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Supplemental Information Received During Public Hearing Communications Item I
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N EO O U E — E U CU O C 0) O M M N E c cn O L cn L cn a C A�` in W C) U C) L6 O CL CU CO OOr W Q i ^^`` r� r U) (n •N U2 uz u: 0 0 v o U! � bA v UPS R. W Y Y N Y m 6J R y` O 0 o m o 0 0 4i v 1. N p w H v Ql p, 1. aJ R R N R N R v l0 v co v N v N v 0 v [d N Yl Y b O N o v w tb ° Y U H v ca y N v w y [n ° A h p d N U O Q ca L L O m E L uj 02 M m cn M CU L cn �m cn L L H O Q.. N EO O U E — E U CU O C 0) O M M N E c cn O L cn L cn a C A�` in W C) U C) L6 O CL CU CO OOr W Q i ^^`` r� r U) (n buo c 4-J L O CL CL V) Helen G. Arens 4532 Fir Ave. Seal Beach, CA 90740 (562)799 -0837 September 11, 2017 Seal Beach City Council City Hall Conference Room 211 Eighth Street Seal Beach, CA 90740 [VIA PERSONAL DELIVERY] ATTN: Sandra Massa - Lavitt, Mayor Mike Varipapa, Mayor Pro Tem Ellery A. Deaton, Council Member First District Thomas Moore, Council Member Second District Schelly Sustarsic, Council Member Second District Re: Support for approving Certification of Final EIR and approving CUP 16 -7 to Construct a 37,000 Sq. Ft. Fitness Club (Fitness Center) at 12411 Seal Beach Boulevard Dear Council: I own a house in College Park East and have lived in the area since 1991. I really miss the old Rossmoor Athletic Club that used to be at that location at Rossmoor Center (what is now called Shops at Rossmoor). I joined that gym back in 1993 only to see it disappear about a decade later, after it had been there since 1975. There are no big affordable gyms in Seal Beach like that anymore and we need one. The little boutique workout places in Seal Beach are too expensive and don't have much to offer. The Rossmoor Athletic Club was a big 2 -story gym and it fit that location just fine. The building was huge and went quite a ways back. It had basketball courts, an aerobics studio, a cardio machine room, raquetball courts, squash courts, a speed circuit room, a coed weight room, a women's weight room, a sauna, a juice bar, and a childcare room. It was about the size of a typical L.A. Fitness. It was open 7 days a week, usually 5:30 am to 10 pm. I still have my old paperwork from there with the schedule. (See Enclosed fliers from there.) That huge 2 -story gym was outside those Rossmoor condos' windows for decades and it did not bring crime, endanger children, ruin anyone's quality of life or clog traffic. But a local podiatrist did set a free throw world record on its basketball courts in 1993. Of course things have changes since then, however, none of those changes militate against a gym at Rossmoor Center. If anything, with obesity at epidemic rates now, we need gyms more than ever to work off those In -n -Out burgers. If the concern is traffic, where were all the yellow yard signs when they were talking about putting in the In -n -Out drive- through? It is terrible for our health, unlike a gym, and causes way more traffic. Just compare the line of cars to the In -n -Out in Rossmoor Center to the quiet parking lot in front of the L.A. Fitness at Valley View and Chapman. I have been a member of that L.A. Fitness for about a decade now, and have not observed any crime on its premises. It certainly does not have any more crime any other location in the immediate neighborhood. But you don't have to believe me, just visit the City of Seal Beach City Coucil September 11, 2017 Page 2 Garden Grove's police department website, http: // www.ci.garden- grove.ca.uVpolice , and click on the "Visit the Dashboard" button to get crime statistics. If you click the map to show all crimes for the last year that occurred at that LA Fitness location, including car break -ins and robberies, you will see there was nothing. (See attached printout from website.) The only crime statistics I have seen cited by gym opponents tend to be in high crime neighborhoods, which this is not and hence not instructive. The Valley View LA Fitness is a much better example. It appears this is mainly about parking for the Rossmoor condos, judging by the 12052 Montecito Road, Rossmoor address of the articles of incorporation for the Internal Revenue Code section 501(c)(3) (later amended to 401(c)(4)) entity, the Coalition Against LA Fitness Project, that was formed to oppose the gym, The fact is this is a shopping center, not the condos' personal parking lot. The condos need to build or purchase parking for their residents, not poach spaces from our shopping center. An LA Fitness will not cause injury to the Rossmoor condo owners. They knew they were buying condos with inadequate parking next to a shopping center. If they want their own personal parking in the shopping center, they could do a special assessment through their HOA to purchase or lease property from the shopping center. They should not deny us a gym in order to get free parking trespassing on Rossmoor Center property. The health benefits I receive as a member of LA Fitness cannot be obtained by simply walking or working out on my own. We need to work with weights, especially as we age. Muscles bum fat and prevent falling. As a Stage III breast cancer survivor, I know keeping my weight down and staying fit is important to prevent recurrence. LA Fitness offers two great weights classes, "Power Circuit" and "Body Works Plus Abs." Those classes motivate me to work out like a personal trainer would, but LA Fitness only charges me $29.95 a month for unlimited classes and use of the gym. That is a tiny fraction of what the local Seal Beach boutique gyms cost, and none of those gyms offer classes like that. The closest LA Fitness to me is the one on Valley View in Garden Grove. If we had one in Rossmoor Center, I'd be able to easily go there 5 days a week, like I did when I belonged to the old Rossmoor Athletic Club. And it wouldn't result in any additional car trips. I already go to the Rossmoor Center pretty much on a daily basis, and have been for decades. I bank there at F &M, I eat there, I shop there. I drive by there every day to and from taking my kid to Oak Middle School, and will continue to do so when he is in Los Alamitos High School. In fact, having that gym there would reduce car trips since I wouldn't be driving to Garden Grove any more. I sincerely believe a gym at that location is what is best for our community. Seal Beach needs the tax revenue. I attended the last City Council meeting and learned we can't even afford a full -time dog catcher. We also need a big affordable gym, for our health. I urge you to approve Certification of the Final EIR and CUP 16-7 to Construct the Fitness Center. Sincerely, /Helen G. Arens Encl. FOR OFFICE USE ONLY 2. 