Angelus is not compared with the other sites is not shown in the EIR or in the
Revision. Towne Center Mall would have no impact on schools.
A 6-lane state highway serves the unstudied "Starlight" site on SRI 9 with full cloverleafs
on both the 10 and 60 freeways. The unstudied Santa Anita 160 freeway site would have
a dedicated full cloverleaf with the 60.
' Rosemead shoppers in East Rosemead find the Baldwin Park store easier to get to than
the proposed Edison site. Placing the supercenter in East Rosemead would be the best
site for downtown. North and East Rosemead Shoppers as bot Mission Dr and Valley
blvd. lead to the site. The relative convenience of the sites for Rosemead residents has
' not been analyzed or discussed.
The East Rosemead site would also require expected foreign shoppers from the West to
transverse completely across and through North/ Downtown Rosemead. This site would
therefore have the greatest impact on North Rosemead surface streets. It is no
coincidence that this is where Mayor Imperial and cowicilperson Taylor live
Truck/ Delivery Access
There is no discussion of analysis of Truck Access in either the EIR or this Alternative
Site report
The EIR only shows access to the Edison site from Walnut Grove Ave. However the on/
of ramps for the EB 10 (At Hellman Ave) and WB 60 on San Gabrield Walnut Grove are
not suitable for over the road Class A trucks. This is not disclosed in the EIR. The
Towne Center Mall site has much superior access, as do the other two sites. The SCE site
would be served also by San Gabriel Boulevard's full cloverleafs. But this probability is
not disclosed or discussed in the EIR or this Revision Truck access to the East Rosemead
is already impacted by truck traffic and the WB 10 has sever problems at the Temple City
blvd. exit for long wheelbase tractor trailers, t is better than the SCE site, however.
There is no discussion of the relative noise from trucks. Walnut Grove descends the
Potrero Heights. The use of Jacob's (compression release) brakes would be a severe
source of noise pollution- While trucks ascending the hill would be - well trucks going
up a hill. With the Congestion on Southerly Walnut Grove Avenue these trucks would be
stop/s starting; while creeping up the hill in the current stop and go traffic. There are not
currently any businesses that require heavy trucks on Walnut Grove Avenue. There are
already business requiring heavy truck traffic at the other sites. The other sites would not
burdened by the use of Jacobs's brakes or trucks ascending hills. This quality of life
issue was not discussed in the EIR revision and should be an over-riding consideration.
All of the other sites have better truck access than the SCE site. This should be an
overriding consideration.
J F-2
(cont'd)
1
James I. Flournoy, Page 4 of 13
A traffic study for a supercenter needs to cover the expected shopper demographic area.
What is it? Where is it? The cut-rent study only covers two blocks of Rush Street and the
southernmost portion of Walnut Grove Ave. Are Shoppers expected to magically appear
in the parking lot? How do they get there? Where do they come from, Where are they
going? Who are they? In order to properly compare the benefits of the various sites and
the SCE site the study must include Northern Walnut Grove. San Gabriel Blvd, Del Mar,
New, Rosemead. Temple City, Potrero Grande, Graves, Angelus, Garvey, Valley and
Mission and the 10 freeway and the freeway ramps on the 10 and 60 to these
aforesaidmentioned streets and the cumulative impacts with our neighbors. If the study
in the EIR had been adequate then we could also make informed choices on alternative
sites. The City of Rosemead abused its discretion as lead agency in setting the scope of
the traffic study too narrow. It is worthless as a planning document.
Public transportation
The Analysis did not cover the Alternate sites as to public transportation issues. The
Edison Site has virtually no public transportation while ALL of the alternative sites are
better served.
Montebello Towne Center is a Transportation Hub and there are limited stop lilies on
both Garvey and Valley Blvds.
The EIR stated that there were no Express Routes near the Edison Site. That Statement
' was false, as there are Express Routes within two miles at Del Mar and the 10 freeway.
And limited stop routes on Garvey and Valley blvd.
' As gasoline becomes more expensive public transportation will become relatively more
important for both employees and shoppers. Minimal wage Wal-Mart employees are
especially affected by this trend.
Bicycle Access
There is no discussion of the relative ease of bicycle access of the various sites. The
Rosemead General Plan requires a bike path along the Alhambra Wash and hence
alongside the Edison site. There is no discussion of bike paths along the other sites.
J F-2
(cont'd)
1
1
11
James I. Flournoy, Page 5 of 13
Pedestrian Access
The Earthquake fault through the SCE parcel forces the building to be pushed to the West
side of the property eliminating the usual separate truck access down the side of the back
side of the building as at Paramount. This causes the truck access to be shared with
pedestrians, bicycles, and automobiles. This is a serious safety issue which is not shared
with the other sites. There is no analysis of this issue.
Black Sky. Light Pollution and Glare
The Edison site is currently free from light and glare. The Alternative sites are all
already developed and have established light and glare.
The Edison site is the only site with housing overlooking the site. All of the other sites
either have no nearby housing or housing at the same elevation. Lowering the elevation
of the parking lot lighting does not mitigate for overlooking homeowners. There is no
mitigation of moving lights from traffic.
Light pollution seriously affects night observation and peaceful use and enjoyment of the
evenings by overlooking residents. Particularly distracting are mobile sources of light
and glare
There is no discussion of the Alternate sites effect on light pollution for the Citizens of
Rosemead.
Open Space
The SCE site is the last large piece of undeveloped open space in the City. It has been
shown that there are several other sites that are available that are already developed.
There is no analysis of the benefits to the Citizens of using all or part the SCE site as
open space, recreation, parks. Such a use is improbable at the other sites. There are
other prospective purchasers for the SCE site, which would maintain the site as open
space. This was not disclosed in the analysis. The other sites are already developed.
There would be no loss of open space if they were used for re-development or a
supercenter. Open space is a valuable and irreplaceable resource. Since other sites are
available its preservation should be an overriding consideration.
Upscale Mall
Montebello Towne Center is characterized as an upscale mall in the Analysis. 1 recently
visited and hoped to find Sacks, a Nieman-Marcus, a Bergdorffs, or a Bloomingdale's.
What I found was a middle class mall. Perhaps everything including Big Lot's, 99 Cent
Store's, and indoor swap meets seem upscale to Applied Planning. Actually siting a
Wal-Mart as stand alone supercenter is the exception rather than the rule. Other local
Wal-Marts co-exist with other major tenants creating a destination for shoppers. Town
Center Mall would provide such a destination for shoppers. There is no analysis of the
benefit of such a siting
J F-2
(cont'd)
J F-3
J F-4
J F-5
11
James I. Flournoy, Page 6 of 13
Storm Water Runoff
The Cities are appealing a requirement that they clean up storm drains. The Alhambra
' Wash runs next to the SCE site and the Rubio Wash is nearby. The SCE site is the only
site where the toxins and contaminates can be removed without costly pumping. The
Cities will be prohibited from allowing contaminated storm water to flow into the Rivers
and Ocean. There is no discussion on the value of maintaining the SCE site for storm
water run off clean up and use one of the other sites for development. There needs to be
a cost/ benefit analysis of the various options of storm drain run off clean up with the
development at the various sites. It could easily be that the SCE site is the most
expensive, taking the City's mandates as a whole. Ignoring the problem will not make it
go away. The hilltop site has no possible use in the Storm Water clean-up mandate.
The Edison site is currently permeable. Most water from light rains soaks into the ground
to recharge the aquifer. This is a beneficial use. All of the other sites are already paved.
' There is no discussion on the relative benefits of percolation and the prevention of
additional run-off
I I Environmental Quality Green Development
Is it anticipated that this project will meet a LEED (Leadership in Energy and
Environmental Design) standard? If so, which one?
Would the Towne Center Site be convertible to LEED standards?
' Air Pollution
The Edison site sets against a hill that shades the site from the prevailing winds. This
creates a stagnant microclimate, which concentrates pollution. This was demonstrated in
the investigation for the CoGEN project at the neighboring countrywide site. The Co-
Generation projection was not accomplished. The launching of balloons and movies of
smoke plumes show this phenomena. The Towne Center site is on the top of a hill where
it can catch the full prevailing wind and disperses pollution. The other sites are far
enough from the Potrero Heights not to be affected. There is no discussion of relative air
Pollution of the sites. This magnifies the distance of the Edison site from the freeway's
effect on emissions. Trucks entering and exiting the Edison site and idling at the site will
cause a greater concentration of particulates and sulfur dioxide than at the other sites.
This is not discussed nor is the effect on local schools relative to the other sites. Sulfur
dioxide turns into sulfuric acid when it makes contact with water. The concentration of
carbon monoxide and oxides of nitrogen will also be higher at the Edison site that at the
other sites due to the factors mentioned above. From an Air Pollution perspective, even
without any analysis, the Towne Center site would be preferable.
This should be an overriding consideration.
J F-6
JF-7
J F-8
James I. Flournoy, Page 7 of 13
Disaster Hazard Mitigation Plan. General Plan Issues
The City was required to have a disaster hazard mitigation plan by FEMA a year ago. It
still does not have one. The City's general plan dates to 1983. Without these documents
or a corresponding disclosure and analysis in the EIR revision it is impossible to
adequately compare the alternate sites.
The General Plan is required by the Seismic Hazards Mapping Act and the Alquist-Priolo
Fault Rupture Act to include their relevant findings and Maps in the General Plan This
has not been done and they are not to be found in the Alternative Site Analysis.
The Disaster Hazards Mitigation Plan and the General Plan are to include "Safety
Elements" which are either obsolete to the point of being unsafe (in the case of the
General Plan) or non-existent.
The Safety Element would include a discussion of Seismic Safety. It does not exist anc
is not discussed in this Revision. It is impossible to compare the Safety issues between
the sites.
A quick look at the Alquist-Priolo map will show an active earthquake fault and seismic
source running through the Edison site. This has been located in Hushmand's "Locate
the Fault" report. This fault would also impact the Auto Auction site but this is not
discussed. The other sites are obviously farther from the fault and the Towne Center Site
is not in the SHMA liquefaction zone while all of the other sites are. The Towne Center
Site is also on better soil and not on valley alluvium.- Neither the "locate the fault" report
or the "civil engineering" report by Geotechnical Professionals discuss Earth Shaking.
Both claims others" did it. Such a report does not exist. Such a seismic report is required
to properly complete the liquefaction study required by the SHMA. The Civil
engineering report is fine in and of itself as far as grading, compaction and site
preparation is concerned, but it is not a SHMA report. Without such a Seismic report
discussion of the relative seismic safety is impossible but it is clear that the SCE site is
much worse than the general background risk in Rosemead in general. The building pad
at the SCE site is expected to move 3 feet horizontally and 3 feet vertically in the
"Characteristic Event" with accelerations in the range of 1.5 Gs both Horizontally and
vertically. This is not true of any of the other sites. None of the other sites are twenty
feet from the faultline. The foundation proposed in the Civil Engineering Report is also
inadequate without the seismic study required by the SHMA. The relative safety of the
sites is not discussed, but it is not expected that buildings on the other sites would move
on their foundations in a moderate shake as the neighboring Panda building did in 1987
with a similar foundation as shown in the Civil Engineering report.
J F-9
James I. Flournoy, Page 8 of 13
Building Code Issues
The California building Code 1997 also requires `'near fault" seismic factors and various
distances from a seismic source. Not only are the seismic sources shown on the Alquist
Priolo map not disclosed for any of the sites the distances from the seismic sources are
not disclosed. A cursory look at the map shows that the Auto Auction site and the Edison
site are in the highest of the "near field" categories. This is not disclosed in the EIR or in
this document, making a cost/ benefit and seismic safety analysis impossible. These
"near fault" lines would be in a Disaster Hazard Mitigation Plan if we had one. They are
not in this document either. Building to the Building Code only works if the underlying
data is provided. It has not been provided in these documents. It is impossible for a
foundation (Civil) or Structural engineer to design or compare the relative costs of
buildings on the various sites. A building on the Edison site will be much more
expensive to construct than on any of the other sites, . The fixtures will be much more
expensive, the stocking of these fixtures will much more restrictive. The Towne Center
site and the East Rosemead site are not expected to have G forces in excess of the pull of
gravity. Items may fall off shelves but they will not be launched.
There is no analysis or discussion of Safety issues.
Public safety should be the overriding consideration of this discussion. It is absent.
Access to Emergency Services and Health Care.
It is well know that Wal-Mart employees are denied access to Health insurance and
health care either through low wages, high premiums and other strategies of Wal-Mart
see attached Wal-Mart Document
The location of Wal Mart stores then affects the availability of Public Health Care.
The Auto Auction site is much closer to Los Angeles County General Hospital
Emergency room which must be the health care provider of last resort for these workers
and their families.
All of the Alternate sites have better public transportation to LA General and local free-
clinics than the Edison Site.
The effect is the same for shoppers. Wal Mart denied mitigating the lack of a paramedic
vehicle at Fire Station 4. This leaves the squad dependent on the available of the truck or
ladder units which are not appropriate for transporting employees, shoppers, or the public
in case on need.
J F-9
(cont'd)
JF-10
Any of the Alternative sites is better served by paramedic units and would be better for
the public safety.
This should be an overriding consideration.
1
1
James I. Flournoy, Page 9 of 13
Economic Impact on other Rosemead businesses.
There is no analysis of the different sites in the impact on local Rosemead Business.
There is no discussion on where Rosemead residents shop currently or who shops at
Rosemead Businesses. There is no discussion on where potential supercenter customers
live or currently shop. IT is therefor impossible to tell which site will affect our local
businesses the most. A quick look at the map will show that the auto auction site and the
Edison site will have a heavy impact on Garvey area businesses while the East Rosemead
is further from a concentration of Rosemead Businesses and will mostly affect
neighboring El Monte.
Our Gain- Their Loss
The Towne Center Mall site is down at the end of a long finger, surrounded by LA
County (South San Gabriel) and Montebello. The Montebello Towne Center site would
therefore affect Rosemead Small businesses the least, preserving the sales tax revenue,
jobs and convenience for Rosemead Residents.
Since the Mall site also provides the most convenient location for shoppers from the West
it would bring in additional sales tax revenue compared with the SCE site. Rosemead
could thus have both local and supercenter revenue. Impacts to Rosemead businesses/
shoppers would be minimized. The SCE site is inherently so disadvantageous the it may
be a temporary location till a site further West can be found by Wal-Mart at which time it
would go dark leaving a vacant 200,000 + sq. ft white elephant, no sales tax revenue and
no Rosemead small businesses remaining in competing categories and hence no sales tax
revenue at all The Towne center site is such a Westward site. The Analysis of siting a
supercenter nearer the center of Rosemead vs. one on the outskirts has not been made.
For Rosemead it should be an overriding consideration, as a dark ssupercenter will be a
financial catastrophe for the city. The Towne center mall site has the least chance of
going dark, the Edison site the most.
Economic Growth
It is in the interest of Rosemead to promote economic development.
However land use decisions have been linked to fiscal policy because the City receives a
share of sales tax revenues generated within our borders. Rosemead is seeking large
sales tax revenue sources, such as superstores, without taking into account all of the
external economic effects that superstores bring to the City or the differences between the
sites.
There is a host of complex land use, traffic, and fiscal impacts. Land use decisions
regarding superstores fall to city as lead agency even if the impacts will be regional as
well as local. The City has been derelict in its duty to fairly analyze these impacts.
The economic impact effect is missing from the Alternative Site Analysis.
Without all of the following an assessment of the Alternative sites cannot be made:
JF-11
11
James I. Flournoy, Page 10 of 13
(A) An assessment of the extent to which the proposed superstore
will capture a share of retail sales in the city, and its market area.
Since retail sales are a zero sum game, which other retailers will be affected
And how. How will site location affect the other retailers in Rosemead and the market
area,
(B) An assessment of how the construction and operation of the proposed superstore
will affect the supply and demand for retail space in the City and the market area based
on supercenter location.
(C) An assessment of how the construction and operation of the proposed superstore
retailer will affect wages and benefits, community income levels, and the demand for
employment in the City and market area. based on supercenter location.
(D) A projection of the costs of public services and public facilities resulting from the
construction and operation of the proposed superstore and the incidence of those costs.
This is to include childcare, day care, health, and on the job training and advancement. It
is obvious that the Alternative sites are better suited for the delivery of public benefits.
(E) A projection of the public revenues resulting from the construction and operation of
the proposed superstore and the incidence of those NET revenues at the different sites.
(P) An assessment of the effect that the construction and operation of the proposed
superstore retailer will have on retail operations in the same market area, and how the
location of the site alternatives would affect those retail operations
(G) An assessment of the effect that the construction and operation of the proposed
superstore will have on the ability of the City, to implement the goals contained in its
general plan, (if we had a current General plan) including, but not limited to, local
policies and standards that apply to land use patterns, traffic circulation, affordable
housing, natural resources. including water supplies, open-space lands, noise problems,
and safety risks.
(H) An assessment of the effect that the location, construction and operation of the
proposed superstore will have on average total vehicle miles traveled by retail customers
in the same market areas of the alternative sites.
JF-11
(cont'd)
James I. Flournoy, Page 11 of 13
There is NO Neighborhood Needs Assessment
The Alternative Site Analvsis does not include a Neighborhood Needs Assessment.
Neighborhood Market Needs. The Proposed Project is a mega discount supercentert, but
he ASA does not contain the following required information:
a. Existing Retail. Since the Commercial Retail Center is a Supercenter, a
region serving retailer, the ASA must include a list of names and addresses of stores of
that type that are located within the sphere of influence of the Proposed Project.
b. Consumer Benefits. The ASA must evaluate the extent to which the
' Proposed Project will provide lower-cost and/or higher quality goods to residents of the
trade area, and how this would be affected with each of the alternative sites.
C. List of Displaced Businesses. The ASA must provide the name, address,
and type of business for any business that will be physically displaced to make way for
the Proposed Project at the Alternative Sites.
Other Amenities.
' The ASA does not describe other amenities that wOl be included in the Proposed Project,
including green space, playgrounds, childcare, community centers, ESL classes and
child-oriented common areas available near the sites.
1
JF-11
(cont'd)
JF-12
11
11
d
James I. Flournoy, Page 12 of 13
Taking and Emanate Domain
The recent U.S. Supreme Court ruling not withstanding, the residents are not in favor of
emanate domain for private projects.
There is no discussion of the effect of Alternative sites on the value of homes and
businesses.
What is not Analyzed in this EIR Revision is the TAKING of private property for a
public purpose.
It was shown in Paramount that property values did increase everywhere around the Wal-
Mart. What was not discussed is that property values near the Wal-Mart barley increased
and did not increase as much as inflation. The nearby homeowners lost real value/
purchasing power. While there was a direct correlation with distance and the amount of
appreciation of similar homes.
It is clear that the Towne Center site and the Santa Anita Site would have the least effect
on the value of homes whereas the other sites would be worse. Comparing the
differences for the other sites is what's missing from this "Alternative Site Analysis."
It is not fair or just to take real value and potential appreciation from citizens and
property owners based upon their distance from a development without compensation.
With Emanate Domain a few houses may be taken for the Auto Auction and East
Rosemead sites. What is not show is that the City may own some this property already,
that most of the land is already "for sale" or would be if an offer were made. There is no
survey in this Analysis to show the cost of acquiring these properties. Just an inadequate
blanket statement that they are privately owned hence unavailable which is obviously not
accurate.
Extortion of SCE, ratepayers, and shareholders
What is also not shown is the loss To SCE, the "taking" of Edison's and it's shareholders
value by refusing to rezone for any other projects several of which would have been more
beneficial to SCE, it's shareholders and the ratepayers. This is a forced subsidy to Wal-
Mart by SCE and the City and a loss of revenue to the City and County as this below
market value forced sale (PUC is forcing SCE to sell), Rosemead is causing the property
to be sold below fair market will result in lower property taxes till the next time the
property is sold. This is an abuse of the City's zoning power. The city's General Plan
requires that the SCE site in the Cities redevelopment area be handled by special zoning
as a "planned development" This requirement was circumvented by the City to
accomplish this project.
There would be no such "below market value" (estimated at 30-5010) extorted transaction
at the other sites.
JF-13
1
1
James I. Flournoy, Page 13 of 13
These hidden subsidies make it impossible to compare the cost/ benefits of the alternative
sites.
The Alternative Site Analysis needs to investigate and analyze the comparative effect of
the Supreenter on the sites. Is a progressively greater taking of value on thousands
nearby homes better or worse than acquiring a few houses or businesses by emanate
domain, if that were even necessary-
The City does not disclose to the Citizens and businesses in this planning document that
value of their properties will vary by location and by distance from the sites.
This is as sure a taking as is emanate domain
The City is negligent in its duty to disclose this taking.
Emirate Domain is the overt taking of the past, a Wal-Mart mega discount supercenter
will insidiously take the future.
Is a beheading worse than a death of a thousand by a thousand cuts?
' Tax Impact.
The Alternative Site Analysis does not contain a projection of the change in annual tax
revenue to the City and the Agency due to the Proposed Project. This projection must
contain data segregated by type of local tax (including the utility users tax, transient
' occupancy tax, business tax, the City's share of property tax and Agency property tax
increment).
' For a supercenter the ASA shall include evidence for any assertion that the Proposed
Project will generate a NET sales tax and/or business tax increase to the City.
Site-specific tax revenue that will be dedicated to the repayment of loans shall not be
considered as new tax revenue.
Evidence of an increase in net sales tax and/or business tax shall he limited to evidence
that the Proposed Project will increase tourism within the City, and/or evidence that the
' Proposed Project is located close enough to the boundary of another jurisdiction that it
may bring new commerce to the City.
The location of the supercenter would have an impact on the property and NET sales tax
' income to the City. There is no discussion in the ASA
Concentration of business and tax generation
' There is no discussion of the relative concentration of retail sales and tax generation and
the effect of such concentration on the future of the City. Each site has its own pattern of
concentration and distribution of small business and employment. There is no analysis of
the effect of putting all the City's eggs in one basket and the demonstrated problems
inherent with such concentration and being held hostage thereto.
Continents on Alternative Site Analysis
James 1 Flournoy
9655 Landis View
J F-13
(cont'd)
JF-14
Fluornoy Attachment 1, Page 1 of 2
SalOJEQ;• ;Al '!A-BVSINFSS 'TRANSPORTATION AND HOUSINSiASFNr~• ARNOLQ SCHWARLFNQrG-cQ Govetnuc
VEPA[,TMENT OF TRANSPORTATION
DISTRICT 7, REGIONAL PLANNING
IGRJCEOA BRANCH
100 MAIN STREET, MS to 16
LOS ANGELES, CA 90012-3606
PHONE: (213) 897-3747
PAX: (213) 897-1337
March 24. 2005
Mr. Bill Crowe
City Manager
City of Rosemead
8838 East Valley Boulevard
Rosemead, CA 91770
Dear Mr. Crowe:
/•I
Flex your power,
Be energy effictenr'
Re: IGR/CEQA FEIR No. 040806/AL
Rosemead Commercial Retail Center
Wal-Mart Shopping Center
Vic. LA-60/PM R8.54
SCH # 2003121095
This letter is a follow-up to the California Department of Transportation's letter dated August 17,
2004, to Mr. Brad Johnson of the City's Planning Department which addressed the Final
Em4onmental Impact Report for the Rosemead Commercial Retail Center, which includes a
proposed Wal-Mart Shopping Center, a 23 acre Supercenter at Rush Street and Walnut Grove
Avenue in the City of Rosemead. We are concerned, as we still have not received the traffic
analysis for State Route 60 (Pomona Freeway) that was requested in our comment letters of
August 17, 2004 and June 24, 2004 (see attached). In our December 23, 2003 letter (see
attached), we also requested a traffic study that would evaluate impacts to State Route 60
mainline as well as affected freeway on/offramps. As we have stated previously:
The Department as commenting agency under CEQA has jurisdiction
superseding that of MTA in identifying the freeway analysis needed for this
project MTA 's Congestion Management Program... stipulates that
Caltrans must be consulted to identify specific locations to he analyzed on
the State Highway System.
Therefore State Route 60 and its facilities need to be analyzed per the Department's
Traffic Impact Study Guidelines. Without such analysis Caltrans is not able to make a
comprehensive assessment of potential impacts to the State transportation facilities-
Also, it could beneficial to the City to require t~! p.-:jest prop,--..n1 to undertake
mitigation that may be needed.
" Caltrans improsws mobdirv across California'
I Flournoy Attachment 1, Page 2 of 2
As you may be aware, even in instances where the number of project generated trips may be
relatively low, but the transportation facilities are already heavily congested, the cumulative
impacts of such vehicle trips can be significant.
We most respectfully, but again strongly encourage the City to require that this analysis of our
State transportation facilities be completed.
1
Again, as we stated in our August 17, 2004 letter, in the spirit of mutual cooperation we would
like the City to coordinate with the Department regarding this project. We request that the City
i meet with Caltrans to discuss this critical need for additional traffic analysis, and the elements that
need to be included in that study.
Please feel free to contact me, James J. McCarthy at 213-897-0721 to schedule a meeting at your
earliest convenience.
Sincerely
es J. McCarthv, Chief
Office of Regional Planning & Public Transportation
Planning Division-District 07
California Department of Transportation
CC:
The Honorable Jay Imperial
Mayor City of Rosemead
8838 E. Valley Blvd.
Rosemead, CA. 91770
City of Rosemead City Counci]
Mr. Henry Lo
Office of State Senator Gloria Romero
Mr. Mario Beltran
Office of State Assemblymember Judy Chu
Save Our Community
8324 Rush Street
Rosemead. CA 91770
Attachments:
Comment Letters of August 17, 2004, June 24, 2004 and
December 23. 200,
"Cakra?TS improves mohilm across California
11
11
I I
Flournoy Attachment 2, Page 1 of 12
Cn"`m ~ WATCH
Reviewing and Revising Wal-Mart 's Benefits Strategy
Memorandum to the Board of Directors
from Susan Chambers
The purpose of this memorandum is to update you on our efforts to review and revise Wal-
t Mart's benefits strategy. In response to concerns about cost trends and growing public scrutiny,
I recently led a 15-person team, drawn from across the company, in (1) evaluating Wal-Mart's
approach to benefits and (2) developing a strategy to address any short-comings.
' We evaluated Wal-Mart's current benefits offering through three lenses - cost trends, Associate
satisfaction, and public reputation - and are now recommending revisions to our benefits strategy
built around nine "limited-risk" initiatives and five "hold steps."
This memorandum summarizes our work and is divided into three sections:
Section 1 provides a detailed analysis of the three most significant benefits-related challenges we
face:
Growth in benefits costs is unsustainable (15 percent per year) and driven by fundamental
and persistent root causes (e.g., aging workforce, increasing average tenure). Unabated,
benefits costs will consume an incremental 12 percent of our total profits in 2011, equal
to $30 billion to $35 billion in market capitalization.
V,-,;dc Associates are satisfied overall with their benefits, they are opposed to most
traditional cost-control levers (e.g., higher deductibles). Satisfaction also varies
significantly by benefit and by segment of Associates. Most troubling, the least healthy,
least productive Associates are more satisfied with their benefits than other segments and
are interested in longer careers with Wal-Mart.
Healthcare is our most pressing reputation issue because well-funded, well-organized
critics, as well as state government officials, are shining a bright light on Wal-Mart's
offering. Moreover, our offering is vulnerable to at least some of their criticisms,
especially with regard to the affordability of coverage and Associates' reliance on
Medicaid.
Section 2 discusses in detail the nine limited-risk initiatives and five bold steps we are
recommending. Given conflicts inherent in the challenges we face, any set of solutions will
require carefully balancing, and sometimes making trade-offs between, cost, Associate
satisfaction, and public reputation.
s Limited-risk initiatives: We are recommending that Wal-Mart realign eligibility
requirements for health insurance; decrease cross-subsidization of spouses; give
Associates more information about how to use healthcare and health insurance; lower
company-paid life insurance coverage levels; capture savings from current initiatives to
improve labor productivity; add a combination of best practice care management
L programs; further develop high performance provider networks; offer Associates bundles
of other benefits (e.g., paid-time of) from which to choose; and continue to explore
A
n
Flournoy Attachment 2, Page 2 of 12
COHF1DFMt1~ WATCH
~,ri,WlNi
adding health clinics in stores. These initiatives will reduce costs and will slightly
improve Associate satisfaction.
Bold steps: The nine limited-risk initiatives will not fully address all the benefits-related
challenges we face. To fully address these challenges, we recommend that Wal-Mart
take five bold steps that will require more explicit trade-offs between cost, Associate
satisfaction, and public reputation. The first two recommended steps primarily address
cost trends, the third addresses attracting a healthier workforce, and the last two steps
address improving our public reputation:
Move all Associates to "progressively-designed" consumer-driven health plans to
help control cost trends while allowing Associates to build up savings in Health
Savings Accounts
Restructure the retirement program (i.e., profit sharing and 401(k) program) to
reduce costs and help Associates better save for retirement
Redesign benefits and other aspects of the Associate experience, such as job
design, to attract a healthier, more productive workforce
Make some select strategic investments in our healthcare offering (e.g., lower
maximum out-of-pocket expenses) so it can better withstand external scrutiny
Improve communication of Wal-Mart's benefits offering so we get more credit
for what we provide, and, over the long-tam, work to shape state and national
outcomes on healthcare
Section 3 summarizes the combined impact of the limited-risk initiatives and the bold steps. The
team believes this new strategy will bring powerful advantages to Wal-Mart, including:
Maintaining benefits spend at or below today's level as a percentage of sales
Offering a more attractive benefits package for healthy Associates
Better positioning us to fight Wal-Mart's critics
I presented this material to the Executive Benefits Steering Committee (Tom Hyde, Lawrence
Jackson, and Tom Schoewe) in late July. They received the recommendations enthusiastically
and asked that I syndicate them widely within Wal-Mart, something I have begun to do. They
also asked that the team continue to test and refine the strategy, especially with Associates and
external stakeholders. Our aspiration is to complete this work by late-September, receive
Executive Committee approval on the overall strategy by early-October, and hold a special
session with you in November for further discussion-
I Major benefits-related challenges
We analyzed the benefits-related challenges facing Wal-Mart through three lenses - cost trends,
Associate satisfaction, and public reputation.
Flournoy Attachment 2, Page 3 of 12
COgflDt~~~"`
Cost trends
WA'T'CH
From 2002 to 2005, our benefits costs grew significantly faster than sales, rising from 1.5 percent
of sales to 1.9 percent. Benefits spend grew from $2.8 billion to $4.2 billion during this period,
at a rate of 15 percent per year. Holding benefits costs as a percent of sales constant is critical
for Wal-Mart's long-term economic success.
A few benefits made up the bulk of this increase: healthcare ($1.5 billion) grew by 19 percent,
paid time off ($I.4 billion) grew by 14 percent, and the profit sharing and 401(k) program ($740
million) grew by 13 percent. (Over the period, the domestic Associate base grew at 5 percent
and domestic sales grew at 11 percent.)
Increased utilization of medical services, which grew by 10 percent per year, was the primary
driver of the rapid growth in our healthcare costs (Exhibit 1). Almost half of this utilization
growth was due to three Wal-Mart-specific workforce factors (distinct from national trends):
Our workforce is aging faster (0.50 years per calendar year) than the national average (0.12 years
per calendar year).
Our workers are getting sicker than the national population, particularly in obesity-related
diseases. For example, the prevalence of coronary artery disease in Wal-Mart's population grew
by 6 percent compared to a national average of 1 percent, and the prevalence of diabetes in our
population grew by 10 percent compared to a national average of 3 percent. (That said, our
workforce is no sicker at present in absolute terms than the national population.)
A segment of our workforce consumes healthcare inefficiently, in a pattern similar to a Medicaid
population. Our population tends to over-utilize emergency room and hospital services and
under-utilize prescriptions and doctor visits. This pattern is most evident among our low-income
Associates, and the team hypothesizes that this behavior results from prior experience with
Medicaid programs.
Compounding these problems am several national trends, such as the increased use of
technological innovations, which are driving increased utilization of medical services across the
U.S. healthcare system.
The cost of Wal-Mart's profit-sharing and 401(k) program and paid time off grew faster than
overall Associate growth, due largely to increasing Associate tenure. Over the past 4 years, the
average Associate tenure has increased by 0.2 months per calendar year. As a result, more
Associates qualify for participation in benefits programs like the profit sharing and 401(k) plan
and for more paid-time off. An even more important factor is wages, which increase in lock-step
with tenure and directly drive the cost of many benefits (e.g., 401(k) is a percentage of wages).
Given the impact of tenure on wages and benefits, the cost of an Associate with 7 years of tenure
is almost 55 percent more than the cost of an Associate with 1 year of tenure, yet there is no
difference in his or her productivity (Exhibit 2). Moreover, because we pay an Associate more in
salary and benefits as his or her tenure increases, we are pricing that Associate out of the labor
market, increasing the likelihood that he or she will stay with Wal-Mart.
Flournoy Attachment 2, Page 4 of 12
CDMFiDf► i WATCH
f. wl.N f+h 6lf~
We have also not effectively leveraged our benefits spend per Associate, which should be
thought of as a fixed cost for employing that Associate. We have allowed our full-time
Associates to average only 34 hours of work per week; increasing the hours worked per
Associate would enable Wal-Mart to lower our labor cost per hour by spreading benefits costs
over more hours. We also have one of the highest percentages of fiill-time Associates in the
retail industry, even though full-tune Associates are more expensive per labor hour (in terms of
both benefits and wages).
Associate satisfaction
Associates are satisfied with their overall benefits package, but they have expressed significant
opposition to most traditional cost-control levers. For instance, Associates strongly oppose
higher deductibles or limits to their choice of providers. Satisfaction varies significanty,
however, by benefit and by segment of Associate, creating an opportunity to rebalance the
benefits portfolio to improve satisfaction while reducing costs. In particular, the least healthy,
least productive Associates are more satisfied with their benefits than other segments and are
interested in longer careers with Wal-Mart.
Overall, Associates are satisfied with their benefits relative to peers at other retailers. In a survey
of retail workers, Associates ranked Wal-Mart's benefits above the industry average in
availability, ability to qualify, quality, and execution (e.g., claims processing). The cost of
healthcare coverage was the only factor on which we scored poorly.
Associate satisfaction and view of importance vary significantly by specific benefit (Exhibit 3).
For example, Associates rank health insurance as the most important benefit Wal-Mart offers,
but they also say it is the one with which they are least satisfied. The stock purchase plan, the
profit sharing and 401(k) program, and life insurance are all ranked high-satisfaction, low-
importance, suggesting an opportunity to rebalance Wal-Mart's investment in these benefits into
other more important benefits. Paid time-off and the discount card are the only high-
satisfaction, high-importance benefits.
Associate satisfaction with benefits also varies significantly by segment of Associates. The team
analyzed the Associate population on a wide variety of factors (e.g., attitude, health behavior,
tenure), the most fiuitful of which was annual healthcare spend. The so-called "low utilizers"
are the most attractive Associate segment because they cost Wal-Mart less in terms of healthcare
expenses and are more productive in their jobs. (Productivity findings were based on analysis of
individual cashier items per hour data.) Moreover, this segment also showed healthier
behaviors, specifically less prevalence of obesity. Unfortunately, the "low utilizers" were also
least satisfied with our benefits and were planning shorter careers with Wal-Mart This segment
favors a different type of benefits package than the "high utilizers," a benefits package different
than what we offer today: a health insurance offering more closely modeled on consumer-driven
health plans - lower premiums, higher deductibles, and health savings accounts. They also
prefer certain nonmedical benefits, such as help in saving to purchase a home and help in paying
for more education, neither of which we offer in a robust way today.
Flournoy Attachment 2, Page 5 of 12
caxFio~KS►W~ WATCH
~ e u~ dr Hb h~l~
It is worth noting, however, that overall benefits only play a small role in attracting Associates to
Wal-Mart and in keeping Associates satisfied while at Wal-Mart. Our benefits offering played a
key role in attracting just 3 percent of our Associates. Moreover, satisfaction with benefits does
not correlate with satisfaction with Wal-Mart. A variety of factors - especially Associates'
interactions with management - are more important.
Public reputation
Healthcare is the most pressing reputation issue facing Wal-Mart. Survey work done last
summer shows that people's perception of our wages and benefits is a key driver of Wal-Mart's
overall reputation. Several groups are now mounting attacks against Wal-Mart focused on our
healthcare offering. These increasingly well-organized and well-funded critics - especially the
labor unions and related groups, such as Wal-Mart Watch - have selected healthcare as their
main avenue of attack Moreover, federal and state governments are increasingly concerned
about healthcare costs, and many view Wal-Mart as part of the problem. (a view due, in part, to
the work of Wal-Mart's critics). Medicaid costs are a major priority on most governors'
agendas; already a quarter of states are spending more than 25 percent of their budgets on
Medicaid, and observers across the political spectrum assert that the current system - with
spiraling costs, a large population of uninsured, and an increasing number of medical
bankruptcies - is unsustainable (although there is little consensus on what should take its place).
In this environment, we can expect efforts like those in Maryland (which is trying to mandate
that companies spend a certain percentage of revenue on healthcare) and New Hampshire (which
requires health services to track where Medicaid enrollees are employed) to accelerate.
Proposals such as these, if successful, will bring added costs to Wal-Mart. Moreover, these
battles with critics and governments are contributing to the decline of Wal-Mart's overall
reputation.
Our healthcare offering is also vulnerable to attack. We have not effectively communicated the
generosity of our healthcare benefits to the general public; instead, we have thus far allowed our
critics to frame the debate. For instance, only 22 percent of Americans find it very believable
that Wal-Mart provides health insurance to 900,000 people. Wal-Mart's critics can also easily
exploit some aspects of our benefits offering to make their case; in other words, our critics are
correct in some of their observations. Specifically, our coverage is expensive for low-income
families, and Wal-Mart has a significant percentage of Associates and their children on public
assistance. Consider the following:
On average, Associates spend 8 percent of their h=rne on healthcare (premiums plus
deductibles plus out-of-pocket expenses) for themselves and their families, nearly twice the
national average. The number varies significantly by plan type, rising to 13 percent for those on
the Associate and Spouse plan.
Critics contend that the costliness of Wal-Mart's healthcare coverage causes it to enroll fewer
Associates in its health insurance plan than do most national employers (48 percent versus 68
percent) (Exhibit 4).
11,
Flournoy Attachment 2, Page 6 of 12
CDNFIDF,ma~ WATCH
,~u~~~.IN,.brl~
Associates also face significant financial risk when a medical catastrophe occurs. On the Family
plan, an Associate must spend between 74 and 150 percent of household income on healthcare
(approximately $13,000 to $27,000) before insurance takes over completely. Though few
Associates reach this level of spending, those who do almost certainly end up declaring personal
bankruptcy. In 2004, 38 percent of enrolled Associates spent more than 16 percent of the
average Wal-Mart income on healthcare.
We also have a significant number of Associates and their children who receive health insurance
through public-assistance programs. Five percent of our Associates are on Medicaid compared
to an average for national employers of 4 percent. Twenty-seven percent of Associates' children
are on such programs, compared to a national average of 22 percent (Exhibit 5). In total, 46
percent of Associates' children are either on Medicaid or arc uninsured.
On both of these issues - affordability and public assistance - it is important to note that our
offering and performance are on par with other retailers; Wal-Mart's critics, however, hold it to a
"large company' standard, not a retailer standard. Despite the difference in industry economics,
critics believe we should behave more like a GM or a Microsoft than a Target or a Sears. While
critics have not yet harnessed all of these facts, they are successfully exploiting those they do
have, suggesting that, when discovered, the others will also become effective ammunition.
2 Proposed revisions to benefits strategy
Against the backdrop of these challenges, the team is recommending that Wal-Mart implement
the nine limited-risk initiatives and five bold steps discussed in detail in this section.
Limited-Risk Initiatives
These nine initiatives require little or no trade-off between cost, Associate satisfaction, and
public reputation. Exhibit 6 provides an overview of these initiatives:
1. Realign eligibility requirements for health insurance so that Associates (full-time and part-
time) and their children qualify after working 1,000 hours and spouses qualify after the Associate
works 2,000 hours. This move would simplify external communications, make Wal .Mart even
more competitive in the part-time labor market, and help align costs with the economics of the
business (in that the benefit is based on hours worked). On average, these requirements translate
into 6 months for full-time Associates (same as today) and 1 year for part-time Associates
(versus two years today).
' 2. Decrease cross-subsidization of spouses through higher premiums or other charges. Spouses
are by far the most expensive plan members to cover, and Wal-Mart pays more per spouse than
per Associate. This change would allow us to put more dollars towards Associates and their
children.
3. Give Associates more information about how to use healthcare and health insurance. Many
' Associates are making inefficient decisions about what healthcare services to use, e.g., over-
retying on emergency rooms. We need to give Associates more information on the cost and
I I
' Flournoy Attachment 2, Page 7 of 12
~pllFl0E1i~ WATCH
' .aaulfl 411f~
' quality of specific health services, better educate them on how best to utilize healthcare, and
develop education efforts specifically for those Associates who have previously been uninsured
or on public assistance.
4. Lower company-paid life insurance coverage levels to a maximum payout of $12,000. Life
insurance, although a small cost, is the fastest growing benefits cost. It is also a high-
satisfaction, low-importance benefit, which suggests an opportunity to trim the offering without
' substantial impact on Associate satisfaction. The company-paid policy currently covers one
times an Associates annual salary, which is slightly more generous than most retailers.
1
5_ Capture savings from current initiatives to improve labor productivity. These initiatives
include reducing the number of labor hours per store, increasing the percentage of part-time
Associates in stores, and increasing the number of hours per Associate. These changes represent
a major cost-savings opportunity with relatively little impact on existing Associates. The most
significant challenge here is that the shift to more part-time Associates will lower Wal-Mart's
healthcare enrollment (even with the more generous part-time offering outlined above), which
could have an impact on public reputation.
6. Add a combination of best practice care-management programs, including utilization
management, case management, disease management, and errors and omissions programs.
These programs primarily improve quality of care, but they will also produce modest cost
savings by improving care coordination and compliance for extremely sick Associates, who
drive a disproportionate share of the cost.
7. Further develop high-performance provider (e.g., doctors, hospitals) networks so as to direct
Associates to the most efficient and effective healthcare providers. The quality of care and cost
of care vary significantly among doctors. We should be on the cutting edge of efforts to identify
the best doctors by, for instance, working with payors to find new ways to identify these doctors.
We should then create provider networks made up only of those doctors and provide Associates
with incentives for using those doctors.
8. Offer Associates bundles of other benefits (e.g., paid time off, education, discount card) from
which to choose. Our benefits package today is "one size fits all," even though different
segments of Associates value specific benefits differently. For instance, one segment would
happily give up some paid-time off in exchange for a more generous discount card. While we
believe every Associate should have a core healthcare and retirement offering, we could more
effectively spend our remaining benefits dollars by allowing Associates to choose from among
several packages of benefits.
9. Continue to explore adding health clinics in stores. Wal-Mart is starting an effort to put
clinics in stores, a strategy currently framed as a real-estate opportunity. Longer-term and with
several important modifications to the current offering (e.g., innovations to create lower cost
visits), these clinics could become an important part of our healthcare strategy, especially as a
substitute for emergency room visits.
Flournoy Attachment 2, Page 8 of 12
CDNFIDENF WATCH
r ~•ur.itit,ul(
Taken together these nine initiatives should reduce Wal-Mart's projected healthcare costs from a
projected 2.3 percent of sales in 2011 to a projected 2.0 percent of sales, largely due to the
impact of the productivity initiatives (initiative 5). The initiatives should also slightly improve
Associate satisfaction. They Krill not likely have any significant impact - positive or negative -
on public reputation.
Bold steps
The following five bold steps will be more difficult to execute than the limited-risk initiatives,
but their impact will be much greater. Exhibit 7 provides an overview of these steps.
1. Move all Associates to "progressively-designed" consumer-driven health plans to help control
cost trends while allowing Associates to build up savings in Health Savings Accounts
While relatively new in the United States, consumer-driven health plans have proven to
control medical cost trends more effectively than traditional plans in both domestic (e.g.,
Logan Aluminum) and international (e.g., Singapore) settings. These plans eliminate the
traditional deductible. In its place, Associates get a Health Savings Account (HSA), a
pretax bank account for health expenses that is similar to a 401(k). An HSA is funded
from three sources: annual seed money from Wal-Mart, an annual contribution from the
Associate, and a matching contribution from Wal-Mart. The Associate uses the HSA to
cover his or her first-dollar medical expenses every year. When an Associate has used up
his or her HSA, there may be (depending on how inuch is in the HSA) a "bridge" the
Associate must cover, which is the difference between the amount in the HSA and the
point at which coinsurance takes over.
Consumer-driven health plans are more effective at controlling costs than traditional
plans because enrollees have greater responsibility for their healthcare spending. HSA
funds belong to the Associate, so he or she has a stake in using the money wisely. If the
Associate leaves Wal-Mart, the HSA funds go with him or her. If HSA contains money
at the end of the year, those funds roll over for use in the following year. An Associate
with high healthcare expenses may also face a bridge, which serves as a further brake on
spending. Consumer-driven health plans are particularly attractive to the healthy,
productive Associate segment, because this segment now "gets something" for enrolling
in health insurance and staying healthy - they can save money in their HSA.
The key to achieving these advantages is to have all Associates participate. Otherwise
only the healthiest enroll and there is very little cost reduction because healthy people
spend so little on healthcare. During this year's enrollment cycle, we are offering a few
consumer-driven health plans (among many options); these existing offerings can serve
as a starting point for a complete transition over the next 1 to 2 years.
