Dr.

Ranajit (Ron) Sahu

Consultant
311 North Story Place
Alhambra, CA 91801

January 11, 2017

Planning Division
City of Alhambra
Development Services Department
111 South First Street
Alhambra, California 91801
Subject: Comments on the Traffic Impact Study for the Proposed Lowes and Office
Development in the City of Alhambra, (hereafter Traffic Study) prepared by Kimley-Horn
and Associates, Inc., October 2016
Dear Sirs/Mmes,
I appreciate the opportunity to comment on the Traffic Study prepared to support the proposed
Lowes and Office Development (hereafter proposed project) at 875 and 1111 South Fremont
Avenue, Alhambra, California.
I understand that the City of Alhambra Planning Commission will be asked to approve this
matter on January 17, 2016 at a public hearing. I am requesting that a copy of this comment
letter be provided to each member of the Planning Commission, the City Manager, and to each
member of the City Council.
Among other obligations, the extant Traffic Study has been provided by the project proponent as
part of the required environmental impact assessment for the proposed project in order to satisfy
the requirements of the California Environmental Quality Act (CEQA). It is my understanding
that the project proponent has proposed and that the City of Alhambra has accepted that the
CEQA obligation of the proposed project can be discharged via a Mitigated Negative
Declaration (MND) as opposed to a full Environmental Impact Report (EIR) the latter being a
more thorough assessment of the potential environmental impacts that may result from the
proposed project.
Based on my review of the Traffic Study alone (i.e., setting aside other potentially problematic
environmental concerns such as Air Quality and potential risk of harm via Vapor Intrusion of
contaminants known to be present in groundwater under the proposed development site, etc.), it
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is my opinion that the MND is not the appropriate CEQA document for a project of this size and
scope at its proposed location namely along Fremont Avenue, currently one of the most heavily
impacted traffic corridors in the City, with unacceptable traffic even without the proposed
project.
I provide this opinion not just because I am a resident of the City of Alhambra (since 1988) but
also as a professional consultant competent to provide such opinions on environmental
assessments. If staff or members of the Planning Commission or City Council would like to
discuss my qualifications, I will be very happy to provide additional details.
The Traffic Study is fatally compromised and, as a result, its conclusions are flawed and cannot
and should not be relied upon. Due to improper and unsupported assumptions made regarding
nature of the proposed project, the Traffic Study consciously significantly underestimates the
number of additional trips that will be generated as a result of the proposed project. It does so by
improperly deviating from standard practices in how such traffic impact analyses are conducted
for such developments throughout the country. As in any traffic analysis, once the project trip
estimate is erroneous, the conclusions of the study are consequently also erroneous.
The additional trips from the proposed project will incrementally burden the already poor traffic
conditions in and around the area, which even the Traffic Study acknowledges. Thus,
underestimating the number of additional trips artificially lessens the impact of the proposed
project. This defeats the purpose of the assessment and moots the CEQA analysis. And, it
makes mockery of the types of mitigations that can and should be considered to lessen the
incremental traffic impacts once they are properly estimated.
I wish to make it clear that I am not against development in the City. I acknowledge that it is
unrealistic to expect that the land proposed for development will not undergo some type of future
development. But, that is simply not an excuse to use poor technical analyses as support for the
proposed development and to ram it through the process. Doing so is harmful on many levels: it
defeats the happy talk of sustainable or smart growth that is supposedly the planning goal in the
City; it invites equally poor analyses on future projects; and it exposes the City to potential legal
risks. I would urge the Planning Commission to send the environmental analysis back to the
drawing board to be reworked and to make sure it properly conforms to CEQA.
Based on a meeting I (and others) had with City staff, I have put together a list of questions
(provided in Attachment A) relating to the Traffic Study. This has been provided to staff and it
is my understanding that staff will obtain responses from the authors of the Traffic Study.
Regardless of whether or not responses are obtained, as a fellow resident of the City, I urge
members of the Planning Commission to fully satisfy themselves as to the Traffic Study before
voting on this matter. I urge Commissioners to become familiar with what can often be technical
aspects of the various CEQA analyses, including the Traffic Study, and to ask pointed questions

and clarifications before considering approval for the project as currently conceived. And, I urge
City Council members to support their appointed Planning Commissioners in this task.
It is my opinion, based on review of numerous documents and many discussions with City staff
over the years, that CEQA compliance for many projects proposed in the City over the years has
been an after-thought a check-the-box exercise that leaves much to be desired. I have
heretofore refrained from commenting publicly on the record on this issue. But, the quality of
the analysis in the present Traffic Study warrants a public response.
While I understand staffs desire (and that of the Planning Commission and City Council
members) to be helpful to folks intending to invest in the City, this desire must be properly
balanced against the regulatory obligations of staff, Commissioners, and Council members and
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their obligations to the citizens of Alhambra. Without a proper balance between the regulatory
and facilitation functions, the desired goal of sustainable development in the City is simply not
possible. This is even more important when considering projects, such as the proposed project,
in an area of the City along Fremont Avenue that is already subject to significant congestion and
which sits on land above contaminated groundwater.
If staff, Commissioners, or Council members have any questions, I can be contacted at
626.308.0421.
Thank you again for the opportunity to provide these comments.
Sincerely

Dr. Ron Sahu

311 North Story Place, Alhambra, CA 91801

I should also add that there is also a matter of simple equity and of perception. Citizens of Alhambra are subject to
the full force of the regulatory aspects of City government, whether it involves code enforcement, obtaining building
permits, or any number of aspects of living in the City when they interact with the City. They have the right to
therefore question why it is that (powerful) project proponents are accorded a perceptibly different reception in their
interactions with the City at staff, Planning Commission, or City Council levels.