3. 4. THIS CONTRACT IS BETWEEN NAME LAST- A l9 ? S Lf EXTRAS: �u Rossmoor Athletic Club "building better bodies since 1975° AND: FIRST 7 % %,0 MIDDLE INITIAL' �. ,`r, I SeafltmchCaljoraia NI/ John Redar I Membership Director 12235 SEAL BEACH BOULEVARD AID S -V MO-o/ _ SELL B SEAL BE ALIFO BOULEVARD 777�✓✓i V 3101 493 -4418 r FAX 310 / 493 -6271 Racquetball • Child Care Sea c%1, C �egrRla 9 National Academy of Basketball (full court) - Sports Medicine mtsh - er Coed Gym (31®) 4934418 Sqguash Aerobics - Etc... - -- e on exercise routines and diets that won't give you the results your looking for, do it right from the start, have'a Personal Trainer design an individual exercise and nutrition program that suits your personal goals and needs. Programs Offered Sport Specific Training Exercise Programs designed to improve your'Strength, Flexibility & Performance for a Specific Sport. Body sculpting Exercise Programs designed to reshape & Sculptyour body how you want it. Targeting Problem Areas. Weight Loss Programs Exercise & Nutrition Programs designed to promote the. fastest possible weight loss safely. Advanced Truiining,Techniques For the experienced weight trainer* Programs designed to Shock the Muscles into New Growth to get over Plateau and sticking points. NOT FOR THE MEEK! -Strength Training Exercise Programs designed to increase strength with minimal muscular size; increases. ALSO POWER TRAINING TECHNIQUES.' Injury Rehabilitation Post Therapy Exercise Programs designed to Strengthen, Rehabilitateand improve Flexibility.,,. SO IT DOESN'T HAPPEN AGAIN! Weight Spain Programs Over So wellness Programs, Exercise & Nutrition Programs that promote Exercise Programs for Seniors to add life to the fastest - Weight & Muscle Gains. your years as well,as years to your life. Single Session.. $41 U. 1 17% mj n-, El act C6 E a C6 r., C6 C6 U2 T E E CL2" I C) C:, n a % in * - . 'C= in en fn rA CD p co :z cm Cl c T R 10 zu, a% %n I CD O CD In C) rf rn in M Z CD M m en U. ti Co O CD Qj kn CZ en Z CD In cnz : , 'Z en 4 IR C4 65 .. IR 'R tz rn C) 4R -Q M in fn Go fm V. I cz zti IR en en cm 05 fn 0 U CD CD Act No a% 0 3 U O U m f7 E C m E U N _i N ° a 0 30 o' o" E - 1$ o�o N N N P P N O q N N N N N N H N H m P N VI P M O N i° n� N N H N H n N N N P •1 Y N - 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Q �C 0 l 1 l m m0 l 1 l ° ♦ l ♦ ♦ 1 ♦ 1 u l ♦ 'n' Ss G r 1mDDDDDC>DD fjj Onyx st A11.1f YI, S! ,W Turps: se St 0 Valley Wev, St C) >1 �.OnCga:eLn 1b C0 j Y - carolild 5{ Sr - Rebekah Baird From: Robin Roberts Sent: Monday, September 11, 2017 2:35 PM To: Rebekah Baird Subject: FW: Item I Correspondence for 9.7.17 Attachments: Correspondence 9.7.17.pdf, image002.png From: Crystal Landavazo Sent: Thursday, September 07, 2017 5:22 PM To: Jill Ingram; Robin Roberts Subject: Item I Correspondence for 9.7.17 BCC: City Council Good Afternoon, The agenda packet delivered on September 7, 2017 contained all project correspondence up to September 6, 2017 at 6:00 p.m. The attachment to this email contains all correspondence received since that time. We will send an email at the end of each day with the correspondence collected from that day. Please let me know if there is any trouble opening the attachment. Respectfully, Crystal Landavazo, Interim Director of Community Development City Of Seal Beach - 211 Eighth Street, Seal Beach, CA 90740 (562) 431 -2527, Ext. 1324 For Information about Seal Beach, please see our city website: http: / /www.sealbeachca.aov NOTICE: This communication may contain privileged or other confidential information. If you are not the intended recipient of this communication, or an employee or agent responsible for delivering this communication to the intended recipient, please advise the sender by reply email and immediately delete the message and any attachments without copying or disclosing the contents. Thank you. ROSSMOOR COMMUNITY SERVICES DISTRICT t;< . `s ♦ 3001 BLUME ORME, ROSSMOOR, CA 90720 / (562) 430-3707 / FAX (562) 431 -3710 September 7, 2017 Jill Ingram City Manager City of Seal Beach 211 8" Street Seal Beach, CA 90740 Dear Ms. Ingram, President Michael Maynard, representing the Rossmoor Community Services District has inquired about the City of Seal Beach's procedures for handling the public hearing on the Proposed Shops at Rossmoor LA Fitness Club Project scheduled for Monday, September 11, 2017. Specifically our question is dependent on the ultimate outcome of the public hearing. Will the Seal Beach City Council have resolutions prepared in advance to support or deny the appeal of the EIR and/or the CUP? The objective would be to hopefully bring closure to this issue. Best Regards, James D. Ruth General Manager Rossmoor Community Services District Cc: Seal Beach City Council �t� Pi*'.., vats M1 -"'�_. - ..;- .+r�,.��ayk���•_ Schelly Sustarsic September 1, 2017 Seal Beach City Hall, 211 8`h St. Seal Beach, CA 90740 Dear Ms. Sustarsic, I have been a Seal Beach resident for 17 years and reside in a condo directly west of where LA Fitness wants to build. I have been a member of fitness centers for over 30 years and I feel the choice of location in the Rossmoor Center is the poorest choice this company could make. I don't need to list the negative reasons for the building as they have been presented at the City Hall meetings. I- have- a- concern -that-has - not - been - addressed -at - these - meetings. It has been mentioned that the negative reasons have come from Rossmoor residents. Well, I wish to bring to your attention the number of Seal Beach residents that live closest to the proposed location. My condo has 54 units and the condo to the north of mine has 255 units. If you average 2 residents per unit (which is low) that totals over 600 residents. The condos to the south of my condo have approximately 170 units or over 300 residents. This means close to 1000 SEAL BEACH residents will be living in close proximity to the fitness center. Vote against this project. S incerely, Adele Brown Adele Brown �t C-.j pit: ': Mike Varipapa September 1, 2017 Seal Beach City Hall, 211 8t' St. Seal Beach, CA 90740 Dear Mr. Varipapa, I have been a Seal Beach resident for 17 yearsf and reside in a condo directly west of where LA Fitness wants to build. I have been a member of fitness centers for over 30 years and I feel the choice of location in the Rossmoor Center is the poorest choice this company could make. I don't need to list the negative reasons for the building as they have been presented at the City Hall meetings. I- have- a-concern -that has -not been- addr - essed -at- these- meetings. -It- has been mentioned that the negative reasons have come