Such plans would have several advantages for Associates. More than 80 percent of
Associates would be better off financially under the proposed consumer-driven health
plans than under traditional plans. Associates can also accumulate wealth in their HSAs.
A typical Associate who is generally healthy would have $600 to $2,100 in savings after
Flournoy Attachment 2, Page 9 of 12
caHFioEKtu~ ■rATCH
r, ~►.,hr,f,~UJi
3 years. Associates can use this wealth both for significant health events and retirement.
Associates can also use their HSAs to cover a wide variety of health expenses, including
vision, dental, preventive care, and other spending not covered by the plan.
To make this change palatable externally, the plan design must be "progressive,"
meaning it cannot involve any cost shifting. In transitioning to consumer-driven health
plans, many companies have chosen to push more costs onto employees, a move that has
given these plans a bad reputation among progressives. The plans proposed by the team
do not involve any cost shifting. Moreover, a growing number of companies are
implementing such plans, providing Wal-Mart with more political cover. Many retailers
(e.g., Staples, Toys R Us) are offering consumer-driven health plans as one option among
many, and the ever-progressive Whole Foods recently moved all of its employees to such
a plan, to much media fanfare.
The primary reason for making this transition would be to reduce future benefits costs,
and those savings would be significant: $400 million to $700 million in FY2011, all
from reduced trend. This change does, however, come with several challenges. Overall
consumer-driven health plans are less popular with Associates than traditional plans,
albeit not dramatically so, and are more difficult to communicate. Strong opposition is
isolated to approximately 10 percent of Associates. Wal-Mart will also face reputation
challenges in implementing this change given that progressives view such plans as a
"Republican answer." Wal-Mart will have to be sophisticated and forceful in
communicating this change internally and externally.
2. Restructure the retirement program (i.e., the profit sharing and 401(k) program) to reduce
costs and help Associates better save for retirement
We should reduce our overall investment in the profit sharing and 401(k) program from
approximately 4 percent of wages to approximately 3 percent of wages. Doing so would
bring the program more in line with retail offerings and would save Wal-Mart a
substantial sum of money. Hewitt ranks our retirement program as the best in its non-
union hourly retail benchmark set. Given the scrutiny that Wal-Mart receives on
healthcare and that retirement is a low-importance benefit for Associates, the retirement
program seems to be the wrong place for over-investment.
We should also redesign the specifics of our retirement program. In particular, we should
convert the 401(k) program from a "no-strings-attached" flat contribution to a matching
program in which Associates receive funds from Wal-Mart based on the contribution they
make to their 401(k). Such a program would help Associates better prepare for
retirement A fully participating career Associate would be able to replace 30 to 40
percent of his or her income at retirement, compared to 15 percent today, resulting in
some 80 to 90 percent of income replaced at retirement (when Social Security is
included).
Overall this proposal would save Wal-Mart a significant amount of money: $650 million
to $700 million in FY2011. With respect to Associate satisfaction, Associates reacted
Flournoy Attachment 2, Page 10 of 12
~pNFSDENF WATCH
positively to a matching retirement program, although they slightly preferred the current
program. Although critics will contend that the new program is less generous than the
current one, retirement has not been a major issue in the external environment.
3. Redesign benefits and other aspects of the Associate experience, such as job design, to attract
a healthier, more productive workforce
Given the significant savings from even a small improvement in the health of our Associate base,
Wal-Mart should seek to attract a healthier workforce. The first recommendation in this section,
moving all Associates to consumer-driven health plans, will help achieve this goal because these
plans are more attractive to healthier Associates. The team is also considering additional
initiatives to support this objective, including:
Design all jobs to include some physical activity (e.g., all cashiers do some cart gathering)
Offer savings via the Discount Card on healthy foods (e.g., fruits and vegetables)
Offer benefits that appeal to healthy Associates (e.g., an education offering targeted at students).
A healthier workforce will lead to lower health insurance costs, lower absenteeism through fewer
sick days, and higher productivity. It will be far easier to attract and retain a healthier workforce
than it will be to change behavior in an existing one. These moves would also dissuade
unhealthy people from coming to work at Wal-Mart. Even a modest shift in Wal-Mart's ability
to attract and retain a healthier workforce could result in significant savings: $22.0 million to
$670 million in FY2011. The key tasks in implementing this fourth bold step, once the team has
developed a more complete list of actions, are to create a clear set of metrics to measure success,
to run pilots in several stores to understand each idea's effectiveness, and then roll-out the most
successful ones.
4. Make a series of strategic investments in our healthcare offering so it can better withstand
external scrutiny
The team is investigating a few potential investments:
To address concerns about affordability, offer at least one insurance plan that
covers Associates for $1 /day (or $14 per pay period) and allows them to cover
their children for another $1/day.
To further address concerns about affordability, lower an Associate's maximum
exposure to medical financial risk (premiums plus deductibles plus co-payments)
to a more manageable level, approximately 15 percent of the average income for a
fall-time Associate.
To address concerns about access, help Associates access the private insurance
market after 30 days of employment and potentially provide them with limited
funding for doing so while they wait to become eligible for Wal-Mart's plan.
' Flournoy Attachment 2, Page 11 of 12
CpNF1UENM1
WATCH
' These changes would give us a powerful set of messages to use in combating critics.
(For instance, "Wal-Mart offers Associates access to health insurance after they've
worked with us for just 30 days.") These kinds of changes would also make Wal-Mart's
' coverage more affordable and accessible, directly addressing critics' and Associates'
most persistent arguments.
' While this fourth bold step should create goodwill both internally and externally, it will
be expensive. In FY2011, the cost of these three proposals would be between $300
million and $350 million. Given this steep price, the team is rigorously testing these
' ideas with the public and policymakers to determine what set of investments will most
effectively "move the needle" on Wal-Mart's public reputation.
5. Improve communication of our benefits offering so we get more credit for what we provide
' and, over the long-terra, work to shape the outcomes of state and national healthcare reform
efforts
We need to be more proactive in the public arena. Three efforts are needed here:
Address the Medicaid issue head-on by refraining the debate (e.g., this is
everyone's problem, not just Wal-Mart's) and by offering some type of counter
proposal or compromise. This first effort is critical because Wal-Mart is under
serious attack from state governments with regard to the number of Associates on
publicly-funded health insurance. These attacks show no signs of abating - in
fact, they seem to be accelerating - and elected officials are proposing
increasingly costly solutions.
Clarify and improve messages about our healthcare offering (building on the
proposed changes outlined above) and engage in a sustained communication
campaign. This kind of communication will help us reframe public perception of
our healthcare offering, the only way for us to start winning the debate with our
critics. It will also help us build the credibility needed to weigh-in more broadly
on U.S. healthcare issues.
Become more engaged in the national healthcare debate, to position Wal-Mart as
a leader in healthcare in general and on access (e.g., individual mandates) and
affordability (e.g., bringing IT to healthcare) in particular. Establishing Wal-Mart
as a leader on this critical issue will help deflate our critics. It will also put us in a
position to help shape the outcome of the public debate about the healthcare crisis
in a way that is at least somewhat advantageous to our interests.
3 Impact of the proposed changes
Taken together the limited-risk initiatives and the bold steps create a powerful set of advantages
for Wal-Mart.
Flournoy Attachment 2, Page 12 of 12
cawF~oE+ma~ WATCH
,i,.,~,Nr~n~6tF1
Significant advantages
The new strategy will enable us to deal with all three of the benefits-related challenges we face.
Cost control. Benefits costs will be at or below 1.9 percent of sales (i.e., level as of FY 2005) in
2011. (The limited-risk initiatives result in about a 16-percent reduction in projected 2011
benefits costs and the bold steps yield about another 9-percent reduction.)
Associate satisfaction. Associates will have a more generous healthcare benefit with an HSA to
cover first-dollar expenses, greater protection against medical risk, and the ability to accumulate
wealth in their HSAs; a retirement benefit that helps them prepare more effectively for
retirement; and more choice, especially with regard to selecting other benefits (e.g., paid time-
off). Moreover, we will be more effective at attracting and retaining the healthy, productive
workforce Wal-Mart wants.
Public reputation. By providing Associates more affordable health coverage and responding to
concerns about Wal-Mart's Medicaid/S-CHIP enrollment, we will have addressed our critics'
most potent arguments. We will also have stepped-up our efforts to communicate the strengths
of Wal-Mart's benefits offering and counter critics' claims. Finally, we will have positioned
Wal-Mart to have a "seat at the table" in the public debate about healthcare reform.
Risks
The risks associated with these changes are worth carefully noting. Addressing them will
require, among other things, attention to implementation planning, communication, and
execution.
Cost risk If savings and investments are not properly sequenced, costs could increase before
they decrease.
Associate satisfaction risk Some of the proposed revisions to the benefits strategy (e.g., the
move to consumer-driven health plans, the changes in the retirement program) have the potential
to upset Associates, especially more tenured Associates.
Public reputation risk Healthcare enrollment will fall several percentage points due primarily to
a shift to more part-time Associates, which could draw additional attacks from Wal-Mart's
critics. Also, despite the proposed efforts, the Medicaid problem will not be "solved." A
significant number of Associates and their children will still qualify for Medicaid. Because
many of these programs will offer more generous health insurance than Wal-Mart provides,
many Assoeiates will still choose to enroll in Medicaid, leaving the door open for continued
attacks.
The team believes that the advantages of the proposed strategy outweigh these risks.
I appreciate your taking the time to engage so fully on this topic and look forward to discussing it
with you at the special Board meeting in November. In the meantime, I would welcome hearing
your reactions to our work to date.
Applied Planning, Inc. (Copyright (D 2005)
JAMES I. FLOURNOY, LETTER 1
Letter Received November 8, 2005
Response JF-1
The EIR Revision appropriately reflects and responds to applicable CEQA criteria
regarding an EIR consideration and evaluation of alternative sites. The multiple topics
cited by the commentor are not germane in that the majority of the referenced topics are
not environmental concerns addressed under CEQA. Further, none of the alternative sites
considered were found to be reasonable, and as such did not warrant analysis beyond that
which has been provided in the EIR Revision. Other statements and opinions expressed
by the commentor will be forwarded to the decision-makers. Analysis and conclusions of
the EIR Revision are not affected.
Response JF-2
Certain traffic impacts of the Project, related to Caltrans vehicle density thresholds along
SR-60, are acknowledged as significant within the Draft EIR. The Project will not result in,
nor create any other significant traffic or circulation impacts, including potential impacts
associated with truck/delivery access, public transportation, or pedestrian access. As such,
there is no requirement to consider alternative sites that would relieve the commentor's
perceived traffic congestion/traffic safety concerns. Please refer to the discussion of
potential Project-related traffic impacts presented at Draft EIR Section 4.3, "Traffic and
Circulation," within Draft EIR Appendix C, "Traffic Impact Study," and relevant responses
presented in the August 2004 Final EIR Section 3.0, "Comments and Responses."
The commentor provides a March 24, 2005 letter from Caltrans (attached), which letter
reiterates comments that have been previously addressed within the Draft EIR and August
2004 Final EIR. No further response to these comments is required. It is also noted that the
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-109
Applied Planning, Inc. (Copyright © 2005)
lawsuit challenging the EIR raised multiple issues; only two (2) of which were found to
have merit. In this regard, when the EIR was challenged in Court, it was determined by
the Court that:
Petitioners criticism of the treatment in the EIR of traffic impact (emphasis
added), light and glare, urban decay, earthquake risks, runoff and drainage, are
also without merit. The EIR adequately considers and discusses those problems,
and the City's decision to proceed with the project in spite of them is supported
by substantial evidence.
Analysis and conclusions of the EIR Revision are not affected. The commentor's statements
and opinions will be forwarded to the decision-makers.
With regard to the "Starlight" and Santa Anita Avenue/SR 60 freeway sites referenced by
the commentor, these locations are beyond the scope of the revised site analysis as defined
by the Lead Agency. CEQA does not require that an EIR Alternative Analysis consider
every conceivable project alternative or alternative project location, only that a reasonable
range of alternatives be considered, as determined by the Lead Agency. The EIR Revision
document considers (and rejects) three (3) potential alternative sites, and further discusses
the reasons for the original rejection of the prior Ralph's Market site. Additionally, within
the Draft EIR, three (3) alternatives were considered (and rejected), and six (6) additional
alternatives (including the CEQA-mandated "No Project Alternative") were assessed and
compared with the Project. The City of Rosemead, as the Lead Agency, has determined
that this analysis satisfies CEQA's requirements to examine a reasonable range of
alternatives, with supporting reasoning for rejection of potential alternative sites from full
consideration. Evidencing available information to permit an informed choice, the City
rejected the initially proposed Project, and adopted the Project Design Alternative.
Not withstanding the previous discussion, the "Starlight" and Santa Anita Avenue/SR 60
sites fail feasibility considerations in that these sites are beyond the jurisdiction of the Lead
Agency, and are not known to be available. Further, there would be no substantial
reductions in the Project's significant environmental impacts if constructed at these
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-110
Applied Planning, Inc. (Copyright © 2005)
locations. That is, both locations evidence proximate residential uses that would be
affected by construction noise; there would be no substantial reduction (if any) in
construction or operations emissions and SCAQMD thresholds would still be exceeded
(construction emissions may actually increase due to necessary demolition activities); and
mainline freeways would still experience increased Project-related traffic resulting in
exceedances of Caltrans vehicle density criteria.
With specific regard to the former "Starlight" drive-in, this location fails feasibility
considerations in that the site is beyond the jurisdiction of the Lead Agency, not within the
control of the applicant, and not known to be available. Further, there would be no
substantial reductions in the Project's significant environmental impacts if constructed at
this location. This location evidences proximate residential uses that would be affected by
construction noise; there would be no substantial reduction (if any) in construction or
operations emissions and SCAQMD thresholds would be exceeded; and mainline freeways
would still experience increased Project-related traffic resulting in exceedances of Caltrans'
vehicle density criteria. This location would require demolition of existing facilities which
would add to air and noise impacts. Additionally, this site is only 11.5 acres and is
therefore too small to support the project.
With regard to the Santa Anita/SR-60 Freeway location, no specific corner was listed, but
all four corners are outside of the jurisdiction of the City of Rosemead and not within the
control of the applicant, and it is unknown if the property is available. Further, there
would be no substantial reductions in the Project's significant environmental impacts if
constructed at this location. Depending on specific corner, there are proximate residential
uses that would be affected by construction noise; there would be no substantial reduction
(if any) in construction or operations emissions and SCAQMD thresholds would be
exceeded; and mainline freeways would still experience increased Project-related traffic
resulting in exceedances of Caltrans' vehicle density criteria.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-111
11
Applied Planning, Inc. (Copyright © 2005)
With regard to public transportation issues cited by the commentor, the Project will not
significantly impact public transportation systems or facilities. As such, the alternatives
analysis need not consider this potential environmental impact. Available public
transportation systems are discussed at Pages 4.3-15 and 4.3-16 of the Draft EIR, and the
Project's estimated transit demands (593 daily trips) are presented at Draft EIR Page 4.3-43.
Even assuming full use of transit systems, this would account for less than five percent of
the Project's total daily traffic. As such, no substantial reductions in traffic or air quality
impacts would result based on potential use of transit services.
It is further noted that speculative reductions in traffic impacts and air quality impacts,
based on assumed use of transit systems and transit facilities or other alternative
transportation modes, is inconsistent with assessment and disclosure of the Project's
probable maximum traffic and air quality impacts, and would be similarly inconsistent
with environmental assessment and disclosure provisions of CEQA and related policies
and procedures adopted by the Lead Agency.
Analysis and conclusions of the EIR Revision are not affected. The commentor's other
statements and opinions will be forwarded to the decision-makers.
Response IF-3
The Project will not result in, nor create significant aesthetic or light/glare impacts. As
such, no consideration of alternative sites relative to reduced aesthetic or light/glare
impacts is required.
The alternatives shall be limited to ones that would avoid or substantially
lessen any of the significant effects of the Project. [CEQA Guidelines §15126.6 (f)]
Please refer to the discussion of potential Project-related aesthetic and light/glare impacts
presented at Draft EIR Section 4.7, "Aesthetics, Light and Glare," and relevant responses
presented in The August 2004 Final EIR Section 3.0, "Comments and Responses." The EIR
Revision appropriately reflects and responds to applicable CEQA criteria regarding an EIR
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-112
Applied Planning, Inc. (Copyright © 2005)
consideration and evaluation of alternative sites. It is also noted that the lawsuit
challenging the EIR raised multiple issues; only two (2) of which were found to have merit.
In this regard, when the EIR was challenged in Court, it was determined by the Court that:
Petitioners criticism of the treatment in the EIR of traffic impact, light and
glare (emphasis added), urban decay, earthquake risks, runoff and drainage,
are also without merit. The EIR adequately considers and discusses those
problems, and the City's decision to proceed with the project in spite of them
is supported by substantial evidence.
Analysis and conclusions of the EIR Revision are not affected. The commentor's statements
and opinions will be forwarded to the decision-makers.
Response IF-4
The Project will not result in, nor create significant open space impacts. Please refer to the
discussion of potential Project-related land use impacts presented at Draft EIR Section 4.1,
"Land Use," within the Project Initial Study, EIR Appendix A, and relevant responses
presented in The August 2004 Final EIR Section 3.0, "Comments and Responses." The EIR
Revision appropriately reflects and responds to applicable CEQA criteria regarding an EIR
consideration and evaluation of alternative sites.
The alternatives shall be limited to ones that would avoid or substantially
lessen any of the significant effects of the Project. [CEQA Guidelines §15126.6
X01
Analysis and conclusions of the EIR Revision are not affected. The commentor's statements
and opinions will be forwarded to the decision-makers.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003 1 2 1 095) Page 4-113
Applied Planning, Inc. (Copyright © 2005)
Response TF-5
The commentor's opinions regarding commercial occupancy compatibilities will be
forwarded to the decision-makers. Irrespective of the mix of users within the Montebello
Town Center Mall, the Robinsons-May/Montebello Town Center site also fails in terms of
its ability to substantially reduce the Project's significant impacts. The Robinsons-
May/Montebello Town Center site fails as well under general feasibility considerations.
As presented in the CEQA Guidelines:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit
a reasoned choice. The alternatives shall be limited to ones that would avoid
or substantially lessen any of the significant effects of the Project. [CEQA
Guidelines §15126.6 (01
Pages 3-11 through 3-14 of the EIR Revision substantiate that the Robinsons-
May/Montebello Town Center site fails at several levels within the context of the CEQA
"rule of reason" criteria and standards for identification and consideration of alternatives
to the Project. Foremost, selection of the Robinsons-May/Montebello Town Center site
alternative would not substantially reduce significant environmental impacts of the Project.
At best, these impacts would be transferred from one locale to another.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-114
Applied Planning, Inc. (Copyright © 2005)
The Robin sons-M ay/M ontebello Town Center site also fails in terms of its feasibility. In this
regard, CEQA provides guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional
boundaries, and whether the proponent can reasonably acquire, control, or
otherwise have access to the alternative site. [CEQA Guidelines §15126.6 (f)
(1)]
As presented in the EIR Revision, the referenced Robinsons-May/Montebello Town Center
site is not configured to reasonably accept the Project building footprint and facilities plans.
Further, the subject site is not currently under control of the Project proponent (and for that
matter is not known to be available). In this latter regard, the EIR Revision acknowledges
that the status of the Robinsons-May/Montebello Town Center site for future
redevelopment is questionable. This is borne out by comments on the EIR Revision
provided by the City of Montebello, which comments have ultimately removed the
Robinsons-May/Montebello Town Center site from consideration as a potential location for
the Project. Based on the City of Montebello's comments, Pages 3-11 and 3-12 of the
Revised Alternative Site-Analysis are amended to read as follows:
a. Site Description
Alternative Site 3, located on the eastern edge of the Montebello Town Center
mall, was identified as a possible alternative due to the recently announced
corporate mergerbetween the May Department Stores Company and Federated
Department Stores, Inc. The closure of the Robinsons-May store is anticipated
by the City, although this store was not identified in the latest list of locations
planned for divestiture, issued by Federated Department Stores on July 28,
2005. In response to the Revised Alternative Site Analysis, Rosemead has
learned that this site will not be available as the store will remain open as a
Macy's store.
stores are being studied for potentiai camveFsiom of the Blbomimgdiqle~s
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-115
Applied Planning, Inc. (Copyright © 2005)
thein being vacated. Thene is no indication, howevet', that the Montebeffo Town
6eritet- location wouid be inciuded in this Plan.
b. Potential Feasibility of Site
a. The existing Robinsons-May store is approximately 140,100 square feet
in size, and is located on an 8.75 acre parcel that provides shared mall parking,
as shown in the following Figure 7.3-3. In order to accommodate the proposed
Wal-Mart Supercenter, substantial re-design of the Project would be required,
resulting in the construction of a multiple-story facility with additional, at-grade
or subterranean parking. Based on the information from the City of Montebello,
as well as problems relating to project design, the site is considered unavailable
and the alternative rejected as infeasible.
Beyond the obstacles of site availability and project design, compatibility
between the proposed Wal-Mart and the existing mall is an additional concern.
The Montebello Town Center is an upscale, regional mall. As such, retailers
within this mall seek to draw consumers from a different market sector than that
of the discount retailer and grocery seller, and the introduction of a discount
retail/grocery use within the existing mall could be incompatible and have a
detrimental economic effect on adjacent retailers. Accordingly, this alternative
site was determined to be infeasible.
As summarized above, and supported by information and findings presented within the
EIR Revision, selection of the Robinsons-May/Montebello Town Center site would not
realize any substantive environmental relief or benefit when compared to the current
Project site. Nor is the Robinsons-May/Montebello Town Center site considered to be a
feasible location for the Project based on its lack of availability and physical constraints.
Response TF-6
The Project will not result in, nor create significant stormwater runoff impacts. Please refer
to the discussion of potential Project-related stormwater runoff impacts presented within
the Project Initial Study, Draft EIR Appendix A. The EIR Revision appropriately reflects
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-116
Applied Planning, Inc. (Copyright © 2005)
and responds to applicable CEQA criteria regarding an EIR consideration and evaluation
of alternative sites.
The alternatives shall be limited to ones that would avoid or substantially lessen
any of the significant effects of the Project. [CEQA Guidelines §15126.6 (f)]
It is also noted that the lawsuit challenging the EIR raised multiple issues; only two (2) of
which were found to have merit. In this regard, when the EIR was challenged in Court, it
was determined by the Court that:
Petitioners criticism of the treatment in the EIR of traffic impact, light and glare,
urban decay, earthquake risks, runoff and drainage (emphasis added), are also
without merit. The EIR adequately considers and discusses those problems, and
the City's decision to proceed with the project in spite of them is supported by
substantial evidence.
Analysis and conclusions of the EIR Revision are not affected. The commentor's statements
and opinions will be forwarded to the decision-makers.
Response JF-7
The Project is mandated to comply with City and UBC energy conservation design
methodologies and construction techniques. However, the Project will not be designed to
any LEED standard, nor is compliance with any such standard required under CEQA, or
by the City. Any such compliance is voluntary and there are no applicable CEQA or City
"LEED" criteria thresholds. The Project will not result in any significant impacts in this
regard. The EIR Revision appropriately reflects and responds to applicable CEQA criteria
regarding an EIR consideration and evaluation of alternative sites. Analysis and
conclusions of the EIR Revision are not affected. The commentor's statements and opinions
will be forwarded to the decision-makers.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-117
Applied Planning, Inc. (Copyright © 2005)
Response TF-8
The EIR does conclude and disclose that, even after the application of all feasible mitigation
measures, the Project will result in certain exceedances of South Coast Air Quality
Management District (SCAQMD) emissions thresholds. In this regard, additional
pollutants generated by the Project will generally affect regional air quality conditions.
However, such effects do not equate to localized health risks. As a point of fact, due largely
to ambient air pollutant conditions within urban Southern California, it is not uncommon
for new development projects to exceed SCAQMD emissions thresholds.
Consistent with the provisions of CEQA, the City may decide to proceed with the Project
in spite of its significant air quality impacts. In this regard, the previous Project approval
included the adoption of a Statement of Facts, Findings and Overriding Considerations
which acknowledged that certain impacts could not be avoided, but found that thebenefits
of the Project outweigh those impacts.
More specifically, potential air quality impacts of the Project are discussed within Draft EIR
Section 4.4, "Air Quality," and the detailed technical Air Quality Impact Study presented
within Draft EIR Appendix D, "Air Quality and Noise Impact Study." Air quality impacts
significance thresholds applicable to the Project are based on criteria pollutant thresholds
established by the SCAQMD, and subsequently adopted by the Lead Agency. And it is on
this basis, when evaluated against established SCAQMD criteria, that certain air quality
impacts of the Project are determined to be significant. The Project's significant air quality
impacts are area-wide or regional in nature, and the SCAQMD thresholds are the accepted
criteria to quantify the Project's relative individual contribution to basin-wide air quality.
These significant impacts are not however, a specific indicator of localized health risks.
With the exception of certain adopted localized criteria and standards, discussed below,
SCAQMD thresholds are not location-specific within the South Coast Air Basin (Air Basin).
On this basis, air quality exceedances that are generated by the Project would result
irrespective of its location within the Basin.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-718
Applied Planning, Inc. (Copyright © 2005)
With specific regard to the commentor's expressed concerns regarding potential air
pollutant health risks that may result from the Project, potential localized air quality
impacts and related health risks for sensitive receptors (not to be confused with numeric
exceedances of SCAQMD thresholds for area-wide Basin criteria pollutants) are addressed
at Draft EIR Pages 4.4-41 through 4.4-48. The Project's potential localized air emissions
impacts as discussed in the Draft EIR are associated with the [previously] proposed gas
station [subsequently removed under the adopted Project Design Alternative], and
potential localized CO concentrations at Study Area intersections. As discussed in the
Draft EIR, the Project would not result in significant localized air quality impacts either
through operations of the previously considered gas station, nor would the Project result
in or cause CO exceedances at Study Area intersections.
Relevant responses to the commentor's concerns regarding potential health effects of
Project-related criteria pollutant emissions have also been previously provided at Pages 3-
110 and 3-111 of the August 2004 Final EIR:
If approved, the operation of the Project will exceed the South Coast Air Quality
Management District (SCAQMD) thresholds of significance for three of the five
criteria pollutants, including reactive organic gases (ROG), oxides of nitrogen
(NOx), and carbon monoxide (CO). Based on these exceedances, the decision-
making body will need to adopt a Statement of Facts, Findings, and Statement
of Overriding Considerations that acknowledges the exceedances and makes
findings that essentially declare that certain benefits of the Project outweigh the
environmental impacts for the Project.
The SCAQMD advises the lead agency in addressing and mitigating the
potential adverse air quality impacts caused by projects both during and after
construction. The SCAQMD has established short-term construction-related and
long-term operational thresholds of significance which they recommend for use
by lead agencies in considering both primary or direct impacts and secondary
or indirect impacts on air quality.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-119
Applied Planning, Inc. (Copyright © 2005)
The SCAQMD emissions thresholds are basically indicators of potential air
quality impacts. They do not indicate whether or not State or federal clean air
standards will be exceeded in the Project vicinity and provide no information
regarding the presence or absence of sensitive receptors. In essence, the
thresholds provide an indication of whether or not the air pollutant emissions
expected to accompany a project are substantial enough to warrant analysis in
an EIR and the application of mitigation measures.
Ambient air quality is determined from data collected at air quality monitoring
stations located throughout the South Coast Air Basin. Ambient air quality data
is given in terms of state and federal standards. These standards represent air
pollutant concentrations which are considered safe (with a reasonable margin of
safety) to protect the public health and welfare. As such, they represent
objectives for acceptable concentrations of specified pollutants in outdoor air.
Ambient air quality standards are designed to protect public health and that
segment of the population that is most sensitive and susceptible to respiratory
distress or infection such as: asthmatics, the very young, the elderly, people
weak with illness or disease, or persons engaged in heavy work or exercise (i.e.
sensitive receptors). Healthy adults can tolerate periodic exposures to air
pollutant levels well above these standards before adverse health effects are
observed.
. . . The pollutant modeling demonstrates that future carbon monoxide
concentrations adjacent to the most heavily used intersection in the Project
vicinity will be one-half of the State standard and one-third of the Federal
standard during weekday peak hours.
Localized effects of Project-related construction air emission impacts may be less
perceptible if the Project were implemented within a commercial or industrial context.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2 003 1 2 1 095)
Comments and Responses
Page 4-120
I I
Applied Planning, Inc. (Copyright © 2005)
However, area-wide air quality impacts of the Project would remain significant as
determined by applicable SCAQMD significance threshold criteria.
With specific regard to the Town Center site, this site has been ultimately removed from
consideration pursuant to direction from the City of Montebello, as discussed under
Response JF-5.
Response IF-9
The Project will not result in, nor create significant seismic/hazards or other safety impacts.
As such, the alternative site analysis need not consider this potential impact. Please refer
to the discussion of potential Project-related land use impacts presented at Draft EIR
Section 4.1, "Land Use," Section 4.2, Earth Resources," within the Project Initial Study, EIR
Appendix A, and relevant responses presented in The August 2004 Final EIR Section 3.0,
"Comments and Responses." The EIR Revision appropriately reflects and responds to
applicable CEQA criteria regarding an EIR consideration and evaluation of alternative sites.
It is also noted that the lawsuit challenging the EIR raised multiple issues; only two (2) of
which were found to have merit. In this regard, when the EIR was challenged in Court, it
was determined by the Court that:
Petitioners criticism of the treatment in the EIR of traffic impact, light and glare,
urban decay, earthquake risks (emphasis added), runoff and drainage, are also
without merit. The EIR adequately considers and discusses those problems, and
the City's decision to proceed with the project in spite of them is supported by
substantial evidence.
Analysis and conclusions of the EIR Revision are not affected. The commentor's statements
and opinions will be forwarded to the decision-makers.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-121
Applied Planning, Inc. (Copyright © 2005)
Response IF-10
The Project will not result in, nor create significant emergency access and/or public services
impacts. Please refer to the discussion of potential Project-related traffic impacts presented
at Draft EIR Section 4.3, "Traffic and Circulation," within Draft EIR Appendix C, "Traffic
Impact Study," and relevant responses presented in The August 2004 Final EIR Section 3.0,
"Comments and Responses." Potential public services impacts of the Project are
considered within Draft EIR Section 4.6, "Public Services," and the Project Initial Study, EIR
Appendix A, and are determined to be less-than-significant. The EIR Revision
appropriately reflects and responds to applicable CEQA criteria regarding an EIR
consideration and evaluation of alternative sites.
The alternatives shall be limited to ones that would avoid or substantially lessen
any of the significant effects of the Project. [CEQA Guidelines §15126.6 (f)]
Analysis and conclusions of the EIR Revision are not affected. The commentor's statements
and opinions will be forwarded to the decision-makers.
Response 1F-11
CEQA specifically states that economic or social effects of a project shall not be treated as
significant impacts on the environment. However, physical changes that could result from
economic or social effects of projects are within the scope of CEQA considerations. The
Project will not result in, nor create significant economic impacts that would result in any
adverse physical change. Please refer to the discussion of potential Project-related
economic impacts presented at Draft EIR Section 4.1, "Land Use," the Project Economic
Analyses presented at Draft EIR Appendix E, and relevant responses presented in The
August 2004 Final EIR Section 3.0, "Comments and Responses."
The EIR Revision appropriately reflects and responds to applicable CEQA criteria
regarding an EIR consideration and evaluation of alternative sites.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-122
Applied Planning, Inc. (Copyright @ 2005)
The alternatives shall be limited to ones that would avoid or substantially lessen
any of the significant effects of the Project. [CEQA Guidelines §15126.6 (f)]
Analysis and conclusions of the EIR Revision are not affected. The commentor's statements
and opinions will be forwarded to the decision-makers.
Response JF-12
The Project is mandated to comply with City site and building design standards, to include
provision of appropriate supporting site facilities. There are no applicable CEQA or City
"amenities" criteria thresholds. The Project will not result in any significant impacts in this
regard. The EIR Revision appropriately reflects and responds to applicable CEQA criteria
regarding an EIR consideration and evaluation of alternative sites.
The alternatives shall be limited to ones that would avoid or substantially lessen
any of the significant effects of the Project. [CEQA Guidelines §15126.6 (f)]
Analysis and conclusions of the EIR Revision are not affected. The commentor's statements
and opinions will be forwarded to the decision-makers.
Response JF-13
The Project will not result in, nor create significant land use impacts, including potential
property value impacts. Please refer to the discussion of potential Project-related land use
impacts presented at Draft EIR Section 4.1, "Land Use," the Project Initial Study, EIR
Appendix A, the Project Economic Analyses presented at Draft EIR Appendix E, and
relevant responses presented in The August 2004 Final EIR Section 3.0, "Comments and
Responses." The EIR Revision appropriately reflects and responds to applicable CEQA
criteria regarding an EIR consideration and evaluation of alternative sites.
The alternatives shall be limited to ones that would avoid or substantially lessen
any of the significant effects of the Project. [CEQA Guidelines §15126.6 (f)]
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCN No. 2003121095) Page 4-123
Applied Planning, Inc. (Copyright © 2005)
It is also noted that the lawsuit challenging the EIR raised multiple issues; only two (2) of
which were found to have merit. In this regard, when the EIR was challenged in Court, it
was determined by the Court that:
Petitioners criticism of the treatment in the EIR of traffic impact, light and glare,
urban decay (emphasis added), earthquake risks, runoff and drainage, are also
without merit. The EIR adequately considers and discusses those problems, and
the City's decision to proceed with the project in spite of them is supported by
substantial evidence.
Please refer also to previous responses regarding the "Town Center" and "Santa Anita"
sites.
Analysis and conclusions of the EIR Revision are not affected. The commentor's statements
and opinions will be forwarded to the decision-makers. Please refer also to Response JF-11.
Response TF-14
Please refer to Response JF-11.
Rosemead Commercial Retail Center Comments and Responses
Revised Final El R (SCH No. 2 003 1 2 1 095) Page 4-124
James I. Flournoy, Letter 2, Page 1 of 2
Y,Ty 'iC `1{G
Uomments on the Amended EIR-Alternative Sites - r J
lama 1 FlournoN LL-
80;5 f Landisvisc%i Lane
,n EIR carries out CEOA's purpose of protecting California's emumunenial quality M Identify ing the
,n-mificani environmental impacts of a proposed pmjcct. the ways those impacts can be nuueated or
ai oided. and the alternativ es to the pmte =
'
JF2-1
?lac core of an E.IR is the tniuganon and alternatives sections. The .Amended EIR dose not contain the
prt+duction of Information su"ficieni to pernut a reasonable choice of altemames so far ac emironmcnial
'
ispccts are concerned
lie Amended EIR must consider and discuss the alicrnam e(s; of a smaller retail cor»pie\ at cash slit
JF2
2
i 1us the Amended EIR wholly fails to accomplish
-
t
-lnother concern is iiith the traffic-related emissions resulting from the Supercenter•s operation (i.e.. use)
F he Alternative sites air quality analysis improperly. fails to disclose and anal%ze the specific traffic-based
'
R(.Xi and NO\ emissions from protect at the alternative sites
I'hc Amended EIR wholly fails to compare the alternative sites by anahzang which best meets traffic bawd
air quality impacts and «hich best meet the state air quality standard for ozone
'
Hic Amended EIR fails to provide adequate information regarding the Alternative Sites individual air
qualm impacts. To be sufficient. the Amended EIR will have to disclose and analvze "hat the Altemative
Sites sWcific traffic-based ROG and NOx emissions (or estimates[ are. what titer contributions to the
r:,ional emissions budgets are. and u hether these emissions and contributions are significant (for example.
'
:n ~ompanson to other existing or planned projects within the transponation confortiut} analysts).
The Amended EIR fails to disclose and analyze. as required b% CEQA the traffic-based ozone precursor
JF2-3
.missions (reactive organic gases-ROG. and nitrogen oxide-NOx) that would be speciftcall% generated bi
'
the operation of the Supercenter or .Alternati%c project at die Alternate sites
'1u: altentauve EIR fatLs to disclose and analize the most fundamental uiformauon about the traffic-based
'
.:er quality impacts Involving ROG and NOx. rncluchn,2 iihui Muse,m.mcrs si vcrlicallrorr and howmuch
•r the rcLUrnal enrrsawi: hudYee.. rrrrr<ursnnrmc
flue Alternaui a EIR does not discuss (lie protects conlonntr\ with the reponal mobtle source emissions
budgets for ROG and NOx or whether these consinutes Ietels of RUG and NOS that permit attammem of
the state ozone standard-
This confornim issue encompasses the application of a distinct. numerical. statuton air quality- standard
(die state ambient air qualil standard for ozone of 0.09 porn; to a distinct. wideli knoisn a11al~vcal
approach for determining air qualit\ impacts There is no discussion on %s huh site . if cols site. man meet
these standards or which can best meet these standards
What is required is the production of infornmtion sufficient to permit a reasonable choice of alternausves so ~ JF2-4
far as environmetnal aspects are concerned
The Superccnter's specific air emissions regarding ROG and NCr, i,cic never disclosed and anahzed but
must be. and for each site
The discussion of the Sites iraffii, 1xj,%cd Rl.>(i NCh impacts rcndcrs the U'R inadequate. ulu)mplete. JF2-5
and insufficient as an infornuiuonal document for the decision makers and the public
James I. Flournoy, Letter 2, Page 2 of 2
The P ltctnattye E1R. Anale sts is &ficicttt in addressing exunpartn, and colwasww-, (tic tugJAtttmc Hoist
impacts to residential neighborhoods from the altemauyc situ
The most fundamental information about the projects noise impacts. including the existing ambient noise JF2-6
levels. the number and fi•equencyv of additional nichrtimc trips and their eflCCI on ambient noise levels and
sleep are non addressed as pan of the Analvsis
What is required is the production of inforniation sufficient to permit a reasonable choice of alternatives so
far as environmental :aspects are concerned The Alternative sites document wholl% fails in tins. JF2-7
The relative mrpacts of the Alternattx a Sites on the various frccwvaN interclta» ges in or new Rosemead is
not compared and contrasted The failure to include an% freeway interchanges m the intunl EIR much less
all of the relevant freewav mterchanges makes it impossible to evaluate their relative impacts JF2-8
Failure to include any freeway interchanges and their on and off'ratnps by limiting the uopc of the stud} is
an abuse of discretion by the lead agency
Failure to mchtde any freeway interchanges or orU off ramp anal~•sis prevents anah-ring comparing
contrasting am of the site's for the effect of auto tnps or truck traffic. JF2-9
.a prejudicial abuse of discretton occurs
If the failure to include relevant infonnattnn precludes informed decision making and infotnted public
pamcipation. thcrcbe thwartim; the statuton goals of the EIR process Such an analysis tivas reasonable
feasible and should have been accomplished
An Altenuitive sites analysis mast evaluate. compare and contrast the prgject's significant
11) direct impacts to the environment
(those caused b% the project and occurring at the same time and place).
rwsonabl} foreseeable indirect impacts
(those causedbN the projeci but later in ume or farther removed in distances and
(3) cumulative impacts
(the project's incremental impact when added to other related projects).
While a lead agency has discretion to choose the method to evaluate en%-tronmcnW Impacts, the mtegnt~ of
the process is dependent on [its] adequacy and the method chosen must provide an adequate analysts.
JF2-10
James I Rournoe
Applied Planning, Inc. (Copyright © 2005)
JAMES I. FLOURNOY, LETTER 2
Letter Received November 14, 2005
Response JF2-1
The commentor's interpretation of CEQA and the EIR process are noted and will be
forwarded to the decision-makers. Analysis and conclusions of the EIR Revision are not
affected.
Response JF2-2
Contrary to the commentor's assertions, there is no requirement to "consider and discuss
alternative(s) of a smaller retail complex at each site." (Nor is an EIR required to provide
an alternative analysis for any other myriad possible combinations of project locations,
sizes, configurations, etc.) An EIR is to provide a reasonable range of potentially feasible
alternatives, as determined by the Lead Agency. The EIR Revision document considers
(and rejects) three (3) potential alternative sites, and further discusses the reasons for the
original rejection of the prior Ralph's Market site. Additionally, within the Draft EIR, three
(3) alternatives were considered (and rejected), and six (6) additional alternatives (including
the CEQA-mandated "No Project Alternative") were assessed and compared with the
Project. The City of Rosemead, as the Lead Agency, has determined that this analysis
satisfies CEQA's requirements to examine a reasonable range of alternatives, with
supporting reasoning for rejection of potential alternative sites from full consideration.
Evidencing available information to permit an informed choice, the City rejected the
initially proposed Project, and adopted the Project Design Alternative.
Response TF2-3
Contrary to the commentor's assertions, the EIR Revision provides sufficient and relevant
analysis of air quality impacts that would likely occur under each of the alternative site
scenarios. Mobile source emission will account for the predominance of the Project's
operational pollutant emissions. More specifically, as presented at Draft EIR Table 4.4-8
"Project Buildout Operational Air Pollutant Emissions (Year 2005 Pounds/Day)," mobile
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-127
Applied Planning, Inc. (Copyright © 2005)
source (traffic) pollutant emissions will account for approximately 99.6 percent of
operational ROG emissions, 97.7 percent of operational NOx emissions, 99.8 percent of CO
emissions, 100 percent of SOz emissions, and 100 percent of operational PM10 emissions.
As such, any discernible alteration in Project operational emissions impacts is effectively
determined and defined by the Project trip generation and resulting traffic volumes. None
of the alternative sites would substantially reduce or alter the Project trip generation
characteristics or traffic volumes, and thus would not discernibly affect Project operational
emissions impacts. Analysis and conclusions of the EIR Revision are not affected. The
commentor's statements and opinions will be forwarded to the decision-makers.
Contrary to the commentor's assertions, applicable air quality impact significance
thresholds are established by the South Coast Air Quality Management District, as
discussed in the Draft EIR Section 4.4, Air Quality." Analysis and conclusions of the EIR
Revision are not affected. The commentor's statements and opinions will be forwarded to
the decision-makers.
Response 1F24
Please refer to Response JF2-2.
Response JF2-5
Please refer to Response JF2-3.
Response TF2-6
Certain noise impacts of the Project are recognized as significant due to exceedances of
applicable City noise thresholds for construction activities. These impacts will dissipate
completely at the conclusion of construction activities. The Project will not result in, nor
create significant long-term operational noise impacts. Please refer to the discussion of
potential Project-related noise impacts presented at Draft EIR Section 4.5, "Noise," within
Draft EIR Appendix D, "Air Quality and Noise Impact Study," and relevant responses
presented in The August 2004 Final EIR Section 3.0,"Comments and Responses." Localized
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCN No. 2 003 1 2 1 095) Page 4-128
Applied Planning, Inc. (Copyright © 2005)
effects of Project-related construction noise impacts may be less perceptible if the Project
were implemented within a commercial or industrial context. However, construction noise
impacts of the Project would remain significant as determined by applicable City
significance threshold criteria. As demonstrated in the EIR Revision, there are no feasible
alternative sites that would substantially reduce the significance of the Project's
construction noise impacts.
Further, as demonstrated within the EIR Revision, the considered alternative sites fail at
other levels within the context of the CEQA "rule of reason" criteria and standards for
identification and consideration of alternatives to the Project. As presented in the EIR
Revision, the alternative sites are either not currently under control of the Project
proponent (and for that matter are not known to be availabie), and/or are not configured
to reasonably accept the Project building footprint and facilities plans.
Analysis and conclusions of the EIR Revision are not affected. The commentor's statements
and opinions will be forwarded to the decision-makers.
Response JF2-7
Please refer to Response JF2-2.
Response JF2-S
Certain traffic impacts of the Project, related to Caltrans vehicle density thresholds along
SR-60, are acknowledged as significant within the Draft EIR. The Project will not result in,
nor create any other significant traffic or circulation impacts, including potential impacts
to emergency vehicle access. Please refer to the discussion of potential Project-related
traffic impacts presented at Draft EIR Section 4.3, "Traffic and Circulation," within Draft
EIR Appendix C, "Traffic Impact Study," and relevant responses presented in The August
2004 Final EIR Section 3.0, "Comments and Responses." Location of the Project at the
considered alternative sites will not substantially alter or alleviate vehicle densities along
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-129
Applied Planning, Inc. (Copyright © 2005)
' Caltrans-freeways, and Caltrans vehicle density significance thresholds would still be
exceeded.
' Further, as demonstrated within the EIR Revision, the considered alternative sites fail at
' other levels within the context of the CEQA "rule of reason" criteria and standards for
identification and consideration of alternatives to the Project. As presented in the EIR
Revision, the alternative sites are either not currently under control of the Project
' proponent (and for that matter are not known to be available), and/or are not configured
to reasonably accept the Project building footprint and facilities plans. Analysis and
' conclusions of the EIR Revision are not affected. The commentor's statements and opinions
will be forwarded to the decision-makers.
Response TF2-9
' Please refer to Response JF2-2.
Response 1172-10
Please refer to responses JF2-1 through JF2-9. Analysis and conclusions of the EIR Revision
are not affected. The commentor's statements and opinions will be forwarded to the
decision-makers.
1
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-130
11
November 8, 2005
City of Rosemead
8838 E. Valley Boulevard
Rosemead, CA 91770
Attn: Brad Johnson, Planning
Yuki Fukumoto, Page 1 of 2
Re: Response to Revised Alternative Site Analysis
The alternative site analysis issue is incomplete as follows:
1. The proposed site has a school within 83 yards and yet alternative site 1 is considered not
feasible because a school is within 1/2 mile. The effect of the Project on Rice School needs to
be addressed and is incomplete.
