HomeMy WebLinkAboutLetter from Craig Maunders (Speaker #4)May 29, 2017
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To:
Whom it may concern
From:
Coalition Against LA
Fitness
(C.A.L.A.F)
Subject: LA Fitness Health Club Draft Environmental Impact Report
Weekday Vehicular Trip Estimates
Attachments:
Map, LA Fitness Garden Grove Site
Trip counting instructions
Example data record sheet
Blank data collection sheet
Data collection schedules, 4/26/17, e, 5/3/17
Data record sheets, 4/24/17 - 5/17/17
Spreadsheets 4/26/17, 5/3/17, including supplemental data (dated as
shown), 6 resulting totals
This paper describes a trip count effort undertaken in response to
concerns about the Low traffic impact assessment made by LSA on behalf of
the Shops at Rossmoor in the Draft Environmental Impact Report of March,
2017 related to an application for Conditional Use Permit for a project
to develop and install an LA Fitness health club on the Shops property,
in the city of Seal Beach, California.
. in Summary
The retained Traffic Consultant (LSA) concluded that there would be, at
most, 1,218 trips per weekday. (This is based on the proposed 37,000
sq.ft. gross floor area and national estimates of health club traffic
provided by the Institute of Transportation Engineers Trip Generation
(ITE TG), 9th edition.) However, our research (including the opinions of
knowledgeable people, such as gym club attendees and long -time employees
of gyms) suggests that this ITE- derived number understates the real
impact.
Given the significance of this figure, not only as the linchpin of the
traffic analysis undertaken by LSA, but the noise analysis performed by
Veneklasen Associates, Inc., and the Air Quality analysis undertaken by
IMG, which all rely upon it, we performed a study to test the analysis.
Specifically, we engaged volunteers to study the actual impacts at the
nearest LA Fitness facility, in Garden Grove.
our actual counts recorded the equivalent of 2,953 and 3,050 trips on two
days in April and May (we adjusted the actual numbers downward to reflect
that the Seal Beach site is roughly 10% smaller). These numbers - over
2.4 times as high - are in startling contrast to the applicant's figures.
Since there is such a gross disparity between the LSA figure derived from
the ITS TG and the equivalent counts derived from actual data, we submit
• that these findings cast serious doubt on the validity of the entire EIR.
City Staff, the Planning Commission, and the Council should carefully
consider whether to rely on the SIR without requiring substantially
further analysis.
The Plen
In order to "sanity check" the 1,218 figure, we obviously could not
perform a count of the proposed project, so we sought a surrogate LA
Fitness site to serve as a substitute. Preference was for a site with a
minimum number of driveway entrances to be monitored, and a minimum of
unrelated businesses directly adjacent to it so as to simplify the
discrimination of vehicle trips.
Sites in the cities of Downey, Long Beach, Fountain Valley and Garden
Grove were considered based upon their proximity to the proposed site, or
easy accessibility via freeway. Finally, the site on Valley View and
Chapman streets (see map, attachment 1) in Garden Grove was selected due
to its having only one directly adjacent business ( Walgreens), its known
area, 41,000 sq. ft., and its proximity to the project.
Automated equipment cannot discriminate between a driveway entry destined
for the LA Fitness, versus one destined for Walgreens. Thus, volunteer
observers were sought to visually separate the two, counting the former's
combined arrivals and departures, since traffic analysis counts both legs
of travel.
Since the layout of the parking areas preclude a single observer from
40 seeing all during the busiest times of the day, two observers were
scheduled. At the volunteer's option, the largest combined parking area
A 6 B was further subdivided into driveway 1 arrivals and departures vs
all others. As a result, at times there were as many as three observers
counting the arrivals and departures of their own respective areas.
Before the count, all observers were provided with the map, a set of
instructions (attachment 2), along with an example data collection sheet
(attachment 3), and blank collection sheets (attachment 4). Volunteers
were encouraged to dry -run a session, or attend an orientation and QSA
period prior to their scheduled data collection session. Most sessions
were two -hours in length, with a few exceptions including the starting
and ending sessions which sought to gather pre- opening and post - closing
trips.
The chosen weekday day -of -week was arrived based primarily upon when the
most volunteers would be available. A schedule (attachments 5) was
distributed to each volunteer so they were aware of their shift on -site.
The instructions detailed preferred observation locations.
On the first date selected 4/26/17, it was soon discovered that arrivals
to the overflow lot D behind the Walgreens was used by LA Fitness
customers much earlier than thought. This was corrected on the second
date selected 5/3/17, to avoid the lost counts.
•
• the count
The record sheets collected arrivals with LA Fitness customers, as
determined by customers leaving their cars, or parking in a location,
e.g. lot B. where the only business to be accessed without visibly
crossing the lot as a pedestrian, was the LA Fitness. Sheets were
collected immediately following the recording, or were handed off to a
count lead on a following day.
Since some of the observers chose to use clickers, the resolution of the
time recorded may have been coarser than the nearest minute, as these
were off - loaded to the paper record every 10 to 20 minutes or so. As can
be seen from the record sheets (attachments 6), some found it easier to
use tally marks, where others preferred to use digits.
Wherever possible, recording time(s) were used to avoid duplicate counts
at shift change -over, since often the incoming observer occasionally
positioned themselves to a slightly different position to begin, before
the outgoing one concluded their count and would otherwise have resulted
in overlap. Where there was a gap between records, the possibility of
lost counts were presumed to be negligible.
Prior to one session, 6:00 A.M., 4/26/17, a volunteer cancelled and could
not be replaced in time. This resulted in the scheduled session being
unobserved. Data from a dry -run on 4/24 for that time period was
• substituted. In addition, after count start, one shift observer reported
that they were confused about the instructions, and were counting LA
Fitness arrivals only, not arrivals and departures. Since the resulting
count could not just be doubled due to the difference between arrivals
and departures for any given shift, substitute data from a later day -
5/1/17 was collected and included in the totals.
The totals
Where data sheet columns were provided on observers' record sheet, these
data were entered from top -down as a summing formula into an Excel
spreadsheet (attachment 7) for the shift / observer. This process was
repeated from the bottom -up and compared to detect any error. Then, a
(negative) adjustment was included if there was an overlap between the
recorded timed counts of an ending session and the beginning of the next
session. This resulted in an observer subtotal, and these were combined
for a shift subtotal. The shift subtotals, then, were combined for a
daily total.
The data then were reviewed to observe trip activity trends over a day.
This unexpectedly highlighted a few anomalously high counts which might
have suggested errors in counting or recording. New data was collected
for the 4 -6pm shift of 4/26, and the 6 -8am and 12 -2pm shifts of 5/3. The
• original data, as well as the new data (having smaller subtotals), and
revised totals resulting are contained in the spreadsheets.
In arriving at an equivalent, i.e. 37,000 sq. £t. count, the final totals
were multiplied by a 37/41 factor to reflect the smaller facility gross
floor area being proposed vs the surrogate being counted. This maneuver
is predicated on the same assumption made by the ITE, that the Trip count
can be determined (at least in part) by scale from the gross floor area.
conclusion
Since there is such a gross disparity between the LSA figure derived from
the ITE TG (1,218) and the equivalent counts of 2,953 and 3,050 derived
from actual data, we submit that these findings cast serious doubt on the
validity of the entire EIR. City Staff, the Planning Commission, and the
Council should carefully consider whether to rely on the EIR without
requiring substantially further analysis.
Prepared by:
•
Z
Craig aunders Date
S. l
Approved by:
6 zsli-7
evin Pearce Date
President,
Coalition Against LA Fitness
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