from Rossmoor residents. Well, I wish to bring to your attention the number of Seal Beach residents that live closest to the proposed location. My condo has 54 units and the condo to the north of mine has 255 units. If you average 2 residents per unit (which is low) that totals over 600 residents. The condos to the south of my condo have approximately 170 units or over 300 residents. This means close to 1000 SEAL BEACH residents will be living in close proximity to the fitness center. Vote against this project. Sincerely, Adele Brown Adele Brown Ellery A. Deaton September 1, 2017 Seal Beach City Hall, 211 8' St. Seal Beach, CA 90740 Dear Ms. Deaton, I have been a Seal Beach resident for 17 years and reside in a condo directly west of where LA Fitness wants to build. I have been a member of fitness centers for over 30 years and I feel the choice of location in the Rossmoor Center is the poorest choice this company could make. I don't need to list the negative reasons for the building as they have been presented at the City Hall meetings. I- have -a- concern- that- has- not _ been - addressed - t- these - meetings. -It has been mentioned that the negative reasons have come from Rossmoor residents. Well, I wish to bring to your attention the number of Seal Beach residents that live closest to the proposed location. My condo has 54 units and the condo to the north of mine has 255 units. If you average 2 residents per unit (which is low) that totals over 600 residents. The condos to the south of my condo have approximately 170 units or over 300 residents. This means close to 1000 SEAL BEACH residents will be living in close proximity to the fitness center. Vote against this project. Sincerely, Adele Brown Sandra Massa - Lavitt September 1, 2017 Seal Beach City Hall, 211 8" St. Seal Beach, CA 90740 Dear Ms. Massa - Lavitt I have been a Seal Beach resident for 17 years and reside in a condo directly west of where LA Fitness wants to build. I have been a member of fitness centers for over 30 years and I feel the choice of location in the Rossmoor Center is the poorest choice this company could make. I don't need to list the negative reasons for the building as they have been presented at the City Hall meetings. I have -a- concern -that has -not been- addressed -at these - meetings.. It has been mentioned that the negative reasons have come from Rossmoor residents. Well, I wish to bring to your attention the number of Seal Beach residents that live closest to the proposed location. My condo has 54 units and the condo to the north of mine has 255 units. If you average 2 residents per unit (which is low) that totals over 600 residents. The condos to the south of my condo have approximately 170 units or over 300 residents. This means close to 1000 SEAL BEACH residents will be living in close proximity to the fitness center. Vote against this project. Sincerely, Adele Brown Adele Brown Beach, •' 90740 Thomas Moore September 1, 2017 Sea] Beach City Hall, 211 8" St. Seal Beach, CA 90740 Dear Mr. Moore, I have been a Seal Beach resident for 17 years and reside in a condo directly west of where LA Fitness wants to build. I have been a member of fitness centers for over 30 years and I feel the choice of location in the Rossmoor Center is the poorest choice this company could make. I don't need to list the negative reasons for the building as they have been presented at the City Hall meetings. 1- have- a- concern -that has -not been- addressed -at- these - meetings. It has been mentioned that the negative reasons have come from Rossmoor residents. Well, I wish to bring to your attention the number of Seal Beach residents that live closest to the proposed location. My condo has 54 units and the condo to the north of mine has 255 units. If you average 2 residents per unit (which is low) that totals over 600 residents. The condos to the south of my condo have approximately 170 units or over 300 residents. This means close to 1000 SEAL BEACH residents will be living in close proximity to the fitness center. Vote against this project. Sincerely, Adele Brown Steven Fowler From: Pat Kearns ND Sent: Thursday, September 07, 2017 4:23 PM To: Ellery Deaton; Thomas Moore; Sandra Massa- Lavitt; Mike Varipapa; Schelly Sustarsic Cc: Jennifer Robles; Crystal Landavazo; Steven Fowler Subject: Approval of growth to Shops at Rossmoor Dear Council People, I know you will have a huge crowd of Naysayers at your meeting Monday night, 9- 11 -17, I'm sorry I won't be there. I have written to you before on this subject and I'm very concerned that interfering with the "Shops at Rossmoor" full buildout saddles the City with Commercial property that is not performing to its full potential as a source of revenue for Seal Beach. You and staff know only too well how the EIR has addressed the mitigation issues and points the way to a safer and more desirable full service center. This is a project that is not being developed to hurt our neighbors. The latest flyer by CALAFSB is very splashy but their bullet points are completely unfounded and misleading, There are very few Rossmore houses near the "Shops At Rossmoor" and the Center has been there in various configurations since the first Rossmoor houses were built. Rossmoor has been a premium community since the first house sale, no matter how the Center was configured. And it will continue to be after LA Fitness is in full operation. Please drive through Rossmoor prior the Monday night or google the map of Rossmoor. The two Parks and four schools are nowhere near the Center. In fact, because of the 4 -story Condos on Montecito Rd. people on that street can not see nor hear what is happening within the Center. The Rossmoor community has a very active home owners association that can and should control the traffic in their community to control parking violations, risk to children walking, skating, bicycling and playing in their streets; and working with the County to control crime within the Community. Seal Beach has always operated to provide for the basic safety needs for its citizens and its neighbors. The City of Seal Beach should take advantage of this major development, the Property and Sales taxes will be substantial. Utility fees will also improve the revenue for this service. Planning and building permits are added income. This project and others proposed for this Center, as- well -as the many finishing or just finished in Old Town will continue to add revenue to the city, which could go along way in improving risk and crime management. I understand the will be a risk and crime management "town hall" meeting later mis moron. News reports in tree -SUN are scary, and snow the need for such a meeting and more action. Added income is important to the City. Thank you for your consideration, Pat Kearns r. 7--7 .