2. The freeway access for both the 60 and 10 are rated "F" for peak hour levels of service. The
rationale that the 10 is heavier than the 60 and therefore the 60 is the alternative "not as
worse as the 10" makes the 60 rating "F or worse". Needs further study and is incomplete.
3. Site 1 has "extensive tracts of existing single-family residential uses" and the proposed site YF-1
has extensive residential uses less than 80 yards away from the proposed "loading docks".
The long-tenn effects of the daily pollution created by idling trucks unloading merchandise
needs further study.
4. The LA. Dealer Auto Auction is a "commercial operation" per the EIR. The proposed site
was not a commercial district until the change in the general plan. Although the designation
has changed, the proposed site is not a commercial district. It is still an industrial light/office
as it was originally designated. The alternate site is commercial but the proposed site is not.
The area is incompatible with a commercial project and needs further study.
5. The same "detrimental economic effect on adjacent retailers" cited in alternative site 3 needs
to be studied with respect to the proposed site. If the detrimental effect makes site 3 to be
infeasible, then the presence of the Project at the proposed site and its "detrimental effect on
' surrounding businesses" needs further study and is incomplete.
YF-2
6. Site 3 is a commercial complex with multiple entrances/exits and the traffic impact would n.of
' be "similar to those of the Project". Access currently is not directly provided by San Gabriel
Boulevard from the 60 freeway as stated in the EIR. This is incorrect, incomplete and needs
further study.
Yuki Fukumoto, Page 2 of 2
General Comments:
The revised EIR alternative site analysis attempts to justify the lack of an alternate site for the
Project. 1 strongly object to reviewing and being forced to weigh the environmental impact of
one site over another. This is in essence pitting one community against another. Each community
is trying to preserve its quality of life devoid of detrimental environmental hazards.
Let me be very clear, I formally object to the development of the Project in the city of Rosemead.
Quite simply, without the forced intrusion of the Project into the city of Rosemead, there would
be no environmental impact issues nor a need to evaluate one site over another.
The redundant ""significant effects would not be avoided or substantially lessened" is the
consistent response in the EIR for rejecting all alternative sites.
The solution for the significant environmental impact of the Project can be very easily mitigated
and abated.
Simply, do not build.
Subm=itted by:
Yuki Fukumoto
/1807 Delta Avenue
Rosemead, CA 91770
YF-3
Response to Revised Alternative Site Analysis Page. 2
Applied Planning, Inc. (Copyright (9 2005)
YUKI FUKOMOTO
Letter Dated November 8, 2005
Response YF-1
Potential effects of the Project on the Rice School are discussed within the Draft EIR. Please
refer to Draft EIR Sections 4.1, "Land Use," 4.3, "Traffic and Circulation," 4.4, "Air
Quality," and 4.5, "Noise."
As a general response to comments regarding Alternative Site 1, Pages 34 through 3-8 of
the EIR Revision, substantiate that the L.A. Dealer Auto Auction site (Alternative Site 1)
fails at several levels within the context of CEQA "rule of reason" criteria for identification
and consideration of feasible alternatives to the Project. Foremost, selection of the L.A.
Dealer Auto Auction site alternative would not substantially reduce significant
environmental impacts of the Project. At best, these impacts would be transferred from one
locale to another.
The L.A. Dealer Auto Auction site also fails in terms of its feasibility. In this regard, CEQA
provides guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonablv acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
As presented in the EIR Revision, the referenced L.A. Dealer Auto Auction site is not
currently under control of the Project proponent, and for that matter is not known to be
available. Nor is it foreseeable that the Auto Auction site or any of the other necessary
adjacent properties would be available for purchase within the foreseeable future.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-133
Applied Planning, Inc. (Copyright © 2005)
The commentor's second point is unclear and appears to make inaccurate or
misunderstood interpretation of information presented in the EIR Revision. Regarding
relative effects of the Project on the surrounding mainline freeway system, the EIR
Revision states:
Freeway access to this site would be provided via Interstate 10 (1-10), which is located
less than one mile to the north. The distance between the freeway and this alternative
site is similar to the distance between the proposed project site and the SR-60 freeway.
Accordingly, Project trips would utilize the I-10 facilities to access the site. A detailed
analysis of the I-10 and the interchanges at San Gabriel Avenue and Del Mar Avenue
has not been conducted; however, a review of the 2004 Congestion Management Plan for
Los Angeles County (MTA, April 2004) reveals that the I-10 has heavier evening peak hour
traffic than the SR-60 on the segments located between the 605 and 710 Freeways.
The above discussion demonstrates that location of the Project at Alternative Site 1 would
still significantly impact the freeway mainline system per Caltrans vehicle density criteria,
and therefore this alternative location would not substantially reduce the Project's impacts
to the freeway mainline system.
The EIR concludes and discloses that, even after the application of all feasible mitigation
measures, the Project will result in certain exceedances of South Coast Air Quality
Management District (SCAQMD) emissions thresholds. In this regard, additional
pollutants generated by the Project will generally affect regional air quality conditions.
However, such effects do not equate to localized health risks. As a point of fact, due largely
to ambient air pollutant conditions within urban Southern California, it is not uncommon
for new development projects to exceed SCAQMD emissions thresholds.
Consistent with the provisions of CEQA, the City may decide to proceed with the Project
in spite of its significant air quality impacts. In this regard, the previous Project approval
included the adoption of a Statement of Facts, Findings and Overriding Considerations
which acknowledged that certain impacts could not be avoided, but found that thebenefits
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-134
Applied Planning, Inc. (Copyright @ 2005)
of the Project outweigh those impacts. No specific significant air quality impacts are
attributable to idling trucks. The commentor's statements will be forwarded to the
decision-makers for their consideration.
Response YF-2
The commentor's opinions regarding commercial occupancy compatibilities will be
forwarded to the decision-makers. The point made in the EIR Revision is that inclusion of
Wal-Mart in the mix of commercial tenants at the Town Center site may be incompatible,
not that there would be significant economic effects which would in turn result in physical
decay, the latter being the applicable CEQA threshold criteria. Irrespective of the mix of
users within the Montebello Town Center Mall, the Robinsons-May/Montebello Town
Center site also fails in terms of its ability to substantially reduce the Project's significant
impacts. The Robinsons-May/Montebello Town Center site fails as well under general
feasibility considerations.
As presented in the CEQA Guidelines:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the Project. [CEQA Guidelines
§15126.6 (f)]
Pages 3-11 through 3-14 of the EIR Revision substantiate that the Robinsons-
May/Montebello Town Center site fails at several levels within the context of the CEQA
"rule of reason" criteria and standards for identification and consideration of alternatives
to the Project. Foremost, selection of the Robinsons-May/Montebello Town Center site
alternative would not substantially reduce significant environmental impacts of the Project.
At best, these impacts would be transferred from one locale to another.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-135
Applied Planning, Inc. (Copyright © 2005)
The Robinsons-May/Montebello Town Center site also fails in terms of its feasibility. In this
regard, CEQA provides guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
As presented in the EIR Revision, the referenced Robin sons-May/Montebello Town Center
site is not currently under control of the Project proponent (and for that matter is not
known to be available). In this respect, the Town Center site, has been ultimately removed
from consideration pursuant to direction from the City of Montebello, as discussed under
the introductory remarks in this Section. Further, the Town Center site is not configured
to reasonably accept the Project building footprint and facilities plans.
As summarized above, and supported by information and findings presented within the
EIR Revision, selection of the Robinsons-May/MontebeIlo Town Center site would not
realize any substantive environmental relief or benefit when compared to the current
Project site. Nor is the Robinsons-May/Montebello Town Center site considered to be a
feasible location for the Project based on its lack of availability and physical constraints.
As discussed in the EIR Revision, Alternative Site 3 would not substantially reduce impacts
to the mainline freeway system, and provides no material relief from these impacts when
compared to the current Project location. As a point of clarification, the San Gabriel
Boulevard/SR-60 interchange is located directly northeast of the Montebello Town Center,
and an access ramp from this interchange leads directly to the site. Analysis and
conclusions of the EIR Revision are not affected.
Response YF-3
The EIR Revision appropriately reflects and responds to applicable CEQA criteria
regarding an EIR consideration and evaluation of alternative sites.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-136
Applied Planning, Inc. (Copyright (D 2005)
The alternatives shall be limited to ones that would avoid or substantially lessen
any of the significant effects of the Project. [CEQA Guidelines §15126.6 (f)]
Other statements and opinions expressed by the commentor will be forwarded to the
decision-makers. Analysis and conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCN No. 2003121095) Page 4-137
Ron Gay, Page 1 of 1
Mayor and City Council
City of Rosemead
8838 E. Vallev Blvd.
Rosemead. CA 91770
Subject: Revised EIR - December 13 Hearing
There is no good alternative site to place a Wal-Mart. The current proposal is not
a good site for a Wal-Mart.
If the Rosemead City Council will look at every knowledgeable report on Wal-
Mart. except for those aaid for by Wal-Mart. they will discover that Wal-Mart is a
morally corrupt organization
They are being challenged in court on discrimination against women, breaking
the child labor laws, using illegal alien labor. coercing cities into paying for
improvements and then moving out (but only far enough to escape repaying the
debt while still destroying the local businesses), etc.
Rosemead will be the next victim. As soon as Wal-Mart can find a site to the
west, Wal-Mart will be gone.
The Rosemead City Council is certainly not any smarter than the leadership of
hundreds of other cities where they have succumbed to the lure of sales tax
money and then have been destroyed when Wal-Mart could work a better deal
elsewhere.
Get out while you can. Rosemead deserves better from its leadership.
Or maybe it needs new leadership.
~1.7 4f~
J
RG-1
Applied Planning, Inc. (Copyright © 2005)
RON GAY
Letter Received November 14, 2005
Response RG-1
The commentor proffers opinions and statements regarding the business operations of Wal-
Mart, but provides no substantive comments related to the EIR Revision. The commentor's
statements and opinions will be forwarded to the decision-makers. Analysis and
conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-139
Estelle Holtz, Page 1 of 3
Revised Environmental Impact Report
Comment Submission
Estelle Holtz
November 9, 2005
Estelle Holtz, Page 2 of 3
The proposed Wil-dart Super Center. on the irrnc•r (it' Rush Street and Walnut Ciro\r
would be in the middle of a residential area.
This land was never zoned for retail until Rosemead Cite Council changed part of the EH-1
,eneml nian to brine in Wal-Mart Super Center. This bid, Super Center would he
<urrouiwt•c h% hume~, ~chook. recn:ation fields and housiM, for seniors and the infirm.
Neither Rosemead nor Wal-Mart have shown any concern for these sensitive receptors.
Since the court has mandated a revised alternative site analysis. Wal-Mar; reluctantl\,
researched other alternatives. This Revised Environmental Impact Report EIR-) sets EH-2
out to prove that two of these sites would have the same problem as the Rush and Walnut
Grove site. Therefore. the report fails to present any viable alternatives. In doing so. it
advocates the destruction of the Rush and Walnut Grove site.
They claim the car :ruction site, alternative site 1. would he a pl'ohlem because Duff
School would only he half-a-mile away from the site. Bia deal! While at the Walnut EH-3
Grove and Rush site. the Ric: S,:hk)ol children would he playing less than 8 _1 Vards from
the NA'al-Mart Super Center
Their analvsis of alternative site demonstrates the same mediocrity. A feeble attempt is
made to say they would not he able to use that site hecause it is zoned Light Industrial
Commercial and nut for retail. Ironically. Ii,-,ht industrial commercial is the same zoninc:
for the Rush and Walnut Grove site. This zoning previously allowed numerous corporate
headquarters to enter Rosemead. Corpioration~, such as Edison International. California
Federal (currentl% Countrvwide). and Chicago Title (currently Panda Express). These EH-4
offices were suitable for a residential neighborhood. This is what should be introduced
on Rush and Walnut Grove site. The cit\ officials that introduced these corporations
yaere "proud" to have their corporate headquaners in the cit\ of Rosemead. These same
itlficials would 110t ha\e but wk midi hrr% in%ned ether cOmnratc
headquarter,,.
Constructing a W a]-Mart Super Ccnicr here is analogous to trying to fit an elephant into
fruit jar. This site would create permit 1-4.000 more car trips during the \veekdays and
.00(i more car irip,. on the weekend.
The third site is Niav Company. on the hill and in a mall. }here the Wal-Mart car] ;
dc,,-.rot :ur% nei,hhorhood. schook. rccreational area. harm the clderly and ,ick c,- :one EH-5
other sensitive receptors. It could he ri<,ht-, fl the N) trcc":,N ~\ith Iour ~~avs 11I _V11nh_1
and enterin!e ti) the Wal-Mart Superc•cnier.
The 60 freeway is perfect for shoppers coming, lrom the west. where most customers and
trucks priOnate. Currently, several W al-Marts already exist east of alternative site
Wal-Mart would hr riOht-off the 00 frrc\vav with four viable entrances and exits.
1
Estelle Holtz, Page 3 of 3
This EIR ;ass Wal-.'v1an ma-, hurt other business in the mall. What about Roseme,ld' J EH-5
,
econom%. of which the majorin is retail. This tact -was never studied. Suntsuctans
estimate three lobs will be lost for even one created by W~al-'vlart. (cont d)
Wh%• wasn't an economic ~tudv conducted" Evidently. Wal-N•lart "vouid tail etch a aud~ ~ EH-6
and its detrimental effects \.sould he resealed.
Estel Holtz
Date
Applied Planning, Inc. (Copyright (D 2005)
ESTELLE HOLTZ
Comment Submission Dated November 9, 2005
Response EH-1
Environmental concerns cited, or alluded to, by the commentor are addressed within the
Draft EIR. [Draft EIR Sections 4.1, Land Use; 4.2, Earth Resources; 4.3, Traffic and
Circulation; 4.4, Air Quality; 4.5, Noise; 4.6, Public Services; 4.7, Aesthetics, Light and Glare;
and 4.8, Cumulative Impacts]. Responses to the same concerns and opinions are presented
in the August 2004 Final EIR Section 3.0, Comments and Responses. The commentor
provides no substantive comments related to the EIR Revision. No zone change is
proposed by the Project. Zoning for the subject site has been Medium Commercial since
the 1970's. A "Commercial" General Plan land use designation is proposed by the Project.
In requesting the change from an "Office/Light Industrial" land use designation to a
"Commercial" land use designation, the proposed General Plan Amendment will establish
an appropriate land use to accommodate the project's proposed retail/commercial uses,
and will provide a General Plan Land Use designation that is consistent with the site's
current "Medium Commercial" zoning designation. Analysis and conclusions of the EIR
Revision are not affected. The commentor's other statements and opinions will be
forwarded to the decision-makers.
Response EH-2
The EIR Revision appropriately reflects and responds to applicable CEQA criteria
regarding an EIR consideration and evaluation of alternative sites.
The alternatives shall be limited to ones that would avoid or substantially lessen
any of the significant effects of the Project. [CEQA Guidelines §15126.6 (f)]
Other statements and opinions expressed by the commentor will be forwarded to the
decision-makers. Analysis and conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Continents and Responses
Revised Final EIR (SCN No. 2 003 1 2 1 095) Page 4-143
Applied Planning, Inc. (Copyright © 2005)
Response EH-3
Location of the Duff School is acknowledged as one element of the environmental setting
for Alternative Site 1. There is no stated nor implied comparison of potential school
impacts of the Project if located at Alternative Site 1 vis-a-vis potential school impacts of the
Project at its currently proposed location. It is also noted that residual impacts of the
Project that may affect the Rice School site are no greater nor substantially different than
would be experienced at any other land use. Other statements and opinions expressed by
the commentor will be forwarded to the decision-makers. Analysis and conclusions of the
EIR Revision are not affected.
Response EH4
Contrary to the commentor's statements, Alternative Site 2 was determined to infeasible
for reasons other than its land use designation. More specifically, at Pages 3-8 through 3-11
of the EIR Revision, it is substantiated that Alternative Site 2 fails at several levels within
the context of CEQA "rule of reason" criteria for identification and consideration of feasible
alternatives to the Project. Foremost, selection of Alternative Site 2 would not substantially
reduce significant environmental impacts of the Project. At best, these impacts would be
transferred from one locale to another.
Alternative Site 2 also fails in terms of its feasibility. In this regard, CEQA provides
guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
As presented in the EIR Revision, the referenced site is not currently under control of the
Project proponent, and for that matter is not known to be available. Nor is it foreseeable
that the site or any of the other necessary adjacent properties would be available for
purchase within the foreseeable future.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-144
Applied Planning, Inc. (Copyright © 2005)
As summarized above, and supported by information and findings presented within the
EIR Revision, selection of Alternative Site 2 would not realize any substantive
environmental relief or benefit when compared to the current Project site. Nor is the
referenced site considered to be a feasible location for the Project based on its current lack
of availability, as well as the unlikely prospect of acquiring and assembling the numerous
individual properties that would be required to create a site of sufficient size and
appropriate configuration for the Project.
Project site zoning and General Plan land use designations are discussed at Response EH-1.
Other statements and opinions expressed by the commentor will be forwarded to the
decision-makers. Analysis and conclusions of the EIR Revision are not affected.
Response EH-5
Certain traffic impacts of the Project, related to Caltrans vehicle density thresholds along
SR-60, are acknowledged as significant within the Draft EIR. The Project will not result in,
nor create any other significant traffic or circulation impacts, including potential impacts
to emergency vehicle access. Please refer to the discussion of potential Project-related
traffic impacts presented at Draft EIR Section 4.3, "Traffic and Circulation," within Draft
EIR Appendix C, "Traffic Impact Study," and relevant responses presented in The August
2004 Final EIR Section 3.0, "Comments and Responses." Location of the Project at the
Montebello Town Center site (Alternative Site 3) would not substantially alter or alleviate
vehicle densities along the SR-60, and Caltrans vehicle density significance thresholds
would still be exceeded.
Further, as discussed at Pages 3-11 through 3-14 of the EIR Revision, the Robinsons-
May/Montebello Town Center site fails at several levels within the context of the CEQA
"rule of reason" criteria and standards for identification and consideration of alternatives
to the Project. Foremost, selection of the Robinsons-May/Montebello Town Center site
alternative would not substantially reduce significant environmental impacts of the Project.
At best, these impacts would be transferred from one locale to another.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-145
Applied Planning, Inc. (Copyright © 2005)
The Robinson s-May/Montebello Town Center site also fails in terms of its feasibility. In this
regard, CEQA provides guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
As presented in the EIR Revision, the referenced Robinsons-May/Montebello Town Center
site is not currently under control of the Project proponent (and for that matter is not
known to be available), and is not configured to reasonably accept the Project building
footprint and facilities plans.
Lastly, as discussed in the introductory remarks to this Section, based on comments
received from the City of Montebello, the Town Center site has been ultimately removed
from consideration as a potential alternative location for the Project.
Other statements and opinions expressed by the commentor will be forwarded to the
decision-makers. Analysis and conclusions of the EIR Revision are not affected.
Response EH-6
The point made in the EIR Revision is that inclusion of Wal-Mart in the mix of commercial
tenants at the Town Center site may be incompatible, not that there would be significant
economic effects which would in turn result in physical decay, the latter being the
applicable CEQA threshold criteria.
Potential economic impacts of the Project are summarized at Draft EIR Pages 4.1-14
through 4.1-23, and discussed in detail in Draft EIR Appendix E, "Economic Analysis."
CEQA specifically states that economic or social effects of a project shall not be treated as
significant impacts on the environment. However, physical changes that could result from
economic or social effects of projects are within the scope of CEQA considerations. The
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-146
Applied Planning, Inc. (Copyright (D 2005)
Project will not result in, nor create significant economic impacts that would result in
adverse physical change.
Please refer to the discussion of potential Project-related economic impacts presented at
Draft EIR Section 4.1, "Land Use," the Project Economic Analyses presented at Draft EIR
Appendix E, and relevant responses presented in The August 2004 Final EIR Section 3.0,
"Comments and Responses."
Other statements and opinions expressed by the commentor will be forwarded to the
decision-makers. Analysis and conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Comments and Responses
Page 4-147
11
u
11
John Kawakami, Page 1 of 4
John Kawakami
8346 Elsmore Drive
South San Gabriel. CA 91770
Comments on "Rosemead Commercial Retail Center, Alternative Site Analysis, EIR Revision."
1. There is a lack of analysis on 24-hour operation.
They stated, at the public hearing, that they require 24-hour operation. After offering a
period without 24-hour operation- they rescinded it and demanded 24-hour operation. I
believe that the City should not be flexible about this issue, and 24-hour operation ofa large
business adjacent to a residential area should not be allowed.
A'ithout the protection of legal regulation against 24-hour operation in a residential
neighborhood, Wal-Mart would be able to attract tragic to the site at all hours, reducing the
livability of residents along Walnut Grove up to the 10 Freeway and Rush and Potrero
Grande, and also encouraging through traffic on Delta.
Unlike a convenience store or a small drug store, a 24-hour super-center would attract traffic
from people who wish to do their week's shopping in the middle of the night. Having lived
near a 24-hour Ralph's in Pasadena, I know that a large supermarket is busy until midnight,
and to around 2 am. on weekends, when people wish to drink alcohol.
2. The Project Objectives language is heavily biased. The words used to describe the objectives
not neutral, and seek to make the project sound like a public good, rather than a business. By
doing so, people who support Wal-Mart will be able to feel good about supporting Wal-Mart;
this feeling is built on a shaky foundation of half truths.
1) Create a new mix of retail commercial uses responsive to the Cite and regional
markets.
Wal-Mart is "new" only inasmuch as it's a new project. The type of business is old, and
already exists in Rosemead- Wal-Mart is a retailer of discount products. and there are
many already in Rosemead. Wal-Mart is also an import business, and many already
exist in Rosemead. Wal-Mart is a low-wage employer, and that is all too common in the
JK-1
J K-2
area and in the Countv.
John Kawakami, Page 2 of 4
i) Provide retailicommerdal uses to service the needs of residences.
Retail business is not a "service." It is a business first and foremost. Services are
controlled by the people, indirectly, through the government.. Businesses are privately
owned
3) Increase economic benefits to the On.- through job creation.
Wal-Mart and businesses don't engage in "job creation" except to attain profit objectives.
To describe it as "job creation" makes it sound like a welfare program or a charity
project, which it is not. Businesses purchase labor, and use it to achieve profit goals.
4) Augment the Cin~'s economic base by providing a variety of tax generating uses.
J K-2
A retail operation is not a "tax generating [use]." It's a business that happens to collect (Cont'd)
sales taxes. Wal-Mart is a tax collector for people who shop at 'Alai-Mart. Technically,
taxes are "generated" only by assessing new taxes and collecting them.
S) Provide reiailicommercial development compatible ~Azth i4cinity land uses.
This is a reasonable goal.
b) Ensure development of the project site in a manner consistent VOth policies,
objectives, and requirements of the Citr's General Plan. Redevelopment Plan and
Zoning Ordinances (Title 17 of the Municipal Code).
This objective was enabled only by a controversial amendment to the City's General
Plan. Thus, this final project objective could be restated as: "Ensure the modification of
City regulations to the objectives of the project" That is exactly what happened.
3. Wal-Mart is being inflexible in is requirement of a specific site dimension and specific
J K-3
operations.
John Kawakami, Page 3 of 4
The analysis states that the development is like a mall. This is only somewhat true. A mall
would necessarily be flexible about the scale of the business, because a mall is a real-estate
business, and the mall operator is a landlord. This project is inflexible about everything
from scale, to hours of operations, and most likely to the specific laws it will follow. They
do this because they are not a mall, but a mall-like-project where one owner controls,
partially or outright, every business within the mall.
J K-3
The Montebello Town Center site could be suitable if the store were sealed down and built (Cont'd)
to serve the shoppers there. One of the first Wal-Marts to open in the County was in
Panorama City, in a vacated Broadway department store. Another early Wal-Mart opened in
Baldwin Hills in a vacated Macv's. There are many "upscale" areas that support a
"downscale" store, like the Ross on Lake in Pasadena, adjacent to San Marino and across
from the Macy's. The Puente Hills Mall contains discount retailers. This is a side effect of
urbanization, where more people live closer together, and expensive stores are adjacent to
discount stores.
4. Alternative sites were not suitable. I agree with this assessment. The sites and area are not
suitable for a large-scale retail operation.
Residences are too close, and only smaller-scale businesses are suitable. The maps and
descriptions indicate that these residents would benefit from a buffer zone between
themselves and the adjacent business. The odd-shaped vacant lot on Valley appears more
suitable for a non-retail use. The Auto Auction site is more suitable, but, would require JK-4
significant mitigation for the surrounding community, and probably some modifications to
mitigate and handle traffic from the 10 Freeway.
Large scale retail as proposed by Wal-Mart is not right for urbanizing areas. 'The
"superstore" model was developed in low-density rural settings in less industrialized states,
and Rosemead is not a low density rural area. -
5. Wal-Mart is the world's largest corporation. Wal-Mart can represent itself: and already has the
upper hand, because there are no special regulations regarding this large-scale type of
J K-5
development. and because ownership of the land is the basis of their rights. The people need
representation. We are in a novel situation, where new conditions demand that cities define
John Kawakami, Page 4 of 4
acceptable and unacceptable behavior for large-scale retail. By acting as agents for a single
business, government fails to represent its electorate, shifting the balance of power in favor of
one business at the expense of the people. Anybody involved in negotiations would see that
there is no so-called "win-win" agreement possible when the negotiating agents of the people
fail to represent the people. \ hen negotiators fail to negotiate, then the parties represented will
take it upon themselves to take action to correct the situation.
Wal-Mart has a bad track record, and a bad reputation. They say they aren't that different from JK-5
other large retailers; unfortunately, this is true. They are, however, the largest such retailer, and (Cont'd)
are singled out for their size. Being the main target might be "unfair," but, it doesn't excuse
their behavior, which allegedly includes svsternatic discrimination against women, minorities,
and unfair firings of people who attempt to organize unions. It doesn't excuse their attitude of
using the public health care system as their health care provider of choice. It doesn't justify
their pay scales, which include a clause to automatically lower your wages if you've worked at a
lesser job for two weeks. These behaviors put people into disadvantaged situations, and they
should be against the law for a business of its size; but they happen to be legal at this time.
Thank you for your time,
1o hn
Applied Planning, Inc. (Copyright © 2005)
JOHN KAWAKAMI
Letter Received November 14, 2005
Response TK-1
As discussed at Page 1-1 of the EIR Revision, consideration of 24-hour operations is not
germane under the current circumstances as the Project Proponent has withdrawn its
request for 24-hour operations. Please refer also to Revised Planning Department
Condition of Approval (COA) presented in Section 3.0 of this Revised Final EIR. As stated
under revised COA No. 54, which now reflects the "no 24-hour operations" restrictive
covenant:
The hours of operation of the major tenant shall be limited to 8:00 a.m. to 10:00 p.m.,
except during Christmas season, in which case the hours of operation may be extended
to midnight.
In addition to the above considerations, Planning Department Condition of Approval
No.43 states: "Truck deliveries shall not occur between 10 p.m. to 6 a.m. the following day
and routing shall be approved by the Planning Department."
Should 24-hour operations, or other substantial modifications to the Project be proposed,
the Lead Agency may require subsequent environmental analysis. Analysis and
conclusions of the EIR Revision are not affected.
Response JK-2
The commentor proffers opinions and statements regarding the business operations of Wal-
Mart, but provides no substantive comments related to the EIR Revision. The commentor's
statements and opinions will be forwarded to the decision-makers. Analysis and
conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCN No. 2 003 1 2 1 095) Page 4-152
Applied Planning, Inc. (Copyright © 2005)
ResponselK-3
The commentor's opinions regarding commercial occupancy compatibilities will be
forwarded to the decision-makers. Irrespective of the mix of users within the Montebello
Town Center Mall, the Robinsons-May/Montebello Town Center site also fails in terms of
its ability to substantially reduce the Project's significant impacts. The Robinsons-
May/Montebello Town Center site fails as well under general feasibility considerations.
As presented in the CEQA Guidelines:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the Project. Of those
alternatives, the EIR need examine in detail only the ones that the lead agency
determines could feasibly attain most of the Project Objectives. [CEQA
Guidelines §15126.6 (f)].
Pages 3-11 through 3-14 of the EIR Revision substantiate that the Robinsons-
May/Montebello Town Center site fails at several levels within the context of the CEQA
"rule of reason" criteria and standards for identification and consideration of alternatives
to the Project. Foremost, selection of the Robinsons-May/Montebello Town Center site
alternative would not substantially reduce significant environmental impacts of the Project.
At best, these impacts would be transferred from one locale to another.
The Robinsons-May/Montebello Town Center site also fails in terms of its feasibility. In this
regard, CEQA provides guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-153
Applied Planning, Inc. (Copyright © 2005)
As presented in the EIR Revision, the referenced Robinsons-May/Montebello Town Center
site is not currently under control of the Project proponent (and for that matter is not
known to be available), and is not configured to reasonably accept the Project building
footprint and facilities plans.
As summarized above, and supported by information and findings presented within the
EIR Revision, selection of the Robinsons-May/Montebello Town Center site would not
realize any substantive environmental relief or benefit when compared to the current
Project site. Nor is the Robinsons-May/Montebello Town Center site considered to be a
feasible location for the Project based on its lack of availability and physical constraints.
Response JK-4
The commentor states that none of the alternative sites considered for the Project were
Revision are not affected.
suitable. This statement is consistent findings of the EIR Revision. Moreover, the EIR
Revision concludes that there would be no substantive environmental benefit in relocating
the Project to any of the alternative sites considered. The commentor's statements and
opinions will be forwarded to the decision-makers. Analysis and conclusions of the EIR
Response JK-5
The commentor proffers statements and opinions regarding Wal-Mart business practices
and operations, but provides no substantive comments related to the EIR Revision.
Analysis and conclusions of the EIR Revision are not affected. The commentor's statements
and opinions will be forwarded to the decision-makers.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-154
Todd Kunioka, Page 1 of 20
00\1 . _1005
fudd kunioU
8400 Wcils titrc:i
Ro-~ 111cad. caldivnlii `)I
,o%cnlher 20W"
Mr Brad JohnSOII
C ;t\ oI' Roseln,• id
s "S;g Cast i l~air\ and
-0
rnea~. Cailthrl;.:.1
Dear Vr. loilnson:
I have r!! i::\\ed the etiised EIR prepared h\ Applicd 1'I:ulni;r_. Inc.. liOr thu ptoposcd "Roscmead
Gtmmercial Retail Center.- it the corner oi'\A-ainut Gio,.e and Rush tiucct. In n1\ opinion. the
repcir is deficient and does not compl\ xiih the la\\ The cit\ shouk' NO I ccrUll the EIR as
~:nmp1--~ie
Please ::onsider the iollo\\jng cnnlmcnts in -valuating the re,.lse 1_:IR
The Ca1ifurnis En\'ir,+nmental OualIt\ Act ICED:\1. section 2", OW2. s::\ ",hat 1-llhlic aUrnclea
should not approve projects as pruposed iC there arc t asinic tlicrnati\ cs r- tcuslble mlugatlon
measures 3\ 1111b1e \\I71Ch \,.ould substantiall\ lessen the si_mlicam t:!r•iR nmental eft"CCIS of such
pri~jcCtS. '
Sim!lari\ the Cr'QA ,,uidcljnes (see. 151_(, f, t:I I1 11? >JMH lies'-: be a ran2c of
aiiernau.e:- I,) the pru!rct. or the hic:iti(,n (11 tlic pi-filecl. %!,:Cil itild te.l:ihl, attall-: TK-1
tltnst )I ,n: basic ahtec,l\cs of the profit :.'t brit .'.Oui•.'• .r-•.
,:"Kant _l1e~t: :,I .in-. _ _li.•.:tt _ .:I , . . I~. ~I:.~..
.in i:t~is added,
Further. parztaraph (bl of sec i 51 t).6 sa\s tha, alternal:%es niust he co nsIdered "'even it tics'-
alternatl\'es \vouId Impeded to ionic deLree the attainment ('1 dic pro Ieck t WC1I\•25. 01" \A•Ollld be
more costi\."
f QA he CL, uidelinrS fCQL11reS a.. I li\ ,t' i,I..~u..S cum,•laii\c Illlpact. of a
rlnall:. ;ec 1.1101.; t
I)1'ilici i. 11 150 l SIU11 l.': Sr EQ)A ',lll lcl!!ll'~ ,ttl tll~: .:!''tl'rll:, l _."I\li'•_ 17illtil7:a. !~e~lltlrleS
L\aluaLlon S\swn, iCERI_S1 \kebslte. ,trj vw litl\' L:Liil _'.11.1::IIleS,Sr'.~I.1)lllll
II(Ae> tllal 1110 Ieild JQL:IIc.,' .`.,hould Itlclu6c: among cun,Xla!i\ l milloC1.` I"la~flflahl\ iinucipatt'd
11Ur;0 a.,l\ I::C~, c?I .`i?TOIt:.I OF aSSOCIatc.d wIlh the pl't.)lel,. Ill nar,il't11.11, it :1 .':filth: ac L!\ II\ "IS a
Todd Kunioka, Page 2 of 20
1':a~l n:hl\ tr)I'C>C2:1111C Ctm.'~CUuence +1I 111C Illlllal prolCCl :11112 i1"" the uiurc action %%ill nr
Ml_'II!tlCail'_ !r. that li v. II ilkok cnanuc the scope 01' MUI.Ir: t~l [11C lnlll.ll hl'c)ll'Ci 01- it,,
;r \ 11'0I1'f lt:aial ;:.f", t:•. thell !L I1111S', bC Uddh-CSSC(i In ill,-- I'.11:.
The revised EIR does not muet these legal requirements, and so should not he Certified as
comrieue 13.fore a final decision can he made conc,,rnu:_ this protect. the pubiir and the cil%'
count::! ne'-d ndditu,nal information cone min`s the 1111paCl Of _=1-hour operation . (a 11 31-11art
Sopereenter. and the public and :!l;, council ntl<2 adall anal information cuncermni.) the c\lcnl to
t\hi~i1 ur::~r);aatlle :a%irlmnlema.:mracts Cnuld be re: L:Ct d or:i%oll:,d s,\ builtlin-I the project at
l- 11[1-RL TO ADDRF,S 24-IIt)l R OI'1 R \'I H)\
The re%!s, iJ EA Loe not address the imparts ihai '.\ould ".~LIlt Iron hour operalltln (it the
5upercent:r 111 other 1.1 :u dart Superrentrrs in Call{or:!Ia +Iper: to rl :1 'a a..n' ,C;1tL1UIC A-:
far a5 alit be deterrnine%L all %k al-Ntirt -Supercenlers in the n,mon opcrilte Lin a -4-hour schedule.
Simllari\. Lea;ed up~t: tesii!nom_' 0% Wal-Marl's r.~lrescnultn~. heii,re 'he l;Llacllltati t i
I:-ounci;. it seems clear tha! the Supercenter proposed i'Or 1\ C;R %%-ill attt•mpt w :on'-ert to = t-
-OUr operation as Smolt as the L'rOcer'1' store CumF.011:r11 01 ',!IV pl'0 1CC! IS CtI111li1e'.ed I'nr example.
11;1-'\iart's spokcsperson. Deter Kanelos (spelled. "C anclos- in the hearing trarscriptl testified
fr_t'.!.'. (ht 11:~aCn1C C it" Council t{13! ancc ills S[-)rC 11CL:111le ti >UpC:'et'!li:r. \`:e' Id'"Aild %%alit to
ila\e it r,prl'aic hours.. Ip. b' c)f iranscripi Irom th. Scpiemht:r =004 til\ Cotlncil
llwnn_a; \1r Kanelcs laf,r Siated. C rt illahtll` a SI~_11111Cani in~Ctit111C1?l in tills particular
store -t\ith the Intention o it bC.:QM1I1L iI sLIpCi'C:.'lllta', Sty \10Lild 10 hZIN: I! be' able 10
op: rate or, a'Y-hour bads (p. ^G 01 t!1C L''ilrti~"ipl
On p '80 of the hear.n__ transcript, \1-. K\JnLIOti C[111[IIlIICI' "BLit OIiCL7 It !"C:Onle~ a Slll)el'CClltcr.
t\,-,ttid ll- ed to be able to operat Thal i,ti rt t not.r;.
t_rn 1110 ilasl.5 of tlli~, 1'CCMd. (Ilene 1. no 10 ;l\ i li tlrittl niL' ii-A:011WILIS1111; t1101 _4-17UU1
o~:ration :s a' r_:ist,!labl~ forese.eablc cons::lucnC. `.,I the initial p rn:tCt " I ei--ihing in 011:
record indicates that Wal-Mart intends to d,-veicl, this protect as a superccnttr. xid ever,-thin- ill
t!lc record siwE!e'sis that ,a-hour operation Is the natural corISCUU:ncC A constrUCtlili-1 a WI!Alart
suI'rr:r2',!cr. Tae in'^aci !I 1+?i:r ttperat:tin shnuL'Q ihUS 1t' Ill\ sseo .-rio ill c,rllll~all )n Ui
th-, [!12. !'t;• Lit) lLsz, \4,-)uld br to iunore the C-t t A =!lid lmcs, \'•h:k:h aik: '1-.n-rscivcs the result of
o -jjc~ of le_a't analy-;.s and hrec.a:nt.
F \11 VIZE 10 V)EQL :111: L.1 C 0~~11)I it \I- 11.10 \l l\ l I.(K A 110\S
I;', -,Ad'ltion to-the 24-tiour opt 31ioll liSLIC. llle Otkl' 211iHOr ~il+ll'tl: x!111!_ +1! IhC rc\'!sed 1JR is (flat
it : nprop,--ri\ i~~!ll'•r J ICLts blC alternati'•C localinnI tt) 111C l'!' )Pt cC ++~':Iln!1! l_720' AN iMIC .111d
TK-1
(cont'd)
TK-2
~TK-3
1
Todd Kunioka, Page 3 of 20
Rush Smrct 1%\ GR) site. Se'-oral potel]Llal alternau\'c Ioeatlons identified ill the rc\iscd FIR Jhut
not \ei subjected to full EIR anal\sis. and thus not pro\ idin_ the Public Or Jrclslun makers \\1111
Sutf,:Mll mflormatillr. to \\eleh these altcrnatl\c localiimr_ a'.'ainst the \lGR ,lteL \`.ould.!ppear.
ip i111li_Il rCllC\\. 't1 li.i\C lil. pol-11twl 1l` heel Illoal. 11 11111 ;lil. t1! the i?I"~+It.: ol`IC'CL'\C5. \\hllt
SI11iL1Il : C1ll,l`. ha\ 111" 'll'C L101Ci1t1Jl to J`.(11d Or SLib.mantl ll!\ lcs;en- It leJsl on,. Ott the
?tilcr\\:5C' .1113VOIdahle "sluninc:ant en ironlnenta! cll'Lm;.. I11 1110 Proposed Proicct I'he\ Should
hC >L'N_t:lfd :C "J 14111 L"It,. h-,"OnC an\ !lI]ai Jec`.si(,n Cell ilic G siti !s m al.,
lie notenti.aI aherr.ati\e sites !denttlied in the revised FIR but no. \et subjected to full impact
canakbi, are JISCUSSCJ helc\\. kAlo\ved b\' a briefdiscussiollell sites not Identified in tile re\.Ised
FI1: hu: st111 potcntiall\ Seasihtc for this de%elopment.
The Rohinson•s-M a\ Store in the Monichello fm\ n ('enter
11-1cre•after referred to as the )ITC site)
Tile re\ised Elf: t.ientifics the silc of the Robinson' -Ma\ stllre. at the
',ITC* as a potentaaI ahernati` to location inr the %Val-',darl i c! 'it
1131 thi> :1Le Cntllj be J\'J11:IMC hceJLl~c Qt illl' :00011! ill::"`CI' t1! the I?ar
R
j
I2C\!'1lilst~11 >-Ala\ anti \I:lc"\ ~ iPa!~CS 18114 :}i 111c !'e\'ItiL'i FIR
t:raL: ;n the NI -I C. and it is Llniikck that the tmerued corporation it!
meratiion.
ar ctt5tcrri .nd oftlle
It notes the likelihood
nt :011.11)JOWS 10
1)"oth ;lores curr:ntl\
.\Jnt to retain 'Toth in
Mlle %ITt site scents tt? offer s-real potL'I1ltill IOr 1'1Cl'tl l'J Cal-ll 01 the j ro1cC; ob*IvC!t\Ls WhIIc
__mul,ancousl}' eiirniratin_u or.ubstan:iall.. IC>JClllll_ It ICasi ii~111C al IhL'.l:!\crs; ronmental
.1-soclateLl %k;-.h tilt' \k l,l;~ SIIC
Comparison of the NFI C and GR Site--,
I Construction oCthe'-Rosemcad Commercial Rctad C'~ntcr' at the M 1'C ,lie «ou!d he at least
as e fecti\e at achieving the substanti\e Stated PrOicet t~hiec:i .cs :IS t\uld he the consu-uction of
the prote n at WCIR.
Of the SIN Pre,{ect objectives nottll in tixlulitic i , hclol\ . orll\ il]c !irzt !i are
The prjg C1'5 sl\ obiecti\es \erL 1:'Icd 01) p,l'_aC '-u u1'111e IV !SL`ll 1'11.. I ilc ubiectl,cs
:.l"L' I.luatin Irom the revised F1R I. I , Crcat_ :t nC\+ nli.~ of :'ctaii cuninlC%1,11 a>:rs rc>Pclnsi\e to
(I',\ a:),I , 'hlonal n1a1'kcts:'1 Pro\ I& rCldil CC'111111C1'CIJI U.SC~ to s, :'\':c, ll %ccs o! residents:
111 1CJ;. CCl?11l)i11iC I C11C111~, Il+ thr l :v, ihrou,_:h mil 41 1u`,n-ic ii tilt. l tl: - ;::onk1111IL'
base provid.iL a var1:'t\ o1 lax i Ccncratlm2 uses: C1 Pro\idt 1'..1;111 CU111111C1'CI:II lIC\'t1U(lmlt nl
ll>?! l.n;t.lrl JC\ _It\i?n1Clll il1C 1?rt1{CC' ,11C I, !1";JnI1CI
Ci!!llpal)'IC \\ltII \ iC!nlt`. 1:1114
_Vt1 I:ICn'. \\'Ith pi llc!C tihlcctl\ es. and rct1U11'Ln7C111: dw l il\ t.ICI'Ci:11 I'lali. I:CJe\'rl0pnlen:
PI:1"..4md ,/t~r1111~: C',rd:nlllcc (TI lie the ~IunIcll?;il t tick
TK-3
(cont'd)
TK-4
Todd Kunioka, Page 4 of 20
Sub,,Lim.,o I0L:,. : I h: ~1~:1111 ~!tJtcd obICCtI -k: h10LL+"1Umi. MOIL lik. II I:i ilaIIII,, ThaI
the nr,11C;I MLIS1 r+.` 1: 0 1I'It:'I 1\1'1:11 1i1C;W." i; hilt: `C., A Ilh1''LI; c dial an Pr(\1Ck:t
...'ti:lll 1^I . ~i: thi IIt% ilnd 1iO11;:ki '1('1111%\!111; .111\ C'11LI!'! .6,1111'1110 \\1}I 111CCt
^roIt-c! In I,,," It it) I
R Uf Lhc remamino obiecuvLS. all Louli be achic\ed b\ bulidin: the project at
\iIC'
f>f? i~II\c :.tCioll;tltnt :1-impatibiC ',\'l^ IC;.'It\ land Usc` .:al be more tltll\
achloved r\ c0n<1rUN:iI!l= !ho ^rolCCl at ;hc \11 C i1lC miller t!lall d-Ic WI IP Site.
IT.c : c ,:le ! ~ I-CD!acc turrL!mJ.%•cN:.-;un_ mator r.:ull opci.mon that might
mhen\I ;C1nU \.tcaw %%Ilh a `ll_it >0111C%k 11:11 Ol'_•raticyn.
-A0LJd „p1a~e 1!Per, : +;iic ++1111; miLl(r ret.tli
N1 I C Sit" \+i;U:d dcvciop a m,;Alor 1"Claa ptoiect adiac,:,w !i, whcr r, ml stores.
Aii ~1I its neighbors \%OLII'd be ctthcr rctai or C:UitClm r scr'. iic LISTS: the W'GR site
\C::ld :1e Pia cci in a icx.i jon adlaccnt It, n('.~:!1Cr %tad La,.,, i1-:.t3`hbors \%'iluld
nc:ude r,s:dcncCS, a sdiool. ot11CC SPJCC. Lllld .1 QO11 Wkir5t Ihe (1cCi Closes:
Ytihl ollet'Xion \%OLAC1 t\C lSlli? ii`:: a.• 11'.11x1
I Cli?teCtl\-e (2) [hrOXICiL' rCtali.C0111111:I-C151 LISTS to Serv;c: the nec±; Cif resljent5j can he
rlor tt1!Iv i;chic\ ed h\ L 'nsiruclw; the Proic~:: ; t !11; \11 C site .,thcr !hmi the W(;R SIlc.
Bc.1 SUhS1,111tiai POI-lion of Rosemead r_sidcnts are !o\A-1:1conw. they do Imt
a`-Vii cars %lan\ others. e\cn those v.Itil ,l vhcr Incomes. dcl 1101 ha\e drl\er"5
ilt'CIl~.'•. `i+;11C':'.T:!\ he r.--cent !n:ni:i,!Iall1~ \\.'`1'+ ;1C\C'' !t::r!iCt! !l:`\\ Jri\ C In divir
Ilall'~: Cullnlr\ ( Wicls, nla\ rte 1cL',lll\ n•irlInmi 11:1\m,-, :I Cir)vcr . IICC`n!"'C.
