Special City Council
June 5, 2023

From: Meli Treichler
To: City Clerk
Subject: 6/5 City Counsel Grocery Outlet Vote
Date: Saturday, June 03, 2023 4:48:33 PM
Melanie Treichler
41701 Eureka Hill Rd, Point Arena, CA 95468
916-666-9990
Please vote yes to open a Grocery Outlet. Groceries on the coast are so insanely expensive.

This is a wonderful opportunity for thousands of continuity members. Please vote YES. -Melanie Treichler

CITY OF FORT BRAGG
REC'D JUN O 2 2023
5-29-23
I/we have been living at the low income Walnut Apartments on Walnut Street.

We are not able to attend the City Council meeting.

Most all the res idents go the food bank every week. This is how we get our staples.

We will be able to walk to the new grocery outlet.

They will also likely contribute to the Food Bank.

We just hope our voices are heard.

Please no more lawsuits.

Thank you for voting yes and please get this done.

Residents of Walnut Apartments, 311 Walnut Street, Fort Bragg, CA Name Apt
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CITY OF FORT BRAGG
REC'D JUN O 2 2023
5-29-23
I/we have been living at the low income Walnut Apartments on Walnut Street.

We are not able to attend the City Council meeting.

Most all the residents go the food bank every week. This is how we get our staples.

We will be able to walk to the new grocery outlet.

They will also likely contribute to the Food Bank.

We just hope our voices are heard.

Please no more lawsuits.

Thank you for voting yes and please get this done.
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CITY OF FORT BRAGG
REC'D JUN D 2 2023
From: Fort Bragg Local Business Matters
To: City Clerk
Cc: Peters, Sarah; cdd
Subject: Public Comment in Opposition to the Proposed Grocery Outlet Matter for Consideration at the City Council Hearing on June 5, 2023
Date: Saturday, June 03, 2023 4:05:31 PM
Attachments: FBLBM GO Opposition Petition 06.02.23 - Copy.pdf June 3, 2023
To the Honorable Fort Bragg City Council:

Attached, please find a copy of the online Petition from Fort Bragg Local Business Matters (FBLBM), in opposition to the proposed Grocery Outlet development at 851 S. Franklin Street, for the City Council's consideration of this matter, at their June 5, 2023 hearing.

As noted in the attached document, we have received over 756 digital signatures (and growing) to date from Fort Bragg residents, activists, families and workers, who have strong concerns about the proposed project impacts and the flawed EIR, that we had hoped would be comprehensive and conducted impartially by independent experts, but that was not the case.

We will share separate comments relating to our concerns about the EIR, and a respectful request that the Council strongly consider not certifying the proposed Final EIR for this development, in separate correspondence through our group's legal representative.

In the interim, please accept this Petition in Opposition to the proposed Grocery Outlet development on behalf of FBLBM, for the public record and for the Council's consideration of this important issue at their hearing on June 5th.

Please also confirm receipt of this email, and attached Petition, and certify that it will be included in the public record and shared with the City Council in a timely manner, prior to the hearing on this matter.

Sincerely,
Fort Bragg Local Business Matters
Protect our Downtown & Local Businesses in Fort Bragg
The backbone of our community are our local businesses who’ve stuck it out through thick and thin over the years. And these last two years have been particularly trying for all of us and our local businesses.

We want to see our town thrive which is why we have strong concerns about the growing proliferation of national chain and discount stores popping up in our community. These stores add little value to the unique character of our town and in fact threaten to upend it by making it difficult for our existing small businesses to survive in what has been a very difficult time.

The latest example is a Sacramento based developer’s plan to build a new discount grocery store at 851 S.

Franklin Street, at the busy entrance to Noyo Harbor. The proposed Grocery Outlet will hurt our existing businesses, like Harvest Market, and would add yet another national chain discount store to our community.

Furthermore, the site of the proposed grocery store, which includes the County Social Services Building that will be demolished instead of repurposed, is also a problem. The Grocery Outlet will generate hundreds of new car trips per day along S. Main Street and N. Harbor Drive, which is also the entryway to the busy Noyo restaurants and shops. It’s hard enough already to try to get down to Noyo Harbor or back on to South Main Street, and we can only imagine how much worse traffic will be if we add hundreds of cars going in and out of this grocery store at this busy intersection, each and every day. The proposed grocery store also raises concerns about impacts to emergency response times, water use and quality, air/light/noise pollution, and public safety.