� ,� Steven Fowler From: James Wethe Sent: Wednesday, September 06, 2017 8:31 PM To: Sandra Massa- Lavitt; Mike Varipapa; Ellery A. Deaton; Steven Fowler; Brian McKinney; Leslie Medina; michelle.steel @ocgov.com; Schelly Sustarsic; Thomas Moore; Crystal Landavazo; Building Official; coalitionagainstlafitness @gmail.com; Michelle.Steel @ocgov.com Subject: Opposition to LA Fitness Attachments: LA Fitness Appeal.docx Dear Elected Officials- I am writing to you to strongly oppose the LA Fitness appeal for a use permit to build in the Shops at Rossmoor. I have attached a letter which outlines the very basics of my concerns. I would appreciate it if you would take the time to read my letter and understand that I kept the letter to one page in consideration of the value of your time. Certainly I have many other concerns and would be happy to discuss them with any of you should you so have an interest. Sincerely James Wethe Rossmoor, CA 90720 September 4, 2017 Dear Elected Official: I am writing to you today to let you know my feelings about the upcoming appeal regarding placing a LA Fitness gym in the Shops at Rossmoor. I could not be more opposed to this plan. I am sure you have heard the arguments against this proposal before but please indulge me as I summarize some of my concerns: Traffic- Already a nightmare in the Shops at Rossmoor and their traffic mitigation plan is so seriously flawed that it ignores simple common sense. Rossmoor /Seal Beach will be severely negatively impacted by the increased car volume with no solution. Noise- There is no measure that will limit or curtail the significant noise pollution that those who live virtually on top of the proposed site will have to suffer. Crime- Situated in the back portion of a busy shopping center with extended hours and known issues of cars being broken into occurring at other fitness center locations in the area. This type of facility invites criminal activity whether they accept that fact or not and the location makes this much more likely. Safety- The adjacent residential streets would be even more crowded than they currently are... and significantly so. This is a family /residential neighborhood and the idea of markedly increased traffic is a major concern and a severe= worr -y "for -all- who- live - here - regarding- safe - passage -of children,- the - elderly, and virtually everyone who lives here. I could continue endlessly about these and even more concerns but I have purposefully limited this letter in the hope that you will both read it and understand the reasoning behind my strong opposition to the appeal regarding LA Fitness. Quality of life and a "small town feel" are key to me and my family and mimic the values our neighbors in Seal Beach state are the goals for their own community as well. Please uphold the denial regarding LA Fitness in the Shops at Rossmoor... please do not destroy the quality of life for those of us who live here. Sincerely, James Wethe Rossmoor. CA 90720 Steven Fowler From: Nita Woolston Sent: Thursday, September 07, 2017 1:23 PM To: Steven Fowler Subject: NO LA FITNESS. Dear Mrs Michelle Steel. Please say NO TO L.A.FITNESS The location ware they are planing to build is Not Facing Seal Boulevard THE BUILDING WILL BE BETWEEN THE BACK OF SPROUTS MARKET AND THE RESIDENCES OF ALONG MONTECITO ROAD. This is a very bad location for a Gim with all the cars coming and going at all hours , like from 5:00 AM. To 11:00 P.M., No enough road space for the cars, trucks that they bring the products for the stores ,noise and the worse of all is the safety for the children that have to go to school in the Rossmoor. . The location is NOT the wright one for this kind of business Please NO FOR L.A.FITNESS. Thank you Sincerely Encarnacion P. Roehm 1 August 16, 2017 To the Seal Beach City Council regarding the proposed LA Fitness in Rossmoor: This letter is to voice my objection to the LA Fitness in Rossmoor. I don't believe I have anything different to add that others have not already said. It's a terrible location; the traffic is already awful trying to enter or leave that area; there are several gyms within a few mile radius, etc. I'm sure you've heard these, and more. I do want to add this though. When does quality of life trump corporate greed? Thank you in advance for your consideration in this matter. 9ulte 'Wic(�ser )(A,6czr-� Crime Experience Seal Beach City Council Meeting September 11, 2017, 7:00 p.m. Good evening Madam Mayor, council members and staff. I am Diane Rush; I live in Rossmoor. Criteria offered in the CUP and FEIR do not adequately address crime associated with large health clubs. In general, these studies focus on short-term goals of the developer without consideration for the long -term synergistic effects of this project's enormity and proximity to a vital residential area. Crime statistics associated with LA Fitness are legion. For thirteen years I lived across the street from a health club. Even though the police department dedicated a unit to the parking lot, physical assaults, auto thefts, home invasions, drug dealing and vandalism escalated. The police officer addressing our Neighborhood Watch stated that fitness centers are "magnets for crime." The proposed location of this project would create a giant alley concealed from street views with late hours of operation. Youth riding or walking through the center would be most at risk. I interviewed a victim of LA Fitness crime, Rossmoor resident Maria Georgakopoulos. Her car was broken into at the LA Fitness Center on Valley View, July 3. Her handbag was stolen and credit cards immediately charged at the Target in Westminster Mall. The LA Fitness manager offered no assistance to Maria. Researching news articles I found that LA Fitness International LLC recently paid a 3.8 million - dollar settlement to resolve a class- action lawsuit for using deceptive contracts and charging for bogus services. A 5 million pending class- action lawsuit with over 100 complainants, includes 6 violations of Federal and California State consumer protection laws as well as the California Financial Elder Abuse Act. In addition to mounting federal cases, online reviews corroborate legal allegations of contract fraud and unauthorized electronic withdrawals from clients' accounts. Fitness centers have a life -cycle of 10 years due to unsustainable membership numbers, poor maintenance and notorious billing practices. Hiring of convicted felons for personal trainers and managers and policy of not drug testing prospective employees are responsible for ever - increasing litigation costs of LA Fitness Centers nationwide. A 37,000 sq. ft. "magnet- for - crime" with unethical corporate culture will negatively impact Seal Beach and Rossmoor residents. Ask yourselves if you are prepared to dedicate a police unit to the proposed LA Fitness site which will inevitably foster crime. Please reject the certification of the EIR and deny the CUP request. Thank you for your consideration. Crime Experience / Diane Rush / Coalition Against LA Fitness / September 11, 2017 Page 1 of 2 LA Fitness Lawsuits and Fraudulent Modus Operandi Links: (LexisNexis) https: / /www.law360. com /articles/ 470757 /la- fitness -to- pay- 3- 8m -to- settle - bogus- contract -suit (Club Industry) http: / /www. clubindustry. com /profits /federal- iudge- denies -la- fitness - arbitration - bid- membership- billing- lawsuit (Top Class Actions) https: / /topclassactions. com /lawsuit - settlements /lawsu it- news / 311718 -1- fitness - hit- membership- con-class-action-lawsuit/ (Consumer Aff airs) https: / /www.consumeraffairs.com /health clubs /la fitness.html (LA Fitness Hiring Practices Answered by Employees) https: / /www. i ndeed. com /cmp /La- Fitness /fag/ does -la- fitness -do -a- background- check -for- personal- trainers ?quid =1 bi49olf10mto3il and https: / /www.indeed.com /cmp /La- Fitness /fag /do -they- hire - felons ?quid =1 biel pc9al bg97e4 (Pissed Consumer) htti)s: / /la- fitness. pissedconsumer. com/ crime -at- the -club- 20161011934856. html (Royal Oak Patch — Health and Fitness) https:/ /patch. com /m ichigan /rovaloak/la- fitness - crime - out -of- control - -70- police- reports (Sun News) http: / /www. sunnews. org /latest- news /quest- column -la- fitness - could- effect -us -all/ Crime Experience / Diane Rush / Coalition Against LA Fitness / September 11, 2017 Page 2 of 2 M Good evening and thank you for your time. My name is Ned Brines and I'm a member of the Coalition Against LA Fitness. There has been significant concern in the community about the possibility of an increase in crime with the addition of a LA Fitness in the Shops of Rossmoor. Therefore, our Coalition contacted three surrounding police departments as well as the Seal Beach PD and requested their police activity records for four large scale health clubs. YOU WILL FIND THE RESULTS OF THIS SURVEY INSIDE YOUR PACKET. The survey covered: 1) 24 HOUR FITNESS (KATELLA): CITY OF CYPRESS 2) LA FITNESS (VALLEY VIEW): CITY OF GARDEN GROVE 3) 24 HOUR FITNESS (SPRING ST. AND BELLFLOWER): CITY OF LONG BEACH 4) LA FITNESS (BELLFLOWER BLVD): CITY OF LONG BEACH We also conducted an interview with the Watch Commander of the Cypress police department to learn more about police work involving health clubs: he most predominate crimes were • CAR THEFTS • BURGLARIES INSIDE AND OUT OF CLUB • PETTY THEFT • VANDALISM Page 1 of 3 ADDITIONAL TYPES OF CRIME AND POLICE WORK RETLATED TO HEALTH CLUBS • 911 CALLS AND EMERGENCY HEALTH RELATED ISSUES • WELFARE CHECKS AND HOMELESS PEOPLE IN LOT OR IN THE LOCKER ROOM THAT NEED TO BE REMOVED • HIT AND RUN ACCIDENTS IN LOT ... DENTS IN CARS WHEN PEOPLE COME OUT • SUSPICIOUS PERSON IN LOT OR CLUB • DISPUTES AT COUNTER • FIGHTS IN THE GYM • INDECENT EXPOSURE AT POOLS • DRUGS IN PARKING LOT and INTOXICATION The police officials we have spoken with from Garden Grove, Seal Beach, Long Beach and Cypress have told us that locations with the following characteristics create ideal locations for criminal activity: a. A busy parking lot with late operating hours b. An area concealed from street view c. Venue with limited access by police d. close proximity to freeways e. near an affluent, unsecured neighborhood This exactly describes the area where the LA Fitness would be located. The conclusion was that there is a significantly higher incident of crime in and around health clubs than found at comparably located businesses. These Page 2 of 3 Statistics are a matter of fact. They are not subjective or exaggerated. They were obtained from Local Police Departments who are neutral parties in this debate. They should not be ignored or swept aside. The crime will not be limited to just the LA Fitness and its parking lot. Some will spill over to other areas of the shopping center and the surrounding community. We realize that the property owner needs to develop this space but LA Fitness is just not the right fit. There are other options that need to be explored that would bring a successful business to the area that would not be so intrusive to the surrounding community. We respectfully request that you reject the certification of the EIR and deny the CUP request. At a minimum, we request that you direct staff to order a new EIR correcting the many deficiencies we have pointed out, including doing a proper traffic study, as urged by the County of Orange. Page 3 of 3 CRIME: Calls for service DATE: January 1, 2016 to May 17, 2017 LOCATION: 24 Hour Fitness at 3030 Bellflower Blvd, Long Beach, Ca. Table below indicate total of crimes and other activity during reporting period. Extracted data 1 L AA T IN LOT Lid kilt D MUSIC 19 7 9 11 12 3 11 12 3 3 139 131 4 4 3 3 5 5 2 2 5 5 1 i 1 3 1 3 143 1 246 Long�>3edch PohcD,epartment p. �a���,Cr1me��lnalysisCi'Int -.�. r CRIME: Calls for service DATE: January 1, 2016 to May 17, 2017 LOCATION: L.A. Fitness at 2180 Bellflower Blvd. Long Beach, Ca. Table DISPUTES VEH CAR CHECK UALLJ, �nArF.RV /HIT AND of 3 3 15 is 9 9 9 9 4 4 1 1 10 10 1 1 2 2 2 2 1 1 5 s 1 1 7 7 4 4 74 74 ressPohceDepartment o Wo Information Request CRIME: Calls for service DATE: January 1, 2016 to May 11, 2017 LOCATION: 24 Hour Fitness at 4951 Katella Ave. Cypress Ca. Table below indicate total of crimes and other activity during reporting period. Extracted data 37xx e-`, -av sjr %�S ` .SA "1F �"t- GardenGl ovexYolce °Departments �'`Grime�lnalysisUniY fti k ° CRIME: Calls for service DATE: January 1, 2016 to May 12, 2017 LOCATION: L.A. Fitness at 11932 Valley View St., Garden Grove, Ca. 92840 Table below indicate total of crimes during re ortin eriod. r�t�'�' 4 ITM Yk. Sim I I • 4 - 4 AUTO THEFT 1 BATTERY 1 3 3 COMMERCIAL BURG 1 OFFICER'S REPORT 1 1 RECOVERED STOLEN 1 11 PETTY THEFT 11 1 TRAFFIC COLLISION 1 18 VEH BURG 18: 2 2 VEH VANDALISM 1 WARRANT 1 6 8 DISTURBING PEACE 17 17 SUSPICIOUS PERSON 2 INVESTIGATION COMPLETED 2 HIT AND RUN ACCIDENT 2 2 8 WELFARE/TRANSIENT /HOMELESS 8 DOMESTIC VIOLENCE 3 44 3 44 HANDLED AT SCENE 1 48 76 125 TOTAL MR ) k k ) k 0 \ ( � 310LA F \ \ \ §7§ (0/ ; |E ;§ / | 2 | I ■� | ) § � \ - \k / \\ � ■| ■ \ ) \ 0 k t,lpo,fnlO. � 4MEAVa Ke /! 0w ;8 ° | / § 0\ !; 10 | am f f! (( ; I M $/ "` ! T |I ; | | § §k � k � � MR ) k k ) k 0 \ ( � 310LA F \ \ \ §7§ (0/ ; |E ;§ / | 2 | I ■� | ) § � \ - \k / \\ � ■| ■ \ ) \ 0 k t,lpo,fnlO. � 4MEAVa Ke /! 