1'11%1'1. t11C :lrl't +tl?ICII'rC.l r1;"S:!-dttl ;1 }C"' .Intl .:1' Cti\ 11~i11 ~U1`~IC tiansll
.n c:trr, 1`u; their ;111 ~[?hlnL' ::1~,u1.Js
1!11, ,'•1 I ~ ":I'. Ct! it\(' n'LSI+`.'' :".t~ I'~~L!I,•~, ,~n1,C al!'i1 II1: .t? !.C.ILICtIII\ dlti
0111:C C',11111':n :11! Ule., I111s 1 e:, :h. ih(1P"5 H'h("1
. F''-.
!;ICI', ....~:io. !(1 :;t. .C:1'clC;, '1111' WVil 11'10 !1 ~i' 111 I 101111•.
L\'Ilich opvratC:s 0111'• dlllUlL' \\cekdix h(1LIri, ,Ini! -IN-1% C? .1:11\ 0110. C;LCh hmir.
I Lt.!ic,, 1}7::: >1n li rVUtC n1a; soon hi '1!%%!
\,lditicna; Inf•11.11Iallon on the PUNIC tr:ln
Cr:'~:ta;;l l!II:lC'r `~CC1il1ll Ill. 1111(14%
,.:':1,--!!`.'c> 101' \k(iP ;:It4 VI C
TK-4
(cont'd)
''•h:1'~PI!!; L':ilt;i 111,1 t.ln ~1i aLrt~,.Cf fir
Todd Kunioka, Page 5 of 20
t~'~ illL' Sflt;nrillL' lelltel'
and. specIa!1\. sclSlti\e 1;cCt1IoIs I to pnll:itIon. hoih aurinu, the
Xni.,tructlot) and the op,--rauon Pf:ase of th:: Lie\'ciOPI11J:nt \\ClLdd 'IC I;UbN1a11IMII1 lover at the
~ M' :te m comparison IL1 the u GR site.
TK-4
--~(cont'd)
MTC is relativcl\ isolated from ar% residential areas For the most pan. land to the
south and east is open space that is neither occupied b\ nur utilized b: aec nfe. The land
'o !Ile South is 11 56e\el rr!%atrl\ heid !and \\itli .ittle or no pcrlrl:rnerlt residents. Nor i~
Il r 'dLlial"1\ OCCLIPICd ll. \\orkerS. T11C' land to the '\eSt is mo.tl\ o hood ^1x111 tllat is
?ntlt:i: ed h\ the public
3. I;he few residentl:ll Properties that :ire located within 11111e of :he Ni TC site will still
be separated by appromrnatel\ 600 horizontal -I-et and a substantial altitude difference. so
r\en those homes should be CXPosed to much IL}\\er 1 \CiS 01'1101:,c. dust. and :ether
poEution -,har, unuill resi:ients liven, ClOSCSI to the WOR site
C This distance --,cnar mon i> parliclll.ir'\ Illrort:mi i! UnC ;JUril and or deliveries were to
bC .111 a .-4-IIOL.r bas-,. '\Vltii and ur p odutio ; x:11 t~!!li'; :i.l~i..~ •t ~llla ! C parliculart\
marl:?. tJ r.a_' U\ern?`'i~l vll:\cr\ irlTi:i t.itn1111'~Ii ;nom:. :17. (~L i~rUnlltil? tilled.. to
2\ Old J !i\en:.s. pr':ssurc f on. \1 < '1. V 1,01). :!:-,,1 the rLihliC a' !art-",' ti?
~,JdresS r :2i0n:l Ct1n`_t S13on isSLles mean that it !S ' re2tsonabk Core;:Cabic that truce;
delive1-,.es Ilia\ later be "CI1courayd to mo\c to o-,T--ic:u% trii1ic pcrio&.:iwludine
.werni,
-j ht hrnlrs.
U Fhe Urtlt FAR treats :ll! noise eXpoSL1rC e,Iuai1%. but ~!e rl\ 1101SC t \hPNElrl 10
restdentia, addresses that WOUid oc.:ur durin'_ construction Lit 4k GR %kould be mu:h
~r:ator than no1St: CX'10il.11e IV residential addresa.~; t!ta: %%ould OCCUr durinv, construction
31 N1,1 L. \ 11n1t;1171naUl~l IC' hC:1'.'IC at h(Ills' SI1~t < Il. :an. ~ l '.1CC ~":Cr
mist t\posurL to peclpie in a park;;-- lilt \\;,1a`in!_' :o or :roni a shonnin,, inall
E. lucre a,-, nu enslu%e receptois I~ttlif:'ll, . 3tI:IaCti. 41?' the c!iL':'i\ iok:Liled it) close
r\r.i}.lll:t: to ;le ..ITC Sett.
-Noce The !i(tnu nl:lir nI'the R;O iHindi' I?1\,r:l: t•. !al: ;mucr t!:. cute:c-r, of Iarc
: D\ f._Y. IIilja SoiIS Ir I'I JiJS- aL!! ail cC)itiL' n, 'A ~1:~ `,!tom ...s _i?; 111 1l ainl: to
ttiii : 1tl~ilial no;.ciltl:i! is .:I: ai'L.! '.ha! :nt!'all\ lackim-, it
~~iliit:~., ii~r ..)!?hLr~l'L~ :~Lltdi•~~r l~l:cr;:I~.I:`1! :i.~:!'- ::I ::I~ :r~ li'.~t_.: .il tllc ~`::ii laal !)ar{~. `
.lL:;: ALJLIhi 005 ne\\il.'tl:r documentu?_ :Lc .\.:I' (rtJ('J'il! .!.a~''1 ha ,141:
'~C ~ ~Ull1'i'C' .\:...i: ♦ti~ :1: `{'.I~ :VI":'::: ~ (t;'.' ~J~ ` :1c',{` - ^'vt.
tllr !?1CILISIOI1 O iht RIO l'lc1:n70 I'fi'~.. \\:1t.rS!'.C.. .~1r 1P.L~:a1~}!1 of tht ;•!'L)Ptlsed 1~;.r!-Bart
±1?_ ]n Roo'-mea:t
TK-5
Todd Kunioka, Page 6 of 20
File NIT C site is over 1 mile aHa\ frllm Fidrid2C Rlcc N-chool. %<Iicreas tile WGR
site is dtf.ctk across Rain St iron als, o%cr
rule, a\\a\ from Roger 'I elnple School. \\her:.l~ tih I., didi} a hilt' a\: a\.
BoIll ':iluul~ arC ..lies \\itn i(i1SIti1C r'::L;ptu! 'aihlete, anj chl:&:n unic,- the
a_;: of I -1 i in 3ddmon to the ucneral SILIJ011 p~i1"ULt11U:1. the 1'IeldS ettitCJ' un 11r
:J.?lac.ill IO 11VIi ichools art: Utillzed h\ 301,CIC~ una,11i'ated v ith Cither school.
Soccer riia\ers til11tL. Rice Schools 11e1(I Jan n1CSt \tiCt'hClld;. 11h1iC haschall.
tMitha 1. and other spoons arc pla-, ed oil tilc :eld south of 'I emple School.
As near as 1 ;all determine. the school cioscst to the !1 TC site would be Don
Bosct? Technical High School. Studctlts or, the athletic field there would appear
to he about of 3 mile Aest-north%%est i'roni the %M TC" site. I Icnce. prex ailing
Jnda III blov\ pollutants well away from this field. Also. heinL ofhieh school
ale. most students ill riot fal! in :hc categor•, ,.1 "scnsiti\ c rcccptor.'
Ill .fir Pollution Resuitinu fron: PCrSOTIJI altomobiic -1 ra\ Would he SJbaantiaiiN Lower if
the Proiec, is De\e1or-,d at 11-1 C Rath.,- than NVGR
"-he \ITC <tie is alrcad\ the location: a:r:ai(`r r:tail de\clolnnn: [i\ replacir.i a
current tenant rather than developtnu open ipalc;. ne! ira01ic ch.mLrs is a result of tile
construction of a Wal-Mart SUperceniLl- at \ITC %WLI'd undnuhtediv Il: less than v.•ould
be rile net traffic chant es resul: fron: huildin_ ut1 a kA11TC11tl\ ac:1:11 lot
Ii An eatplclr cr ioca,ed si \l i C could more Itlc:t :1t NID': rule '_,U= Ill the
manner, :t uas :mended: B% r;(il*c::1c the :1tis;il
.iulomohll:s IJ L ilillnJ.}l' 10 \-'Wk. 1 Ills k
C. File \11-C' pit. :urrentk er\ea n~ nunWrutlS i)us rnute~, ;t\W %'ICUopnhtan Transit
Autrionty IN1'1 A, ruu,._-,..•,\L an< <,rle 1-ot"hill
Transit i M route) The ple: iom of bu; routes ser% inf.: \1 1•C pru\ IdeS Loth shoppers and
emplovees with a .Iahie aitertlati\'e to uui!ZI:7L' nnvale atnornahiles This substanti.-IIN
:tollgates both the air :pollution and the trai'iic conuLstion impacts of bulldinL at the \'1TC
in a \\a\ that coul4 not occur \.crc .;unstru.tion to occur a: \4 GR. Fhe U GR site is
served b\ a cin_le' ITA route. .\I1ieh or_crates md,. ,n~ \\ccl.(i:1\c.:ind onl% at ho:Jrl"
iw::rtlus durini. "mir:11a1 businL-;i dour.. I'J.-.hV7- %61 i i%.~, r:nc:iic;l;\ Iue21e~,Ied either
cancehna or nloditiinl: the mute It ir. hi_h;v :hat the 511r1IC rI'(1tc that~\tiould :cr\es
rile V%,CiR S!1C Oriller c`n.~atc a> rurr:nt1% laic! ot: the %%'GR site is
TK-5
(cont'd)
TK-6
More- dotatlee i!lforitlation on 01C vuilh, :r~i1:•I:.1;terCall\e5 'or arrl\ inL' ai \1 fC are llsled
Todd Kunioka, Page 7 of 20
M] C site front two diffe:rnt directions. "\i~'c'st-1w)undr huar+ leave Thu El Monte
Bus Station. and, after much wander im!, eventual1% passes b- dic Roscmcad
S:luare shopping cr^ter. at Rosemcad 141%d and M.irshall enuc 'I hose buses
.hrri irw\v csl o1i N.f.ryhall A\cnue. p;iatiiq rnan\ rctiidcntwi hoincs Thc, then
tra%ci c,)Lth On a! nut (;revs. Turn ea..t or, Sar, ~iahliti. and cntcr the %f'rC irom
the norki '-Ease-bound'buses oriuinat: ut Cab fur ii,l State t. nr. ersm. Lo_-
.role Thc•. tra,e! cv-si or, Hellman A%enur 10 C\'- 1,enue. then ira,el nonh
on feu A, enue trl ; alle; Blvd. 'xhcrr they travei east to her Mar :;venue. These
buses the. tm%el south on Del Mar :Mist crossing I'3trcro Grande. 1)L! Mar Ave
turns into Hill Jrt'.c. Buses cunttnuc suutheant or. k iiii lturc turnrnL nht at
Paramount Rk d T nc, ther: trivel south nn llarumnunt Bk d hc`nr: ent.ring (ITC
tt~e e=t ~cr. tee iy hauri,. Ii,r-da,, a „eri,
duantov►•n Los
;n and points vrest. Parts of this route duplicate NIBI. ~1. and ma\ be
i!$. ?Ilti 1i:Cd ut 3 ..itiir~ jilts. 1rrL'tit i., itC i}
nten zi<_. se, et', da.% s a wrc i.
\i•.'nt~hcil Bu_ L,Ilcs 't' ze--es M" t' Crow i.xu dttf--rent jM:c!wn~. rrom the
north MBI '_t nroviuc~ da0l, service at tlticcti minute tntervals Irinn the coiner
li Garwe,:Avcnue and Spin Gahric; Blvd. In add!tion.:iunng wmkda,k, e-vm
fourth Rus t2iw pic" up passcii£ers at Gary. cl an j fan Gabriel origin lt: from the
Stara Madre ~ illa gaold lit;: It, _,ht rats station to l'as:tdc! a. Ihose buses tha'
LIr{eiriatc a: St:na \ tI1-tra,ci cast on Foothlii M--d tv Sari wbnel 131,d.
!bier :ru, ei south aion{ Sar Gabnci 1,11. d. -+a:.' ;ili corner C Clan c, and San
Ganrlei '~.ihcrc div o-zhel t1 rC~ .'iL2 U :10U1 ..r L'1 ldt~ 21.l Yin:llil;L'b SUuth
on Sir. Gabriel Blvd. then bear Itft ,there San Gahrle: like anities sharpie to the
:ast MB' .U ihen :rousts over the Pomona : rc.%6zjt and enter. tit rC frorn the
north. From the south. MBL 20 on'vinates in Pico invert:. near Ga__'c and
T., -rar'i,. ,.i fii-eLr: 7n111WZ 1:11C11,ai, i' ! rlnlar' m-1r!h or. Montebello
anL : ior: rnl rin; \41 from
Fi =61] k7riiinates
1+!. En routr;.:i vAill
at The
have
Fl Monte hus siati
irtleled t1irouvh El
on alld
'ioni
amt
c and
s at ai
truth
l C 1_70m the
1:1 Mortie bcklrl
cos: r, SaSi l:
even i;!\, S
ahr:
ing
c, 13",! 11 ,ti- JtC>
ti : l;.:c St
.11
atio
.111nu
' ltllcr%ais.
tOr, ^u>
(cont'd)
Todd Kunioka, Page 8 of 20
er\'ice !n the pan i;ahrlcl VailC\ J.\i1PrO MULCl_. M 1.\ rOUtCS and ten hT
Oules t ?n\ C'N", un E1 N•luntc Station 1'rom d I dir;ctlons 1. I I '09 1 and I -ITA 17().
+hile it Lisisl makes \TI C public transit-aye : sihlc' l'n+ln I,r;icticallN all point.', HI
he Sail (.iahric, Vaile\
D. Possible chan',es to 1\'11:? scr\ ice: ti'{ I 'A is considering ex1vil ling di x roulc 26, to
\91 C ^.ITA 26"; orlLlnatcs x rile I.akewot)d Center Ma11 From I..tl;ellnt+d C enter. the
1`:11,11Z gencrdl\ mi\els north an P:iranluLill 'I l31\d j;:,\CeN !'or a &IOLIV to the Lakcwood
n.. 1;ne rail jta,.1on]. pa-SMI-1 1111'0uLh I':11:1MOL1111. Don me%. and Pico kl\era. it turns
cast at Whime:- R1% d in Pict, Rivem. and terminm-,:~ at tht: cornei of `N limier and DLITIe
! tt\\Il l ::IliCr ~rlll'1tiC':..
\i ! A. is als,+ ll+tl~ii l'1!1+? cancelin+L, w- idicriI1C ut 1-9 -Ant; !I'lSlll'allli_` I'11L11c 68.
Tho eUSMI-11 tit:lanClli 01 % 1 l.-% 6~. 1xjre>1 the 11C I . , o%\ rlah\ -,erl llt
1!!: i'• prm;dcd b\ NI [it, and I'll-1. i scull hus JCr1lec. ! 1,11CC, e\Cn i1
\11 A hS \\cr% ea necIled, service I11 the \iTC locution 4kwld sail! far superior to
!.1:1 s :rar. , i!It~'rr.:lti\'cs its \•l'GR.
11- \i 1:1, Iis allere:l. %l'• :t1111Cr~all+!nh 1\!l!i N 1.1 ~il'I\C! .tillULCil- tl:al at lea l
cart o!'that !ire would hu hic',cd up by \111;1 . I'Vhis a hat harrened when \t l':\
i.limit:atei the ou:h:rn Shur Of it; Old route '-64Which usc.i tv run !urue!\ afong
Sal (;ahrie! 131\d. itrininaurlv.:t the %1TC. \iBl_ picked uh the .'outhern segment.
which is wh\- ever, t'Murth north-13OU110'. \9131- =4 bus on \+eel:dal: noA continues
al'.'lie \~a% :r `;ierr: '\ladre \'illaj.
Dependim-, on ',k hich propos:d changes 10 '\'1 1 A st:rVil:es :ire c\'cntually adopted.
\FTC \`.'lli Vic,%i h\' .,r.:)m: 'Inc, illlc. \{1A bus'.ine-. , .t three'\9I3L
mutes. And One ! r+)llt `C+'1'i,e 11'll~ ~OIi:I!luC a: I: !1'llllllt: flit' I +'als :liOn2 \ltil_
_I!..In;i aI n1111111: 1 i11:1 \i131. %1131 71C'I, LIP a
j1t11"Ilo:i Mr:\ ! ll. it \lullld uPer:lle :ll 110111';\ !n er. J!S, r;,n1liar 1J the
':rCyLlenC: C:Irrentl\ 01-ON 1C fd ''1' \1 I . 1C +`th,:7 ~I ! rtR +\c+lllu Umerate
at ?lO-o(-) minu[- Intcr\ a!c ] t'+_Cl!1C1'. 1!105: RIUIC~, prl \';dt_ m,in\ C:,nvenient
E111.r11at1V,S t0 +?CI\ lie auiomoblie ira\ el it` tl:L~ .'\I l !1 :al: hxIe a sl^illl!cant
:!:1p:tct oil F)otk mu'flie and air pollutiva in the \ icmii. +)I the ilronosed
is C:~DITI:^t. And. :,in ;Gllttl~lt 1`I.C . L!,: ..:_1 -.;t:... _ ...1` .:ri Cmaln'•e:
\1 i 1- it) m=.:%(.)`,ID :'uie ill a `.1;1i'..1..tl k:A,Ui'_. ,1.1'. .li "A (JR.
,l
A. .,CCJL1SC _1i irtC }lCe\ 11`.!`!` - lul'U tiCj lirllli?i1 L:~UC. ai 7 l'tCl: U-C' Al,- %I :S :!d'ead% a
al+tr t:tl:ni ert:!ai .Cte!Or!llcn`.. II1CI';!11 nt:I! il"il! .111: !!.!r ~t'11ut„ill _i4c'C15 \\'!!I be
TK-6
(cont'd)
TK-7
Todd Kunioka, Page 9 of 20
hstantialk less SiLnificlul', ;f the prOJccI is constructed at MITC rather than `A'GR. This
hartic-A arl'. the case i t operation Of tilc pror",Scd G\ :11-Mari. crc t; he on a _'-:-hoar
:ICdul,
B. Late-ni gill 1!L'llllll1-' cOUld PI-CS1,111 J :~lllllialll :!il(lall from. cmi,::' ;%)r oti:'1_ration of
the hlomere'. Park Obser\ai.or\. which is one it onl\ l\+u Iwmiclpall~ co^eriiwd puhllc
observatories I,-, 1.os .~n~eles Couni\. and is located onl: about three miles a\\a\ from the
1 UR. or NI R ,I-es TO tile exlent that late-ilient hizhtim, rlla\ :Ill:cl dare: skies.
i,'rz.,rl ion :\oulc probabl\ }la\c tt_► be sfliftec 10 1110 t alie. Tcinrlc Cit: ;Ize. or the "Trap
:old Skeen' site. .;Iseusscd later ul this ieucr _
\Ct tiurfaCC Street Traffic Impacts W 11 be Substanut111~' Less is the hc\eloy~nlent is Located
1f1 C Rather Than WGR.
1-he Cit\'s Ellt.frroileousli.asserts that at:el'opfflu the Suhcrcenter at WGR \.ill not
result ;n an,. signiticallt trai'f-ic Illwacts. I his I:, nccausc the L:t\'s tfe1i1116011 r,f"inlpact"
is o erl+ narro\+. 11 cc+n~idcrs W;IMc \tAunle IS a Proportion of came;t\ oi'an
intersection. ] lowe\er. because of' tile dense 00110; nuatillll o!'traITIC ,iznals near the
% GR site. xolunlc is artiiiclalk depressed. C:us cant nluko it thr >uL.,il an intersection
hC COI%: S liCht C\'Clc hUS c("moleted 11CC:it.]Se !Ile Cars in f1nni o t'!lelll al': hi,7Cked b\' ;1 red
hi_,ht lit the 110\! Inter";cCtiun. This occurs at t\+,, locailkinS proximate in the WGR site.
%,ir:il of the 't\ (J.' sit:. 'henc• :are I,iur a;!laic ,i r,~ +ithin a : mdtc scemcnt of road, I lic
,:Orner of %1.1;11111 Grrl\c and Rush. the pe:icstrian crosswalk l'or L:ilson kiiernational. the
hy,hi on 'hc rark:lw, lot entrance 1 :linLit l,m\ C and ::dl,on 'A zi,: )..ill.: 111nu-, Gm+: and
Similarl\ to the south. traltic lights at \1 siriul (11'UVe and LZIndis Walnut Grove anti
far. C;ahri_-:. pan Gahriel and the ramp., _ inn.ctin_ t,-the \+esthuund Pomona 1'reewa\.
ar;d San Gabriel and To\\n Center. and To\cn Center and 1-lontelkilo Blvd (,and the ramps
connectlnu to the eastbound Pomona fre,,wa\ -laces live traffic siumals rk'thin a mile
space. AS C0L nter-intuiti+c as it ma+' weal. It anp_-ars lirw the 'zrid!ock conditions at these
1-105 \ Nj a=-i traffic siOnals actually Prr\ents.,.jiv onC of :hose Intersections From
Yroducin~, tr.iflic ,olumos that rxce::d "cahacit+
111 addlrlt)11.11 \+cakih:ss ~)1 the original L-IR %%a- .•.111. tt'it' :C C allOil Models for
l:.'.t!lC cnc!r.ileJ 1~`• U ul-'\larl S11?OICCIltCa'. \l'\\ !h::: a 1111'111^.Cr it . Upc!'Cenler> ha\'r
I,eell 011en 101 .11111C -soille 11.11C.' in t-al:Iornia. it ii1;Ss,-n 11, Isit !hc trip
!,eneration L:omro-,ers:' to pI'udUCC a more accurate trip CS:Illlate. particlllar]\ for stores
thal open-ate on a _4-111wr i:hcdltlC 11iU1'C 11C.tii'atC I1l0,_.CI !oi li':1' ~:Il":'allC)Il of a 24-
hOL11' 'al-Nlal': SLIPCt'Cenl~•1' \Viii likcll, indicate th:it sw-Cac: ~trcci tr:;flic Impacts will. in
lace. he siLmiticani
TK-7
(cont'd)
TK-8
C.11',ell tlle~r'AI1'11LT ('i,T!.T,;"II III CtinLel"1•. II1'.' ,'!!L'Ct:\C "UrI11c :ra111I
Todd Kunioka, Page 10 of 20
:Iternat;\e lu Scr\e tllr retai'i de%clopin%:nI \`,OLI J rrtil idc \\CiC t i1C miIIi. rclleI'. And_ as
?reN IOLIS .:lute. puhliC M1 [ISit aIternatIves U., \1 I arc IM 1•ladt \\hdc those to \1'Gi: are
:`:lrCnlel\ :ttlllll'd
\ISO. tll•~- GR ~lte ill need to rcl\ can iusIt I\\t, pi,intS ttl L:ru\ l itiur 1'r-t:1, WalnLit
Jr ::'+!nl Rush Vie! crated U'!p, nlu,t ctl!Cr ?10111 ju ; tlw c 1\w point S.
and all th-_,e '0,111 hM%L u, r,a< lhr +1:,' :."IC ill tit: I,'.c+ tr.!!'Iic bottlenecks
!WIC.t abu\t ,"OL.: t:uf'cx a; a:i15 In iJos uewrartlllc:ll proxIIIIII\ It, eAC11 ;thcr( Io get to
B-% Conlrast. access to \ITC is acct5,,:blc from fully dIS1111Ct elltrlCS. So. e\er It the net
traffic len+:ratei ,\:rr the same for \'TC as for 1\ OR ;and it 'ie mnaller. because the
rLizid e\etupmeilt aI M\ C ,kill be rcplacim! a clostn_ retail devciormcnij. the traffic
inlpactS \\uuld he Spread 3111011V a lar•~er numhc~- Ott cntn Baal ti. In rarticular. -ITC can be
1~CCti_ell direcil\ Cron,, :h\: Pomona irCC\1:1:. from 1\f? C;,I1,rcn:: 1•: `lti_I11C! C`:ItS Car>
%\ould +iCI ti-om the t'ree\\•a\ dn'cctl\ into the \•1'1 C Some inipro% emems In the capacity o1
thc~: irier>ecimn-s rmLht ;urther mIti-,ate :h_ ci'l'cts +1 the ad.... rc:ail dc\elopment.
In aadiuon to the access at :he:se fret:'\ n\ Oil-ramn,.:ICCe`;S L:,m he 1?tali: !'rom either
\l+tnteilrllt~ 13!vd or Plaza Dr:\C. Plaza 1)rl\c L:olmccts to San (rlh!%L! li!•,L;. Within
s-•clul I 11111e tml*\\ila:.a intersr is :\ilh San (i;:hr'c! Blvd. GA-rlcl Blvd intersects
itll Llncr+ln A%- . Rosemead 131\ . anii Dur!"i St. H-JS :glean,; !;1; i'la; a Jmr : entrance
iv:111C11;S ll11dI.rui:L:ie'l m c(? lvvr:SCtll \\Itll the .!tics w11 l entf rcc`iI pcmlits eaS\' accesS
to tll Site !ill' dri\erti Cu1:1111p- Irom easi \'iCF111C1h,,!lo. South I-,! MOMI:. LI \'Iunle. 1111[1Cf.
1101'th ROSelllcad. aild IIO:Ills cast. File Montebello 131\ d miratic: pru\ Ides atCc` ti to the
site li)r \v:sierr. \lontei,ello. Momercy r'srl.. 1 tmth ~ 1) t;ahrlel. R~\senl.ad. and puints
"I St.
I ccaLIU' of tl; 1`I't`tnc~' tll 111 ISS lr in: l: ;a.cril~lll\ la•. arlcl lI1C `.!sIC:'ICC ,ti cral ;ICL'C5S
rilads. Includi i hllti (11:1! l~ '_Crh"':tl!'• lil:J,:rllt:liii:J At t!'IC Ill01'lIVW- Jlt_' :!--ta.\cd
lour eLti,n:_:.Iai.:r::nt '0 III ( il{ :lnJ NTI C X11::: \vill Sjl'i't:r ~:Ih .la,ltlall~ less Con-'estion
the de\:ltt'!11C11? tti:Lt!'` .11 N! I l IIISl,~all (+I:
\'I C"ll tnictlon ul the \1';11-\1::rt su1wi-ccrter at the VAC \wllld pres,r•,c :he GR site for
llterna:~\'e clsrs -,vhllc still realbdiiu tic ta.,\ re\eiwl: InC:-c.151 r.sult:n-1 gent construction ol'the
sun,rCLnte:'. Anion--, tl1C rot~mti ll al tcm atlvv !'Or Inc t• GR' >'I!C :oL.IJ
The '.•on,,irm two of a Illllic:- '•21I'r!!t1} CII WJ; ^n+i\t-._I 1,+• \n111U1s de
:_ds 111CS. SLICII a de~CIOPII1C:1! \\i+l!Id bC CUI1:"+Ient \\llh ti: a;> C,~rC.`;Sect ill tilt: 1Ulls
le_lSla!]+?Il n+t'.['_: \I' \'lt?1t5i., I' \Ut:id 1~rllk,' 111 '11I111!\ .C.:" dl<.ne;'4 t!utdoo:-
rCC:_.L!.71'+ ll; ,..lf all t L'.`:1Cr:! ! ~nttrla!111I
1, I;IC.~.Ia: i11 :alC I ..I
TK-8
(cont'd)
TK-9
Todd Kunioka, Page 11 of 20
Alhambra ash to percolate downward u\ r charge ,_roLind \\atcr suPpfir:' in southern
Calli'Ornc:. Tail u e n•OUld be consistent \\ith the wetlands park alicrnall\v ahn\e. anj
couid realize a return on investment ol•an Undeterlrlined anu1utlt l'his use %vould be
~Illlilar to the us.' Of lnflat:;hlc' daI115 uli!r,! th': S:!n ( ;:I,rl,! R _:t1 tUri ,!I, t'. ~,q. TK-9
,}rnUnd\\ater rcchar~: r
(COnt,d)
lie consu-11C11,011 o I111XCd ~l~\~iiihnle!ll.'\i"'.1C1:. `t! "1 I! ;I!cr
or :Ic\ vloped park- riedluIn-den~It\' ht`.utiI11L a:... \ . hC
I_;s irnp, ,cing and les.- disrapu\e than the cUrre!.t rlrcipo:•-:!
VH Operation of a ma) or retail development at X11 C %WLIId a\ 01d tllc- need it-ir truck-trailers to
natiit?ate the "u-turn' necessar\ to ;ei from the nest-bound Pomona 1=rcewa\ to north-hound
W1111u1 Grovc.
Tractor-trailers attenl}nins to service the WGR site from the nc;t-hound Pomona freewa\
n°ould need W execute two right turns \vlthin about 100 acct o!* each other as they exit the
freewav and turne:l on to W2inut Gro4e. Making this turn \vould disrupt all traffic
;Xitulz the freena\ because the trailer would need to block bode right-turning ianes at the
iclp of the rarer) to n-.ake the first turn. then. aua:n. both I-IUht-turllin~ lanea from San
iahri: l to 11 alnalt i rro\'e In na\ 1_ate Ole ~rcr,nt iurn. \A\ hide \\oui.l need to be started
esscntlall bcti\re the first tui'I'I IS OC11 c\implctca.
In summary. a rLrrsort an.tl: sis Of the NITC sil", arpe"Ir-s 1+1 pr.SCrIl the pntennal In achieve all of
the stated substantt\e project objc.:nes whiie sinltllU111CUUSIN providing the pntentlal for
ch-linatln`_ or ~LID~tdI1t1all\ rcducing :1.:1!i\ of the :I'.\ lri !P!!~:1i:!i I 'j .1L'l :!::It ',1'OUI;1 be imposed
if the tit-{iR site Is de% eloped.
N ,
NE)nei}1C1CjS, re\'ls:a FIR IP.11Jrf1pL'ri'+ rciccts till} ,l.tel7latl\e trmn tail I:!P consideration. The
r°asons L;\-en for this reiet i~~n. and n,,• response to :h_;c
-The Muntebello To-+vn Center is an upscale, ;e~_iunal rt.all.... l-llc introduction of it
iiscount retaiic r ~re~cer use 4\ithin the -xi-,tine mall ciluld he inconipitihic and have detrimental
:cononw- ;-tlcctS mad;acent retai itrc" l p. ;-1 ~ I
a. Clan-sif\ing the MTC as is nithout li)UI-IJallOn. Among t!!c three caller
anchor ;cores la;suming a'-Mart nere to c,cc:1^\ thr lOl!Il!1 :111Ch,fl. 0111_. Mac\'s serm~
to fall in the tat:+go^, of Tho other t%vo anchors ir::: \ ier\'\m and a .I.C.
1= one'. tl. <.t;•re mari;ts it clalttt ti tar_et sn
tier - _ i,,Clai ne!.) ilt', dcscrih s the:!
Todd Kunioka, Page 12 of 20
st''• le, ]Li:illt`•'. find ::SILK lilt Ia111111; Our L'(~a1 la ^ till :I1LI i f'Il;llltlc Io hl' to ~LLII,4\
ill' _".I [1C I1l:C~ ~\17l''il,lLl ns honer An we ::;tl:lrt:.,Llllrl h`• i, l l'lllu . 1~ l:_ Iltalitl.
e\_:='llenl ,erg Al at a good price.. 1% "n" :ilex`., Il,.~;?Il? 4 ?ri' _1h,"Llt tls.:LSh\ j
C. I.C. 1'CIllle`, ':111lclal ++CE site read_:. in n:IrL 1C Pellnt: wwes sell lashlon at 1'aluc
prices. Our tango', cuslo:ner, fall into the middle Q* the \,nlui!can "Oro atlOn. Thc~ have
a :amlly hl?usdv,ld mconle r"4114_'In, S!'I.001! 11l W .000 a See
1'1F: 4(\C`A.'ChC'1111", .a el ritlll`-1211% 11'r,'IIis Il!\'!IISl,w, hIllll.
d Ile expressed concern over " demmemal economic elfc N* on adjacent retailers if
Wal-hart IUCaLe5 in the M C is 'A'ill'1001 'ounciaLion.
:lhsent in econon11(: impact analysis of the ;Lot that %%OUld Il t\ e hecn required h\
SB IMr, AB 1056 1which was passed byte ;tale I;:,-j laturc in 21)(14 but -.'Cl.ocd
h1 the onvormt-1 there is no AM= that rcwlon71c 1111r:1cts on other Rosemead
retailers. Mether locawd in the NVI C ur ;?utsldc 01'111C M FC- V'ouid be ureat r if
the supercenwr +\w h.l k in the VITC versus W it xwr'c c,"wrUCLed less than a
mile a\va~ from the MIT'. at the \ GR site.
.An! in any even.. '•a.'nidin(a dommemal .°ctln(allic 011::11 on adjacent retailers..
was nor t'!ne o tli rri)iCC1 ,1h!t'c!11 es so h. 2-6 o We reVed EIRJ
sal it : 11: ih+t LI ii.? Llt~tf:r UUC 111 teC!:ati\ :tC' i'rllnl
fill `~li7 e::fl it'll
In vracr to :LCCOM11WdWC illC prOl)OSed 'A :iMart Supcrcemcr sikhtantlal re-dman 01 &C
Plat :et meuW he required. resulting to the C011MI'LlCill)Il 01 :1111LIhinlt:-sion 1:1C111t\ %filth
r. j-1-•
aLidiliLnL. iI. at-, rr~t% id--d °r the t (P.. -12)
.raSe Harkid--d un'tut. 1.
a. AccordinL, to CEQA, aiternatlves to a prcmowd dinvormenl nnal he considered
even if Use ahcrnadves \\'cluld be more conly-
h. The rrssi ddy :hat de\elllning the prow at M I C' n1 gM rcauir'c huilllin`! a multi-
itbr\ !51Cu:ILlre :S net I'e :dill :11UL11h lc cscllldc the "itL' 1r011? lurthcr -nstruction. As land
alLlCti 111 L:11ifor 111: increase, bath t~ al-\"lart and other ret:lller~ have be_un building
\enicalll rather 03n ht wortmil\ Vor CXamP1C, the rcc:cntl_\-orcnea Kohl's It Mission
Road and 1•relllogi Stree-, in :\1h vllhra is. :,o tar a> 11.11011, the c1111'. :vw--,lor\' Kohl's slorc
lr: C aIi i~?rnia Bul. i~ecau:~c 01"11W iinlite,i ::iFd .1L th <le\ eltlllra.nt'ti location. Kohl";
elected zo hudd a t:\C•wory bulldlil, MY= LI n?ulft ~i,tl' V\ a:-%l:1rt 1, ceriailll.. not
unprecedented! J Bald%~ill I lilLz. Slor: l: a Lhll';'~iUl'1 struitLLr'e isee ? of
the lranscriPt f'-'r the ~il'. Co"lnrif niee;l!1'_. 1~'r1;:11 '1 ~1J{
TK-10
(cont'd)
C. There, is ".I' "Ian IIa! land sur,ntuldin, the Xfi C I1C IQ .Hold W dC%CkTed ac a
:)ark m ~ Shull!:? LdJition1d p a r in g K IIudol I IHs 1\ aiQ u up some o f t Iw
Todd Kunioka, Page 13 of 20
:llr:''Cni arE.1I1C lU1 , I;1!' ! "l;l:. TK-10
flat t ,,{LInJ (cont'd)
The Lott Ali--eles Den Ier Auto .auction, Gam ec A%cnuc, 1;A \lilc e,,t of Sall GaI)rii'I BI, A
I Hereailer Rcrer-red to as the Gan v) Niel
The Los :Angeles Dealer :auto Auction site is located at 8001Gal -,c, Boule-,ar,;. het`.%ecn Del
%la-, Choi' and Sari 64im-le! 13,'niiL ..'.I'j The ref I ;cal 1' l R.. Ja S [flat ;he land :(>ntrullCd b) . the
ALIC110.". lliOlIC cunlprises acre>
(lniP:IT-IS011 Of the Gar\'e\ and GR site
1. lln initial re\ iew the. Gam e\ site appears to Prc!\ ij dlc plrictltiai It, t'Llll\ achie\'c all of the
prmoc( L1bmant:\'t: '.11?)eCt1\':5. It "odd also 'gTeal"t'+ has c the po'. ntbi a, no qv hill; achkvc
objectives (2) and 15) AI wall duclopinom (11'ibw \`•lien compared l.` y\ C
A. When CcullpKed 10 1110 'L\, (l l; S11C. 010 (tar\'C\ >1l' is wore ccntr all\ 1, 1cated \\ith111 dlC
Ai\' s geogwph\ the 5 10 Sile 15 at We C!1\ s far souihCrll ani.l m ll., of t1lC
Issidencos closest 10 ille prl.}pt.WO AIL' C!i!r1l1OU UM 11111 it _ ,C:'1i•,,,ad rep;:ie1ll~- I herelo' e.
the tic we\ tine wH1 letterachieve PR)lec'. 0twuh\e t,:_ IT.,I\1.!Iil` 1Cl:'il Loninlercla! L1,;Ci-
to scr\ICC !.he neeU> Of if2J:,eITte::.l ._ali'fCl?t_ l i1' %wLili I'. .:as::r i,.-! HceSt
a retail development Awed nwir'Cr t'1L CCllle: ttl'..:11\ l:1tncr :hall ;1 je\ ei-renew :!i !.hti
:It., s kinscs. As !s parlicutar!\ inv g zn the q awr Onplenn: ill p& A: TK-11
u-.1r15POrtation ser\ ice 'o ale Gar\'c. site \\ilen C011111,11-CLl IL' S.:r\ icr 10 11n 1\ (i1' :,Ite ;.A
discussion ol"hliS Acct' S to the li;lr`-c}' Soo occal':' Iii 17;li-I t1l1, hefll.`•:
B the i=ran'e~ site \\nuid place a ne\\ retail de`, clopmerll iuiacent to nlan\ [other retail
Upet:amns. on one N 'the Clt\ main streLns. It thus .[tale` L` nrilfec,, ob.iI!cti\e i 5) more
full\ than the \\OR sit;. MliC:l \\trLIIJ rl.tcc al rrt;lli ir:.iil ;,rep where no
cill r relall ,:!1•eratmny exist.
fl. BUS St'r\ Ic tip the (;at'\ e\ itc is ut\~riL~r to that of lie 1\ GIZ site. So. iiKc t11c MT( site.
ridrshal'e is nowe ICaslhle a( the 1. a ve\ We than !l \\oultl he m G 106 nwnns na ilc and
poll non impact= "A he lea. and can he noire' casdi miti~ tee a1 the Ci:1r\=\ site -,,:rsu,,; tile
(,r-'. lt.. An elllpiol 'er :il (hz oe colllL: 012-1.0 :11.11'L' ..1SI!^ c' !111'`1_ \ 14.. A 1\ID rUIL
=I _
A, \1T.\ ?lrovidca 24 Quin so% or-Jun _:I. Hl' u.. hcl\leen LI
\ l"ntl' J:1~7 \\'.1!•. \t !1 \n_.'IC. DU; :l_ 11it'a( 1!al: er. 1L'_ !5 .11 .1 _11 I1i11l.Ill'
Todd Kunioka, Page 14 of 20
111 t: r:\UtC :i ?t1
C'. The Garvc\ Blvd corridor is scheduled I-or Upgrade to nwludv %Ivnrn Rapid bus
ser\ ice \\ithin the next fe\\ Nears. Presurnlnu M-l'A fOIIt,\\s its nunlbvrInu system. this
\\OLIIJ he desrurated M 1-.1 7-0, `,'ICtrl: Rapid buss are lil;liwd stop_ but also have siznaJ-
rmv!l\ lt `Ior J!<__'his J h!> 11:15 MaLJC OIC111 \Cr\ rMOPU.Ul- \ itll btl~ C:OlTlmuicrs.
I) NIT. ,'l. :70. and 1\\hln It thecomes opcrauona(1 770 \,ullId ail pro%We a link
bet\\etn if,%&nto\\-n Los Angeles' I_ nion Sttn:on and the El \,lontc Bu; Station. Both are
Mawr hubs Cor sores of NII-.-1 al:d F`J- pus roulcs. 'Flic Garvc\ A%\ :nuc routes also
intersect with \IBL and N"I".A routes at 1110.91 major cross-;trcets het\\ccn those two
destinations [Del Mar Ave.. San Gabriel Bl,,d. Walnut Gro\e BI\d. Rosemead Bled. etc].
11115 Ille:Ir15 Cull\'rallent btls access to the 11:i1'0C'• Slte is 'Xo% IJcJ. not lull to those ll\'lI1F
alum`-, liar\e\ ;%%lenu . but tt' t IrtUFtiJl 3N ptlbll, ira;'.1iE-Jri?C:hi.ll! ~.'llI)1t 1x1 much O
;nuthern i allloruia.
lll. l \\er -;ensittve recL*rlors-' \clll be exposed t0 all- noliutinn JUrill!Q the ,nnstruction and
't`rrk Ion o! a SUP,-%ellter 11 cnIIstruc11,011 wcrC h, OCCur u; !h:: Gar%c'. silt Insicad of the WGR
(Ties paint is address:d in Lh"' liev section, in nl\ rchuttai to ;hc I-JR . reasons tier
:•ectine tilt C;ar\ e\ rte !11,,11 full viv, ironniv!llal x1:11\ Nis i
The Garve\ site thus \\uuld appear. IT. initial rexlc\\, to Provide the potcnual for tchie\ ing all of
the project's, suhstanuve obleetive,, at least as :om IQu:l-, 35 \\uulJ Jc\clopmem at the \ GR site,
\\hile slmultaneousiv sueL~estinwu the abilit\ to reduce or eliminate at least somL, ol'the significant
environmental efftvs associated wlih de\elnpnlcm oi'the 41 GR site.
Nonetheless. the re\ iseJ SIR chUUS; to rejec. Iurthrr stuta\ I the C1ar\e% A.enUC site. J-he
r.-asons giver, for this rejection. and nl\ rvs~on>c;. follo\\
1. The rrimar_• areUnlerlt prc\ hied in the FIR :reaill;t furthvr r'or!s:Jvrjlwr' .I'thc Cian e\
\\er,Lie ,Iti• i< !Ilat ziIAI a> -i Rri\al: Jt-.elopcr. li, , IImiI tf ,IhjI!!\ i4 assUr: 111,11 ,1
de"Ce oPahlc Carl he a»cillhlrd thlvuLh the ;uCCCSsI-tii r,ur,Jha,: of spct:!'ic Iti;ntlli::d parcCl`
A. 11 il'.'CCSSaI':. il1C cli\ Cal? :\Crt: SQ 1tS j1U\\:r t\i Cill:ll.flt J~~Ill:,lli atise!17t?le additional
Parcels Illu, a Ial'`- r sill.! e "!-o p'rl` Rl;l :t :1,,11'. :l'.::t :I drUSUL S11--p l\t'Uid
be n~_rJrl
i, Tilt AL11u ALIC11011 Ili 11'CfI.• alum. \\itiluut an., udditl n ua par;; ls. is rcporl;:d to be
acres m area. I'llis is -Disc c:TIQ `'h 10 111C'TOOl irCj I~ acrc.Ilflanii Ip. 0fthC
TK-11
(cont'd)
Todd Kunioka, Page 15 of 20
TIM 11111 ih.it r is rill all al! 1l1r:200L :illll l!.:~eGi. t11a1 ,1 ti:nlr-L.A_,lct ~a!' 1.101 hC
~,)I1SlrU~ICtI ~i)1e1. +'U tlll~, parcel. J The ,)rrtit`LINi',-n01CLi t%%4"It'IN Kohl • Jcpartnient
shire at ~rvrnonI. and A1!s:=ion 111 -%:harn. -a pr(?\i1_1r1\ ilf+ jaUarc feet t)t rela11
s1we on a parcei ui lust your acr s. Ibis su<ggews bui+l dig a r,+ woo Suptementer voth
a^c)Ut 25(t.9!t 0 SL:UUYC feel slluuld he posslhl on ;ust ll•! aere.I
C. As noted in the NV C discussion above. there is nothing rnauncai about the need to be
able to fransn!an! unrevised the same blur print that "Wd be used at WGR to the Gan,cN
At enue stt . Ahemiions to the proiecl :icci--r. Moult reduce or eliminate the need for
utilising propertybeyond the boundaries ol^ -.he L.A. Dealer Auto AUC11011. For example,
aulldln_ a r\+o-ston Supewenler uoWl reduce the t.)htpr!nt 01 the Supewenter by nem$
llal!'. thus reducing land "needs" h\ o-S at reg.
D. %1 hJL' hui1L111V \criicail\ would be nlorcthan htiiiding hor-.zoiltall\. CEQA
iSvc 1 -12(1 6) is clear ill Si3tlni'. that tilt tap-.:hai am aILernative nla\ he more cost Iy is not
a suftlcient reason IN falling io e\aluate the Inipacts of an ahernat:\'e
E: As pre\ iously not+rd. the .onsiructi0I1 Of multi-stor\ \k al `t1.:rts. or similar department
.I, res, is nat without precedent.
