February 27, 2017

City of Alhambra Mayor and City Council

111 South First Street
Alhambra, CA 91801

Subject: Alhambra Court Commercial Development Mitigated Negative

Declaration, (TTM 74223 and IP 16-4) P17002

Dear Mayor and City Council:

This letter supplements my comments earlier today on the Transportation/Traffic

component of the proposed Mitigated Negative Declaration (the IS/MND) for the
proposed Alhambra Count Commercial Development (the "Project") in the City of
Alhambra (the "City"). My qualifications to perform this review are thoroughly
documented in, and my resume is attached to, that earlier letter.

The reason for this supplement is the City's Supplemental Comments &
Responses to Comments for the Mitigated Negative Declaration & Initial Study
dated January 17, 2017, that were posted with the City Councils agenda
materials for tonights meeting.

Although my earlier letter extensively addresses how extremely inappropriate the

traffic impact study was to rely on trip generation data collected on single days at
a single Lowe's store in Poway, CA instead of relying on the authoritative data in
Trip Generation, 9th Edition, a section of the January 17 Response attempting to
defend this inappropriate action has drawn my attention.

At page 34 of the January 17 response document, the response cites a quote

from Trip Generation, 9th Edition that states " When practical, the
user is encouraged to supplement the data in this document with local data that
have been collected at similar sites" and errantly claims that statement justifies
use of the Poway store data. Let us be clear about this matter. The traffic
impact study did not supplement the Trip Generation, 9th Edition data; it
completely disregarded the entire data base from Trip Generation, 9th Edition for
its analysis of weekday and Saturday peak hours and substituted data collected
on a single weekday and a single Saturday at a single, apparently
underperforming Lowe's store.

And the data substituted is not local data. The Poway Lowe's store is 94 miles
from Alhambra as the crow flies. According to Lowe's own 'storefinder' search
engine on the internet, there are at least 25 Lowe's stores within a 40-mile radius
of the Alhambra site (see Ex. A hereto) and another 14 Lowes stores beyond

SMITH Engineering & Management 5311 Lowry Road, Union City, CA 94587
City of Alhambra Mayor and City Council
February 27, 2017
Page 2

that range in the direction of Poway before the Poway store is reached (see Ex.
B hereto). It appears quite evident that the Poway store was cherry picked as
the single trip generation data source for the Alhambra analysis not because it
was 'local' but for the purpose of minimizing the trip generation estimate (and
consequent potential for significant traffic impacts) of the development proposed
for Alhambra Court.

If one were to plot the Poway store trip generation on the plots of actual data
points for Home Improvement Superstores represented in Trip Generation, 9th
Edition, one would find that the Poway store data points are an extreme outlier to
the other data points.

In summary, the cited response to comments is inaccurate, misleading and not in

keeping with the good-faith effort to disclose impacts that the California
Environmental Quality Act demands.

Sincerely,

Smith Engineering & Management

A California Corporation

Daniel T. Smith Jr., P.E.

President

SMITH Engineering & Management 5311 Lowry Road, Union City, CA 94587
 2/27/2017 Lowe'sHomeImprovement
FREESHIPPINGONQUALIFYINGORDERS$49ORMORE

Prices,promotions,styles,andavailabilitymayvary.Ourlocalstoresdo
nothonoronlinepricing.Pricesandavailabilityofproductsandservices
Openuntil9PM!
aresubjecttochangewithoutnotice.Errorswillbecorrectedwhere
NorwalkLowe's
discovered,andLowe'sreservestherighttorevokeanystatedofferand
tocorrectanyerrors,inaccuraciesoromissionsincludingafteranorder
hasbeensubmitted.

FindaStore MiraLomaLowe's
38.5mi

91801 FIND 6413PatsRanchRd

MiraLoma,CA91752,Store
#2330

Phone:(951)2569034
MonSat6am9pm
1 NorwalkLowe's FMYSTORE Sun7am8pm
[ 14873CarmenitaRd
StoreDetails
Norwalk,CA

SHOPTHISSTORE
2 LaHabraLowe's
[ 1380SouthBeachBlvd SHOPTHISSTORE
LaHabra,CA
5.8mi

Smith Engineering Exhibit "A"

3 N.E.LongBeachLowe's
[ 7300EastCarsonSt SHOPTHISSTORE
LongBeach,CA
8.5mi

https://www.lowes.com/store/ 1/2
 4 AnaheimLowe's
[ 1500N.LemonSt SHOPTHISSTORE
Anaheim,CA
8.7mi

5 PicoRiveraLowe's
[ 8600WashingtonBlvd SHOPTHISSTORE
PicoRivera,CA
8.7mi

6 CentralLongBeachLo
[ 2840BellflowerBlvd

Report
Map data 2017 a map error
Google, INEGI

Need Help?
Call18004456937

Products & Sales

Call1877GOLOWES

2017Lowe's.Allrightsreserved.Lowe'sandthegabledesignareregisteredtrademarksofLF,LLC.

https://www.lowes.com/store/ 2/2
 2/27/2017 Lowe'sHomeImprovement
FREESHIPPINGONQUALIFYINGORDERS$49ORMORE

Prices,promotions,styles,andavailabilitymayvary.Ourlocalstoresdo
nothonoronlinepricing.Pricesandavailabilityofproductsandservices
Openuntil9PM!
aresubjecttochangewithoutnotice.Errorswillbecorrectedwhere
NorwalkLowe's
discovered,andLowe'sreservestherighttorevokeanystatedofferand
tocorrectanyerrors,inaccuraciesoromissionsincludingafteranorder
hasbeensubmitted.

FindaStore

poway FIND

10
[ MurrietaLowe's SHOPTHISSTORE
24701MadisonAve
Murrieta,CA
48.4mi

11
[ MenifeeLowe's
30472HaunRd SHOPTHISSTORE
Menifee,CA
55.6mi

12
[ SanClementeLowe's
907AvenidaPico SHOPTHISSTORE
SanClemente,CA

Smith Engineering Exhibit "B"

56.7mi

13
[ LakeElsinoreLowe's
29335CentralAve SHOPTHISSTORE
https://www.lowes.com/store/ 1/2
 29335CentralAve SHOPTHISSTORE
LakeElsinore,CA
59.8mi

14
[ HemetLowe's
350SouthSandersonAve SHOPTHISSTORE
Hemet,CA
67.7mi

15
[ AlisoViejoLowe's
26501AlisoCreekRd SHOPTHISSTORE
AlisoViejo,CA
69.0mi

VIEWMORE

Report
Map data 2017 a map error
Google, INEGI

Need Help?
Call18004456937

Products & Sales

Call1877GOLOWES

2017Lowe's.Allrightsreserved.Lowe'sandthegabledesignareregisteredtrademarksofLF,LLC.

https://www.lowes.com/store/ 2/2