0w ;8 §( §k , >PX.A�C,O! �° ME§§ OF ;m2�|| ;, ( `° {2 | § §k ( / §/ \f / §k c . ,....,.,,, )! - - -- §: &k)kkk)))) !!)! a § § §§§ § § §§ m! §§ .......... .... M §C "92#»§ HH9 § § § § §■ § § §§ H H �§§§ ƒ 2, ■ !a§ *!�+ (\ ;[ �§3■ � , � M a� V tip, It _ 10 -y + I -a- r k' w e l Y _ •T - t.?f _ i of - . 1 if S I r Y t p A 4o+ -r AL 0* r1 •S VIM 6 � T- ua Coalition Against LA Fitness Project Petition Counts (Current as of September 11, 2017) Zip code 90720 Zip code 90740 Zip code (other) (915) (579) (301) Total: 1,795 Petitions can be viewed at the City Clerk's office. l �I v hl r N O 2 U) U) O w 0 Q a m J Q w LL O z w J U a W J 0. O O O U f+ .O L ra7 a J t a N. N Q ^L W W ^V' W �3 3 0 d t— 3� � 0 }'rm L E E O V L O O O L 0 .Ch Q J (�pp-ee-11 t) (Z Coalition Against LA Fitness Project Petition Counts (Current as of September 11, 2017) r � Zip code 90720 (915) Zip code 90740 (579) Zip code (other) (301) Total: 1,795 BARRY A. ROSS A PROFESSIONAL CORPORATION 2 VENTURE, SUITE 450 IRVINE, CA 92618 Sent Via US Email rroberts@sealbeaclica.gov sealbeachca.gov September 6, 2017 Honorable Mayor, Members of the Seal Beach City Council and City Staff City Hall 211 Eighth Street Seal Beach, CA 90740 Attn: Robin Roberts, City Clerk Re: LA Fitness Projecl al The Shops at Rossmoor 949 - 727 -0977 949 - 727.9927 fax baffy&Ossrealestatelaw com www.rossrealestatelaw.com Dear Honorable Mayor. Members of the Seal Beach City Council and City Staff: My law firm represents The Coalition Against LA Fitness. My office is located at 2 Venture, Suite 450, Irvine, California, 92618. On behalf of The Coalition Against LA Fitness, I express my opposition to the pending proposal by CPT Shops @ Rossmoor, LLC to develop a 37,000 square foot fitness club at The Shops at Rossmoor Shopping Center ("Shopping Center') located at 12411 Seal Beach Boulevard, Seal Beach, California. The two matters before you are the conditional use permit ( "CUP ") and the environmental impact report ( "EIR "). Based on the information that has been presented to you and that will be presented to you prior to the time that you vote on these two matters, I respectfully suggest that you must vote "No" on both the CUP and the FIR. In the EIR, in section 9.0, entitled Responses to Comments on DEIR, there are opposition comments presented by more than 220 people. The vast majority of these comments are from residents of the community affected. Most of the comments express concerns relating to traffic and transportation. On this subject, the EIR states that there are no significant environmental effects. Section 4.4 -10. Are 220 of your residents wrong? I don't think so. September 6, 2017 Page 2 Equally important is the fact that no one other than the developer expressed an opinion in support of this project. Why does no one support this project? The FIR states that the only significant environmental impact of the project that requires mitigation is noise from the HVAC and temporary construction noise. Section 5.1. The EIR could not be more wrong in its analysis. THE APPLICATION FOR THE CONDITIONAL USE PERMIT SHOULD BE DENIED A. WHAT IS A CUP? "A conditional use permit is administrative permission for uses not allowed as a matter of right in a zone; but subject to approval." Sounhein v. City of San Dimas (1996) 47 CA.4th 1181, 1187 The point here is that a CUP is a discretionary permit. The City has a choice to decide whether or not it should be issued under the circumstances of this case. B. UNDER WHAT CIRCUMSTANCES SHOULD A CUP BE GRANTED? "A conditional use permit may be permitted if it is shown that its use is essential or desirable to the public convenience and welfare and at the same time that it will not impair the integrity and character of the zoned district. It must also be shown that it is not detrimental to public health, public morals, or public welfare." Tustin Heights Association v. Board of Supervisors of County of Orange (1959) 170 CA.2nd 619, 626 "It is appropriate and even necessary for the [local agency] to consider the interest of neighboring property owners in reaching a decision..., and the opinions of neighbors may constitute substantial evidence on this issue." Harris v. City of Costa Mesa (1994) 25 CA 4th 963, 973, quoting Desmond v. County of Contra Costa (1993) 21 CA.4th 330, 337 In Saad v. City of Berkeley (1994) 24 CA. 4th 1206, the court upheld the denial of a CUP for one single family residence because of the detrimental effect on nearby residential neighbors. After an extended hearing, based on the opinions expressed by over 220 neighbors concerning traffic, parking and other matters, the Planning Commission denied the conditional use permit. There is insufficient evidence presented supporting the findings necessary for the City to issue a CUP, and the City Council should affirm the decision of its Planning Commission. P. THE EIR IS INADEQUATE AND SHOULD THEREFORE BE DENIED. A. WHAT 1S REQUIRED FOR AN ADEQUATE EIR? An EIR must set forth the basis for its conclusion; a bare conclusion without an explanation of its factual and analytical basis is not a sufficient analysis of an September 6, 2017 Page 3 environmental impact. Laurel Heights Improvement Association v. Regents of the University of California (1988) 47 Cad 376, 404. If an EIR concludes that particular environmental impacts are not significant, it should explain the basis for that conclusion. Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 CA.4th 1099, 1111; San Joaquin Raptor /Wildlife Rescue Center v. County of Stanislas (1994) 27 CA 4th 713. The EIR in this case is woefully inadequate in explaining why there are no significant environmental effects for traffic, transportation and other issues discussed below. An EIR must propose and describe a reasonable range of alternatives to the project that have the potential to obtain most of the project's basic objectives, but would avoid or substantially lessen the significant environmental effects of the project. Public Resources Code Sections 21002.1 and 21100(b)(4); 14 Cal, Code Regs §15126.6. Project alternatives should include alternative locations as well as alternative designs. 14 Cal. Code Regs § 15126.6. The EIR provides an inadequate description of alternatives to the project, such as relocating the site of the fitness center to another location within the Shopping Center, reducing the size of the fitness center or selecting an alternative location for the fitness center outside the Shopping Center. An EIR must include a "no project" alternative, among the project alternatives, along with a comparative analysis of the impacts. 