K, dntw pnu at Gar-\'e\ -v enuc. the city ar+nes that cn\ irc-rimental ilnp:lct; would not be
i'.,.tlcClf :(ii!atlar':'~. i'La .f1:I'Cl' relo%::i%-;
In ' :1nal~ ~in_" the envirnnmental impacts o de-, clopmcnt of :llc Garr'-e\ ,-venue site. the
revised FIR seems to he placing a __mater \aluc on the inlpact~- here than, at % GR. For
e~:atnpie, \4hiic the Nk 611 site rein;; iocated circctl~ across the street ifom it school is not
Lons,c ere-i si_+naicant. the :act that a school located some nliie a\\ ;;v from the
uarve\ A%cnue site is considered ;igtliiicam. %Ihile the fact that athietic competitions
+socce,r matches I mvol\'tng. scores Of cump;.t!tors are re`'ulari\ he!d dlrcctly aCTD55 the
street from the %k OR site is not considcred significant. the present: of park with little or
no %anized athietic conlpcttlions Wank apprn`::matcl: P.liic directl\ to the cast.
~urihCr alcing ort Gar\ e\ A, onuc k :1-tw d nj srenlltcaw The fell?. Two not anpl\ the
Sallie ~t:Indar:+. tit significance !or n%'Ironn)ent',ll i*iccts %VhCI' it ~~aiuate; the potential
:Illpacts of ie.,ciorlll`1` i!1t~C I"% IN sllcS.
l-hc re5idencm near the Clar\'a Venue qIC area alread\ 11),:JICd dirc,:r!% ;id)acent its
either cWt:ng retail ur We eximinu'•I, h-,iicsall' UnJ NO UiC 1;-a:_.11al LiiCCl 01'a
%Val-Mart t\.ould be exr)rcted In he lCSS sigill ticallI :hall :1 a ~t :tl-~'lar' '..ere hullt in an
area cl`1nomer\ hcl:mg an' Tesler rox! ire =1itP^-+ars i•1 IC ItZ..1!?"men noems lt1
TK-11
(conVd)
)I1llt:1Cl:-, 11. 1+! ilia 111: :C, alld .L ,llt'1: :...!':11 •t ...i!, I:. :111 '11: r_'.I`:u 1'iV
Todd Kunioka, Page 16 of 20
Ir„ ,F., 111'1!_{;! 1?Cry 1F ,,-:Ia h::. :I '~inll!::I' ir1!~:'.C: I ! 'I. TK-11
(cont'd)
l i s Nor IheasI Corner of ViIle\ IiI%it and I cnllllc 011 NI%d
IFIcreaftcr rcfcrrcll 1t ai the VTC ±itcl
Thir location is on the :ar northeastern portion of my cit%, The parcel alluls the F.aion \1 ash.
hick t,_ a concrete-encased stream. Across the wash is the city of El Mme. I-he revised EIR
5,a\ s that jirectl\ across the wash ill El Monte ;s high-i ensi1\ residential, alth, h judginL b\' the
satellite photo. ii appears hat industrial or commercial uses also line parts elf the El Monte hank
to the Eaton Nash. If so. the potential feasihilir. Of derclopirlU 11.15 site \\Ould improve. This
ll OUld be n:Jr11icL:LJr1\' !roc f the :tv ul Rosemead )tick to attcmrt a c ca;i\ C. lonll-pLl\aers
dc"Clc'pmcni ^rclicc: here. unlilai to what was Jo1w \\llcil .he Voni.: Jl , i own t(_ enter was
C1'n~irt;:!Cd
( c)n p;bison (it' the N 1 U and \N (IR Sites
1. I? them are commercial and industrial uses U1011U' portions ul' the L-1 N]owe s:d o1 the Salon
\1 .15,11. than SLi1fICleili lflllll could he asscnlhleci tit do\clah thi prnic:t in such a t~ as to achieVe
111 .1I Ille iuh"mllnl o oL 1L:: cr\'es o ih,: f1I'UIL'C:.
~L1Cti ~lt.Cl~l^l1i.n! ~~tC~tL.~ ~:CI°.a1111~ I'L'.Illll'C ~ll,l.:l"lL •i::ll:.Il~ ,,111:1' :Ii:Sti
t.'r1~.or.tall\ 11„\\e'. r. a r.oied in the pre\ iou: \i'I ( ;cL tic mul:: -t,.,; , 41 al-Man
ture> :Jrc nl~t itil~.~ut rr:.~.:.rt
l) SUCK a L1C\'CI11rle111 \WUld alsa rcgwr, a O1!ll de% lclpmenl .!rcell2ent with El
\ 1(+111C.
11. 11*Tile `'TC site were dc\eloptd. it would Ila%e the ad-, antay of LIC11fOr .Hass transit JCCCss than
1C)UIL I?e ~~'Git ±Ile. Tjll~ co lli: me:ln a11' p:\llilthln :11ltl 1x;11111 11111`:11:14 cO:ild hl' lessened
hecausc of Ies,, rehuncr of p:i,aic UU1011lc11\ilcs 101 LIL:CO; 10 the \*T"' Silt;.
\'Tt 2~er\ ed h\ %;J] -h. 1th sex'. iL c s L:11 .f a, a weCk
Frcnurnl:% durit:-_~ must .da, run: 111111UIC5
1t;1':IlL' \\:eh11:1'• I ?!1 liars. \i t, i~ L'LI I, \I 1'. lilllib:J ;i•1r.;'Cr\ICL'
ill: , I i11C th;l:l 1C1; .;n 1C !rUtl1 il1C
Monte but jlainll. lh-, alit' 1,,r Iila`` :1%1:.-~i1 :r:
1 +Crc_'Xlrnal:`.'. '1' VIA xid F j 1-7 bU`, ;-owc, or. i11,_ 1 1 M-n!,,: Bus Statlcln
non all
_I'! 111. 1`cahr;e. \';I',i; a: ,\ri' j, ~~+u':!• h_ n..
2
Todd Kunioka, Page 17 of 20
D :Vtth the :Sc_ptlon of laic I:I!_hi carl\ ni orniC:_' ' ~I ht O%%i* V 1 6 and 7-1
`'user alba sw%v the El Mollie WrAinl. ?t;lllt~n. thin rro%idln_ Clan'.:mcni '•erocL, to
VI -C from a, tat cast as RKYNld': `ail Ban:ucili o and as by now as i lilt'n Mon.
1. t' 1 C is mrl e~ l?\ \1 T.A. '0-. an houri..+e W long Ton me CA, 3h
M + . , 6 hm tile. El Mon:c: Bus st: uan %"th panis non! ;nclUttln'_ h:!>.admi
F. Collecti\ei~. this means that Ili `.'TC' snc pro%idus u iment:r powntial for ndahare on
t.'le par n _rllnlo'.c:es and custorler to be mom site iha: v oul J not he available for
the development at %N GR.
III me \"TC site does not appear to he proxhi to to an), sensiti,: recepturs. l*hem do not
appear to ne an} schools. parks. retirement homes. er and oihl:r such Caciliii:s near the VTC site
Dgvnding on the bambliits of negon4ing a doekTMCnt agre nlt w » ith IA Monic. ill is Sa%: TK-12
nlal or T;t~ not n:.-, L :.it: 1'0ieatlal 10 aChiclc ad !!he priYCLI Ol' CL '.I:CS it: 1:.;;S1 »'s Cotnplet.': a,' (ciont,d)
the WGR say Because of superior transit access and the lack tit am sonSim e -cccptors nearl».
it aisu has the potential suhataraiall~ lessen at least some of file siLnillcanl ,n~ iiannlcntal effect;
:1:... 'A +L:lL' OCC:.. dM r. Mil OW %%cre ttl occur a, the I C+1: sitC
Nlonetlleiess. the revised FJR rejects this site \"Tvut amductmg a CA! an ironmmmal
absessment.
*Vhe primary argument l?resented ir. die rv%is.u FIR ,:_ainst the V-1 t.' X11: i:: the ack of =ufficienl
tpacc Ho%--ever. as "oh pm\ won ;lies. if the structum o w mtiuu.icd a% a mule->ttl, huildinT.
any: {t construction ',k !I+c i a1':n V1 'o;I..I 1+ t :L ;i+llla me
d5~eliihlC.f
Vic reVed FIR also says that high dcnsit~ re~idential parcels arc located acHns the Eaton Wash
from the VTC site. Ho%kever. an mal' si> C?i a Satella-, pholo 01 the iIle nlak--s it appear that the
resid,nnal parcels are only 10C,11CLI nzar ',he soul lerr old w''.hc nttrcei. :\kqg the northern
pi)rtitln .+t the par h it appears !hai industrial lhe:+ arc .++Cal:ll :iCros-- the ',.ash
Other Potential Sites fur a Supercenter Dc%chilrmenI That \1 crc \nt Idrntilird in the
14% ised I' I H
'1 afn n Cimve a, %usson. nonh coo non,:!
rCl it!' C1, i:11~C 111 t)t pf:', t: ~)S'1+i~:rl\ i1)h_iSSJ~~ tl~ti'n..j h~ !1C l;• \ t?Ulsl IUCilwd
~rC I' It l l~eSli ;l ail ..I~..'>eat +t+r ;`t'. :I.:n•l?1S`.•ItI'1 :+11e . 13: 1-iL!I:Ll111L 2 11.r '.',10
TK-13
Todd Kunioka, Page 18 of 20
Supercenter or the prik ate lot alld 11101'1.tn_ the .an:!I1Clll !i)r h.ll'I.1!1_ alld s:a~~i11aI recall.
the Ro: emcau C orlnwi-c".0 1 Rctall aevetopmtni'~, hIcc'.l`.Cs i:ould 1`k)1Cn11;II['. he achie\ed
here
t1 es:Temple C its 131% J. north X11' Valle\
The area to the norih and ~tiest of the V1 site and south of the railroad tracl.s appear to
be occupied h.. ianptf inciustrial users. The land is clucslion, sL'on1,~ in an ",irphaned"
portulr of 1 1 -Ionic. It is isolated front the rest ail Ill %Ionic n~ hoth the Eaton A "ash and
lh<' nl(rn !'aciiic railroad tr ick~. It ~~c uld thus seen,. LO he id ill I% suited for a join[
pw%ers developmem agreement. similar t,) uhai %nas utilized in the c:anstruction of the
Monicbello Tovm Center. If it loins de\ clopment aurcement hc:ween Rosemead and El
Monte were slLned. all five of the substant:%c proiect ohiccii~os c()uld ;till be realized.
And. because of the presence of the Eaton ash and the l_'ninn Paci:ic railroad tracks.
mam' of the noise and air pollution ci ects ofcunstruction \~ould ne isolated from
en in the absence of a iciini dL:',elopmeni aurecmem. Four oi*th: 11\c project objecilVes
.lid be realized h\ constructinL,, at this site.
\o sensime reccpioi's are adiacent to this area
\mse from rail tragic probably :iirraL\ e~r~.lis c,;pos tre standards 11 the retail
.;c~elorment could he ccrostructed in concert \vith Alar:le;la 1_ orridol Last-related
l~•~~I"111'. Ut ill': tali tr'.hl.~. 111(: It~l .i1C::t ~r; ii~11:1: Cl)L!lit acl!I:Y;IC 1'~CTllccd h1'
cnnstructinc a l:u"_t' retati a':~'tlclrmenl here
I'hc "Trap and Sheet" Site
Four of the fl VC sttbstanw, e project objectives listed on p. 2-6 of the revised EIR can be fully
realized even it the Wal-Mart Supercemer de:~eloptTtier.! +~tre to mmlr out;idt (!the city s
boundaries. Hence. iimitinu the a'tterrativ.- analysis rroccs-.:,dei\ to ;ices ~mlilin the city of
Roscmo-ad can be iustilied oniv if nroleci u~ltcilt e 01. "I'?ro\ i"iiw,' :i v:1r1Ct~ of :1}: uenerating
is U0, he Ll\•.'tl pr1\'ilC_rd statllu I1 C.. it tilt 0111c! tl~ aattCl r:'illccl o!hJc:,mcs are mercl%
dreSsini-, to ohtect!vc and onlt ;1 Crt3t1' allC'aAt1~-'~ s.ich as InlLr-civ, d.nelopment
.1 !'r .?T1t11tF or aline\ation '11 adiacent t:oun!\ lands are :c' i,c ~!einl:i:a:.d in,nl considz.-ration
wlthOL11 conducting an cn\ ininnicnial impac: tinalvsiz~
TK-13
(cont'd)
If % e reject the aSSumpt;on that pro.%:c! (I~~l:"C't!~ C lrl~ 1! I'. I .L'O'CI ~latitti. LInd ii NAv ;1CCCpt the
p(l~~lt?tllt~ i~I . CC:IL~ C .{C~ cll)pmClll :11?rl'(l Cl: a~ !ii''1:: .th,' 111 a1 i:'•'.1':il ,i.:.liI onal !ncatinn
ca?'. 1'r ~i'r!51Cicr.'d.
11
Todd Kunioka, Page 19 of 20
shuoun range. west of Rosciltead Bl--d and south of the Poni ,n:1 1'rLt%.n% his parcel is lame.
flat. and isolated from an% residential uses or sensitive receptors.
Althou-h this site has a I ,outh El Ivialltc nlaiiim_ address. the land fuel! remwns in
unincorporated Los Angeles County. Primar% ac:esc WOUld he from Rownivad Blvd. The lack
Dfncarh'• ;Somes woula~ntinimizc the environnlenial impacts on adlacent people. both during
con;tructicn and dUnn operatiOn
Tl~e site aldt fall under the catevon of land targeted bti Ren. 1 {iide Swiis' San Gabriel River
\ atersheu ie'_lslation previous noted: however. bCCULI C tits :L[rTC11t site LLCC is not conduci.e to
1iSpe*Ce: outdoor recreation. curstructinc a retail development Ilcrc «'M toot nec~ssaril~ h:
inc~rs;steat X10th the ; ~1slatiL:n'~ intcnt. Indeed. xith carci';li piannill_. the petal] deLtlopment
aou,C f e 3i:Rnipil~l: 4t'f11:. >7:I1Lilt31't4)11511 ..moro,~ im, d11;i .11?l:;lltlC> ~1~Q::>Cl~
lisp a, actn i *,o the .,tali ur.~l,lpnlcnl
Ll SUM, a curcor~ anal 5fS Rfthis parer! sl: gists the no;tC 1u:al to ach!c'. r :iiosst. 1 f not al i. of the
prolck.:I's suhstanti e Ot)jC:II'.CS N1]!1C 1111tILatim-, .u Icjsl sonic of the cn, lrowncntal r:'l--~cts :i the
project »ere to he constructed at the trap and skeet ranee location instead of \VGR. Were the
Lalui to he arme\C6 ti~~lll i_o~~ \nLCies aunlN .::fi tier sLlbstanllvc 17r()icc: ()hIee:ives could he
St \1N1,\R)
ile revised E-- 'R remain= wuefui;-.:n:ideuuzie. I1 does Not :s,ldreNs -%-hcluropcration of the
,roj-k)s::cl SL!perc::r:tcr. nor dots 11 make a ,cricus ::'fort at connnar;llg the potenual for attaining
nest ' if not a111 of the proiect's mated mbsLantive nbiectivL. %%hilc ~uhstantiall~ lessening or
'llnliliatillg at lcas: Sonic of Ins SICIIHIC3111 C!1:~? thv nr: C : %kLfL Ci IItit :1C1Cd 31 1 location
ether than the V%'GR bite.
B\ failing to conduct this aralysis. the rcti iced FIR fails to nleet 01C (I-J."A rcatltr _ment fox
pro'~iding the public and decision makers %kiih suf i:::%!lt infur^atit~t lndrr~t.tnd the
.:nrnedtate and reas~'r.~hl' tilr~sC'rahle ot, t ,,mmCrCi i Retail
l :a:C'r Jus;,,nc:1..11 lilt OR ,!liC li also laity it, pji)%idj' the i uhhl - lieu Jecision makers
~1':tl~ tiL.Itie1~:1? IniUf[natlt'•:; u! •.i~...:.1[~11 .'.I...IIC :1::.... , .~•.........:i:; ta. j`fD;CC: JI a1i~
location inner than. IIle 'A t.ih :tC.: :l1oklan a cart :17:1:1 sly Slt'~,C>t~ Ili;i'. there are a number
! U::17t:3I1~ tCa_S:f•iC 311~rnali'•'c legations %%lier: the nr r,:c'-oL1l ± he i,~ll~IrLll'lCd other than at
'til IZ
For these %asons. i U1721' i171C C It` I'i:tnnin' D)Dar:1110:11 .-Ind :lic Cw- C oun'.:;' 'elUsL to "rilt\
,he revised EIR for the SLipercLn?cr.:zn,' TIC- ::thcr r:colllnl_nd tha: -\pp:led !"anniri_L'. In, conduct
..:u.orC tho-ou`,ll enviro.1111Cnt.lt ;1111 aC'.:lt1:ll.•Sl~. :.m);;1cT 111111 '.h;]l ably lU fulfill the
latter and srirll of tht! C'EQA 1a%+ "roduce a \211io if-nri;-nta; :llirli i rl'?o!. fur this :?roivc:
TK-13
(cont'd)
TK-14
Todd Kunioka, Page 20 of 20
1UtIltI IIF:'' 10 !1OV 60T the I'CCord that. C. C11 tllilll`'Il I j t!%: IhuII I;1;St11 ,:j and pro,,
`-krit ten comments. compkn %kilh m% Cul'Cllt Ill;tdinu iddr"rj at t:1C icc`t1111L' Il1CCtIIIL :011cciming,
the preparation of thr ori,.iinal FIR. ;md ca n thuuzh 1 IcStilicd at the i'Iallr,!n,.~ C ommission
n1Ca1n'a tilal C JIi~IUC"CU the t)r1 111tH I-.1R. I was i. pparcrill% NO -1 on it,,: 1;.11hm-, 'iil o re plC to
be iolitacteJ wheel the rC` izcd FIR \4as relca,cd I nCc.1cc rC!\ i;ion :I L';:C i .lrt to !nlQrm illt
of (he r leasc of the rel.l,ed LIR and t.)Cilic comnlkfnt clcadhllt
Sinc~rci~.
TK-14
(Cont'd)
Todd Kunioka, Letter 2, Page 1 of 17
• _ 4r~tc.
Todd Kunioka
9400 Wells Street
Rosemead. California Ul 7-170
S ~<o~cmber 201)5"
MI. Brad Johnson
Cit:, of Rosemead
8318 Fast Valley Boulevard
Ros=tead. California yl 70
Dear Mr. Johnson:
I have re,. iewed the revised EIR prepared b~ -\pphed Planning. Inc.. for the proposc-d "Roselnrad
Commercial Retail C.nter." at the corner of Walnut Gm~e and Rush Street. In nit opinion. the
report i.s dcticicnt and does not contpk with the la\%. The cite should NOT certify, the EIR ;us
.,.~r,tt-+lete.
I'!casr n.;idcr the follo inc comments in el aluatin-, the revised FIR.
ThL Caiifornia Ell-•iromnental Qualh Act [C1=QAj. section 1002, say's "that public agencies
should not approve projects as proposed if there are feasible alternatives or teasihle ninjeation
measures avai:able whicb would substantialiv lessen the significant environmental effects of such
proiect "
Sintilariv. the CEQA guidelines [sec I _'60, +a d requires that -'.fin EIR shall describe a range o',
reascmahle alternatives to the nrc.iect. or the location of the project. which would feasibly attain
most if the basic objectlvcs of the protect but \wuld avoid or substantiall\ lessen any of the
sl~nlficant effects of the project. and evaluate the comparative merits of the alternati\es"
rntpha;is added t.
Farther. paragraph 1bI of sec 15126.6 saes that alternatives must be considered •'.ven 0 these
alternati.es could impeded tip some degree the attainment of the proiect obieetives. or would be
morn cc stl~.
Flnall}, sec ! 41 o u.'the C-EQ:? •_.,uitichnes require, an FIR to "disl tlss ,:wltutativc impacts Ot-a
project... The discussion of C Ef►A auidelines on the C alifornia FrIvironnienta! Resources
E,.aluatlon Syslem 1CF-RI1` 1 website. Into: ccre~.ca.,ox topic cla la%\ cecrl gwdC1Inc art'J.httnl
notes that the lead a2encv should include amoni_ , untulatl e impacts "reasunahl . anticipated
tll1Ul'e ;t,:t1\ IUtS "!'a protect or associated Mirth the prol-Cct. In particular. 'i a wwr: ctiviit • "IS
reasonahl,, foreseeable consequence of the initial pro.iect- and if ":he future action ,vill he
,Ztcnificant to that it will likely' change the scope or nature of the initial project or its
11
u
Todd Kunioka, Letter 2, Page 2 of 17
:nvironmentsl effects." then it must he addressed in the projr.ct EIR.
Ille revised DR does not meet these legal requirements. and so should not be certified as
' tlntllett Before a tidal decision can be made concernlna, this project. the public and the cite
:ouncil need additional information concerning the impact 01"2-1-hour operation of a Wal-blan
Supercenter. and the public and c}"- council need additional informatiun concerning the extent t(,)
' % iiich una\ oidabie en\ ironmenial impacts could he reduced Or avo}ded hy building the project at
,afferent location
11
FAILURF TO ADDRESS 24-HOUR OPERATION
' I he revise E[R dues not address the impacts t[Zat \\ould result tiolll '4-luaur nperatiotaN ' the
Supereenter. All other ti'l al tilart S iperceniers in California operate on a -24-hour schedule. As,
iar as ::in be d:termined. all W'al-Mart Supercent(:rs in the nation operate on a 224-hour schedule.
the Rosemead CI .
' " Iirilark. haled uPf,n testimony by Wal-]•lari'~ rcpresentati\"es hefor.- I t\
• kim:dal-id ko ennead Pl:Lining C Ommission. it St- S clear tliat lhC SUpCTCetltCr pT0j)u5td fol"
GR Ill littempi to conven to -24-hour operation as soon as the ujvL:er\ coillp,~nent of t}7c
pr,tiea conipleied. For ~xampic. Wal-Marts spokesperson. Fcter Kaneios (spelled. -Canelos'.
in the hearing transcripti testified before the Rosemead C}tv COLincil that "once this store
necame a supercenter. we would -want to... have it operate :-t hours" i p. 07 of transcripi from
' the September'. 2004 Cit\• Council meeting. Mr. Kanelos later stated, -*\%'e're making a
:1i-nificant in;tstmem in this particular store \\"}th the intention of it becoming a supereenter. do
\\e Would need to have it br able io operate on a'-I-hour basis-- (.p. of the transcript).
' Cin n. 28t' of the hearing' transcript. %ir. Kanelos continued: "But once it becomes a supercenier.
+e Mould need to be able to operate that (store) - hours."
' _in the basis of thi<. record. there is no \caV to avoid drawing the conchisi(:1n tliat 241-1101.11
-iteration is a -reasonabl\ iurese:ahle consequence of the :nlual pro-ioct.' Eyer-1hul11 i 1 [he
r„ord indicates that Wal-Mart does not intend to deveiop this pn>_lect as a superc,nter. and
' ,\et-\thin,-, in the record s1,102ests that 24-hour operation i. the natural ci~nsequeilce Of
c,nlaru_tine a al-Mar superccnter. The impact of 24-hottr operat}cin should thus br full% as-,rd
prior to certification of the EIR. To do less would be to Ignore the ('F(IIA _auideilnc;.:+•hich are
h,msel\es ih, result :)f decades of ietaal analysis and preccdznt.
I m-i'RE To ADLQl--1TELY CONSIDER ALTERN:1 FIVE LOGS.TIONS
%-llo!.ir operation issue. the other major sh0i"tcumin_ i?f thr 1"c\ fled) 1R i5 :hat
lnlproperl\ i`_nores Icasihle alternative locations to die pioposed Walnut Grove A%enue :lnd
Street [WtiP J site Several potential alternau\e locations identilie.l in the revised EIR'bu
t.' "1111 L- it? am-1 thuj not Cr(,\ I,.11iY_ thr ~lilhllC r dC~LI.'ll alat:erti ~l'llh
1
_C
Todd Kunioka, Letter 2, Page 3 of 17
surficient information to weigh these alternative locations auainst the NVGR site). would appear.
(in initial review. to have the potential to meet most, if not all. of the project's ohjectlves.' \,vhiie
Slnlultaneousl\ having the potential to "substantially lessen" at least one of the otherwise
uuaN oldablc ":~i_ni ticant environmental effects" of the proposed project. The', shrnild he
Albjet:tr:I t O "Lill FIR. before an\ final decision on the WC.iP. site is made
The potentiai alternative sites identified in the revised EIR but not \et subiected to full impact
anal\ sis are discussed below. followed by a brief discussion of potential sites not identified in the
revised FIR but still potentially feasible locations for this development.
The Robinson's-May Store in the Montebello Town Center
(Hereafter referred to as the MTC site)
The revised EIR lists the site of the Rohinson's-Mai store in the MTC as a potential alternative
site !`or the Wal-Mart development. It notes the likelihood that this site could be acquired
because at Clle recent merger of the parent companies to Rohinson's-.,May and Macy's [pages
1 1 ind '-12 of the revised EIR]. Both stores current[\ operate in the NITC. but it is unlikely that
the n,er_e,a corporation \vill want to retain both in operation.
The MTC site ,gems to offer ;real potential for meeting each of the project objectives k%hile
:ir'UI1.1ne+~u~l~ Chminatine or substantially reducint? at least some of the adverse environmental
el.C, . as ~ tilatC.'. 'A 10'. the WGR site. `
tiuitahilih of the NITC in (comparison to the N\GR Site
1. Construction of the "Rosemead Commercial Retail Center" at the 1VtTC site would be at least
as effective at achieving the substantive stated project objecti\es a: would be the construction of'
the prefect at WGR.
A. Of the six proiect obiectives noted in footnote i I ► below, on]\ the first five are
suhstantiv e obiectives The sixth stated object ve i procedural: baslcall\. it is 3taun_, that
tale prulert MUST be consistent xvith the iav. It thus goes -Xithout say 1n1: that am- project
'The orc~'vct's six objectives were listed on page 2-h of the revised EIR. The objectives
are [quoting from the revised EIRI: I t Create a new mix of retail commercial users responsi~ e to
City and re,-,ional markets: 2) Provide retail: commercial uses to ser\ ice the needs of residents: I i
Increase economic benefits to the Cite through job creation: 4) Augment the Cit\-*s economic
ha.e h\ llrnt]ding, a varietti of tax ;generating uses: 1 Pro%ide retail commercial development
compatible with vicinity land uses: Cif Ensure development of the project site in a manner
a,n>tSlClll wall pull, e~. +hfecUt es. and regtllretnC)11S of the it\'s t_ycncral Plan. Redevelopnlent
I':,111 arnl Zonin, t.)rdillancc Title Of the Llunlc1p::1 Code).
N.L► _ of 17
Todd Kunioka, Letter 2, Page 4 of 17
eventuall% approved b% the city and upheld following any court challenges will meet
project nh(ectn e 16).
B. Of the five remaining objectives, all could be achieved by building the project at
C. Objective [development compatible with vicinity land uses] can be more fully
achieved hw constructing the project at the MTC site rather than the W tR site.
The X-11 C site would replace a currentl-existing major retail operation that might
otherwise stand vacant with a similar. though somewhat larger. retail operation:
the WGR site would replace open space with a major retail project.
The \9TC site would develop a tnajor retail project adjacent to other retail stores.
All of its neighbors would be either retail or customer service uses: the %VGR site
would be placed in a location where no other retail uses exist. Its neighbors
would include residences. a school, office space. and a golf course.
II. Exposure of residents land. especially. sensitive receptors] to pollution. both daring the
construction and the operation phase of this development would he suhstantiall% lower at the
MTC site in co niparisnn to the WCTR site.
A. MTC is relativel' isolated from any residential areas. I-or the rnost part. land to the
south and east is open space that is neither occupied b\ nor utilized by people. The land
to the south is [l believe] privately held land with little or no permanent residents, nor is it
regularl occupied h~- Nvorkers. The land to the w-st is mostl% a tliood plain that is
t►nutilized h\. the public.,
B. 1'lic f"e\~ residential properties that are located within mile of thr NIT C site ill still
he separated b\ apprroximatel., 600 horizontal fret and a substantial almude difference. so
even these homes should be exposed to much lover ie.els of noise. dust. and other
pollution than would residents living closest to the WGR site.
C. The Draft EIR treats all noise exposure equally. nut clear]\' noise exposure to
=Note: The flood plain of the Rio Hondo River ma_-, fall under the cate2or% of land
targeted by Rep. Hilda Solis in PL 108-42. but so could be WGR site. This le_islation aims to
identity' and develop lands to their full recreational potential in an area that is (generally lacking to
opportunities for dispersed outdoor recreation. Both areas are noted in the National Park
S,fr\ ice':, Au,_,ust 2005 newsletter Jocumentina the SEW Lrn;i .Ur,tuzle;r,z~
S.VeC'lili ;tiesoui-i.eSrudl (see hitp' tN\t'~~ npS Qt~1' ?wro'sanuabriel.'tian Ciahriri SR ne%ks=.pj1:
r i' r inclusion of the l'o Hondo River watershed. P. ~ for inclusion col-the proposed Wal-Mart
ite in Rosemeadr.
1'a2e 4 o! 17
Todd Kunioka, Letter 2, Page 5 of 17
residential addresses that would occur during construction at WGR would he much
_ureater than noise exposure to residential addresses that would occur durirn, CrlnStrUetiUn
at NITC. Mininuzing noise exposure to people at home should take precedence over
no1SC exposure to people in a parking lot -vyalkinp to or from a shopping mall
D This distance separation is particulady important if'operation and or deliveries were
;n he can a 24-11Oulr basis. Noise and air pollution from idling trucks would he part cularl-,
intrusive :iuring overninltt deliven• hours. Althouah there may be "promise," today to
av+lid overni-zhi deliveries. pressure frorn NITA. ac, MD. and the public at lan. e tcl
address reinonal coriLesiion issues mean that it is -easonabl". foreseeable" ilia, truck
deliveries to any new major retail development will occur on a 2-4-hour schedule.
E. Light and LIare considerations will also be a factor if 24-hour operation were to occur.
Not only COUIJI it disturb the dark skies of nearby residents. but it could also affect the
operation of the Monterey Park Observatory. %Nhich is one of only two municipal]y
operated public ubs:rvalories. and is located only about three riles away front the \VCiR
+lr NI FC site..
F. There are no sensitive receptors [students. athletes. or the elderly] located in close
pr,-)ximiiy to the MTC site.
The NfTC site t~; over I mile away from Eldridge Ric: School. %l, hereas the WGR
site is direct!•, across Rush St from Eldridge Rice School. ITC :s also over
miles a,va., from Ruger Temple School. whereas WGR is less than a mile away.
Both schools are sites with "sensitive rec- pLors" (athletes and children under the
age of 14]. In addition to the ^_,neral student population. the fields either un or
adjacent to both schools are utilized be athletes unaffiliated witli either school.
Soccer r_lrt~ers Julize Rice School'--. Iield on most weekends. while hasehall.
i+u;thall. and other titl(+rtJ are played on the llcld youth ofTe:nple School.
As near as 1 can determine. the school cio+ o,t to the \ITC site v\ould he Don
Bosco T:chnical High School. Students on the athletic field thcrc wott{d appear
to be about , ol'.c mile west-nnrif:~~~a from the \1TC site. Ilence. prevailing,
winds w111 hlov pol!utants well axay from this field. .11so. being, of hieh school
al!r. most tudenu ill not fall in the catet,er% of °scnstti~e receptor."
Ill. .-fir Pollution Resulting from Personal .,\uiomohile Tr3%el tX uuld he Substantially Lcmer H
the Pmiect is DeN eloped at NAT C Rather than WGR
.A. The MTC site is alread\ the location Of -J maior retail d:,elopment. 13\ replacing a
current tenant rather than developim-, Open. sp:ice. ne: traffic charlues as a result of the
cunstrucuun cif a .:I-Mart Supercenter at M rC vvouid undoubtedl%- be less than Would
the net traIIic chan_,es result from huilJlnL' Oil 3 C1-1-lCntly-vac alit Iol
Todd Kunioka, Letter 2, Page 6 of 17
B. An employer located at !'`ITC could more easily meet AONID's rule 22(72 in the
manner it Was intended: Bx rrducing the emissions resulting from the use cif private
autnmobile, t;i commute w ,vork.
C. The N,1TC site is currently served by numerous bus routes [two Me-ropoliian Transit
luthurM tNITAI routes. IWO Montebello Bus Lines l1WBL► routes. and one Foothill
I-ransit FT; bus route]. Routcs run as ireyuentl% as ever, fifteen minutes. seven days a
%yeek. The plethora of bus routes serving MTC provide. both shoppers and employees
with a viable alternauye to Ulili?ing private automobiles. This substantially miticates
bath the air pollution and, the traffic congestion impacts o; building at the \•lTC rather
than the W6P, s:ire. B\ contrast. the WGR site is served by a sinele VITA route. which
operates onl% on weekdavs. and only at hourly intervals during "normal" business hours.
Further. \1'1" has repeatedl, suggested either canceling or modifyinc the route. It is
ht,.!hl\ likelN that the single route that would sen-e the W'GR site Will nu ]on,(er operate as
curretltl\ laid out by the time the WGR site is developed.
More detailed information on the public transit alternatives to arriving at N ITC are listed
1 N-ITA 1-0 route [the onl\ bus mute currently servinu the WOR site] serves the
\I'I C site tram two different directions. -West-bound" buses leave the E1 Monte
Bus Station. and. after much -wanderinLl. eventually passes by the Rosemead
Square shopping center. at Rosemead Blvd and M.Irshall Avenue. 17it)se buses
then 1 'ravel west on ?Marshall .avenue. passing many residential homes. They then
iraye: south on W'alnui Grove. turn cast on San Gabriel. and enter the \7TC from
the north. "East-bound" buses orlLinaie at California State University. Los
Anvcles. lhe, tray el ea;: on He] lman A\ enue to Nevy enue. then travel north
on \cN\ AyerltlC to Valle-, Blvd_ where they :rave: east it, Dr! Mar Avenue Those
buses then travel south on Del Mar to Potrero Grandc. Thr\ turn northeast at
1'otrero Orande. Own travel -,+utth )n Paramount Blvd `cline enwrin: \iT( from
the west. Service is hourly. five-da. s a week.
%FFA rc+ute 68 link:. 4ITC to i•'tuntercy Park. East LL's Anueles. dovti-nto\,\n l.:
.Anoeles. and points ,vest. Pars of this route duplicate \.III] 7l1. and rrta\ be
discontinued at a future date. Currenik, service ti L'enerally :it lit minute
intervals. seven days a week. `
. ,,\1~mtebrll~.~ Bus Lines ,(t serves r`iTC from t~~,i~ different directtrms. From Lhe
north. \IBL CU pro•\ ides daily service at iiftc.n minute intervals from the corner
of Ci;trve• and ~ n-n taabnel Blvd In addittun. durin•a U-4zkdays. ever, founh hus
that hicks up passengers it Garvey and San Gabriel orwinates Trom the Sierra
~Iadr: `:lla cold fin: iicht rai] station in Pasadena Thus: buses tllat uri_inate at
Sierra: Madre %'illa travc] e:at on Foothill Blvd to San Gabriel 131%d. then travel
Todd Kunioka, Letter 2, Page 7 of 17
south alon San Gabriel Blvd, past the corner of Garvey and San Gabriel [where
:hr other three trips per hour originate]. \IBL 20 continues south on San iiahriel
Bli d. then hear left where San Gabriel Bled angies sharp],, to the east \,IBT.'U
then crosses over the Pomona Freeway and enters N4TC rom the north. From the
-south.:N-1B1_ 'tt ori_inates in Pico Rivera, near Gage and Slauscn. at tliieen
minute intervals. It primary travels north on Montebello Bled. past numerous
residential and commercial areas before entering \ITC from the west.
\1BL %i.! ~ri_inates just south and east of the Commerce Metroliitk station.
generall-, heads north into Montebello along Wilcox Ave. passing near Schurr and
Montebello high schools. It then serves the Montebello Plaza shopping
development before aniving at N4TC, generally at 30 minute intervals during
weekdays.
FT 260 ori,inates at the El ?Monte bus station and arrive` at !\ITC from the
east. En route. it will have traveled through El Monte and `ouch El Monte beliarl'
heading east on San Gabriel Blvd. It operates it roughly :0 minute intervals.
seven days a \\eCk. Since the FI Monte Bus Station is the major huh for bus
service in the Scut Gabriel Valley [Approximately 20 'VITA routes and ten FT
routes converi_,e on El Monte Station from all directions). FT 269 [and NITA 170.
\yhile it lasts) makes \ITC public transit-accessible from practically all points in
tine `;an Gabriel Valley.
D. Possible than,-,es to \1TA 5er\':~e' \ITA is considering e>aendinC their route'[ ; to
\1T('. \1TA 2C)5 originate!~ in at the La-e\;,ood Ccntrr \lall. It ,ocnerally goes north in
Paramount Bl\d. except for a detour to the Lake\\ood green line rail station. \1TA is also
considerin_, cancelin,-, or alterirn_ route 17(). and truncatim-, rOuite 68.
The eastern stum.nt of \ITA 68. nearest the NICT. largely overlaps service
already provided b\' \1131- and Monterey Park's Spirit bus sen-ice. Hence, even if
NITA b8 were cancelled, service to the NTTC location would still be tar superior to
mass transit altcrnntives to WGR.
11' 1[11:1 1-0 is altered. my conversations tth \ITA driyrrs sw-niests that at least
part of that line would he picked up by NIBI [This is Miat happened when \-ITA
eliminated the >r1tititL-l-n spur of its old r(Iutr 264. \yhicln used LO !yin larLel\ llon,
San Gabriel BI\d. ict-urinating at the \I1 C: \1L-',L picked up the Southern segment.
which is \\in\ ever•. t",urth north-bound \IBL 20 hus OD \ye.b:di\s now continues
all the \y3\ to Sierra Madre Villa).
Depending on \\hich proposal charges to MT:\ services are eyentuall\ adopted.
'\iTC' ,viii still he served h\• het\veen one and threr \1T:\ bus lines. t\yo or thre.
'MLIL routes. sod ,)ne FT route. Ser: ice \\-111 cr,rtinue at 1 `-minute intervals alai:,
Todd Kunioka, Letter 2, Page 8 of 17
MBL 20. and at 30 minute intervals for FT 7-69 and MBL 70. Should MBL pick
up a portion of VITA 170. it would likely operate at hourl-, intervals. similar to the
ficquency currently provided by MTA 170. The other 'N1 7A routes would operate
at 30-60 minute intervals. Together, these routes provide many convenient
alternatives to private automobile travel to the proposed Wai-start development.
The,, can have a significant impact on both traffic and air pollution in the vicinity
Of the proposed development. And they can definitely provide an effective w3v
for an employer at Nf*TC to meet AQMD rule 220-2.
Licht and Glare impacts will b: substantially less if the development is located at MTC
rather than GR
Because of the previottsh•-noted separation issue. and because the \.1T(' is already a
tn:►jor commercial dovelopment_ incremental light and glare pollution effects \,yill be
-ubstan!'all% less siJnificant if the pr.oiect is constructed at \7TC rather than VvGR. This
is panicularl\ the :as if operation of the proposed Wal-Mart were to he on a ,-'-hour
schedule.
\ \et Surface Street T:affi: impacts 'A ill be Substantially Less ifthe Deveiopment is Located
at \1 I i Zather Plan WGR.
The Citv's EIR erroneous]% asserts that developing the Supercenier at \\'OR %vill not
result in an, significant traffic impacts. This is because the city's definition of "impaci
is ut erly narru\ti . It considers traffic volume as a proportion of capacity of an
intersection. However. because of the dense concentration of traffic signais near the
W(IR site. volume is artificially depressed. Cars cant make it through an ittersection
before a liLht cycle has completed because the cars in front of them are blocked b% a red
Licht at the next intersection. This occurs at tiro intersections proximate to the WGR site.
North of the WGR site. there are four traffic signals N%idtin a mile segment of road: The
corner of '\Viinut Grove and Rush. the pedestrian crossWalk for Edison International. the
light at the parking lot entrance (Walnut Grove and Edison W 3y). and Walnut Orove and
Klin•!erman.
Similark to the south. traffic huhts at alnut Orove and Landis alnut CIroVe and
San Gahriei. San Gabriei and the ramps connecting, to the westbl_)und Pomona Freeway.
rind San Gabriel and the ramps connecting to the eastbound Pomona Freeway also place
t",,!:r tnfiic pals within a : _pa:: :V, ;:oUnter-1r,1tr1ti\e a~, is 111W. tiec:117. 1t appears that
the __rtJl~ct.:c.ndiuons at ,h,,sc:iose[\ spaceu trat'ti::it-nal, actually pr,\ents any one o1
iho<e Inier<L-I'iwn- M.''Llucin' tra'f" is volumes that excC:ed ~aF=1CIt''.
t ii ~ en these ;urfa x: trett concestion concerns. the presence of an cffectt 1'c puhlir transit
alternatiN ewould suostantialk• lessen the actual concestinn that WOUld re>ult from a
n,dwr mail d \elopment at \1*fC. as opposed to JcVcloPMn 'he WGR site.
Pazc S of 17
Todd Kunioka, Letter 2, Page 9 of 17
Because of the presence of mass transit alternatives. the over-taxed intersections adjacent
to the WGR and NITC sites will suffer substantially less congestion if the development
occurs at MTC instead of u GR..
VI. Construction of the Wal-Mart supercenter at the MTC would presen~e the WGR site for
alternative uses while still realizing the tax revenue increase resulting from construction of"the
supercenter. :among the potential alternative uses for the'KOR site could be:
A. The construction of a Whittier Narrows Wetlands Park. as proposed b, amigos de
Loy Rios. Such a development would he consistent with the coals expressed in the Solis
Ieuislatton noted previousl%. It would bring all opportunit} for dispersed outdoor
recreation in an area that :s uenerally lacking in such opportunities.
B. Utilization of the site as water storage, with seasonal diversions of flows from the
.alhambra Wash to percolate downward to recharge around ~,yater supplies in souther
California. This use would be consistent with the wetlands park alternative above, and
could realize l return on investment of an undetermined amount. This use would be
similar to the use of inflatable dams along the San Gabriel River to capture runoff for
groundwater recharue.
C. The construction of a mixed-use development, which could include a smaller
wetlands or developed park. medium-density housing. and retail operations that would be
less imposing, ~ and less-disruptive than the current proposal.
V11. Operation of a major retail development at MTC would avoid the need for truck-trailers to
naviuate the "u-turn' necessan to uet from the west-bound Pomona ; reeway to north-bound on
~i alnut Groyc.
Tractor-trailers attempting to service the WGR site from the west-bound Pomona freeway
would need to execute two right turns within about 100 feet of each other as they left the
trL:way and turned on to Walnut Grove. Makin.' this turn would disrupt all traffic
exittne the frcowa} because the trailer would need to block both right-turttinu. lanes at the
:op (if the ramp to make the first turn, then. tgaiii. bath rioht-turning lanes, from San
Gabriel to Walnut Grote to nayiRate the second turn, which would need to he started
essential]\ bef()re the firs; turn is even completed.
In sumrttan•. a cursory anah,'sis of the MTC site appears to present the potential to achieve all of
the stated substantive protect objectives while simultaneously providing the potential for
,°liminating or substantially reductn~u mam of the environmental impacts that would he imposed
ft Iile \VCiR site is de\eloped.
Todd Kunioka, Letter 2, Page 10 of 17
:oneiheless. the revised FIR improperly reiects this alternative from full Elk consideration. The
eascros ,-tven for this rejection. and m% response to these reasons. follox~.
1. "The \Iontehello To~vn Center is an upscale, regional mall.... The introduction ofa
discount retailer.crocer use within the existing mall could be incompatible and ha%e detrimental
economic effects on adiacent revilers" !p. --I i
a. C'lassif,-Ing the NTIC as "upscale" is without foundation. .-kmonv the three other
anchor store> [assuming Wal-Mart were to occupy the fourth anchor), only Macy's seems
to gall in the Cate0r\ Of "unSCaie." The Other tV6'0 anchors are a `ier%~yn's and a J.C.
P.nnev Neither store markets itself as being "upscale." nor do they claim to target an
"un;cale" clientele.
b. \'Iervvn's official ~keb site describes their stores as deliyerine "the rizht balance of
style. quality. and value for families.... Our pal has been and continues to he to satish
our customers' expectations hetter than the competition by oiferinc stele. qualm.
excellent set-vice. all at a good price- [See 14N11.mer%!yns.com,COrp'alltlllt us.asnxJ.
c J.C. 1) enney's official web site reads, in part. ".1CPennec stores sell fashion at value
prices. OUT target customers fall into the middle of the American population. They have
1 hWusei old income ranging from S7,0.000 to ~`,II. 00 a year." [See
c. The expressed concern over, "detrimental economic effect,- on adlacc:nt retailers if
Wal-Mart locates in the NITC is without foundation.
Absent an economic impact analysis of the sort that would have been required h:
S13 I G`6: AB 1056 [which was passed by the state leUislature in 20()4 but vetoed
by the of ernorj there 1S nO e% idence that economy impacts on other Rosemead
retailers. whether locatcd in the NITC or outside o1 rite \iTC. Wnuld he -seater ii
the supercenier %\erc huili in the 1.11 C versus if it \kere constructed less than a
mile uAa\ from the \1TC. Lit the WGR site.