Attachment A
Questions Provided to City of Alhambra Staff Relating to the Traffic Study
1. On Table 2, page 17, why did the traffic analysis not use the trip generation rates from ITE Trip
Generation Manual, 9th Edition, code 862 in order to calculate the rates for the Lowes store for AM Peak
Hour, PM Peak Hour, and Weekend Peak Hour?
2. Were the trip generation values for Lowes ever calculated using the ITE 9th Edition code 862 rates?
3. Regardless of the answer to Q2. above, what would the Lowes' trip generation values for AM Peak
Hour/PM Peak Hour/Weekend Peak Hour be if ITE 9th Edition code 862 rates were used instead of the
Lowes/Poway rates?
4. Did Kimley/Horn request approval from the City of Alhambra prior to using the Lowes/Poway trip
generation rates instead of the ITE 9th Edition rates for the Lowes store in the traffic analysis? Please
provide details (such as approval letter, etc.).
5. Please provide examples of other traffic impact analyses (say, within the last 10 years) either
prepared by Kimley/Horn or known to Kimley/Horn in which the trip generation rates associated with a
Home Improvement Store land use did not use the ITE Manual (appropriate edition at the time of the
analysis) trip generation rates or another state-approved trip generation rate in order to determine the trips
associated with the new Home Improvement Store.
6. How were the trip distribution assignments shown on Figures 5, 6, and 7 determined? The analysis
states that the distribution assumptions were "submitted to and approved by the City of Alhambra staff"
(see p. 18). Please provide details of this correspondence between Kimley/Horn and City of Alhambra.
7. How would the conclusions of the traffic analyses as shown on Tables 3, 4, 5, 6, 7, and 8 change if the
trip generation values for the Lowes store used the ITE Manual 9th Edition Code 862 rates in Table
2 instead of the Lowes/Poway rates, along with the assumed trip distributions shown in Figures 5-7?
8. Does Kimley/Horn typically address accidents and other safety metrics at the potentially affected
intersections within the assumed area of study in its traffic analyses? The current analysis does not seem
to contain this type of information.
9. Appendix C contains a report prepared by Crown City Engineers. The following questions pertain to
Appendix C. Not sure if they should be addressed by Kimley/Horn or Crown City.
(i) Please provide support for the statement that "Lowes home improvement superstores are considered
different than other typical home improvement superstores...." (unnumbered page 1 of the report in
Appendix C). What is the basis of this statement? Please provide references as appropriate.

(ii) Please provide support for the statement "Lowes stores sell home improvement items geared more to
the homeowners whereas Home Depot stores sell these items geared more to small contractors."
(unnumbered page 2 of the report in Appendix C) Was this statement based on observations (please
provide documentation), company statements (please provide documentation), or other sources (please
provide documentation)?
(iii) Please provide information on the customers (i.e., home owners, small contractors, large contractors,
MRO, etc.) that Lowes intends to target to its Alhambra store - if known.
(iv) Please clarify the statement "....Alhambra Lowes will not share any driveways form
other businesses." It is apparent from the traffic analysis that traffic to and from the two proposed office
complexes also planned as part of the development (which will presumably house "other businesses") will
be able to enter/leave the development via the Lowes driveways.
(v) On what basis was the Lowes in Poway deemed "similar" to the proposed Lowes in Alhambra?
(vi) Using the support for "similar" as used in Appendix C, are there any other Lowes stores located
closer to the proposed Alhambra Lowes than the Poway store, which could also be considered "similar" to
the Alhambra Lowes?
(vii) Were there any other Lowes stores other than the one in Poway considered for traffic count data
gathering described in Appendix C?
(viii) Were any actual traffic counts collected at any other Lowes, other than the one in Poway. If the
answer is yes, please provide this data.
(ix) The Lowes store in Poway is located across a Walmart Superstore. Please comment on the effect this
could have on traffic counts observed at the Poway Lowes in contrast to, for example, the Lowes being
all by itself - i.e., could it have depressed the observed traffic counts? If not, why not?
(x) Please comment on whether the ITE Manual or other applicable ITE guidance and methodology was
followed in gathering this additional data from Lowes/Poway, when the intent was to use this data as
opposed to the Code 862 data from the Manual in the subsequent traffic analysis. If the answer is yes,
please provide cross references to ITE documents.
(xi) Was the City of Alhambra consulted prior to the collection of the data from Lowes/Poway - i.e., was
the need for this data and the collection methodology discussed and/or approved prior to the data
collection.
10. Were any drafts of the traffic analysis provided to the City of Alhambra prior to its finalization? If
yes, did Kimley/Horn receive any written comments from City of Alhambra? Please provide these
comments and responses by Kimley/Horn.