14 Cal. Code Regs, Section 15126.6 (e). Planning and Conservation League v. Department of Water Resources (2000) 83 CA. 4th 892, 917 (Even if the "no project" alternative will not reduce significant impacts of the project, the "no project" alternative must be discussed and considered.) The description in the EIR of the "no project" alternative is inadequate and unsupported. The EIR's response to comments on the draft EIR must provide a reasonable, good faith analysis. 14 Cal. Code Regs. § 15088(b). The response to comments on the draft EIR are generally non - responsive. There is an inadequate analysis provided. The lead agency must not approve the project unless the agency finds, based on substantial evidence in the record, that the project will not have a significant effect on the environment, or the agency finds that all significant environmental effects have been eliminated or substantially reduced to the extent feasible and that any remaining Unavoidable significant affects are acceptable due to specific economic, legal, social. technological or other benefits of the project. Public Resources Code Sections 21002, 21002. 1, and 21091: 14 Cal Code Regs. §15021(a), 15091 - 15093. The findings must be based on substantial evidence in the record. 14 Cal. Code Regs 15091(b) September 6, 2017 Page 4 City approval of a home improvement store improperly failed to make feasibility findings on a reduced -size alternative. Preservation Action Council v. City of San Jose (2006) 141 CA 4th 1336, 1355. There is insufficient evidence in the record that the proposed project will have no significant impact on traffic, transportation and the other factors described below. 1. GREENHOUSE GAS EMISSIONS HAVE NOT BEEN ADEQUATELY CONSIDERED. Greenhouse gas emissions, including transportation, must be properly addressed in an EIR. Public Resource Code §21083.05(b); 14 Cal. Code Regs § 15064.4, 15126.4(c). EIR invalidated for failure to comply with the requirements for greenhouse gas emissions. Communities for Better Environment v. City of Richmond (2010) 184 CA 4th 70; Center for Biological Diversity v. Department offish & Wildlife (2016) 62 Cal. 4th 204; Friends of Oroville v. City of Oroville (2013) 219 CA 4th 832, 842. EIR's finding of no significant greenhouse gas emissions impacts was not supported by evidence that project's energy efficiency goal would be reached. Spring Valley Lake Association v. City of Victorville (2016) 284 CA 4th 91, 102 The EIR fails to consider the impact of greenhouse gas emissions from persons driving vehicles to and from the fitness center for one hour workouts all day long, from early morning to late evening, and particularly during rush hour traffic. 2. THE WATER SUPPLY REQUIREMENTS HAVE NOT BEEN ADEQUATELY CONSIDERED. The impact of the project on water supply must be assessed and analyzed. 14 Cal. Code Regs §15155(b)(1); Water C § 10911(b). National Heritage Project v. County of Stanislaus (1996) 48 CA 4th 182 (EIR rejected - failure to properly analyze the impact of supplying water to the project); See also: Santiago County Water District v. County of Orange (198 1) 118 CA 3d 818; Santa Clarita Org. for Planning the Enviroment v. County of Los Angeles (2003) 106 CA 4th 715; Preserve Wild Santee v. City of Santee (2012) 210 CA 4th 260 In the EIR, there is no analysis of the fact that persons will be using the swimming pool, the showers and the drinking fountains at the fitness center from early morning to late at night. There is no analysis as to how this water usage will affect the water supply. 3. TRANSPORTATION AND TRAFFIC HAVE NOT BEEN ADEQUATELY CONSIDERED. Public Resources Code 21099 - CEQA Guidelines must be developed for transportation and traffic. Whitman v. Board of Supervisors of Ventura County (1979) 88 CA 3d 39 (EIR insufficient for failure to adequately discuss traffic impacts.) There has been no adequate traffic study prepared that considered the traffic anticipated to be generated by this particular project. The County of Orange took the unusual step of September 6, 2017 Page 5 specifically requesting a traffic study for this project based on actual traffic numbers for similar facilities nearby. But no such traffic study has been presented for this project. The EIR states that there are no significant environmental impacts of this project for traffic and transportation. Section 4.4 -10. Yet most of the 220 opposing comments concerned various aspects of traffic and transportation impacts, which I will not restate, but which are incorporated herein. 4. THE IMPACT OF CRIME HAS NOT BEEN ADEQUATELY CONSIDERED. Residents have presented statistical information that fitness clubs are "magnets for crime'. similar to bars. The EIR provides no analysis of crime. The EIR provides no response to this statistical information. 5. THE IMPACT OF PARKING SHORTAGES HAS NOT BEEN ADEQUATELY CONSIDERED. Taxpayers for Accountable School Board Spending v. San Diego Unified School District (201 215 CA 4th 1013, 1050 - all environmental impacts that could result from a parking shortage must be evaluated in an EIR. The EIR provides an inadequate discussion of parking shortages. Prior to the current fitness project, nearby community association residents could park in the Shopping Center. However, the residents have been informed by the Shopping Center that in order to allow adequate parking for the fitness center, the residents will no longer be permitted to park in the Shopping Center. This will cause parking problems for the nearby residents. This issue is not properly addressed in the EIR. There has been no parking study for this particular project, considering the parking requirements for the fitness center. 6. THE IMPACT OF VISUAL. AND AESTHETIC RESOURCES HAVE NOT BEEN ADEQUATELY CONSIDERED. Visual and aesthetic resources must be considered. Public Resources Code Sections 21000(b) and 21065; Pocket Protectors v. City of Sacramento (2004) 124 CA 4th 903; Ocean View Estates Homeowners Association v. Montecito Water District (2004) 116 CA 4th 396. Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 CA 4th 1597 The EIR fails to consider the impact of the close proximity of the 600 residential units at the nearby community associations to the proposed fitness center. The residential condominiums are approximately 200 feet from the entrance, 150 feet from the building and 15 feet from the parking lot. This creates issues of noise, crime, parking, visual blight and disturbance. The hours of operation of the fitness center are 5:00 a.m. to 11:00 p.m. Monday through Thursday, 5:00 a.m. to 10:00 p.m. Fridays, and 8:00 a.m. to 9:00 p.m. on Sundays and Saturdays. September 6, 2017 Page 6 7. THE MITIGATION MEASURES ARE INADEQUATE. An EIR must describe mitigation measures for each potentially significant environmental impact that it identifies. Pub Resources Code Sections 21002. ] (a) and 21100(b)(3); 14 Cal Code Regs §15126.4 A mitigation measure may reduce or minimize a significant impact without avoiding the impact entirely. 