.-\nc. it,. am event. "a\ oidin, deu•imental eeonorruc effects on adjacent retailers"
way not one of the statk:J proJect ohjecilves [again. see p. of the revised FIR].
so it can not he used tc` either include or exclude an alternative site.
-In order to accommodate the proposed Vl'al-\'fart Supercenter. substantial re-desjun of the
Pro ,ieci would he required. resulting in the constriction )t 'a multiple-stony facilit.' with
addiuoma'., at-grade parking provided tinder the store" Ip.
a according to -F t~l a, altern ttiLes 10 a pmpaced development must be considered
"t.cn if these alternatives wc~uid he more costly.."
Todd Kunioka, Letter 2, Page 11 of 17
b. The possibility that de%elopin_ the project at \1TC might require huil:iI _ a muhl-
I[rln _U•UClllre is not reason enough to excludi. the site from further construction. .-%s land
%alues in California increase. both Wal-Mart and other retailers have begun buildin,f
vertically rather than horizontally. For example. the recently-opened Kohl's at Mission
RoZI4 and Fretnon-L Street in Alhambra is, so far as I know. Ole on]v two-stony Kohl's store
in C'a:it~,rnla. But. because of the limited ;and area at the development's location. Kohl's
elected to build a two-story buildinu. Further, a multi-store \ValAlart 1s cenainly not
unprecedented: a a]Alart's Baldwin Hills store is a three-stony structure (see p.
transcript for the city council meeting. September 7. ?004).
c. There is substantial land surrounding the MTC site that could br developed as a
parking stnle►ure. should additional parking he needed. Phis would flee up same of the
current-parking lot for a larger footprint for the proposed Wal-Mart Supercenter. should
that be found necess:u-V.
The Los Ant_,eles Dealer Auto .auction, Garvey Avenue, Ir-l llile Nest of San Cabriel Blvd
Hereafter Refrrred to as the Garvey Situ
The Los Ancocles Dealer :auto auction site is located at 5001 Garvey Boulevard. between Del
Mar A%enue ::id ti,ul ( labor! Bottik~vard. The revised EIR says that the land controlled by the
\LICU-111 ai.)ne con" nri~cti 1 ~ 24 acres.
a ( omparison of the (;aney site to the \\GR site
1'he Garye\ site fully achie%es all project's substantive objecti\ es. and more fully achieves
,hiecnvcs and 1 of the nfuilI development prolect when Compared to WCIR.
A. \Vhen compared to the WGR site. the Garvey site is more centrally located \aithin the
city's geography. The WGR site is at the cit's far southern reaches. and many of the
residences closest to the proposed deg elopment are not Rosemead residents. I herefore.
the Gar:eN site \~ill hettcr ac,hie\c proiect objective pro idinu, retail, commercial uses
to ,erg ice the needs of residents. City residents %Nould find it easier to access a retail
development located near :hr center 01*111e cite rather than a development at the city's
frin_e~. This is narticularl% true L'I%'en the .treater frequr110• of public transportation
service to the Gan e\ site t+lten compared to sen ic; to the WGR site [A disclls 1011 of bus
access to the t larve- tine ()ours in part , II1. I-,eiow]
R. The Gar\ ey site would he place a nc-,~ retaii dcvopmnt adjacent it, rnanv other retttil
,peratlon~. on gym; of the cit\''s mail] streets. It thus ]chieves prolect obiective i `1 more
full., than the GR ~itc. which would place the retaii de\ cionmeni in at,, area where no
,111.r retad operatiOr;_. AMA
Page I 1 of .
Todd Kunioka, Letter 2, Page 12 of 17
11 Bus *~eryice n\ the Gar,,-e\ site is superior to that of the WGR site. So. like the \'lTC site.
ndeshare is more feasible at the Garvey site than it would be at W'GR. This means traffic and
pollution impacts will be less. and can be more easily mitigated at the Garve\ site versus the
\%GR. Fitz.
\IT:N 70 provides 24 hour, seven-day a week service alone, Garvey Blvd_ bet\\'een El
\lonte :uid doNviltown Los An«eles. During most days. service is at 10-20 minute
inieryals
B. During weekday rush hours. NITA 370 provides faster. limited-stop scrvice alone the
tianle POU[e as, 70.
C. The Game: Blvd corridor is scheduled for Upgrade to include Metro Rapid bus
service +vithin the next yew years Presuming MT:% follows its numherine svstem, this
\yould be desi<_nated %ITA 770. This would further speed bus travelers along tile Oai-ve,,
Orrklor. and :ase access t.~ the retail .ieyeiopment from both point: east and pointy %vest.
D. iNIT.-\ 70. anc [\+hen it ^ecomes operational] 70 would all provide a link
bet++eei'. jowntown Lk» Anueles' 1. pion Station and the El Monte Bus Station. BCAh are
mater hubs for scares of \ITA and FT bus routes. The C,ar\ey Avenue routes also
intersect with \1BL and MTA routes at most major cross-streets bet\\,een those two
d;stinaticros [Fremont St. Atlantic Ave.. Garfield Ave. Del Mar Ave.. San Gabriel Blvd,
etc 1. This means convenient bus access to the Ganev site is provided, not just to those
living alone Garvey A\ enue. but to virtually: all public trans] t-dependent people in much
of southern California.
11[ l ever -sensitise receptors" will be exposed to air pollution during the construction and
opemin,m o a superc; rater if construction We.rc 10 uCCUr at the (.Tarve\' site instead of the WGR
Sll':.
[This point is addressed in the next section, in my rebuttal to the EIR's reasons I-or
reiectim_ the Oraryey >ite from a full enyircnmental analysis]
'['he Garvey site thus +yould appear. on initial re\ ic++. to provide the potential ii~r achievim: all of
the pulicct's substanti\ e obiccti\ es at least as cc~mplctel% as ++ould development at tine WGR site-
while simulianeousk su~_Lesting ;hr abilit+ tc> reduce or eliminate at least s:lm; (~:'the _,inniticant
eM MIT1mental affects associated ~N ith development of thr W6R site.
\onetheless. the rrvise:J FIR i'e1eCt fUrther -ZtUdl l ;Ili' t IJT,, % •Vt:nue site. The
reasons iWen for this retectioll. and nn\ response-'. to
fag i-'of 1,
Todd Kunioka, Letter 2, Page 13 of 17
1. The priman argument provided in the EIR against further consideration of tile Gar\-e\
avenue site is that --WalAlart. as a private developer. has limited ability to assure that a
Ievelopabie site can he assembled through the successful purchase of specific identified parcels
it .7r] Nate propen% I.P. -h of the revised EiR].
A. if necessar\. the city can exercise its power of eminent domain to assemble additionai
parcels into a larLler single propcrt-. But it is far from clear that such a drastic sten would
ire needed
B. The Auto Auction property alone. without any additional parcels. is reported to be
1 acres in area. This is close enough to the "required" 18 acres of land [p.:-5 of the
revised EIR] that it is not at all a foregone conclusion that a Superenter can not be
constructed soleiy on this parcel.
C. As noted in the 'OTC discussion above. there is nothing magical about the need to be
abie to transplant unrevised the saute blue print that would be used at WGR to the Guru-e,,
avenue site. Altcrations io the project design would reduce or eliminate the need for
utilizing property be%ond the boundaries of the L.A. Dealer Auto :suction. For example.
building a ti.\o-story Supercenter «ould reduce the footprint of the Supercenter b\ nearly
hall. thus reducing land "needs" by 6-8 acres.
D '`','hilt build inu \ erticall< would be more costly than buildini ho±rizont;tlh, CEQA
Iscc : 1~r,.t is clean- in tatin, that the fact that in alternatike may be snore costly is not
~utfici::nt rv;lson for l'ailrng tip evaluate the impact: of an alternative.
By developinu at Garvey Avenue, the city arguos that environmental impacts would not be
reduced or eliminated. but merely relocated
In "anal zMC the environmental impacts of development of the Gan-e% Avenue site. the
revised EIR seerns to be placing greater value on the impacts here than at W`GR. For
example, while the VGR site being located dtrectly across the street trom a school is not
considered siunificant. the fact that a school is located some' _ mile 3\1a\ from the
Garvey Avenue site (and tar to the .vest. up-\\-Ind from the Garn•ev Avenue sit:.] is
considered swril scant. While the faCt that athletic competitions tsoccer matches)
involvin~_ scores of competitors are re,_ularl% held direcily across the street from the WGR
site is not considered significant. the presence of parks with little or no organized athletic
competitions iOcateci :ippro\hnatel,. : mile away from th_ G rye" .avenue site is
considered siLmificant. fhe EIR noes not apply the same standard of'>i_Mficance for
environmental effects when it evaluate:, the potentiai impacts of ie.velopin-g these two
- 'S.
The residem:et. near the Garvey :avenue site area already located 4irecth aotaccnt to
either exi! ttnu rtlall or the :xisting wholesale NIStnesSCS. altd No the m.ir Tlnal effect ot :1
[ 2 e 13 1 1
r
Todd Kunioka, Letter 2, Page 14 of 17
r _
\ ;y;-~,l,ll'I t\Ulll~i t, C`:pCLlCd to be ICJ.S S1_nttlcani than I I ; VN al-Marl ~'•Cr. '.1u111 ll] lrl
Completely lacking am' other retail developments. The EIR. however. seems to
, Ju'-_!e_t 'US1 the orposue.
'M L.iu`C 11I lhC SUp"i'lOr public transportation alternatives at :he Gare\ site in
lnparison to the W(A site. the revised EIR's claim that building here would have a
:milar- impart I p. 3 the revised EIR) on Bail} traffic trips and mobile air emissions
' sti' not nhtain.
I I The 'sm-dieast Corner of Valley Blvd and Temple Ciry Blvol
Hereafter referred to as the VTC situ
r I'!-, is location is on the far northeastern portion of the cir}'. The parcel abuts the Eaton Wash.
%k hich is a concrete-encased stream. Across the wash is the cite of El Monte. The revised EIR
a'• that direcily across the wash in E-1 Monte is hieli-density residential. althouuh judging b, die
:liellite photo. it appears that industrial or commercial uses also line parts of the EI Monte bank
the Eaten Wash, if so. the potential feasibility of developing this site would improve. This
'AOtild be particularly true If the city of Rusemead were to attempt a creative. joint-powers
' I-,. lonlmml project here. r imilar to what was done when the Montebello To,,k•n Center was
!)Articied.
' II thcrr are commercial and industrial uses along portions of the L_1 Monte Side of the Eaton
'i's :I:di. then sufficient land could be assembled to develop this prolert in such a okay as to achieve
al: 01'I11r Substantive uhjectives of the project.
Such a development would certainly require building vertically rather than
horizontally. HowC~.er, as noted in the previous NITC section. multi-tor Wal-.Mart
;tones are not without precedent.
B Such a development wyiuld also require a Joint development agreenicill "k,1111 El
\limte.
II. If the \TC site -werc developed. it would have the ad\ antage of better mass transit access than
~xouid the WGR site.
A VTC is served I,\ \ 11 A 76. with service -hours a day. seven days a week
FrLquene_.' dun ni,, most of the da\ runs betWeen ! f)-_tt minutes.
Uurin_ ~yeel~da~' rusk; hours. `'TC is scr ed by M TA 70, a limited Slidp service
IT.~ 'l, ,-h Service places the VTC site is less than ten minutes transit tune from the
1 NIOnle bus station. the major hub fair mass transit in the San Gabnei `~";aleti'.
Todd Kunioka, Letter 2, Page 15 of 17
A. pro>>innatei,, -D.! \1 I A and I'.1 FT bus routes comergr on the E:1 Monte lius mauon
' !•rom all directions. meaning that a development at VTC would have tiood transit access
:o all areas of the San Gabriel Valley. as well as points beyond.
' 1). With the exception of late night early morning "'`light Owl" service. ,JMTA 76 and 376
buses also sen•e the E1 Monte Metrolink station. thus providing convenient service to
V'FC from as far east as Riverside:'San Bernardino, and as far west as Union Station.
' VTC is served h NITA 2077. an hourly weekday sen'ice along Temple City Blvd.
% =67 links the El %lunic Bus station %vith paints north. including Pasadena.
! collectively. this means. again, that the VTC site provides a greater potential for
:'!,ieshare on the part of both employees and customers to the store iite that would not be
' .1vailable Ior the development at WGR.
111. 1 he VTC site does not appear to be proximate to any sensitive receptors. There do not
' apl)ear to he am schools. parks. retirement homes, or any ether such facilities near the VTC site.
t ).pending on the feasibility of negotiating a development agreement with El Monte, this site
i la\ or ma\ not have the potential to achieve all of the project objectives at least as completely as
tilt WGR site Because of superior transit access and the lack of an} sensitive receptors nearby.
Aso has the potential substantial1v lessen at least some of the si«nificant envirorunental effects
!.a +\ouid .occur if the development were to occur at the WGR site.
I I I"onetheless. the re`lsed EiR rejects this site without conducting a full environmental
assessment.
' 1 .`te rrimar argument presented in the revised EIR against the VTC site is the lack of sufficient
-.pact:. However, as wjth pre\ioUS sites, if the structure is constricted as a multi-story building.
Intl if construction were io (':cur across; the E=aton Wash. a lot of suf'icient size could be
' Other Potential Sites for a Supercenter Development That \N ere Not Identified in the
Revised Fill
' 1. r~ia!:'._!;+ .~'.~_C i++' t'i^I';'.';:IC :11t~p[•r~\ 11~(lc.~!b1','++`.\h~~: 1,~ lhC 1~~_+ \i:;+lltI ~~1111C~1
acre. It is adjacent to an easement for power transmission lines. B\ building a three ston_
~llper~Cii[Cr on !11: ("-:%ate lot dill 111t' ,'a ~tnent for parkinC. the Ro ern-ad
I I
Todd Kunioka, Letter 2, Page 16 of 17
Commercial Retail development's objectives could potentially he achieved here
l~ est of Temple City Blvd. north of Vallee
The area to the north and west of the VTC site and south of the railroad tracks appear to
be occupied by large industrial users. The land in question seems in an "orphaned"
portion of El \Ionic. It is isolated from the rest of El Monte by both the Eaton Wash and
the Union Pacific railroad. It would thus seem to be ideally suited for a joint-powers
development agreement. similar to what was utilized in the construction of the
Montebello Town Center. If a joint development agreement between Rosemead and El
Monte were signed, all five of the substantive project objectives could still be realized.
And. because of the presence of the Eaton Wash and the Union Pacific railroad tracks.
mane of the noise and air pollution effects of construction would be isolated from
residential areas.
Even in the absence ofa joint development agreement. four of the five project objectives
could be realized by constructing at this site. No sensitive receptors are adjacent to this
area.
'poise from rail traffic probably already exceeds exposure standards. ifthe retail
development could be constructed in concert with Alameda Corridor East-related
loherin_, of the rail tracks. the net effect on noise could actuall\ be reJuced by
.0nstnictin-, a larue retail development here.
Other Potential Sites. Outside of Rosemead
Four of the five substantive proiect objectives listed on p. 2-0 of the revised EIR can be fully
realized even if the Wal,klart Supercenter development were to occur outside of the city's
boundaries. Further. the fiftth objective can be accomplished if Rosemead were to either annex
select areas that are currently outside ofour city's boundaries. or to enter into a development
agreement with an adjacent cite to share tax revenue resulting from a development that straddled
several jurisdictions. Hence. iimiuriLl the alternative analysis process soleh to sites within the
city Of Rosemead can be justified only if project objective (4). -providing a variety of tat
generating, uses." is to be given privileged status [i.e.. if the other five stated project objectives
are inerely window dressin, to obiective I4A. and on]h if creative alternatives such as inter-city
development aureentents or armexation of adiacent county lands are to be eliminated from
consideration without conductin an environmental impact _,inal' sis
If we reiert the assumption that proiect objective i4t ht_s pri; ileLed status. and if we accept the
possihjljtN- of creatit e development approaches as noted above. then several additional locations
,;xi he considers i
( one possibility would be to ocatc div,development at the current site of the trap and skeet
Page I6 of 1
Todd Kunioka, Letter 2, Page 17 of 17
>hoolina ran«r. off of Rosemead Blvd Lind south of the Pomona freeway. This parcri is laruc.
!lat. and isolated from any residential uses Or sensitive receptors.
:hots ,h this site has a South El Monte mailing address. the land itself remains in
unincorporated Los Angeles County. Primary access would be from the Rosemead Blvd. or from
the Rosemead Blvd off=ramp to the Pomona Freeway. The lack of nearby homes would
minimize the environmental impacts on adjacent people. both during construction and during
operation. Wildlife use of this parcel is minimal due to the shooting that occurs over the land.
In sum. a cursory analysis of this parcel suggests the abillr\ to achieve most nt the projects
substantive objectives while mitigating at least some of the environmental effects if the project
%%ere to be constructed at the trap and skeet range location Instead of \ GR,
til N1N1.ARY
The revised EIR remains woefullt inadequate. It does not address 24-hour operation of the
proposed Supercenter. nor does it make a serious effort at comparing the potential for attaining
m~:,tt i it. no'all i cif the vrciieet's stated substantive objectives while substantially iesseninti or
ii hina!in at le.I~t some ofthe si_nificant etlects ofbuildim! at the WGR site.
i;,, fulling to conduct this t ial\sis. the revised EIR fails to meet the CEO A requirement for
providing the public and decision makers -vith sufii:ieni information to understand the
imrnediate and reasonably foreseeable effects of constructing the "Rosemead Commercial Retail
(.enter" at the 1A'CiR site as desiuned. It also fails to provide the public: and decision makers with
~uf icient information to reasonably evaluate the merits of constructing the proiect at any location
ether than the WOR site. even thou,-,h a cursor- analysis suguests that there are a number of
potentially leasibie alternative locations where this project could be constructed other than at
WGR.
For these reasons. I urge the Cite- Planning Department and the City Council to refb-w to certifi-
tltc revised EIR t'Qlr the yupcrcent.:. and to either recommend that Applied Planning. Inc conduct
a more thorough cmironmental impact anah•sls. or have another firm that is able to fulfill the
lc:ter and spirit of the CF(AN, lim producc a valid em ironmemal impact report for this proiect.
sinc~-rely.
Pa ,c i of I
Applied Planning, Inc. (Copyright © 2005)
TODD KUNIOKA
Letter Dated November 9, 2005 z
Response TK-1
As demonstrated within the EIR Revision, none of the considered sites would substantially
reduce any of the Project's significant environmental effects. Please refer to the EIR
Revision at pages 3-1 through 3-14. Further, as documented in the EIR Revision, the
considered sites fail the CEQA rule of reason criteria at one or more additional levels,
including the proponent's unlikely ability to acquire or control the considered sites, and
untenable site configurations or other physical incompatibilities.
The commentor proffers opinions regarding adequacy of the EIR Revision, and provides
CEQA citations. Opinions presented, and CEQA citations provided, are acknowledged,
and will be forwarded to the decision-makers. Analysis and conclusions of the EIR
Revision are not affected.
Response TK-2
As correctly summarized by the commentor, Page 1-1 of the EIR Revision provides the
following discussion:
Although the Court also found that the 24-hour operation issue was not
adequately analyzed in the EIR, this issue is no longer relevant as Wal-Mart has
provided notice to the City that it has withdrawn its request for a 24-hour
operation and a restrictive covenant will be recorded guaranteeing that no 24-
hour operation of the Wal-Mart Supercenter will be allowed without further
environmental review.
2 Mr. Kunioka also submitted a 17-page comment letter dated November 8, 2005. The content of the November
8 letter is substannvely the same as Mr. Kunioka's November 9, 2005 correspondence. Responses provided to the November
9, 2005 letter comprehensively address all of M r.Kunioka's comments, The November 8, 2005 letter has also been included
in order to provide a complete administrative record of comments received; however, duplicate responses have not been not
provided.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-191
Applied Planning, Inc. (Copyright © 2005)
Please refer also to Revised Planning Department Condition of Approval (COA) presented
in Section 3.0 of this Revised Final EIR. As stated under revised COA No. 54, which now
reflects the "no 24-hour operations" restrictive covenant:
The hours of operation of the major tenant shall be limited to 8:00 a.m. to 10:00 p.m.,
except during Christmas season, in which case the hours of operation may be extended
to midnight.
Should 24-hour operations, or other substantial modifications to the Project be proposed,
the Lead Agency may require subsequent environmental analysis. Analysis and
conclusions of the EIR Revision are not affected. Other statements and opinions expressed
by the commentor will be forwarded to the decision-makers. Analysis and conclusions of
the EIR Revision are not affected.
Response TK-3
Introductory comments are addressed in the following responses.
Response TK-4
The commentor provides a speculative comparison of realization of the Project objectives
that may occur should the Project be located at the Robinsons May/Montebello site.
Irrespective, selection of the "Robinsons-May site" would not substantively reduce the
extent or significance of the Project's environmental impacts. Further, for reasons other
attainment of the Project Objectives, as discussed below, the Robinsons May site is not
considered to be a feasible alternative site for the Project.
Pages 3-11 through 3-14 of the EIR Revision substantiate that the Robinsons-
May/Montebello Town Center site fails at several levels within the context of the CEQA
"rule of reason" criteria and standards for identification and consideration of alternatives
to the Project. Foremost, selection of the Robinsons-May/Montebello Town Center site
alternative would not substantially reduce significant environmental impacts of the Project.
At best, these impacts would be transferred from one locale to another.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-192
Applied Planning, Inc. (Copyright © 2005)
The Robinsons-May/Montebello Town Center site also fails in terms of its feasibility. In this
regard, CEQA provides guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
As presented in the EIR Revision, the referenced Robinsons-May/Montebello Town Center
site is not currently under control of the Project proponent (and for that matter is not
known to be available), and is not configured to reasonably accept the Project building
footprint and facilities plans.
As summarized above, and supported by information and findings presented within the
EIR Revision, selection of the Robinsons-May/Montebello Town Center site would not
realize any substantive environmental relief or benefit when compared to the current
Project site. Nor is the Robinsons-May/Montebello Town Center site considered to be a
feasible location for the Project based on its lack of availability and physical constraints.
Opinions presented by the commentor will be forwarded to the decision-makers. Analysis
and conclusions of the EIR Revision are not affected.
Response TK-5
The EIR Revision at Page 3-12 acknowledges greater separation between the Montebello
site and residential area than would occur under the Project. However as also discussed
in the EIR Revision, significance criteria thresholds established by SCAQMD would still be
exceeded, and significant impacts realized under the Project would remain significant at
the Robinsons-May/Montebello Town Center site.
Noise from construction activities would still exceed applicable City noise thresholds, and
would remain significant at the Robin sons-M a y/M ontebell o Town Center site.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-193
Applied Planning, Inc. (Copyright © 2005)
Air pollution and noise from idling trucks are not significant Project-related impacts.
Please refer to Draft EIR Sections 4.4, "Air Quality," and 4.5, "Noise," the detailed air
quality and noise impacts analyses presented in Draft EIR Appendix D, and relevant
responses presented in The August 2004 Final EIR Section 3.0, "Comments and Responses."
As noted previously, the Robinsons-May/Montebello Town Center site also fails
considerations as a feasible site due to its lack of availability and unacceptable
configuration. Please refer also to Response TK-4. Analysis and conclusions of the EIR
Revision are not affected.
Response TK-6
The commentor speculates on potential reductions in personal automobile travel, increased
use of transit, and related air emissions that may be realized through location of the Project
at the Robinsons-May/Montebello Town Center site.
Available public transportation systems are discussed at Pages 4.3-15 and 4.3-16 of the
Draft EIR, and the Project's estimated transit demands (593 daily trips) are presented at
Draft EIR Page 4.3-43. Even assuming full use of transit systems, this would account for
less than five percent of the Project's total daily traffic. As such, no substantial reductions
in traffic or air quality impacts would result based on potential use of transit services.
It is further noted that speculative reductions in traffic impacts and air quality impacts
based on assumed use of transit systems and transit facilities is inconsistent with
assessment and disclosure of the Project's probable maximum traffic and air quality
impacts, and would be similarly inconsistent with environmental assessment and
disclosure provisions of CEQA and related policies and procedures adopted by the Lead
Agency.
The commentor's opinions will be forwarded to the decision-makers. Analysis and
conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-194
Applied Planning, Inc. (Copyright © 2005)
Response TK-7
The Project will not result in, nor create significant aesthetic or light/glare impacts. Please
refer to the discussion of potential Project-related aesthetic and light/glare impacts
presented at Draft EIR Section 4.7, "Aesthetics, Light and Glare," and relevant responses
presented in The August 2004 Final EIR Section 3.0, "Comments and Responses." The EIR
Revision appropriately reflects and responds to applicable CEQA criteria regarding an EIR
consideration and evaluation of alternative sites.
The alternatives shall be limited to ones that would avoid or substantially lessen
any of the significant effects of the Project. [CEQA Guidelines §15126.6 (f)]
Analysis and conclusions of the EIR Revision are not affected. The commentor's statements
and opinions will be forwarded to the decision-makers.
Response TK-8
Certain traffic impacts of the Project, related to Caltrans vehicle density thresholds along
SR-60, are acknowledged as significant within the Draft EIR. The Project will not result in,
nor create any other significant traffic or circulation impacts, including potential impacts
to emergency vehicle access. Please refer to the discussion of potential Project-related
traffic impacts presented at Draft EIR Section 4.3, "Traffic and Circulation," within Draft
EIR Appendix C, "Traffic Impact Study," and relevant responses presented in The August
2004 Final EIR Section 3.0, "Comments and Responses." Location of the Project at the
Montebello Town Center site (Alternative Site 3) would not substantially alter or alleviate
vehicle densities along the SR-60, and Caltrans significance thresholds in this regard would
still be exceeded.
Response TK-9
CEQA does not require that an EIR consider multiple combinations of Project
configurations and alternative sites within the Alternatives Analysis, only that a reasonable
range of alternatives be considered, as determined by the Lead Agency. The EIR Revision
document considers (and rejects) three (3) potential alternative sites, and further discusses
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-195
Applied Planning, Inc. (Copyright © 2005)
the reasons for the original rejection of the prior Ralph's Market site. Additionally, within
the Draft EIR, three (3) alternatives were considered (and rejected), and six (6) additional
alternatives (including the CEQA-mandated "No Project Alternative") were assessed and
compared with the Project. The City of Rosemead, as the Lead Agency, has determined
that this analysis satisfies CEQA's requirements to examine a reasonable range of
alternatives, with supporting reasoning for rejection of potential alternative sites from full
consideration. Evidencing available information to permit an informed choice, the City
rejected the initially proposed Project, and adopted the Project Design Alternative.
Further, the Project is that proposal described and assessed in the EIR, not some variation
or redesign not agreed to by the Project proponent and Lead Agency.
With specific regard to suggested multiple-story (less imposing) configurations for the
Project's major tenant (Wal-Mart), such a design is infeasible and would not be considered
by the Project proponent. More specifically:
• The cost of designing, engineering and construction such a store would be prohibitive,
particularly if it involved subterranean parking.
• The Project Major tenant described and assessed in the EIR is a Wal-Mart Supercenter,
which includes a general merchandise component and a supermarket component.
There are no multi-story Wal-Mart Supercenters in California. This is a function of
customer convenience. Supermarkets are generally not multi-story (if there are any
at all). Wal-Mart has determined that customers generally dislike shopping in multi-
level stores for convenience items such as groceries and household products.
Therefore, the multi-story format would put Wal-Mart at a competitive disadvantage
in comparison to its competitors. There is not the same concern with a Wal-Mart
general merchandise (only) store. This is evidenced by the existence of several multi-
story general merchandise stores in California.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 2 2 7 095) Page 4-296
Applied Planning, Inc. (Copyright © 2005)
The commentor further speculates on land use, taxation, and water storage/recharge issues
beyond the scope of the EIR Revision. These statements will be forwarded to the decision-
makers. Analysis and conclusions of the EIR Revision are not affected.
Response TK-10
The Project will not result in the need for trucks to execute "u-turns" or nor were any other
significant truck turning/truck movement impacts identified. Please refer also to previous
responses addressing infeasibility of the Robinsons May/Montebello Center site. Analysis
and conclusions of the EIR Revision are not affected.
Response TK-11
The commentor provides a comparative analysis related to realization of the Project
objectives that may occur should the Project be located at the Los Angeles Dealer Auto
Auction (Garvey) site. Irrespective, selection of the "Garvey" site would not substantively
reduce the extent or significance of the Project's environmental impacts. Further, for
reasons other than attainment of the Project Objectives, as discussed below, the Garvey site
is not considered to be a feasible alternative site for the Project.
Pages 3-4 through 3-8 of the EIR Revision, substantiate that the Garvey site (Alternative Site
1) fails at several levels within the context of CEQA "rule of reason" criteria for
identification and consideration of feasible alternatives to the Project. Foremost, selection
of the Garvey site alternative would not substantially reduce significant environmental
impacts of the Project. At best, these impacts would be transferred from one locale to
another.
The Garvey site also fails in terms of its feasibility. In this regard, CEQA provides guidance
when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003 1 2 1 095) Page 4-197
Applied Planning, Inc. (Copyright © 2005)
As presented in the EIR Revision, the referenced Garvey site is not currently under control
of the Project proponent, and for that matter is not known to be available. Nor is it
foreseeable that the Garvey site or any of the other necessary adjacent properties would be
available for purchase within the foreseeable future.
Please refer also to air quality considerations discussed previously under Response TK-5.
Significant air quality impacts at the Project location would remain significant at the
Garvey site. Analysis and conclusions of the EIR Revision are not affected.
Response TK-12
Pages 3-8 through 3-1 of the EIR Revision, substantiate that "Alternative Site 2" fails at
several levels within the context of CEQA "rule of reason" criteria for identification and
consideration of feasible alternatives to the Project. Foremost, selection of Alternative Site
2 would not substantially-reduce significant environmental impacts of the Project. At best,
these impacts would be transferred from one locale to another.
Alternative Site 2 also fails in terms of its feasibility. In this regard, CEQA provides
guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
As presented in the EIR Revision, the referenced site is not currently under control of the
Project proponent, and for that matter is not known to be available. Nor is it foreseeable
that the site or any of the other necessary adjacent properties would be available for
purchase within the foreseeable future. In point of fact, the City's efforts to assemble 18 or
mor acres at Temple City and Valley was ultimately deemed infeasible, and was
abandoned. Subsequent development activity in El Monte presents even further barriers
for such an assemblage.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCN No. 2003121095) Page 4-198
Applied Planning, Inc. (Copyright © 2005)
As summarized above, and supported by information and findings presented within the
' EIR Revision, selection of Alternative Site 2 would not realize any substantive
environmental relief or benefit when compared to the current Project site. Nor is the
referenced site considered to be a feasible location for the Project based on its current lack
of availability, as well as the unlikely prospect of acquiring and assembling the numerous
individual properties that would be required to create a site of sufficient size and
appropriate configuration for the Project. Analysis and conclusions of the EIR Revision are
' not affected.
' Response TK-13
The commenter generally identifies a number of alternative sites that should have been
considered including sites located at Walnut Grove at Mission, west of Temple City
Boulevard, north of Valley and the Trap and Skeet site. The following is a brief overview
of the physical aspects of these proposed sites.
The approximately 3.5-acre Walnut Grove at Mission site is not under the control of the
' applicant, and is not of adequate size to accommodate the Project. It is therefore not
possible to successfully complete the Project in a reasonable period of time at this location.
' No substantial reduction in significant impacts would result from construction of the
Project at this location. Localized perceived reduction of temporary construction noise
' impacts may result, however permanent air quality impacts and freeway mainline impacts
would still occur.
' Although the precise boundaries of the site are not specified, the west of Temple City
' Boulevard and north of Valley site is developed site containing at minimum large industrial
buildings. In addition to being outside of the City of Rosemead, there is no indication that
this property is available for purchase or could be reasonably under the control of the
project proponents. The City of Rosemead's previous efforts to assemble property at and
around this intersection were ultimately deemed infeasible and were abandoned.
Rosemead Commercial Retail Center Comments and Responses
' Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-199
Applied Planning, Inc. (Copyright © 2005)
Finally, the Trap and Skeet site, also known as the Triple B Shooting Range, is recreational
(park) land in the Whittier Narrows Recreation Area, under the control of various public
entities including, but not limited to, the Army Corp of Engineers and the Los Angles
' County Department of Flood Control and the Los Angeles County Department of Parks
and Recreation. The site is not within the jurisdiction of the City of Rosemead, nor is it
' within the control of the applicant. Acquisition of this site for commercial development can
be considered speculative and highly unlikely. Further, there would be no substantial
1 reductions in the Project's significant environmental impacts if constructed as this location
' Irrespective of the commentor's speculative statements regarding potential attainment of
the Project objectives through its (the Project's) siting at various other locales, there is no
' demonstrated reduction in the magnitude or significance of Project impacts that may be
realized through Project relocation. Further, there is no indication that any of these sites
could be reasonably acquired or controlled by the Project Proponent. Additionally,
' locations outside of the City fail to achieve one of the primary objectives of the Project,
which is to augment the City's economic base. Locations outside of the City also fail to
' meet feasibility criteria due to lack of jurisdiction or control by the Lead Agency. Analysis
and conclusions of the EIR Revision are not affected.
Response TK-14
' Please refer to Responses TK-1 through TK-13. Analysis and conclusions of the EIR
Revision are not affected. The City has provided, and will continue to provide notification
' regarding the Project and related environmental actions consistent with the intent and
requirements of CEQA. In the specific case of the commentor, the Lead Agency records
inRosemdicate ead C that a coommercipy al of Re the tail "Center EINOTICE R -R OF evised Alternative Site Anal AVAILABILITY/NOTICE ysis OF " (Notice) HEARING-
was
mailed to Todd Kunioka at 8400 Wells Street, Rosemead CA. This Notice was not returned
by the Post Office, nor is there any indication that it was not otherwise delivered. Public
Notices have also been posted at eight (8) public locations throughout the City of
' Rosemead, including, but not limited to City Hall and the public library.
Rosemead Commercial Retail Center Comments and Responses
' Revised Final EIR (SCN No. 2003121095) Page 4-200
Germori Lavarin-Garcia, Page 1 of 1
Mayor and City Council
City of Rosemead
8838 E. Valley Blvd.
Rcsemeaa, CA 9 1770
Subject: December 13 Public Hearing on the Revised EIR for the Proposed
Wal-Mart Development
The City of Rosemead for many years has missed opportunities to clean
lip and improve the east (Valley Bou~evard) entrance to the city. Do not
move that mistake again.
A property landscaped Wal-Mart development with the buildings set back
and with a resiouront and/or fast food establishment or. Valley Blvd. could
create a pleasant entrance to Rosemead and.replace the current weed-
infested lot that has been there for years. GL-1
Cieoning up the appearance of the city would please everyone.
Strengthening that commercial area would also be a major improvement.
Making wise decisions to oenefit the entire city is the job of the Rosemead
City Council_ 7niy one more council member needs to step up to the
pl-re and exhibit eadersnip.
Sincerer
1
Applied Planning, Inc. (Copyright @ 2005)
' GERMORI LAVARIN-GARCIA
Letter Received November 14, 2005
Response GL-1
The commentor expresses opinions about the Project, but provides no substantive
comments on the EIR Revision. Commentor statements and opinions will be forwarded
to the decision-makers. Analysis and conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center
Revised Final EIR (SCN No. 2 003 1 2 1 095)
Comments and Responses
Page 4-202
11
Brian Lewin, Page 1 of 4
Mr. Brad Johnson
Citv of Rosemead
8838 East Valley Boulevard
Rosemead, CA 91770-1787
09 November 2005
Dear Mr. Johnson:
,s'_I` zi;al
T
This letter is a response to the call for public comments
to the Revisions to the Draft EIR for the Rosemead
Commercial Retail Center (Alternative Site Analysis),
hereafter referred to as the Revised EIR.
As a citizen of Rosemead, one who grew up and attended
schools in this area, the planned location for the
proposed development disturbs me greatly. Locating such a
huge commercial project in a residential area adjacent to
a school will undoubtedly have a profoundly negative
impact upon the quality of life for both the area
residents and the small children who attend the school.
The court found the Alternative Site Analysis in the Draft IBL-1
EIR unacceptable; it is unfortunate that there are still
significant inadequacies in the current Revised EIR. It
is my hope that this letter will expose some of these, and
factor into your ultimate decision.
The Revised EIR was supposed to seriously explore
potential alternative sites, and it does so in a very
incomplete, half-hearted manner, underplaying its relative
impact on the area surrounding the Walnut Grove site and
overlooking perfectly viable and more appropriate
alternatives. The best of these, the L.A. Dealer Auto
Auction site, is the one I will focus on in this letter.
The Revised EIR bases its dismissal on the self-determine3
difficulty of acquiring the necessary land to form the
lot. It claims that because "(n)one of the identified
properties...are...for sale, nor is it reasonably
foreseeable that any of these properties will become
available for sale in the near future," it will therefore
be too difficult, time-consuming and expensive to purchase
the land. It comes to this conclusion-without ever having
made any sort of inquiries with the City or any of the
involved parties. That is hardly the action of a group
BL-2
Brian Lewin, Page 2 of 4
investigating viable alternatives. It is particularly
implausible when Wal-Mart is the group in question. With
thousands of stores nationwide and more than 1800
Supercenters, Wal-Mart is no stranger to land acquisition.
They know the proper avenues for inquiries, and the proper
official channels to go through - eminent domain, for
example - if the owners are not immediately open to
selling. Assuming none of these avenues were investigated
- and none were indicated in the Revised EIR - it can only
be because Wal-Mart was not serious about looking into
this as an alternative site.
In its "Comparison of Environmental Impacts," the Revised
EIR proposes that "The proximity of the homes adjacent to
Virginia Avenue ...is similar to the proximity of the homes
on Delta Street to the proposed project site." In
actuality, it is an improvement, considering that Garvey
is at least a commercial area and the site has been zoned
as such for decades, whereas the Walnut Grove site
required discretionary approval to revise the General Plan
land use designations from "Office/Light Industrial" to
"Commercial." As such, the homes around the Garvey site
would continue to be located near a commercial site (no
change), while those on Delta (and Rush) would now have
their homes no longer near a potential office/light
industrial zone, but instead a commercial zone, a change
that could hardly be viewed as positive.
Furthermore, while Duff Elementary is, as noted, "less
than one-half mile" away, that is certainly better than
the Walnut Grove site, which is directly across the street
from Rice Elementary, and has an entrance along a street
(Rush) commonly used by children and parents traveling to
and from the school.
Looking at transportation issues, while it is true that
the impact of potentially greater traffic on the I-10 for
the Garvey sire could be the same or greater than that of
the Walnut Grove site on the SR-60, there are significant
differences in surface street impact. A viewing of the
map for the L.A. Dealer Auto Auction site - included in
the Revised EIR - shows that its primary (if not
exclusive) access would have to be Garvey Avenue, a major
thoroughfare in a commercial area. The Walnut Grove site,
conversely, is bounded on two sides by residential
streets, one of which, as noted previously, has a planned
BL-2
(cont'd)
Brian Lewin, Page 3 of 4
entrance to the site. It is referred to as a "secondary"
entrance, and it is claimed that "delivery trucks would be
prohibited from using [it]," and even if that were to be
so, it would hardly eliminate the problem. Drivers are
forever in search of shortcuts and less-congested routes,
and it would not take them long to discover the
convenience afforded by the Rush Street entrance -
particularly with delivery trucks streaming in and out of
the one on Walnut Grove - and the Delta Street connection
to San Gabriel Boulevard, thereby leading to a dramatic
increase in traffic and pollution on those streets and in
the surrounding area.
Additionally, the Garvey site is served by a major, 24-
hour public transportation corridor extending from Los
Angeles to E1 Monte, whereas the Walnut Grove site has
much poorer and more infrequent service. This difference
means that, having fewer options available, people would
be forced to drive to the Walnut Grove site (thereby
tremendously increasing the traffic on both SR-60 and
local streets), while the greater options available to
those commuting to the Garvey site would substantially
lessen its effects on both the I-10 and the surrounding
streets.
Looking at the above-cited information, it is clear that
the L.A. Dealer Auto Auction site meets CEQA Guidelines
15126.6(f)(1)(2)(A) that only a location that "would avoid
or substantially lessen any of the significant effects of
the project need be considered for inclusion in the EIR."
And it does so in the following ways:
1) The transportation impact on both freeways and surface
streets would be lessened, due to the presence of a well-
developed public transit system along Garvey;
2) The impact of a retail development on the surrounding
area would be reduced, as in the Garvey site one retail
operation would simply be replacing another;
3) Due to the greater distance of schools and - again -
the fact that there was previously a retail operation in
that location, the relative impact on long-term,
operational air impact would be much lower
BL-2
(cont'd)
And finally, it should be noted that, as regards the six
"Project objectives" noted in Section 2.5 of the Revised
EIR, the Garvey site meets the first four on an equal
Brian Lewin, Page 3 of 4
basis with the Walnut Grove site. While as a retail site
replacing another retail site in a commercial district -
as opposed to a retail site moving into a location (Walnut
Grove) previously zoned as "Office/Light Industrial" and
adjacent to a school and a residential area - it more
fully meets the fifth and sixth, which goals are to
"[p]rovide retail/commercial development compatible with
vicinity land uses" (#5), and to [e]nsure development of
the project site in a manner consistent with policies,
objectives, and requirements of the City's General Plan,
Redevelopment Plan and Zoning Ordinance (Title 17 of the
Municipal Code)" (0)(emphasis mine).
In short, considering the clear traffic and other problems
associated with the Walnut Grove site, and the obvious
advantages afforded by the Garvey site, and the inadequate
exploration of the latter's potential in the Revised EIR,
it is my hope that you will request that a more
comprehensive review of the L.A. Dealer Auto Auction site
be perfomed with an eye towards relocating the project to
that more appropriate location.
Thank you for your time and consideration.
Sincerely,
Brian Lewin
9442 E. Ralph St.
Rosemead CA 91770-2111
(626) 579-1951
BL-2
(cont'd)
BL-3
Applied Planning, Inc. (Copyright © 2005)
BRIAN LEWIN
Letter Dated November 9, 2005
Response BLA
The commentor is expressing opinions regarding the environmental process. These
opinions will be forwarded to the decision-making bodies for consideration during their
deliberations on the EIR Revision. The analysis and conclusions of the EIR Revision are not
affected.
Response BL-2
Pages 3-4 through 3-8 of the EIR Revision substantiate that the Garvey site (Alternative Site
1) fails at several levels within the context of CEQA "rule of reason" criteria for
identification and consideration of feasible alternatives to the Project. Foremost, selection
of this alternative site would not substantially reduce significant environmental impacts
of the Project. At best, these impacts would be transferred from one locale to another.
The Garvey site also fails in terms of its feasibility. In this regard, CEQA provides guidance
when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f)(1)].
As presented in the EIR Revision, the referenced Garvey site is not currently under control
of the Project proponent, and for that matter is not known to be available. Nor is it
foreseeable that the Garvey site or any of the other necessary adjacent properties would be
available for purchase within the foreseeable future.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-207
Applied Planning, Inc. (Copyright © 2005)
The commentor also provides a comparative analysis related to realization of the Project
objectives that may occur should the Project be located at the Garvey site. As discussed
above, irrespective of this comparative analysis, selection of the Garvey site would not
substantively reduce the extent or significance of the Project's environmental impacts
Further, for reasons other than attainment of the Project Objectives, the Garvey site is not
considered to be a feasible alternative site for the Project.
Additionally, with the exception of the freeway mainline impacts, none of the other impact
reductions cited by the commentor were found to significant. Impacts to both the
surrounding roadway network and economic impacts were found to be lee-than -
significant and therefore, alternatives are not required to improve these impacts. The s
conclusions made by the commentor relating to freeway impacts are speculative and not
borne from any traffic analysis.
The commentor incorrectly cites the discretionary actions necessary to develop the
proposed project. The existing zoning on property is Commercial. An amendment to the
General Plan Land Use designation for the site, from "Office/Light Industrial" to
"Commercial" is necessary to facilitate the project.
Response BL-3
As discussed within the Draft EIR, Section 4.3, "Traffic and Circulation," the Project does
not produce any unavoidable impacts on the local roadway network. The only significant
traffic impact identified in the Draft EIR was the addition of traffic along the mainline of
the SR-60 freeway, resulting in exceedances of Caltrans vehicle density thresholds. As
discussed in the EIR Revision, transferring the Project to the Garvey site would not
substantially lessen any identified significant impacts. In this respect, the EIR Revision
acknowledges that using the Garvey Site would likely create similar impacts to the
mainline Interstate 10 freeway, which is currently even more heavily impacted than the SR-
60. As such, location of the Project at the considered alternative site will not substantially
alter or alleviate vehicle densities along Caltrans freeways, and Caltrans vehicle density
significance thresholds would still be exceeded.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-208
La Don Lewin, Page 1 of 3
Mr. Brad Johnson
City of Rosemead
8838 East Valley Boulevard
Rosemead, CA 91770
• ~s:' ~ rail
November 8, 2005
Dear Mr. Johnson:
This letter is in regard to Revisions to the Draft EIR for
the Rosemead Commercial Retail Center (Alternative Site
Analysis).
Even though I live in the northwest portion of Rosemead, I
am very concerned about the quality of life for the
residents living in the immediate area around this
proposed development, which would be in a primarily
residential neighborhood with an elementary school
directly across the street.
The court found the Alternative Site Analysis to be
inadequate in the previous EIR. I hope you wll carefully
consider my letter in your final decision.
First, I would like to introduce the relevant passages I
will address in this letter.
In Section 2.3 ("PROJECT OBJECTIVES"), #5 states "Provide
retail/commercial development compatible with vicinity
land uses."
"DISCRETIONARY APPROVALS" in Section 2.4, #2, states
"Approval of a General Plan Amendment to revise General
Plan land use designation for the site from Office/Light
Industrial to Commercial."
Using the above criteria, it is clear that the Walnut
Grove site would have to have its land use designation
changed to meet the Project Objectives #5 requirement.
Section 2.5, "Significant Impacts Associated with the
Project Design Alternative", addresses vehicle densities
and other cumulative impacts mainly as they relate to the
Pomona (60) freeway. It does not address the impact on a
primarily residential area with an elementary school
across the street from the center.
LL-1
LL-2
LL-3
La Don Lewin, Page 2 of 3
I believe the alternatives to the Walnut Grove location
have not been fully explored.
Of the 3 alternative sites rejected, I believe the most
feasible one is Site #3 at the Montebello Town Center
Mall. It meets a major Project Objective (2.3, #5). The
land is already a retail/commercial development. It is a
large building, with potential for re-design. A multiple-
story facility in a mall would not be a first for Wal-
Mart. There are some already in existence in other parts
of the country.
It is possible to re-design the building and construct an
underground parking facility. The mall is already set up
to handle traffic and has multiple entrances with signals
in place. As far as compatibility between Wal-Mart and
the existing mall, "The detrimental economic effect on
adjacent retailers" would be no worse than it would be on
small businesses in another location.
Montebello Town Center is not what I consider an "upscale"
mall, but if it were, the same people who shop there would
not likely be switching to Wal-Mart.
The impact to the 60 freeway would be no different by
locating on the mall property versus the Walnut Grove
property. The big concern is the difference in the noise,
light and pollution in the mall area (which already has
lights and traffic appropriate to a large commercial area)
versus that in a primarily residential area. The overall
pollution (air and noise, vehicular, etc.) would be much
worse in an area where people take walks, sit outside to
enjoy the weather, garden, and where children are walking
to and from school and exercising out of doors while
breathing the polluted air caused by the increased traffic
(cars and delivery trucks) due to a large store basically
across the street.
It isn't a matter of the level that is "allowed" being the
same in commercial and residential areas, it is a matter
of "should" it be done in a residential area when there is
an alternative in a nearby commercial area.
LL-4
La Don Lewin, Page 3 of 3
Section 7.3.1.3 (Alternative Sites Summary) states,
"Pursuant to CEQA Guidelines 15126.6 (f)(1)(2)(A), 'Only
locations that would avoid or substantially lessen any of
the significant effects of the project need be considered
for inclusion in the EIR.
In my opinion, the Montebello Town Center site would
"avoid or substantially lessen" the following "significant
effects" in a primarily residential area:
1. Short-term construction-related air quality
impacts;
2. Long-term, operational air quality impact; and
3. Short-term construction-related noise impacts.
Although it is true that these things will still happen,
it is much preferred that they happen in a commercial area
rather than in a primarily residential area.
I respectfully request that you re-consider the
feasibility of Alternative Site #3, Montebello Town
Center.
La Don Lewin
9442 Ralph Street
Rosemead, CA 91770
(626) 579-1951
LL-4
(cont'd)
Applied Planning, Inc. (Copyright © 2005)
LA DON LEWIN
Letter Dated November 8, 2005
Response LL-1
Introductory remarks provided by the commentor will be forwarded to the decision-
makers. No further response is required.
Response LL-2
Introductory remarks provided by the commentor will be forwarded to the decision-
makers. No further response is required.
Response LL-3
Certain traffic impacts of the Project, related to Caltrans vehicle density thresholds along
SR-60, are acknowledged as significant within the Draft EIR. The Project will not result in,
nor create any other significant traffic or circulation impacts. Please refer to the discussion
of potential Project-related traffic impacts presented at Draft EIR Section 4.3, "Traffic and
Circulation," within Draft EIR Appendix C, "Traffic Impact Study," and relevant responses
presented in The August 2004 Final EIR Section 3.0, "Comments and Responses." The
commentor provides no substantive comments related to the EIR Revision. Analysis and
conclusions of the EIR Revision are not affected. The commentor's statements and opinions
will be forwarded to the decision-makers.
Response LL-4
As presented in the CEQA Guidelines:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the Project. Of those
alternatives, the EIR need examine in detail only the ones that the lead agency
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-212
Applied Planning, Inc. (Copyright © 2005)
determines could feasibly attain most of the Project Objectives. [CEQA
Guidelines §15126.6 (f)]
Pages 3-11 through 3-14 of the EIR Revision substantiate that the Robinsons-
May/Montebello Town Center site fails at several levels within the context of the CEQA
"rule of reason" criteria and standards for identification and consideration of alternatives
to the Project. Foremost, selection of the Robinsons-May/Montebello Town Center site
alternative would not substantially reduce significant environmental impacts of the Project.
At best, these impacts would be transferred from one locale to another.
The Robinsons-May/Montebello Town Center site also fails in terms of its feasibility. In this
regard, CEQA provides guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
As presented in the EIR Revision, the referenced Robin sons-Ma y/Montebello Town Center
site is not currently under control of the Project proponent (and for that matter is not
known to be available), and is not configured to reasonably accept the Project building
footprint and facilities plans.
As summarized above, and supported by information and findings presented within the
EIR Revision, selection of the Robinsons-May/Montebello Town Center site would not
realize any substantive environmental relief or benefit when compared to the current
Project site. Nor is the Robinsons-May/Montebello Town Center site considered to be a
feasible location for the Project based on its lack of availability and physical constraints.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-213
11
Polly Low, Page 1 of 2
'tiovemher 10. 200~
Mayor and Ulty Council
City of Rosemead
383S E Valie\ Blvd
Rosemead. ( 1 91:70
Subject. Revised EI.R - Wal-Mart Project - Alternate Sites
The Revised EIR for the proposed Wal-Mart development purports to examine the
alternative sites for the proposed Wal-Mart project. The report obviously and
deliberately has avoided one pool of alternative sites. Incidentally, the repon has done a
totalh inadequate study of the three sites included in the Revised EIR.
There are a number of altemative sites within a reasonable distance of the boundaries of
the cit\ %lost of these sites would meet a majority of the project object i\ es as restated in
the I:evised EiR
I Create a nev, ntix of retaiUcommercial uses responsible to City and regional
markets.
Provide retail, commercial uses to service the needs of residents
3 Increase economic benefits to the City through job creation
' Augment the Citi 's economic base by providing a variety of tax generanng uses
Provide retaiUcontmercial development compatible v,Ith vicinity land uses
b Ensure development of the project site in a manner consistent with policies,
objectives, and requirements of the City's General Plan. Redevelopment Plan and
Zonine Ordinance (Title 17 of the Municipal Code)
The Re\ised EIR is inadequate %vithout consideration of the out-of-city alternative sites
and the effect on the health of the many persons/ sensitive receptors that currently live.
work, and exercise close or adjacent to the proposed site
Objective I should be validated by a full Economic Impact Report
Sales I ax uained vs. lost
Business Services achieved vs lost
Jobs Gained vs lost
The Revised EIR continues the pattern of the Original EIR It includes only the
information that proves the desired outlook and ignores any problem that might defeat the
hoped-for end
PL-1
PL-2
PL-3
The Croy Council did not order flit Re\•ised EIR and certainly has no obligation or need to
ribber-stamp an incomplete stud
The City Council should not invite further legal action
Polly Low, Page 2 of 2
Superior Court Judge David Yaffe stated in open court that the EIR was a sham, meant to
confuse the residents of Rosemead.
The City Council will be held responsible if it invites another legal action based on a
biased and incomplete Environmental Impact Report Don't force Judge Yaffe to declare
another "shame on the people of Rosemead.
Polk, I.o%~,
IU,Q La Presa Ave
Rosemead. CA 0 1'?0
PL-3
(cont'd)
Applied Planning, Inc. (Copyright m 2005)
POLLY LOW
Letter Dated November 10, 2005
Response PLA
As presented in the CEQA Guidelines:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the Project. Of those
alternatives, the EIR need examine in detail only the ones that the lead agency
determines could feasibly attain most of the Project Objectives. [CEQA Guidelines
§15126.6 (f)]
The rationale for not discussing locations outside the City is presented on Page 3-1 of the
EIR Revision. Specifically, the reader is referred to Section 1.9.7. For ease of reference, this
section is excerpted below.
1.9.7 Locations Outside of the City
One of the requirements for the consideration of an alternative is that it must meet most
of the basic objectives of the Project. (CEQA Guidelines §15126.6(f).) Relocation of the
Project Design Alternative outside the City would thwart one of the primary objectives
of the Project which is to augment the City's economic base. Additionally, even if
located outside of the City, the Project may not contribute to any localized air quality
impacts, but would still contribute to air pollutant loads within the affected air basin
and would still cause significant impacts on the region's freeways because of Caltrans'
threshold level of one additional vehicle creating a significant impact. For these reasons
locations outside of the City were rejected as alternatives.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-216
Applied Planning, Inc. (Copyright @ 2005)
It is further noted that locations outside of the City are beyond the jurisdictional control of
the Lead Agency, and fail to meet feasibility criteria in this respect. The analysis and
conclusions of the EIR Revision are not affected.
Response PL-2
Potential economic impacts of the Project are summarized at Draft EIR Pages 4.1-14
through 4.1-23, and discussed in detail in Draft EIR Appendix E, "Economic Analysis."
CEQA specifically states that economic or social effects of a project shall not be treated as
significant impacts on the environment. However, physical changes that could result from
economic or social effects of projects are within the scope of CEQA considerations. The
Project will not result in, nor create significant economic impacts that would result in
adverse physical change.
Please refer to the discussion of potential Project-related economic impacts presented at
Draft EIR Section 4.1, "Land Use," the Project Economic Analyses presented at Draft EIR
Appendix E, and relevant responses presented in The August 2004 Final EIR Section 3.0,
"Comments and Responses."
Other statements and opinions expressed by the commenter will be forwarded to the
decision-makers. Analysis and conclusions of the EIR Revision are not affected.
Response PL-3
The Revised EIR was prepared pursuant to a court order. The commentor incorrectly
quotes Superior Court Judge David Yaffe's comments. The Judge was specifically
addressing the manner in which the City considered the 24 hour operation. He did not
state that the EIR was a sham, as quoted by the commentor. Analysis and conclusions of
the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-217
11
u
Lydia Martinez, Page 1 of 3
November 1. 2005
Mr. Brad Johnson
City of Rosemead
Planning Department
8838 E. Valley Blvd.
Rosemead. CA 91770
Dear Mr. Johnson:
rive 't` L• i Jr1r,
First of all, please include this letter in the Alternate Site Analysis EIR Revision.
11
11
i was vel'y much against the EIR being done by Applied Planning as they were knowh to produce
favorable EIRs for Walnlart. The City of Rosemead failed the people when it did not hire all
OB.IECTIVE- company to do the EIR. I still object to the EIR revisions done by Applied LM-1
Planning. They are totally biased, It is obvious that this is something that is being hurried
through without regard to the negative effects the project will have on the residents of Rosemead.
(.Just put anything„ the people will never know.)
We certainly don't need another "mini mall". We don't NEED any more liquor sales. There are
already plenty of liquor stores in the area. Wal-Mart also sells weapons and ammunition. LM-2
The proposed bale and pallet storage would be approximately 100 feet from someone's bedroom.
This project would NOT create good design nor open space. In fact, it would occupy OPEN LM-3
SPACE.
,lust the fact that an},thing would have an unavoidable significant impact is enough reason to
DENY the project altogether. This project would not decrease traffic. In fact, it will cause traffic
to increase by 12,000 more cars/trucks per day. This project would not help to decrease air
pollution. In fact the addition of 12,000 car/truck trips per day would definitely raise the already
unhealthful air pollution in the City. Traffic would be negatively impacted for miles off the
Pomona Freeway, the San Bernardino Freeway, San Gabriel Blvd.. Rosemead Blvd., Valley.
Garvey, etc., etc., etc. These thoroughfares are already heavily traveled, and to add 11000
more cars and delivery trucks is totally IRRESPONSIBLE. LM-4
The report itself says that the project will "contribute to air pollutant loads and will cause
significant impacts on the region's freeways". And it will certainly not be able to reduce or
avoid significant impacts
The City's econornic base will not be augrricnted because the small, mom-and-pop stores \vlll
probably be forced to close This would only create a shift of revenues. There will not be any
ecollOMIC biiSe aL1Qll1Cllt,'7tlOll herelll
-111 these issues that Wal-Mart mal:zs refercner to indicate. to nlcc that this %-Vill he a 24-hour __JLM-5
Lydia Martinez, Page 2 of 3
operation. It is my understanding that Wal-Mart has amended its position (at this time I'm sure)
that the proposed project would be a S am-10 pm operation. It was very clear to me when I heard
the Wal-Mart lawyer stand up during the hearings last year at Rosemead High School and say
that Wal-Mart will not be restricted to any hours other than a 24-hour operation. He was ver\
emphatic about the 24-hour fact. That was and still is the Wal-Mart position. The report
reiterates with the word "Supercenter."
A Wal-Mart Supercenter CANNOT be compared to a typical neighborhood or community level
shopping center. Certainly Wal-mart carutot be compared to Beaches Market, nor Sav-On. nor
Rite Aid.
Alternate Site I ......Fhe report makes reference to Duff Elementary School located less than orre-
half mile from the site. Excuse me"! I Rice Elementan' is directly across Rush Street (at
Delta) from the project site. Are the kids at Rice Elementan not imporaant? How about the
kids down the street on Walnut Grove at Sanchez and `Kemple intermediate? How about the kids
at Willard, or Janson. or Williams on Del Mar! How about the kids at Don Bosco? Is it OK For
one of them to be injured on their way to or fi-om school?
i believe that a real traffic study should be conducted. The traffic study done by Applied is
unacceptable and is a total sham. It's not real. It is fabricated.
Alternate Site 2..... File report says that '-the potential for noise impacts to nearby SENSi rm
RECEPTORS would not be significantiv reduced...... What is this? Are the residents alone
Delta and surrounding streets not SENSITIVE RECEP'TORS? We will be subjected to increased
air pollution. traffic. trash, crime, noise, loiterin,,,,"dav laborers.. etc.
Alternate Site 3..... In Pasadena, the old Robinsons-May store on Colorado is now a'Farget. No
modifications were necessary for parking accommodations.
In Buena Park, the old May Co. near Knotts Berry Farm was converted to a Fedco years ago. It
was three stories with merchandise on the first and second floors, and the market in the
basement. No parking redesign.
The old May Co. in the Crenshaw area \vas converted to a Wal-Mart.
So what's the problem here''?`'`'
In addition. the report says that the Montebello Town Center is an upscale. regional mall and
retailers there seek to dra\► consumers from a different market -,ector than that of the discoum
retailer and grocery seller..... the introduction of a discount retail;'nrocerv use within the existin<_,
mall would be imcompatihle and have a detrimental economic effect on adjacent retailers.
LM-5
(cont'd)
LM-6
7 LM-7
LM-8
LM-9
Do you know what that says? It says that Vdal-Mart is a love, grade retailer. and that's ok for our
neighborhood, but not for the Tow n Center? "fhen the introduction of this discount retailigrocery
project is INCOMPATIBLE to our neighborhood and will have a detrimental economic effect on
Lydia Martinez, Page 3 of 3
adjacent merchants and small husinesses. Therefore, the project site on Walnut Grove i~: LM -9
infeasihle. - (Cont'd)
This whole report is consistent in that sites are incompatible to this and incompatible to that.
1'he noise and air quality emissions are significant impacts. The traffic is a significant impact,
not only on the neiLhborhood streets. but also on the freeways. Everything about this project has
a SIGNIFICANT impact that cannot be reduced. If all the alternate sites have significant impacts
on the people. then it would logically also have a significant impact on the proposed site on
Walnut Grove. Therefore, this project needs to be DENIED on every level.
The 34 acres on Walnut Grove. Rush and Delta Avenues was intended to for corporate office
use. That's the way it should stay. The ordinance changing the zoning to commercial should be
rescinded as it was pushed throuuh without reward to the people of Rosemead.
A corporate office park with a restaurant. coffee store, fast-food store would be a more logical
use of that property. It would compliment the neighborhood, keep the kids at nearby schools
safer, keep the elderly and infirm healthier. Corporate offices would be open fi-om 8 to > pm and
closed on weekends and holidays.
Rosemead is NOT the place for a Wal-Mart supercenter.
Lydia Martinez
197-11 N. Delta Avenue
Rosemead, Ca 91770
LM-10
cc: City Clerk. Rosemead
For distribution to Mayor and Councilmembers
Applied Planning, Inc. (Copyright © 2005)
LYDIA MARTINEZ
Letter Dated November 1, 2005
Response LM-1
The commentor expresses opinions about the Project and City review/approval processes,
but provides no substantive comments on the EIR Revision. These comments and opinions
will be forwarded to the decision-makers.
Response LM-2
The project does not propose the construction of a mini mall. The out pads that will be
constructed on the eastern portion of the site involve the creation of parcels of less than
45,000 square feet that could be developed with multiple uses. As defined within Chapter
17.04 of the Zoning Ordinance, development on parcels less than 45,000 square feet in size
are considered a "mini mall" and require a Conditional Use Permit. Additionally, Planning
Condition No. 60. states "No guns, handguns, rifles, or other types of firearms or
ammunition shall be sold from any business on the Project Site."
The commentor expresses opinions about the Project and City review/approval processes,
but provides no substantive comments on the EIR Revision. These comments and opinions
will be forwarded to the decision-makers.
Response LM-3
While the site is currently vacant, it is not open space. It is not designated as opens space
within the City General Plan or the Zoning Ordinance as either public lands, parks or open
space.
The commentor expresses opinions about the Project and City review/approval processes,
but provides no substantive comments on the EIR Revision. These comments and opinions
will be forwarded to the decision-makers.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-221
Applied Planning, Inc. (Copyright © 2005)
I I
Response LM-4
Certain traffic impacts of the Project, related to Caltrans vehicle density thresholds along
SR-60, are acknowledged as significant within the Draft EIR. The Project will not result in,
nor create any other significant traffic or circulation impacts. Please refer to the discussion
of potential Project-related traffic impacts presented at Draft EIR Section 4.3, "Traffic and
Circulation," within Draft EIR Appendix C, "Traffic Impact Study," and relevant responses
presented in The August 2004 Final EIR Section 3.0, "Comments and Responses."
Certain air quality impacts of the Project are recognized as significant due to projected
exceedances of applicable SCAQMD criteria pollutant thresholds. Please refer to the
discussion of potential Project-related air quality impacts presented at Draft EIR Section 4.4,
"Air Quality," within Draft EIR Appendix D, "Air Quality and Noise Impact Study," and
relevant responses presented in The August 2004 Final EIR Section 3.0, "Comments and
Responses."
Consistent with CEQA requirements, the City has adopted appropriate findings and a
Statement of Overriding Considerations (SOC) which acknowledge and disclose the
Project's identified significant environmental impacts.
Potential economic impacts of the Project are summarized at Draft EIR Pages 4.1-14
through 4.1-23, and discussed in detail in Draft EIR Appendix E, "Economic Analysis."
CEQA specifically states that economic or social effects of a project shall not be treated as
significant impacts on the environment. However, physical changes that could result from
economic or social effects of projects are within the scope of CEQA considerations. The
Project will not result in, nor create significant economic impacts that would result in
adverse physical change.
The commentor provides no substantive comments related to the EIR Revision. Analysis
and conclusions of the EIR Revision are not affected. The commentor's statements and
opinions will be forwarded to the decision-makers.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003 7 2 1 095) Page 4-222
Applied Planning, Inc. (Copyright © 2005)
CEQA specifically states that economic or social effects of a project shall not be treated as
significant impacts on the environment. However, physical changes that could result from
economic or social effects of projects are within the scope of CEQA considerations. The
Project will not result in, nor create significant economic impacts that would result in
adverse physical change. Please refer to the discussion of potential Project-related
economic impacts presented at Draft EIR Section 4.1, "Land Use," the Project Economic
Analyses presented at Draft EIR Appendix E, and relevant responses presented in The
August 2004 Final EIR Section 3.0, "Comments and Responses."
The commentor expresses opinions about the Project and City review/approval processes,
but provides no substantive comments on the EIR Revision. These comments and opinions
will be forwarded to the decision-makers.
Response LM-5
The commentor is directed to Page 1-1 (paragraph 3) of the EIR Revision. The discussion
states "...Wal-Mart has provided notice that it has withdrawn its request for a 24-hour
operation."
Please refer also to Revised Planning Department Condition of Approval (COA) presented
in Section 3.0 of this Revised Final EIR. As stated under revised COA No. 54, which now
reflects the "no 24-hour operations" restrictive covenant:
The hours of operation of the major tenant shall be limited to 8:00 a.m. to 10:00 p.m.,
except during Christmas season, in which case the hours of operation may be extended
to midnight.
Should 24-hour operations, or other substantial modifications to the Project be proposed,
the Lead Agency may require subsequent environmental analysis. Analysis and
conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-223
Applied Planning, Inc. (Copyright © 2005)
Response LM-6
The EIR Revision discussion cited by the commentor simply acknowledges the considered
alternative site's proximity to the referenced schools. As discussed within the Draft EIR,
the Project will not result in significant traffic/safety hazards that would affect the Rice
Elementary School, nor any other schools. Please refer to the discussion of potential
Project-related traffic impacts presented at Draft EIR Section 4.3, "Traffic and Circulation,"
within Draft EIR Appendix C, "Traffic Impact Study," and relevant responses presented
in The August 2004-Final EIR Section 3.0, "Comments and Responses."
Response LM-7
The commentor is expressing an opinion regarding the Project Traffic Impact Study. These
opinions will be provided to the decision-makers for consideration during their
deliberations on the Project. The commentor provides no substantive comments related
to the EIR Revision. Analysis and conclusions of the EIR Revision are not affected.
Response LM-8
The intent of the analysis is to discuss the relative impacts of the alternative site. The
discussion is demonstrating that Alternative Site #2 does not offer a substantial lessening
or avoidance of the identified significant Project-related impacts, and therefore does not
merit consideration as an alternative location for the Project. In summary, implementation
of the alternative would change the receptors, not lessen or avoid the the impact.
Response LM-9
The facility reuse examples cited by the commentor represent different scenarios than those
considered within EIR Revision because the referenced conversions did not involve the
conversion of an existing anchor within a viable regional mall. Irrespective, selection of the
"Robinsons-May site" as discussed in the EIR Revision would not substantively reduce the
extent or significance of the Project's environmental impacts.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-224
Applied Planning, Inc. (Copyright © 2005)
As presented in the CEQA Guidelines:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the Project. Of those
alternatives, the EIR need examine in detail only the ones that the lead agency
determines could feasibly attain most of the Project Objectives. [CEQA Guidelines
§15126.6 (f)]
I I
CEQA does not require that an EIR consider multiple combinations of Project
configurations and alternative sites within the Alternatives Analysis, only that a reasonable
range of alternatives be considered, as determined by the Lead Agency. The EIR Revision
document considers (and rejects) three (3) potential alternative sites, and further discusses
the reasons for the original rejection of the prior Ralph's Market site. Additionally, within
the Draft EIR, three (3) alternatives were considered (and rejected), and six (6) additional
alternatives (including the CEQA-mandated "No Project Alternative") were assessed and
compared with the Project. The City of Rosemead, as the Lead Agency, has determined
that this analysis satisfies CEQA's requirements to examine a reasonable range of
alternatives, with supporting reasoning for rejection of potential alternative sites from full
consideration. Evidencing available information to permit an informed choice, the City
rejected the initially proposed Project, and adopted the Project Design Alternative.
Further, the Project is that proposal described and assessed in the EIR, not some variation
or redesign not agreed to by the Project proponent and Lead Agency. Lastly, with specific
regard to suggested multiple-story configurations for the Project's major tenant (Wal-Mart),
such a design is infeasible and would not be considered by the Project proponent. More
specifically:
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-225
I I
Applied Planning, Inc. (Copyright © 2005)
• The cost of designing, engineering and construction such a store would be prohibitive,
particularly if it involved subterranean parking.
• The Project Major tenant described and assessed in the EIR is a Wal-Mart Supercenter,
which includes a general merchandise component and a supermarket component.
There are no multi-story Wal-Mart Supercenters in California. This is a function of
customer convenience. Supermarkets are generally not multi-story (if there are any
at all). Wal-Mart has determined that customers generally dislike shopping in multi-
level stores for convenience items such as groceries and household products.
Therefore, the multi-story format would put Wal-Mart at a competitive disadvantage
in comparison to its competitors. There is not the same concern with a Wal-Mart
general merchandise (only) store. This is evidenced by the existence of several multi-
story general merchandise stores in California. Pages 3-11 through 3-14 of the EIR
Revision substantiate that the Robinsons-May/Montebello Town Center site fails at
several levels within the context of the CEQA "rule of reason" criteria and standards
for identification and consideration of alternatives to the Project. Foremost, selection
of the Robinsons-May/Montebello Town Center site alternative would not
substantially reduce significant environmental impacts of the Project. At best, these
impacts would be transferred from one locale to another.
The Robinsons-May/Montebello Town Center site also fails in terms of its feasibility. In this
regard, CEQA provides guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (0 (1)]
As presented in the EIR Revision, the referenced Robinsons-May/Montebello Town Center
site is not currently under control of the Project proponent (and for that matter is not
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No, 2003 1 2 1 095) Page 4-226
Applied Planning, Inc. (Copyright © 2005)
known to be available), and is not configured to reasonably accept the Project building
footprint and facilities plans.
Response LM-10
Consistent with the provisions of CEQA, the City may decide to proceed with the Project
in spite of its significant impacts. In this regard, the previous Project approval included the
adoption of a Statement of Facts, Findings and Overriding Considerations which
acknowledged that certain impacts could not be avoided, but found that the benefits of the
Project outweigh those impacts.
The commentor expresses opinions about the Project and City review/approval processes,
but provides no substantive comments on the EIR Revision. These comments and opinions
will be forwarded to the decision-makers. Analysis and conclusions of the EIR Revision
are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCN No. 2003121095) Page 4-227
Al and Jewel Mehlman, Page 1 of 1
1055 Walnut Grove Ave.
Rosemead, CA 91770
November 7.2005
Mayor and City Council
City of Rosemead
8838 E. Valley Blvd.
Rosemead, CA 91770
As two of the many Rosemead citizens living around the proposed site of the Wal-Mart Supercenter, we urge the City
Council to substitute the site of the Robinson's-May department store in the Montebello Town Center for the present
proposed site on Walnut Grover Ave. and Rush St, This would be an excellent alternative location. This already-
developed site is complete with a very accessible location with lots of developed parking space directly off the SR60 AJ M-1
Freeway, yet easily reached by city streets or the 1-10 Freeway about 1-112 miles away. It is not in a residential
neighborhood, not near five schools, nor directly across from the athletic field of an elementary school (where liquor
will be sold at the Wal-Mart Supercenter fifty feet away).
The designation for the area around Walnut Grove and Rush should never have been changed from'officellight
industrial'to'commercial.* It is a mixed residential area, complete with a public golf course, small university (The AJ M-2
University of the West) and lots of neighborhood walkers and runners.
The substitution of this Robinson's-May store for the presently designated location would also eliminate the following
negative impacts of the present project design identified in the Revised EIR as "significant impacts associated with
the project design alternative:"
• Increased vehicle densities on the Pomona (SR60) Freeway AJ M-3
• Short-term construction-related air quality impacts
• Long-term operational air quality impacts
• Short-term construction-related noise impacts; and
• Cumulative impacts relating to traffic on the Pomona Freeway, air quality, and construction-related noise
In closing, we would remind you, Mayor and City Council, of the words of Steve Copenhaver, Consultant, at an early
Rosemead Planning Commission hearing, that the traffic noise on Rush St. is established at 1-112 decibels from
additional traffic. But trucks will no doubt come down Walnut Grove in order to deliver merchandise to the Wal-Mart AJ M-4
Supercenter, and a truck emits noise of 95 decibels. Compare this to the noise of a jet plane, which operates ai 105
decibels!
Our question to you, Mayor and members of the city council of Rosemead, is:
How many decibels of noise and pollution can our ears and lungs take before a serious health hazard exists in this
area? AJ M -5
We urge you to move the Rosemead Commercial Retail Center from the present location to the Robinson's-May
Department Store in the Montebello Town Center,
Yours truly,
AI Mehlman Jewel Mehlman
Applied Planning, Inc. (Copyright © 2005)
AL AND JEWEL MEHLMAN
Letter Dated November 7, 2005
Response ATM-1
As presented in the CEQA Guidelines:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the Project. Of those
alternatives, the EIR need examine in detail only the ones that the lead agency
determines could feasibly attain most of the Project Objectives. [CEQA
Guidelines §15126.6 (f)].
Pages 3-11 through 3-14 of the EIR Revision substantiate that the Robinsons-
May/Montebello Town Center site fails at several levels within the context of the CEQA.
"rule of reason" criteria and standards for identification and consideration of alte;natives
to the Project. Foremost, selection of the Robinsons-May/Montebello Town Center site
alternative would not substantially reduce significant environmental impacts of the Project.
At best, these impacts would be transferred from one locale to another.
The Robin sons- May/Montebello Town Center site also fails in terms of its feasibility. In this
regard, CEQA provides guidance when assessing the feasibility of alternative sites:
"Feasibility also includes factors such as site suitability, jurisdictional boundaries, and
whether the proponent can reasonably acquire, control, or otherwise have access to the
alternative site" [CEQA Guidelines §15126.6 (f) (1)]. As presented in the EIR Revision, the
referenced Robinsons-May/Montebello Town Center site is not currently under control of
the Project proponent (and for that matter is not known to be available), and is not
configured to reasonably accept the Project building footprint and facilities plans.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-229
Applied Planning, Inc. (Copyright © 2005)
As summarized above, and supported by information and findings presented within the
EIR Revision, selection of the Robinsons-May/Montebello Town Center site would not
realize any substantive environmental relief or benefit when compared to the current
Project site. Nor is the Robinsons-May/Montebello Town Center site considered to be a
feasible location for the Project based on its lack of availability and physical constraints.
Response AJM-2
Potential land use impacts of the Project are discussed at Draft EIR Section 41, "Land
Use." Relevance of the commentor's statements to the alternative sites analysis is unclear.
Analysis and conclusions of the EIR Revision are not affected.
Response AiM-3
The commentor provides unsubstantiated opinions regarding potential reduction of
impacts that may be realized through selection of the Robinsons-May/Montebello Town
Center site alternative. These opinions will be forwarded to the decision-makers. Please
refer also to Response AJM-1.
Response A]M-4
Certain noise impacts of the Project are recognized as significant due to exceedances of
applicable City noise thresholds for construction activities. These impacts will dissipate
completely at the conclusion of construction activities. The Project will not result in, nor
create significant long-term operational noise impacts. Please refer to the discussion of
potential Project-related air quality impacts presented at Draft EIR Section 4.5, "Noise,"
within Draft EIR Appendix D, "Air Quality and Noise Impact Study," and relevant
responses presented in The August 2004 Final EIR Section 3.0, "Comments and Responses."
The commentor provides no substantive comments related to the EIR Revision. Analysis
and conclusions of the EIR Revision are not affected. The commentor's statements and
opinions will be forwarded to the decision-makers.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-230
Applied Planning, Inc. (Copyright @ 2005)
Response ATM-5
The commentor expresses general concerns that will be forwarded to the decision-makers.
Analysis and conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-231
11
Celia Nishimura, Page 1 of 2
14 November 2005
City of Rosemead
Community Development/ Planning Department
8838 Valley Boulevard
Rosemead. CA 91770-1714
Attn: Brad Johnson
Mr. Johnson:
Again. I am hopeful that the City of Rosemead will read and consider the comments of
those of us who will be severely and adversely affected by the proposed Wal-Mart project
at the Rush Street/Walnut Grove Avenue/Delta Street location. Below are my comments.
Size Limit Justification
If, as the Revised EIR states (page 3-3), a "Wal-Mart Supercenter... can be compared to a
typical neighborhood or community level shopping center...", why are all of the proposed
sites unacceptable for size reasons? Is it because a Wal-Mart Supercenter is the
approximate equivalent of 5 football fields (store only), rather than the size of a "typical
neighborhood shopping center"?
What is the problem with a redesign of the Wal-Mart stores? Why can't the Wal-Mart
stores, as well as any required parking, be housed in a multi-level structure, rather than
using so much space in a city that "is essentially a built out urban community" (page 3-3) ?
Health and Safety Issues
In addition to a questionable "size limitation" justification, all three alternative sites
are not directly across from established residences and an elementary school.
According to the EIR, more than 6000 additional cars per day will be on mainly residential
streets to arrive at the proposed Wal-Mart site. (In addition, it is projected that 170 truck
trips/week will access the site.) Many children of the Rice Elementary school will be at risk
when they attempt to cross Rush Street to get to and from school. In addition, the plans
for the Wal-Mart indicate that the store and its loading dock will be directly across the street
from the playing field of the school. The Rosemead Planning Commission and the Rosemead
City Council, by approving the EIR, with no regard for the health and safety of the students
and other "sensitive receptors" (who will be adversely affected by the air pollutants) in the
area. went against the wishes of the majority of the residents of Rosemead.
Land Usage
CN-1
CN-2
The three alternative sites were all designated for "commercial" use.
Celia Nishimura, Page 2 of 2
The Rush Street/Walnut Grove/Delta proposed site was originally designated as
"Office/Light Industrial". However, to accommodate Wal-Mart, the Rosemead General CN-2
Plan was amended to allow for the massive Wal-Mart store and mall and the land use was (cont'd)
changed to "commercial', even though the streets in the area are incapable of handling
the projected massive amounts of traffic.
Liquor Sales
The closest of the alternative sites is approximately 1/2 mile from a school
Rice Elementary School is directly across the street from the proposed Wal-Mart, where a CN-3
Conditional Use Permit, allowing the sale of alcoholic beverages was issued by the
Rosemead Planning Commission. The Rosemead City Council, without any regard for the
health and safety of the children of Rice Elementary School, determined that for public
convenience, liquor sales are a necessity at Wal-Mart.
Locations Outside of the City
The arguments for the locations outside of the city (pages 3-1, 3-2) are not justified. The CN-4
City of Rosemead could broker a deal with an adjacent city to split the prospective revenue
in a mutually-beneficial manner.
Detrimental Economic Effect on Montebello Town Center
The argument that the placement of a Wal-Mart at the Montebello Town Center "could be
incompatible and have a detrimental economic effect on adjacent retallers (page 3-12),
Wal-Mart has a reputation of driving other local stores out of business. Why would the
Rosemead City Council care that businesses in Montebello go bankrupt because of Wal-Mart CN-5
and not care if businesses in Rosemead go bankrupt because of Wal-Mart?
As stated above, again. I am hopeful that the City of Rosemead will read my, as well as
everyone else's comments about the Revised EIR and come to the conclusion that the
proposed site is totally wrong for a massive Wal-Mart Supercenter and that any one of the
alternative sites is more suitable.
Very truly yours,
Celia Nishimura
1634 No. Delta Street
South San Gabriel, CA
Applied Planning, Inc. (Copyright © 2005)
CELIA NISHIMURA
Letter Received November 14, 2005
Response CN-1
The commentor is misinterpreting the text of the EIR Revision. The discussion within the
EIR Revision is stating that a Supercenter essentially contains the individual components
that would typically be found within a neighborhood shopping center. As such, rather
than having an individual food store, drug store, sporting goods store, optometrist, and
bank spread throughout a typical shopping center, all of these goods and services are
provided under one roof. Rather than making multiple trips and parking, a customer can
obtain access to all of these retailers and services with one trip, only parking the car once.
Neighborhood shopping centers vary in size, but usually range from 175,000 to 300,000
square feet.
As presented in the CEQA Guidelines:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the Project. Of those
alternatives, the EIR need examine in detail only the ones that the lead agency
determines could feasibly attain most of the Project Objectives. [CEQA Guidelines
§15126.6 (f)]
CEQA does not require that an EIR consider multiple combinations of Project
configurations and alternative sites within the Alternatives Analysis, only that a reasonable
range of alternatives be considered, as determined by the Lead Agency. The EIR Revision
document considers (and rejects) three (3) potential alternative sites, and further discusses
the reasons for the original rejection of the prior Ralph's Market site. Additionally, within
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-234
Applied Planning, Inc. (Copyright (D 2005)
the Draft EIR, three (3) alternatives were considered (and rejected), and six (6) additional
alternatives (including the CEQA-mandated "No Project Alternative") were assessed and
compared with the Project. The City of Rosemead, as the Lead Agency, has determined
that this analysis satisfies CEQA's requirements to examine a reasonable range of
alternatives, with supporting reasoning for rejection of potential alternative sites from full
consideration. Evidencing available information to permit an informed choice, the City
rejected the initially proposed Project, and adopted the Project Design Alternative.
Further, the Project is that proposal described and assessed in the EIR, not some variation
or redesign not agreed to by the Project proponent and Lead Agency. Lastly, with specific
regard to suggested multiple-story configurations for the Project's major tenant (Wal-Mart),
such a design is infeasible and would not be considered by the Project proponent. More
specifically:
• The cost of designing, engineering and construction such a store would be prohibitive,
particularly if it involved subterranean parking.
• The Project Major tenant described and assessed in the EIR is a Wal-Mart Supercenter,
which includes a general merchandise component and a supermarket-component.
There are no multi-story Wal-Mart Supercenters in California. This is a function of
customer convenience. Supermarkets are generally not multi-story (if there are any
at all). Wal-Mart has determined that customers generally dislike shopping in multi-
level stores for convenience items such as groceries and household products.
Therefore, the multi-story format would put Wal-Mart at a competitive disadvantage
in comparison to its competitors. There is not the same concern with a Wal-Mart
general merchandise (only) store. This is evidenced by the existence of several multi-
story general merchandise stores in California. Pages 3-11 through 3-14 of the EIR
Revision substantiate that the Robinsons-May/Montebello Town Center site fails at
several levels within the context of the CEQA "rule of reason" criteria and standards
for identification and consideration of alternatives to the Project. Foremost, selection
of the Robinson s- May/Montebello Town Center site alternative would not
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCHNo. 2 003 1 2 1 045) Page 4-235
Applied Planning, Inc. (Copyright © 2005)
substantially reduce significant environmental impacts of the Project. At best, these
impacts would be transferred from one locale to another.
Response CN-2
The impacts of the Project in terms of traffic and circulation, including pedestrian safety,
are discussed within Draft EIR Section 4.3, "Traffic and Circulation," and within Appendix
C of the Draft EIR, "Traffic Impact Study." The impacts of the Project in terms of air quality
are presented within Draft EIR Section 4.4, "Air Quality," and within Appendix D of the
Draft EIR, "Air Quality and Noise Impact Study."
The commentor is providing unsupported statements regarding the surrounding roadway
network's ability to handle traffic generated by the Project. The commentor is directed to
Section 4.3 of the Draft EIR, "Traffic and Circulation," and Appendix C of the Draft EIR,
"Traffic Impact Study." Based on the analysis, development of the project, as proposed,
will not have a significant effect on the surrounding street network The analysis and
conclusions of the EIR Revision are not affected.
Response CN-3
The commentor is expressing an opinion regarding, the issuance of a Conditional Use
Permit for the sale of alcoholic beverages. The analysis and conclusions of the EIR Revision
are not affected.
Response CN-4
Section 1.9.7 (Page 3-1) clearly presents the reasoning for rejecting sites outside the City.
It is further noted that locations outside of the City are beyond control of the Lead Agency,
and therefore fail to meet CEQA feasibility criteria in this regard. The commentor's
opinions regarding "shared revenue" concept will be provided to the decision-makers for
consideration during their deliberations on the Project. The analysis and conclusions of the
EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-236
I I
Applied Planning, Inc. (Copyright (D 2005)
Response CN-5
The commentor is providing an opinion regarding the economic impacts of the Project.
These comments will be provided to the decision-makers. The analysis and conclusions of
the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-237
David Perea, Page 1 of 1
Mayor and City Council
City of Rosemead
8838 E. Valley Blvd.
Rosemead. CA 91770
Subject: Revised EIR - Hearing - December 13, 2005
For each and every reason stated in the revised Wal-Mart EIR that the Auto Auction
site is not adequate and correct, the exact opposite is true.
The site is in a commercial zone. With a minimum of acquisitions, the site is
adequate for the basic Wal-Mart Discount Supercenter. The closest school is a half-
mile away and the adjacent and close by residential housing is not expensive large
homes as occur at the proposed site.
The City Council. Planning Commission, Staff and Consultant need to take an
honest - not prejudiced - look at all three of the alternative sites.
Any and each site will improve the adjacent commercial area and be a real
jmprovement for the City, meeting all objectives stated in the EIRs.
Don't become so locked into the one site and so dominated by Wal-Mart that your
ultimate decision isn't for the greatest benefit to the City and citizens of Rosemead.
The City Council is our representative - not Wal-Mart's.
Sincerely,
DP-1
DP-2
Applied Planning, Inc. (Copyright © 2005)
DAVID PEREA
Letter Received November 14, 2005
Response DP-1
Pages 3-4 through 3-8 of the EIR Revision substantiate that the L.A. Dealer Auto Auction
site fails at several levels within the context of CEQA "rule of reason" criteria for
identification and consideration of feasible alternatives to the Project. Foremost, selection
of the L.A. Dealer Auto Auction site alternative would not substantially reduce significant
environmental impacts of the Project. At best, these impacts would be transferred from one
locale to another.
The L.A. Dealer Auto Auction site also fails in terms of its feasibility. In this regard, CEQA
provides guidance when assessing the feasibility of alternative sites: "Feasibility also
includes factors such as site suitability, jurisdictional boundaries, and whether the
proponent can reasonably acquire, control, or otherwise have access to the alternative site"
[CEQA Guidelines §15126.6 (f) (1)]. As presented in the EIR Revision, the referenced L.A.
Dealer Auto Auction site is not currently under control of the Project proponent, and for
that matter is not known to be available. Nor is it foreseeable that the Auto Auction site
or any of the other necessary adjacent properties would be available for purchase within
the foreseeable future.
As summarized above, and supported by information and findings presented within the
EIR Revision, selection of the L.A. Dealer Auto Auction site would not realize any
substantive environmental relief or benefit when compared to the current Project site. Nor
is the L.A. Dealer Auto Auction site considered to be a feasible location for the Project
based on its current lack of availability, as well as the unlikely prospect of acquiring and
assembling the numerous individual properties that would be required to create a site of
sufficient size and appropriate configuration for the Project.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-239
Applied Planning, Inc. (Copyright © 2005)
Response DP-2
The commentor is expressing opinions regarding the selection of an alternative Project site.
The analysis and conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-240
Victor Ruiz, Page 1 of 2
v c
R':Hemead, Cy
recent read L,-- :...ue_r_'s Me`. a c
21_'>Se CbServe: 1.1 Wal-Mari says about Wal-ma?
n' 7c ~:sErt .
Keen .,bs;-rvarion we =he
spa--eme-.: of Wal-Mart the Revised EiR trial :r!e, have
to ✓ _Se'
-cvenan' Sub:.e• z: tz, t ;e pr: vi _:.ns :.F =ara%r3
'c:'enanZs and agree= :nE no':rs
o operation of the -Prefect on the Wal-Mart p:oDerty :_E.,
and _~I , ::ice L rur_.__ the CLr_ssm3s season, c,mer tia:-
Mar*_ 23venaR-s and agrees to Limit :.he hours of
~DBLdi.
`::e , _:%4_s:ons of iaracrap[ below, ihdl-Mar ve'.ar, s
end ~g:eez :.C ZcLra-:l Irom opetat,nq the Pie jec- zn _:Le
-da:-Mar_ property aurinq any hours cnccr L:.ar. the ac;:rs
o:~v_ded _:^e lfieciatr-` pre:e=_r.C ser,-_ence.
authorizes addz tional hours of
operation based on additional env2roamental analysis in
Co=p.liaace with the California Envlro-ental Quality Act
?oilcwi.:g ar.y s._n auLhCWa_-ti.~__ _n:..
r.e _ecor-Jej 3 _rlwLr 1ITlenL =3.^.CC__r^ L :C rCvenalnts
Cn ~_"1cC n!erclr. _Ind Lc_~i:idL 'ia _5 DeC_.._..__J;..
VR-1
Victor Ruiz, Page 2 of 2
e_sewne_e, _eaving Rosemead wittl an emp'-f 210,0'-'-
5C. v~ Li:: C11~sQ as an evescre, no sales tax, and
!-ems empty smal_ bua-,cE where v'_ve!l
businesses in:o closure. (con
cont'd)
The R semead riLV Cou:lcll :.i-u_' waKe a-
Mart reputation across Amer--ca, and ae:._Qe t::at tr:e`.'
:r. L:_•77 ' t ex^.ose Rosemead to that d:sa5te_'.
0-7 Olnev St.