14 Cal Code Regs 15370(b); Pub Resources Code Sections 21002.1 (a) and 21081(a)(I). EIR is invalid because it fails to "adopt' mitigation measures. Murrieta Valley Unified School Dist. v. County of Riverside (1991) 228 CA 3d 1212, 1254 In the present case. the EIR erroneously concludes that there are no significant environmental impacts for air quality, greenhouse gases or traffic and transportation and therefore is not required to present any mitigation measures or consider any alternatives to address these environmental issues. The EIR is incorrect. III. CONCLUSION The CUP and the EIR should be denied. Very truly yours, BARRY A. ROSS BAR:kj CC: The Coalition Against LA Fitness Jill Ingram, City Manager - jingram @sealbeachca.gov Jim Basham, Community Development Director -.ibasham@sealbeachca.gov Steve Fowler, Assistant Planner - sfowler @sealbeachca.gov June 22, 2017 MICHELLE STEEL CHAIRWOMAN, SECOND DISTRICT ORANGE COUNTY HALL OF ADMINISTRATION 333 W. SANTA ANA BLVD., SANTA ANA, CALIFORNIA 92701 PHONE (714( 834 -3220 FAX (714) 834 -6109 Michelle.Steel@ocgov.com Seal Beach City Council City Hall 211 Eighth Street, Seal Beach, CA 90740 RE: LA Fitness Project at the Shops at Rossmoor, St. Cloud Dr./ Seal Beach Blvd. — Traffic Concerns Dear Honorable City Council Members, I write to you in regard to the proposed LA Fitness Project at the Shops at Rossmoor. As the directly elected representative for the residents of Rossmoor, I have heard many concerns regarding this project and its possible traffic impacts. I asked our Public Works department to review some of these concerns, and that resulted in the attached letter of additional findings. Public Works recommends that the applicant conduct a traffic study of at least two similarly located LA Fitness clubs to ascertain the average daily traffic for this facility. I respectfully ask that you consider these recommendations, as well as the concerns of Rossmoor residents, and ensure average daily traffic is accurately and fully analyzed before proceeding with this project. Sincerely, 77�44 MICHELLE STEEL Chairwoman, Second District Orange County Board of Supervisors cc: Jill Ingram, City Manager Jim Basham, Community Development Director fi PubhcWorks Integrity, Accountability, Service, Trust Shane L. Silsby, Director June 15, 2017 City of Seal Beach 211 Eighth Street Seal Beach, CA 90740 Attention: Mr. Jim Basham, Community Development Director Subject: LA Fitness Project at the Shops at Rossmoor, St. Cloud Dr. /Seal Beach Blvd. — Traffic Concerns Dear Mr. Basham, Thank you for the opportunity to comment on the Environmental Impact Report (EIR) for the Health Club within The Shops At Rossmoor. Subsequent to our initial comments on the EIR, we received communication from Mr. Kevin Pearce (Coalition against LA Fitness) via email (attached) on May 19, 2017. In conjunction with discussions with City of Seal Beach staff on June 13, 2017, County staff provided the following findings based on further research and review of the traffic study for the EIR of the subject project: e The Average Daily Traffic within the traffic study in the EIR is based on ITE trip generation rate of 32.93 trips per thousand square feet. Due to a small sample size provided by the ITE Trip Generation Manual (attached) for health /fitness clubs used in the EIR (see attached page 18 from EIR), County recommends that applicant conduct a traffic study of at least two (2) similarly located LA Fitness clubs to ascertain the average daily traffic for this facility. In regards to the concern of the subject project trip distribution which shows 10% of the trips generated using Montecito /St. Cloud and 90% of Rossmoor Center Way, County has reviewed the traffic analysis in the EIR and is in concurrence with the trip distribution layouts. Montecito would provide an indirect route to Seal Beach Boulevard whereas Rossmoor Center Way would provide a direct access. In addition, Rossmoor Center Way is projected a better Level of Service (LOS) than Montecito /St. Cloud Drive. Please contact myself at (714) 647 -3213 or James Tyler at (714) 667 -3210 if you have any questions. Sincerely, 4AL; Khalid Bazmi, P.E. Assistant Director /County Engineer, OC Public Works 300 N. Flower Street, Santa Ana, CA 92703 P.O. Box 4048, Santa Ana, CA 92702 -4048 www.ocpublicworks.com 714.667.8800 1 Info @OC P W.ocgov. wm cc: Shane L. Silsby, P.E., Director, OC Public Works Nardy Khan, Deputy Director, OC Infrastructure Programs James Tyler, P.E., Manager, Development Support Division Fiona Man, P.E., T.E., Manager, Traffic & Design Attachments: Email from Mr. Kevin Pearce on 5/19/17 ITE Trip Generation Manual, 90 Edition, Page 940 EIR, Traffic Analysis, Page 18 300 N. Flower Street, Santa Ana, CA 92703 P.O. Box 4048, Santa Ana, CA 92702 -4048 www.ocpublicworks.c rn 714.667.8800 1 Info @OC P W .ocgov. oom INFRASTRUCTURE GROUP, INC. 2672 N. Vista Crest Road Orange, California 92867 (714) 749 -6386 Cell (714) 974 -3616 Fax drbilodeau@gmail.com September 10, 2017 Mr. Steve Fowler Assistant Planner City of Seal Beach 211 Eight Street Seal Beach, California 90740 Subject: Draft Environmental Impact Report (SCH# 20170110033) for the Proposed LA Fitness Health Club Dear Mr. Fowler: Infrastructure Group Inc. (IGI) appreciates this opportunity to review the draft Environmental Impact Report (EIR) for a proposed LA Fitness Health Club located at 12411 Seal Beach Boulevard in the city of Seal Beach, California. Page 4.4 -11 of the EIR provides the basis for the trip generation and projected future conditions of the proposed project. Specifically, it references Institute of Transportation Engineers (ITE), Trip Generation, Ninth Edition (2012). The publication on page 940 provides the following admonition for Health/Fitness Club trip data: "Users are cautioned to use data with care because of the small sample size" In fact, the trip data was derived from only 4 studies conducted across the United States. It is my professional opinion and recommendation that additional trip generation observations be conducted at existing LA Fitness Clubs in Southern California to accurately assess the traffic impacts associated with the proposed project. The use of the ITE trip generation rates is inadequate given the small sample size. Sincerely, Infrastructure Group Inc. 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