:<osemcad,~ C
Applied Planning, Inc. (Copyright © 2005)
VICTOR RUIZ
Letter Received November 14, 2005
Response VRA
The commentor is expressing opinions regarding their interpretation of the proposed
covenant regarding store operations. The analysis and conclusions of the EIR Revision are
not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCN No. 2 003 12 1 095) Page 4-243
' Paul Sa`kb `Pagb`1 of 3
' 4 November, 2005
Re. Response to Rev. EIR
' City of Rosemead
8838 E. Valley Boulevard
Rosemead. CA 91770-1714
ATTN: Mr. Brad Johnson. Planning Director
Dear Mr. Johnson:
' The impact of traffic along Walnut Grove demands a further study as now
all commercial deliveries have been diverted to Walnut Grove. The final
EIR of 2004, accepted by the City has now been changed, per your revised
' EIR., from Rush Street. The new conunercial deliveries warrants a new
study because at Rush and Walnut Grove the speed limit is 45 miles per
' hour. and the projected deliveries certainly would create a traffic hazard to
this fast flow of moving vehicles. We are told by the City. that this street is
already at full capacity with its 45 mile speed limit. This additional burden
' of accommodating commercial trucks, including 18 wheelers, plus projected
12,000 car trips would certainly alter the calculated movement of traffic. It
appears nearby school and residential neighborhood must weigh heavily on
the thinking of the developers or they would not have moved the entry of
commercial trucks from Rush Street that already had been approved
' LOCATION IN SPECIFIC DISTRICTS
The City of Rosemead has accepted the Land Use Elements, as stated on
' Page 3 of the Final EIR report of Cotton/Beland & Associates, which states,
"Land use Elements also call for the intensification of commercial
developments in SPECIFIC DISTRICTS"' Dead end streets such as Rush
and Walnut Grove do not make for prudent traffic flow. When traffic
conversions clog the traffic this leads to additional emissions from autos.
This 1986 EIR for Rosemead's change of the General Plan in 1986, has
comment from the Air Resource Board that says "We believe there \vill be
SIGNIFICANT air emissions from developments consistent with the
' update of the General Plan. We believe these emissions will come primarily
from traffic increases as predicted in the transportation/circulation"......
PS-1
PS-2
Paul Saito, Page 2 of 3
"Rosemead, is located in the South Coast Air Basin which currently
EXCEED the State and/ or national ambient air quality standards for Ozone,
carbon dioxide(CO),TSP, Particulate Matter(PM10), & Nitrous
Oxide(NO2)" The final 2004 EIR by Applies Planning concludes that the
study recognizes that the Traffic is SIGNIFICANT AND
UNAVOIDABLE. (Page 4-3-61) If this project did not develop, then
surrounding residents would not suffer from additional unhealthy toxic
emissions, AUTO CONGESTION that are known to be harmful, especially
to children, elderly and those susceptible to respiratory hazards
SHOPPERS PROTECTION DURING EARTHQUAKES
The EIR (2004 states) " The City of Rosemead is the lead agency under
CEQA and as such is solely responsible for the approval of the proposed
project"---It further states that CEQA asks these questions:
Does this project:
1. EXPOSE PEOPLE or structure to risk of injury or death from (1)
Earthquake (2) Strong seismic groundshaking (3 Seismic related
ground failure including liquefaction or (4) Landslides.?
2. Create seismic-related ground failure including liquefaction,
landslide or other seismic induced hazards.?
The exposure of people to these hazards has never been discussed in the
EIR. The comments only referred to standards required in the building code
and the need for a consultant for the building due to its proximity to an
active earthquake fault. But seismologist tell us that you can design a
building that MAY withstand an earthquake, but you cannot STOP THE
SHAKING.. We are told that this sedimentary ground will shake 10 times
more than rocky soil Their LIES an KNOWN ACTIVE EARTHQUAKE
FAULT that transverses the entire property in a N/S direction. Seismologist
inform us that Earthquakes almost always FOLLOW THE SAME
EXISTING FAULTS. In addition, this site is KNOWN TO BE IN A
LIQUEFACTION ZONE. Most serious destruction results from
earthquakes result from liquefaction, as the soil liquefies and becomes
unstable for its buildings.. This site contains both an ACTIVE FAULT
AND LIQUEFACTION.ZONE
Unaware shoppers in a 230,000(5 acres+ of building) may be seriously
injured or killed from merchandise falling, or heavy objects plowing into
them. Containers of dangerous pesticides, ammunition glassware may
become dangerous articles when shoved from their normal places. This
structure is to he constructed along a known active fault that did
PS-2
(cont'd)
PS-3
Paul Saito, Page 3 of 3
SUBSTANTIAL damage to surrounding buildings in the Whittier PS-3
Earthquake shaking(5.7 shake, almost considered a MAJOR)) that had as its 3cont'd)
EPICENTER, ON THIS VERY SITE near Rush Street In spite o these
extremely dangerous, negative elements, City of Rosemead, still insists that
this project is good for the City, because it will bring in revenue from sales..
Recent economic studies have proven that some cities DO NOT TAKE IN
MORE CASH BECAUSE OF WALMART STORES. It has proven that
many loyal businesses were forced to close due to competition from PS4
Walmart and consequently the City showed a negative cash flow to it's
treasurery. The anticipated bonanza never happened, period. We don't need
Walmart at this site. Please be advised, there exists numerous dangerous,
unhealthy, and undesirable aspects to this project, as mentioned above,
please abort this project, the gamble is NOT WARRANTED.
Sincere]
Paul S. S it , a doncerned neighbor
8361 Sierra Bonita
So, San Gabriel, CA 91770
Applied Planning, Inc. (Copyright © 2005)
PAUL SAITO
Letter Dated November 4, 2005
Response PS-1
Certain traffic impacts of the Project, related to Caltrans vehicle density thresholds along
SR-60, are acknowledged as significant within the Draft EIR. The Project will not result in,
nor create any other significant traffic or circulation impacts. Please refer to the discussion
of potential Project-related traffic impacts presented at Draft EIR Section 4.3, "Traffic and
Circulation," within Draft EIR Appendix C, "Traffic Impact Study," and relevant responses
presented in The August 2004 Final EIR Section 3.0, "Comments and Responses."
The traffic study assumed that trucks would be traveling along Walnut Grove Avenue.
The prohibition of trucks on Delta Street does not change this assumption. Rather than
traveling west on Delta Street, the trucks would simply proceed south to the main
driveway. The change in driveway access was a direct result of community concerns
regarding the potential for truck intrusion into the surrounding neighborhood and student
safety issues.
The commentor provides no substantive comments related to the EIR Revision. Analysis
and conclusions of the EIR Revision are not affected. The commentor's statements and
opinions will be forwarded to the decision-makers.
Response PS-2
Certain air quality impacts of the Project are recognized as significant due to projected
exceedances of applicable SCAQMD criteria pollutant thresholds. However, the Project
is not a source, nor generator of toxic emissions.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCN No. 2003121095) Page 4-247
Applied Planning, Inc. (Copyright © 2005)
As determined by the Lead Agency, the EIR employs accepted or established significance
thresholds in determining impact significance. It is also noted that the Lead Agency
ultimately determines the significance of Project-related impacts.
Potential air quality impacts of the Project are discussed within Draft EIR Section 4.4, "Air
Quality," and the detailed technical Air Quality Impact Study presented within Draft EIR
Appendix D, "Air Quality and Noise Impact Study." Air quality impacts significance
thresholds applicable to the Project are based on criteria pollutant thresholds established
by the South Coast Air Quality Management District (SCAQMD). With the exception of
certain adopted localized criteria and standards, discussed below, these thresholds are not
location-specific within the South Coast Air Basin (Air Basin). Based on established
SCAQMD criteria, certain air quality impacts of the Project are determined to be significant.
The Project's significant air quality impacts are area-wide or regional in nature, and the
SCAQMD thresholds are the accepted criteria to quantify the Project's relative individual
contribution to basin-wide air quality.
Potential localized air quality impacts and related health risks for sensitive receptors are
addressed at Draft EIR Pages 4.4-41 through-4.4-48, In this respect, the Project's potential
localized air emissions impacts are associated with the [then] proposed gas station
[subsequently removed under the adopted Project Design Alternative], and potential
localized CO concentrations at Study Area intersections. As discussed in the Draft EIR, the
Project would not result in significant localized air quality impacts either through
operations of the previously considered gas station, nor would the Project result in or cause
CO exceedances at Study Area intersections.
Relevant responses to the commentor's concerns regarding potential health effects of
Project-related criteria pollutant emissions have also been previously provided at Pages 3-
110 and 3-111 of the (Original) Final EIR, August, 2004):
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCN No. 2003121095) Page 4-248
Applied Planning, Inc. (Copyright @ 2005)
If approved, the operation of the Project will exceed the South Coast Air Quality
Management District (SCAQMD) thresholds of significance for three of the five
criteria pollutants, including reactive organic gases (ROG), oxides of nitrogen
(NOx), and carbon monoxide (CO). Based on these exceedances, the decision-
making body will need to adopt a Statement of Facts, Findings, and Statement
of Overriding Considerations that acknowledges the exceedances and makes
findings that essentially declare that certain benefits of the Project outweigh the
environmental impacts for the Project.
The SCAQMD advises the lead agency in addressing and mitigating the
potential adverse air quality impacts caused by projects both during and after
construction. The SCAQMD has established short-term construction-related and
long-term operational thresholds of significance which they recommend for use
by lead agencies in considering both primary or direct impacts and secondary
or indirect impacts on air quality.
The SCAQMD emissions thresholds are basically indicators of potential air
quality impacts. They do not indicate whether or not State or federal clean air
standards will be exceeded in the Project vicinity and provide no information
regarding the presence or absence of sensitive receptors. In essence, the
thresholds provide an indication of whether or not the air pollutant emissions
expected to accompany a project are substantial enough to warrant analysis in
an EIR and the application of mitigation measures.
Ambient air quality is determined from data collected at air quality monitoring
stations located throughout the South Coast Air Basin. Ambient air quality data
is given in terms of state and federal standards. These standards represent air
pollutant concentrations which are considered safe (with a reasonable margin of
safety) to protect the public health and welfare. As such, they represent
objectives for acceptable concentrations of specified pollutants in outdoor air.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-249
Applied Planning, Inc. (Copyright © 2005)
Ambient air quality standards are designed to protect public health and that
segment of the population that is most sensitive and susceptible to respiratory
distress or infection such as: asthmatics, the very young, the elderly, people
weak with illness or disease, or persons engaged in heavy work or exercise (i.e.
sensitive receptors). Healthy adults can tolerate periodic exposures to air
pollutant levels well above these standards before adverse health effects are
observed.
The pollutant modeling demonstrates that future carbon monoxide
concentrations adjacent to the most heavily used intersection in the Project
vicinity will be one-half of the State standard and one-third of the Federal
standard during weekday peak hours.
Localized effects of Project-related construction air emission impacts may be less
perceptible if the Project were implemented within a commercial or industrial context.
However, area-wide air quality impacts of the Project would remain significant as
determined by applicable SCAQMD significance threshold criteria. As demonstrated in
the EIR Revision, there are no feasible alternative sites that would substantially reduce the
extent or magnitude of Project's significant air quality impacts.
The commentor provides no substantive comments related to the EIR Revision. Analysis
and conclusions of the EIR Revision are not affected. The commentor's statements and
opinions will be forwarded to the decision-makers.
Response PS-3
The lawsuit challenging the EIR raised multiple issues; only two (2) of which were found
to have merit. In this regard, when the EIR was challenged in Court, it was determined by
the Court that:
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-250
Applied Planning, Inc. (Copyright m 2005)
Petitioners criticism of the treatment in the EIR of traffic impact, light and glare,
urban decay, earthquake risks, runoff and drainage, are also without merit. The
EIR adequately considers and discusses those problems, and the City's decision
to proceed with the project in spite of them is supported by substantial evidence.
The Project will not result in, nor create significant seismic/hazards or other safety impacts.
Please refer to the discussion of potential Project-related land use impacts presented at
Draft EIR Section 4.1, "Land Use," Section 4.2, "Earth Resources," within the Project Initial
Study, EIR Appendix A, and relevant responses presented in The August 2004 Final EIR
Section 3.0, "Comments and Responses." The EIR Revision appropriately reflects and
responds to applicable CEQA criteria regarding an EIR consideration and evaluation of
alternative sites. The commentor provides no substantive comments related to the EIR
Revision. Analysis and conclusions of the EIR Revision are not affected. The commentor's
statements and opinions will be forwarded to the decision-makers.
Response PS-4
The commentor proffers opinions about the Project and City review/approval processes,
but provides no substantive comments on the EIR Revision. These comments and opinions
will be forwarded to the decision-makers. Analysis and conclusions of the EIR Revision are
not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-251
Marlene Shinen, Page 1 of 9
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Marlene Shinen, Page 9 of 9
4 9a i
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Applied Planning, Inc. (Copyright © 2005)
MARLENE A. SHINEN
Letter Dated November 9, 2005
Response MS-1
Certain air quality impacts of the Project are recognized as significant due to projected
exceedances of applicable SCAQMD criteria pollutant thresholds. However, the Project
is not a source, nor generator of toxic emissions. Please refer to the discussion of potential
Project-related air quality impacts presented at Draft EIR Section 4.4, "Air Quality," within
Draft EIR Appendix D, "Air Quality and Noise Impact Study," and relevant responses
presented in The August 2004 Final EIR Section 3.0, "Comments and Responses."
Mr. Johnson's comments were based on the analysis of experts who prepared the Air
Quality analysis. The commentor provides no substantive comments related to the EIR
Revision. Analysis and conclusions of the EIR Revision are not affected. The commentor's
statements and opinions will be forwarded to the decision-makers.
Response MS-2
Certain noise impacts of the Project are recognized as significant due to exceedances of
applicable City noise thresholds for construction activities. These impacts will dissipate
completely at the conclusion of construction activities. The Project will not result in, nor
create significant long-term operational noise impacts. Please refer to the discussion of
potential Project-related air quality impacts presented at Draft EIR Section 4.5, "Noise,"
within Draft EIR Appendix D, "Air Quality and Noise Impact Study," and relevant
responses presented in The August 2004 Final EIR Section 3.0,"Comments and Responses."
The commentor provides no substantive comments related to the EIR Revision. Analysis
and conclusions of the EIR Revision are not affected. The commentor's statements and
opinions will be forwarded to the decision-makers.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-261
Applied Planning, Inc. (Copyright © 2005)
The commentor is directed to Planning Commission Condition No. 43 which states that
"Truck deliveries shall not occur between 10 p.m. to 6 a.m. the following day and routing
shall be approved by the Planning Department". It would be speculative to assume that
trucks would circle through residential neighborhoods to avoid a "to be adopted" AQMD
rule that requires trucks to not idle more than five minutes.
Response MS-3
Please refer to Response MS-1.
Response MS-4
Please refer to Response MS-2.
Response MS-5
Certain traffic impacts of the Project, related to Caltrans vehicle density thresholds along
SR-60, are acknowledged as significant within the Draft EIR. The Project will not result in,
nor create any other significant traffic or circulation impacts, including potential impacts
to emergency vehicle access. Please refer to the discussion of potential Project-related
traffic impacts presented at Draft EIR Section 4.3, "Traffic and Circulation," within Draft
EIR Appendix C, "Traffic Impact Study," and relevant responses presented in The August
2004 Final EIR Section 3.0, "Comments and Responses." The commentor provides no
substantive comments related to the EIR Revision. Analysis and conclusions of the EIR
Revision are not affected. The commentor's statements and opinions will be forwarded to
the decision-makers.
Response MS-6
As correctly summarized by the commentor, Page 1-1 of the EIR Revision provides the
following discussion:
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-262
Applied Planning, Inc. (Copyright © 2005)
Although the Court also found that the 24-hour operation issue was not
adequately analyzed in the EIR, this issue is no longer relevant as Wal-Mart has
provided notice to the City that it has withdrawn its request for a 24-hour
operation and a restrictive covenant will be recorded guaranteeing that no 24-
hour operation of the Wal-Mart Supercenter will be allowed without further
environmental review.
Please refer also to Revised Planning Department Condition of Approval (COA) presented
in Section 3.0 of this Revised Final EIR. As stated under revised COA No. 54, which now
reflects the "no 24-hour operations" restrictive covenant:
The hours of operation of the major tenant shall be limited to 8:00 a.m. to 10:00 p.m.,
except during Christmas season, in which case the hours of operation may be extended
to midnight.
Should 24-hour operations, or other substantial modifications to the Project be proposed,
the Lead Agency may require subsequent environmental analysis. Analysis and
conclusions of the EIR Revision are not affected.
The covenant has not been recorded as of the writing of this response, because the property
has not changed ownership from Edison to Wal-Mart. A fully executed copy has been
provided to the City. Once the land transaction has been completed, the City of Rosemead
will record the covenant, not Wal-Mart.
Response MS-7
As presented in the CEQA Guidelines:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-263
Applied Planning, Inc. (Copyright © 2005)
substantially lessen any of the significant effects of the Project. Of those
alternatives, the EIR need examine in detail only the ones that the lead agency
determines could feasibly attain most of the Project Objectives. [CEQA
Guidelines §15126.6 (f)]
Pages 3-11 through 3-14 of the EIR Revision substantiate that the Robinsons-
May/Montebello Town Center site fails at several levels within the context of the CEQA
"rule of reason" criteria and standards for identification and consideration of alternatives
to the Project. Foremost, selection of the Robinsons-May/Montebello Town Center site
alternative would not substantially reduce significant environmental impacts of the Project.
At best, these impacts would be transferred from one locale to another.
The Robin sons-May/M ontebe 11 o Town Center site also fails in terms of its feasibility. In this
regard, CEQA provides guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
As presented in the EIR Revision, the referenced Robinsons-May/Montebello Town Center
site is not currently under control of the Project proponent (and for that matter is not
known to be available), and is not configured to reasonably accept the Project building
footprint and facilities plans.
Other statements and opinions expressed by the commentor will be forwarded to the
decision-makers. Analysis and conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-264
11
11
Applied Planning, Inc. (Copyright © 2005)
Response MS-8
The commentor expresses opinions about the Project and City review/approval processes,
but provides no substantive comments on the EIR Revision. These comments and opinions
will be forwarded to the decision-makers.
Rosemead Commercial Retail Center
Revised Final EIR (SCH No. 2003121095)
Comments and Responses
Page 4-265
Edward Stepanian, Page 1 of 1
November 0, 2005
Dear Rosemead City Council Members.
This letter is a response to refute a comment made on page 3-12 in the
Alternative Site Analysis EIR Revision. Referring to the existing Robinsons-May
store I feel the compatibility argument between Wal Mart and the existing mall is
flawd.
I believe consumers find it very convenient when they can drive to one general
location in order to shop for a variety of items which fulfill their different needs.
Having a discount retail/grocery use within the existing mall or next to it (as is the
case with Costco), has a positive economic effect for all businesses at the location
and benefits the consumer.
I truly believe that the Robinsons - May site should be given serious
consideration as an alternative site for the proposed Wal Mart.
Sincerely.
ES-1
Edward Stepanian
1813 Delta Avenue
Rosemead
Applied Planning, Inc. (Copyright © 2005)
EDWARD STEPANIAN
Letter Dated November 6, 2005
Response ES-1
The commentor's opinions regarding commercial occupancy compatibilities will be
forwarded to the decision-makers. Irrespective of the mix of users within the Montebello
Town Center Mall, the Robinsons-May/Montebello Town Center site also fails in terms of
its ability to substantially reduce the Project's significant impacts. The Robinsons-
May/Montebello Town Center site fails as well under general feasibility considerations.
As presented in the CEQA Guidelines:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the Project. Of those
alternatives, the EIR need examine in detail only the ones that the lead agency
determines could feasibly attain most of the Project Objectives. [CEQA Guidelines
§15126.6 (01
Pages 3-11 through 3-14 of the EIR Revision substantiate that the Robinsons-
May/Montebello Town Center site fails at several levels within the context of the CEQA
"rule of reason" criteria and standards for identification and consideration of alternatives
to the Project. Foremost, selection of the Robinsons-May/Montebello Town Center site
alternative would not substantially reduce significant environmental impacts of the Project.
At best, these impacts would be transferred from one locale to another.
The Robinsons-May/Montebello Town Center site also fails in terms of its feasibility. In this
regard, CEQA provides guidance when assessing the feasibility of alternative sites:
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-267
Applied Planning, Inc. (Copyright (KD 2005)
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
As presented in the EIR Revision, the referenced Robinsons-May/Montebello Town Center
site is not currently under control of the Project proponent (and for that matter is not
known to be available), and is not configured to reasonably accept the Project building
footprint and facilities plans. As summarized above, and supported by information and
findings presented within the EIR Revision, selection of the Robinsons-May/Montebello
Town Center site would not realize any substantive environmental relief or benefit when
compared to the current Project site. Nor is the Robinsons-May/Montebello Town Center
site considered to be a feasible location for the Project based on its lack of availability and
physical constraints.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-268
David A. Stewart, Page 1 of 1
November 7. 2005
Mayor and City Council
CM, of Rosemead
8838 E. Valley Blvd.
Rosemead, CA 41770
Subject: Revised EIR - December 13 Hearing
In reading through the Alternative Site Analysis document prepared by Applied Planning, Inc., it
is very obvious the Wal-Mart "spin doctors" are still at work attempting to force a Wal-Mart
Super Center into a community that does not want it. As I understand it, this document was
prepared without some members of the City Council knowing the work was going on. If this is in
fact true. having this document prepared in "secret" is another damning factor of the document's
contents.
There is no good site for a Wal-Mart Super Center in the City of Rosemead, regardless of what is
«riven on paper. It is interesting that the Applied Planning document rejects the Montebello
Mail site in part because a Wal-Mart shouldn't be located in an "upscale" mall area. This points
out that Wal-Man is a "bottom feeder" of the retail industry - if Wal-Mart isn't good enough for
a mall site then why does a certain faction of the Rosemead City Council continue to insist to that
this retailer be inflicted upon a residential Rosemead neighborhood and school area? Every
knowledgeable report on Wal-Mart, others than those paid for by Wal-Mart, point out that Wal-
Mart is a morally corrupt organization that could care less about the communities they pollute
with their stores as lone as profit is maintained. A recently leaked internal Wal-Mart report
cements this fact. This particular report, uncovered by the Wal-Mart Watch organisation, is a
recommendation to the Wal-Mart board about how Wal-Mart profits are being eroded by benefit
costs - especially as they relate to their older workforce. The report outlines steps to cut
employee benefits. discriminate against older employees, and use more part time workers to keep
profits intact and benefit costs down. Is this really the type of employer Rosemead wants
especially since Wal-Mart will eliminate many small businesses in the area along with existing
jobs?
One item this updated report makes very clear - no matter where a %Alal-Mart Super Center goes,
it will create noise, pollution, and huge traffic messes. If the goal of the City Council is to
provide jobs and tax revenues, Why can't this be done by attracting, a croup of smaller, less
impacting businesses instead of one huue retailer who could decide after a few years to pack their
tent and move on to another communirv. leaving- Rosemead with a huge, blidtltted building? In
looking at Wal-Man's past behavior, this is part of their operating- model. It is no secret Wal-
Man wants stores in I,ns Angeles - when that happens Val-Mart will move west and no longer
need Rosemead. Rosemead leaders should be smart enough to recognize this threat, cut the tics
With Wal-Man and their corrupt spokesman Mile Lewis. and move on with looking at other
development options that Rosemead residents would appreciate and support. As voters, we
descn-e this type of wise action from our leaders - or from new' leaders elected to replace those
who just don't get it.
DS-1
David A. Stewart
Rosemead. California
Applied Planning, Inc. (Copyright © 2005)
DAVID A STEWART
Letter Dated November 7, 2005
Response DS-1
The commentor expresses opinions, but provides no substantive comments on the EIR
Revision. The commentor's statements and opinions will be forwarded to the decision-
makers. Analysis and conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-270
Paul Thomson, Page 1 of 1
City of Rosemead
8838 E. Valley Blvd.
Rosemead. Ca. 91770
Attentions Brad Johnson, Planning Director
Subject: EIR Revision of Alternative Sites
Dear Mr. Johnson:
The EIR Revision of Alternative Sites (page 3-1) states that the primary objective
of not considering alternatives outside the City of Rosemead is to augment the
City's economic base. It also states that air quality impacts would be the same in
the air basin.
The EIR Revision of Alternative Sites leans heavily on CEQA Guideline's,
Section 15126.6 (f), which is the rule of reason. However, this rule of reason
states: "The alternatives shall be limited to ones that would avoid or substantially
lessen any of the significant effects of the project."
The sites listed in the EIR Revision encompass a radius of two miles from the
proposed project site, all within the City of Rosemead. If the two-mile radius is
observed outside the City of Rosemead, at least four sites would be seen that
equal or exceed the acreage of the proposed site. These sites are not adjacent
to residential structures or schools as is the proposed site. Perhaps the
statement in CEQA Guideline's, Section 15126.6 (2) (A) Key Question, would
apply. It states. "The key question and first step in analysis is whether any of the
significant effects of the project would be avoided or substantially lessened by
putting the project in another location."
PT-1
Locating the site outside the City of Rosemead would lessen the air pollution,
traffic congestion, and noise. It would be away from residential structures and an PT-2
elementary school. These are three major concerns for the people and children
who live and attend school next to the proposed site.
The City of Rosemead's primary concern is augmenting the city's economic
base. It has no concern for the health and welfare of the community where the PT-3
proposed site is located,
Paul Thomson
8320 Scenic Dr.
So. San Gabriel, Ca. 91770
Applied Planning, Inc. (Copyright (D 2005)
PAUL THOMPSON
Letter Received November 2, 2005
Response PT-1
The EIR Revision appropriately reflects and responds to applicable CEQA criteria
regarding an EIR consideration and evaluation of alternative sites.
The alternatives shall be limited to ones that would avoid or substantially lessen
any of the significant effects of the Project. [CEQA Guidelines §15126.6 (f)]
The selection and scope of potential alternative sites presented within the EIR Revision is
as determined by the Lead Agency, and the EIR Revision is presented consistent with
CEQA Guidelines §15126.6. As stated by the commentor, the other referenced sites are
outside of the City limits, and therefore would not achieve one of the primary objectives
of the Project, which is to augment the City's economic base. Further, the referenced sites
are beyond control of the lead agency. In this latter regard, as noted within the CEQA
Guidelines:
Feasibility also includes factors such as site suitability, jurisdictional boundaries
(emphasis added) and whether the proponent can reasonably acquire, control
or otherwise have access to the alternative site. [CEQA Guidelines15126.6 (f) (1)]
The referenced sites fail to achieve feasibility criteria in that they are not under jurisdiction
or control of the Lead Agency. Nor is it likely that the Project Proponent could reasonably
acquire the referenced properties.
Lastly, it is reiterated that the purpose of the Alternatives Site Analysis is to identify
potential locations which could foremost, substantially reduce the Project's significant
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-272
Applied Planning, Inc. (Copyright © 2005)
environmental impacts. The purpose of the Alternative Site Analysis is not to conduct a
real property search and inventory, the sole purpose of which is arbitrary relocation of the
Project.
The commentor's opinions will be forwarded to the decision-makers. Analysis and
conclusions of the EIR Revision are not affected.
Response PT-2
As presented in the CEQA Guidelines:
The range of alternatives required in an EIR is governed by a "rule of reason"
that requires the EIR to set forth only those alternatives necessary to permit a
reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the Project. Of those
alternatives, the EIR need examine in detail only the ones that the lead agency
determines could feasibly attain most of the Project Objectives. [CEQA
Guidelines §15126.6 (f)].
As noted under Response PT-1, locating the Project outside of the City is not considered
feasible as these locations would not achieve primary economic objectives of the Project,
and sites outside of the City are beyond the jurisdiction of the Lead Agency. The
commentor provides no substantiation for conclusory statements regarding potential
reduction of the Project's impacts by relocating it (the Project) to another site. To the
contrary, the EIR Revision at Pages 3-1 through 3-14 demonstrates and concludesthat there
would be no net environmental benefit realized through relocation of the Project. Further,
locating the Project outside the City of Rosemead is contrary to one of the Project's Primary
Objectives, i.e., to augment the City's economic base. The commentor's opinions will be
forwarded to the decision-makers. Analysis and conclusions of the EIR Revision are not
affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-273
Applied Planning, Inc. (Copyright © 2005)
Response PT-3
The commentor is providing an opinion regarding the Project, which will be provided to
the decision-makers for consideration during deliberations on the Project. Analysis and
conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-274
NOV S 4 2005
JULIE L. WANG
Itll: aFrnuc 1 :Alhambra. Culifurnia 01803-20-1;3 ' Cell: (626( 233-8648 ' jtlwang@ayahoo.com
November 13, 2005
Mr. Brad Johnson, t 11', P l ann~:r
City of Rosemead
8838 E. Valley Blvd.
Rosemead, CA 91770
Re: Revised frtp:.tct I.er ut
Mr. Johnson:
Attached are n corimonl, re,-ardint- the 1Ze-ised !.n4 ironmcntal 1111a_ic, Report ("EIR"). I am
submitting two copies, itil n.: cnr. to he r, rained hw m% l,.,r... submitting my comments.
Please time stamp I-,,,tiI C,,f)lt 1 JW-1
Thank you for your .,~t. n: this „1;tttcr.
Respectfully,
Julie L. Wang
Enclosure (1 page)
Julie Wang, Page 2 of 2
After almost four years of effort, Rosemead earned the opportunity to permanently
preclude Wal-Mart from entering its city. Save Our Community, a Rosemead-based volunteer
activist group, retained a lawyer and brought a lawsuit against Wal-Mart. At the trial, Judge JW-1
David Yaffe ruled that the original EIR's alternative site analysis was insufficient; therefore, (cont'd)
another analysis was undertaken. My public comments are regarding the revised EIR.
Rosemead's political setting will fully explain the significance of the revised EIR. The
revised EIR was issued shortly after Rosemead voters successfully petitioned for a recall
election, which will be held on February 6, 2006. This election is preceded by a public hearing
on December 13, 2005, which the city arranged immediately after learning of the recall election.
This hearing befalls on a holiday month and the motivations behind these arrangements are
evident - the current administration hopes to expedite the approval of a final EIR before the
recall election. This election was approved on the premise that Rosemead voters do not want
Wal-Mart in its city and demands new leadership. Wal-Mart is not good for Rosemead or for
any other city. This behemonth's avaricious and pernicious policies undermine every democratic
principle our country represents. In short, the credibility of this revised EIR is highly
questionable considering the political atmosphere surrounding its issuance.
Furthermore, this EIR failed to satisfy Judge Yaffe's ruling by providing a meaningful
alternative site analysis. Moreover, the revised EIR is self-contradictory. These sites did not
comply with the fundamental criterion setforth by this report. The magnitude of this
construction required an acreage minimum of 18-acres. None of the alternative sites analyzed
were 18 acres, although alternative size 1 could become 19 acres. Moreover, alternative site 2
could only be 8.75 acres and alternative site 3 was only 8.75 acres. How can an alternative be an
alternative if it cannot be an alternative? In fact, the EIR eliminated the Rosemead Supermarket
site as a possibility "due to its limited size" but failed to apply the same reasoning towards the
other alternatives. 1 In short, this EIR is extremely insufficient and inconsistent. In addition, if
this construction is completed, its effects will be disastrous to Rosemead. According to the
United States Census Bureau, Rosemead's retail establishments consist of 147 businesses, which
outnumber any other industry-type.2 As a retailer, Wal-Mart would eliminate any viable
competition in Rosemead and the surrounding cities.
In conclusion, this revised EIR lacks meaningful analysis and a new study must be
conducted in order to meet Judge Yaffe's ruling.
JW-2
JW-3
::1 JW-4
1 Revised EIR pg. 3-4
2 United States Census Bureau: Selected Statistics by Economic Section for 2002
Applied Planning, Inc. (Copyright © 2005)
JULIE WANG
Letter Received November 14, 2005
Response JW-1
The commentor is providing an overview of the Project; no response is necessary.
Response JW-2
The writ and judgement issued by Judge Yaffe required the City to revise the EIR and
report back to court within a short period of time and the December 13'h hearing was the
first possible date to accomplish this task.
The commentor is expressing opinions regarding the environmental process. The analysis
and conclusions of the EIR Revision are not affected.
Response JW-3
The commentor is expressing an opinion regarding the site selected for analysis within the
EIR Revision. As stated within Section 7.3.1.2 (page 3-3) of the EIR Revision, "The City of
Rosemead is essentially a built out, urban community. There is a minimum of vacant land
available to accommodate a development the size of the Project. Based on current
knowledge of available land within the City of Rosemead, City Planning and
Redevelopment Staff have identified the following locations as the only (emphasis added)
possible alternate development sites within the City.
Response JW-4
The commentor is expressing opinions regarding the environmental process. The analysis
and conclusions of the EIR Revision are not affected.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-277
Jeffrey K. Yann, Page 1 of 2
WUV 2 y 2005
ALTERNATIVE USE FOR ROSEMEAD WAL-MART SITE
November 6, 2005
Prepared by, Jeffrey K. Yann. P.E.
In March, 2005, the City of Rosemead approved development of a Wal-Mart Superstore on a parcel of
land approximately 24 acres in size bordered on the east by Walnut Grove Avenue, on the west by
Delta Avenue, and on the north by Rush Street. Alhambra Wash, a regional storm channel that
provides flood management for the City of Rosemead and a number of upstream cities traverses the
northeast corner of the property,
This location is well known to me. As a former employee of Southern California Edison, I worked JY-1
across Rush Street from this property from March, 1980 to June, 1996 when I retired, taking advantage
of an early retirement offer arising out of a decision by the California Public Utilities Commission to
deregulate the electric utility industry In addition to my work experience, I am an active walker who
took almost daily walks past this property dtuing the time 1 worked there. I am a licensed Civil
Engineer in the State of California and worked most of my time at Edison as a Lead Civil/Structural
Engineer or Project Engineer on many utility projects. Although not'a resident of Rosemead, my
interest in this maner is as a concerned citizen, and not as a paid consultant.
I do not believe this site is suitable for the large volume of traffic the Wal-Mart superstore would
generate. During my career, on those days when I left work at regular quitting time, traffic on Walnut
Grove Avenue southbound toward the Pomona Freeway was often backed up for approximately one-
half mile to the bottom of the hill adjacent to the property on which the superstore is to be build.
While Delta Avenue offered a possible alternate route on some days, this residential street is not
suitable for heavy traffic, and traffic must then proceed south on San Gabriel Blvd., which is equally
restricted at its intersection with Walnut Grove Avenue prior to reaching the Pomona Freeway. For
traffic traveling north on Walnut Grove, the situation is limited by the need for vehicles traveling either
east or west on the San Bernardino Freeway to make a left turn from Walnut Grove to enter the
freeway on-ramp. As one of the oldest freeways in southern California, built through an already
congested area in the 1950's, this freeway still has many exit and entrance ramps that do not conform. JY-2
to standards used today While Garvcy Avenue has the potential to relieve traffic for those traveling
east, its intersection with Rosemead Blvd, is among the most difficult intersections in the area,
particularly for those turning left on RosetrRead Blvd to approach the freeway
I believe this site is unsatisfactory for the use approved by the City of Rosemead. Traffic associated
with a large retail facility will greatly exacerbate already existing heavy traffic from several nearby
office buildings at a time when many shoppers are also returning home. Alternate sites should be
evaluated in Rosemead and in other nearby cities if it is intended to accommodate this use Once the
city properly evaluates infrastructure costs on all adjacent streets that would be required to produce an
acceptable traffic pattern, the economic advisability of the superstore will, in my opinion, be entirely
different Alternative, less intensive uses should also .be explored for this property by the city.
This site is an attractive site for a number of purposes. It could accommodate a mixed-use
residential/commercial district that would offer an asset to surrounding neighborhoods rather than a
liability It could also offer an opportunity for green space and park use, which, from my many walks JY-3
around the surrounding neighborhoods, 1-know is very limited in this vicinity.
Jeffrey K. Yann, Page 2 of 2
Consistent with park use, the presence of Alhambra Wash offers a unique opportunity to help
Rosemead and other upstream cities meet Total Maximum Daily Load (TMDL) requirements for many
contaminants now being released in storm waters. These contaminants include trash, chemicals from
urban runoff, suspended solids, metal contaminants, oil and grease. Currently, much of this
contaminated water ends up in the ocean or on beaches near the mouth of the rivers, creating a
tremendous burden on downstream cities. The Los Angeles Regional water Quality Control Board is
currentl promulgating extremely low limits for many of these contaminants.
Immediately downstream of this location, Alhambra Wash enters a natural channel of the Rio Hondo
behind Whittier Naxrows.Dam This natural channel allows many of these contaminants to percolate
into the ground water basin at a location where the U. S. Environmental Protection Agency operates a
water clean-up system designed to clean up contaminants in the South E] Monte Operable Unit. Less
hazardous to health, but far more visible, this channel area, which is lined with native trees and shrubs,
is also littered with trash -spilling out of the neighborhoods drained by the concrete channel of
Alhambra Wash.
Ideally, the property proposed for the Wal-Mart could be used as a regional water treatment facility
that would allow all upstream cities, including Rosemead, to meet TMDL requirements with a regional
solution that could set standards for TMDL compliance. Current plans for meeting the TMDL limit for
trash is provision of catch basin inserts at each inlet point to the vast storm drain network throughout
most cities. Such a solution would not only be expensive to builds, but would also have to be
maintained very closely to assure that accumulating trash would not block the storm drain opening. In
addition, while this approach might work for trash, it is not suitable for any of the other TMDL's.
At the Rosemead property, it is possible to divert a significant quantity of the storm water that occurs
during most years, and a]1 of the initial storm runoff that contains the largest amount of contaminants
and trash, directly into a lake located adjacent to the wash. Trash would be collected in a settling basin
and immediately cleaned out following each storm and hauled to a disposal facility Other
contaminants could be removed through either filtering through plants that would line the pond or by
chemical treatment prior to a gradual release downstream. During summer, when storms are not
occurring, all urban runoff from local irrigation would also be routed through the lake to maintain a
flow of water through the water body to avoid stagnation, as well as provide a water treatment
opporwrrity for this urban runoff The lake would provide habitat for aquatic wildlife as well as a
central feature in a passive park, suitable for walling or running, nature study, education and other
similar purposes, which could be built around it. The remainder of the pmperty would be available for
an active parr a residential area or commercial area, all of which would be enhanced by the adjacent
lake Traffic generation from such use would be minimal
While no detailed design for this facility has been prepared, consultants to Amigos de los Rios working
on feasibility of removing Alhambra Wash from its concrete channel east of Walnut Grove Avenue,
are confident of its ability to be implemented. Similar features exist in other local watersheds serving
similar purposes intended here. While this facility represenu only one of many possible uses for this
site that would provide far greater compatibility with its surroundings, this project would nor only
provide an attractive park for residents of-Rosemead and South San Gabriel., but it would provide a
model facility for cities to pool their resources working together on a regional solution to storm water
clean-up requirements. _
JY-3
Applied Planning, Inc. (Copyright (D 2005)
JEFFREY K. YANN, P.E.
Letter Dated November 6, 2005; Received November 29, 2005
Response JY-1
Background comments provided by the commentor are acknowledged. No further
response is required.
Response JY-2
The commentor expresses concerns regarding potential Project-related traffic impacts.
Certain traffic impacts of the Project, related to Caltrans vehicle density thresholds along
SR-60, are acknowledged as significant within the Draft EIR. The Project will not result in,
nor create any other significant traffic or circulation impacts, including potential impacts
to emergency vehicle access. Please refer to the discussion of potential Project-related
traffic impacts presented at Draft EIR Section 4.3, "Traffic and Circulation," within Draft
EIR Appendix C, "Traffic Impact Study," and relevant responses presented in The August
2004 Final EIR Section 3.0, "Comments and Responses." It is further noted that when the
EIR was challenged in Court, it was determined by the Court that criticism of the treatment
in the EIR of traffic impacts was without merit. And further, that the EIR adequately
discusses this issue, and the City's decision to proceed with the Project in spite of identified
traffic impacts is supported by substantial evidence.
Response JY-3
The commentor suggests alternative uses for the Project site, but provides no substantive
comments on the EIR Revision. These comments are beyond the scope of the EIR Revision
but will be forwarded to the decision-makers for their consideration. The commentor is
also referred to the previous consideration of potential alternate uses for the subject site,
which alternate uses were evaluated and rejected, as presented in the Draft EIR
Alternatives Analysis.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-280
Susan Young, Page 1 of 1
November 16, 2005
Mayor and City Council
City of Rosemead
8838 E Valley Blvd.
Rosemead, CA 91770
NOV 2 5 Zoos
Subject. Revised EIR
The City Council should use all of its efforts and possibly a part of the accwnulated
Community Development funds to assure that the Wal-Man Discount Supercenter, if it
proceeds, is placed at the current Robinson's-May location in the Montebello mall.
The exposure to the Pomona Freeway would be excellent, access from the freeway would
be easily available from either San Gabriel Blvd. or Paramount Ave ramps, the estimated
14,000 to 20,004 vehicle trips per day would strengthen the Montebello mall, the sales
tax would be credited entirely to Rosemead, the Wal-Mart center would be close to
Rosemead shoppers, any new jobs would easily be available to qualified Rosemead
residents, and the freeway would attract - and provide easy access to - the shoppers from
East Los Angeles, Montebello, Monte cy Park and Alhambra.
From all necessary aspects, it is the perfect location - no housing close by, no schools on
the approaching traffic routes, and with no material increase in problems such as light
and glare
Tithe City Council doesn't make a concerted effort to place the proposed Wal-Mart
center at the Montebello mall, it will strongly reveal that the current site was selected for
reasons other than those stated in-the oiigansl -or Tevised EIRs.
Help Rosemead with a perfect solution to an issue that has and will split the citizens of
the city now and in the future
Sincerely,
SY-1
Susan Young
1836 Rosebrook Lane
Rosemead, CA 91770
Applied Planning, Inc. (Copyright D 2005)
SUSAN YOUNG
Letter Dated November 16, 2005; Received November 29, 2005
Response SY-1
Pages 3-11 through 3-14 of the EIR Revision substantiate that the Robinsons-
May/Montebello Town Center site fails at several levels within the context of the CEQA
"rule of reason" criteria and standards for identification and consideration of alternatives
to the Project. Foremost, selection of the Robinsons-May/Montebello Town Center site
alternative would not substantially reduce significant environmental impacts of the Project.
At best, these impacts would be transferred from one locale to another.
The Robinsons-May/Montebello Town Center site also fails in terms of its feasibility. In this
regard, CEQA provides guidance when assessing the feasibility of alternative sites:
Feasibility also includes factors such as site suitability, jurisdictional boundaries,
and whether the proponent can reasonably acquire, control, or otherwise have
access to the alternative site. [CEQA Guidelines §15126.6 (f) (1)]
As presented in the EIR Revision, the referenced Robinsons-May/Montebello Town Center
site is not currently under control of the Project proponent (and for that matter is not
known to be available), and is not configured to reasonably accept the Project building
footprint and facilities plans. As summarized above, and supported by information and
findings presented within the EIR Revision, selection of the Robinsons-May/Montebello
Town Center site would not realize any substantive environmental relief or benefit when
compared to the current Project site. Nor is the Robinson s-May/Montebello Town Center
site considered to be a feasible location for the Project based on its lack of availability and
physical constraints.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2003121095) Page 4-282
Applied Planning, Inc. (Copyright © 2005)
In this latter regard, the EIR Revision acknowledges that the status of the Robinsons-
May/Montebello Town Center site for future redevelopment is questionable. This is borne
out by comments on the EIR Revision provided by the City of Montebello, which
comments have ultimately removed the Robinsons-May/Montebello Town Center site from
consideration as a potential location for the Project. Based on the City of Montebello's
comments, Pages 3-11 and 3-12 of the Revised Alternative Site Analysis are amended to
read as follows:
a. Site Description
Alternative Site 3, located on the eastem edge of the Montebello Town Center
mall, was identified as a possible altemative due to the recently announced
corporate mergerbetween the May Department Stores Company and Federated
Department Stores, inc. The closure of the Robinsons-May store is anticipated
by the City, although this store was not identified in the latest list of locations
planned for divestiture, issued by Federated Department Stores on July 28,
2005. In response to the Revised Alternative Site Analysis, Rosemead has
teamed that this site will not be available as the store will remain open as a
Macy store.
stot~-_;s are beimg studied for potentisi conversion of the B!6om~mgdale~s
nameptate,.- which would Fesult in these stoFes . . - . i operation rathe
them being vaceted. Them is me indication, howevet-, that the MemtebeHo Town
b. Potential Feasibility of Site
a. The existing Robinsons-May store is approximately 140,100 square feet
in size, and is located on an 8.75 acre parcel that provides shared mall parking,
as shown in the following Figure 7.3-3. In order to accommodate the proposed
Wal-Mart Supercenter, substantial re-design of the Project would be required,
resulting in the construction of a multiple-story facility with additional, at-grade
or subterranean parking. Based on the information from the City of Montebello,
as well as problems relating to project design, the site is considered unavailable
and the alternative rejected as infeasible.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EiR (SCH No. 2003121095) Page 4-283
Applied Planning, Inc. (Copyright C 2005)
Beyond the obstacles of site availability and project design,
compatibility between the proposed Wal-Mart and the existing mall
is an additional concern. The Montebello Town Center is an
upscale, regional mall. As such, retailers within this mall seek to
draw consumers from a different market sector than that of the
discount retailer and grocery seller, and the introduction of a
discount retail/grocery use within the existing mall could be
incompatible and have a detrimental economic effect on adjacent
retailers. Accordingly, this altemative site was determined to be
infeasible.
Rosemead Commercial Retail Center Comments and Responses
Revised Final EIR (SCH No. 2 003 1 2 1 095) Page 4-284