Which is why we successfully fought hard to get the City and developer to conduct a full and comprehensive Environmental Impact Report (EIR) so that we would know the true negative impacts this project will have on traffic, the environment and our community. We learned in April 2022, that the City approved the selection of the "suspicious" De Novo Planning Group to manage the EIR for the controversial Grocery Outlet project in Fort Bragg. The De Novo Group had already started work with the developer on the EIR before being selected and plans to use old impact studies to make the EIR cheaper and quicker.

So what we seem to have is a sham of an EIR being conducted that the City Council knowingly signed off on, and we have to wonder why that is.

Despite the City Council's questionable behavior and apparent greed to get this project approved, again, there is still time to act and to urge the City to use their discretion to say NO to the proposed Grocery Outlet at this site! NO to another discount store in Fort Bragg! NO to more traffic on Main Street and Harbor Drive! NO to something that will hurt our downtown and existing local businesses! Thank you for SIGNING this petition and for supporting our downtown and local businesses! Link to the online Petition: https://chng.it/NZbhVQt8
Digital Signatures to the FBLBM GO Opposition Petition
756 Signatures, as of 1:30 P.M. Friday, June 2, 2023
Name City State
Postal
Code Signed On
Sam Parker Fort Bragg CA 3/23/2021
Ken Armstrong Fort Bragg CA 95437 3/23/2021
Diana Theobald chico 95973 4/6/2021
Kassandra Taylor Fort Bragg CA 95437 4/6/2021
Constance Huebert Fort Bragg CA 95437 4/6/2021
Derek Hooper Mendocino CA 95460 4/6/2021
Allison Crawford Fort Bragg CA 95437 4/6/2021
Roslyn Satten Fort Bragg CA 95437 4/6/2021
Mikael Blaisdell Fort Bragg CA 95437 4/7/2021
Jamie Peters Fort Bragg CA 95437 4/7/2021
Connie Schartz Fort Bragg CA 95437 4/7/2021
Jenn Davis Fort Bragg CA 95437 4/7/2021
Carin Berolzheimer Fort Bragg CA 95437 4/7/2021
Jacquelyn Cisper Fort Bragg CA 95437 4/7/2021
Christopher Cisper Fort Bragg CA 95437 4/7/2021
Jo Bradley Little River 95456 4/7/2021
Margaret Guhde Mendocino CA 95460 4/7/2021
Frank Bender Alameda CA 94502 4/7/2021
David King 4/7/2021
Matthew Griffen Fort Bragg CA 94537 4/7/2021
Patty Madigan Comptche CA 95427 4/7/2021
Zoleta Lee Fort Bragg CA 95437 4/7/2021
Teresa Meche Fort Bragg CA 95437 4/7/2021
Daton Dean Memphis 38114 4/7/2021
Katie Shellman Fort Bragg CA 95437 4/7/2021
Scott Roat Mendocino CA 95460 4/8/2021
Ann Lee Fort Bragg CA 95437 4/8/2021
Katie Turner Fort Bragg CA 95437 4/8/2021
Jasmin Ortiz Santa Barbara 93105 4/8/2021
Richard Council Lodi 95242 4/8/2021
Karen Reynolds Fort Bragg CA 95437 4/8/2021
Ann Brezina Fort Bragg CA 95437 4/8/2021
Agim Demirovski Staten island 10310 4/8/2021
Elaine Charkowski Fort Bragg CA 95437 4/8/2021
Jenna Hoyt Fort Bragg CA 95437 4/8/2021
Steven Taylor Fort Bragg CA 95437 4/8/2021
Nicolas Binfield lakewood 44107 4/8/2021
Kristene Markert Fort Bragg CA 95437 4/8/2021
Yaz Pickaxe Germantown 20874 4/8/2021
Bernadette Coyle Leland 28451 4/8/2021
Eve Ball Tucson 85730 4/8/2021
Macey Nelepovitz Fort Bragg CA 95437 4/8/2021
taryn Oakes Westport CA 95437 4/8/2021
Diane Buxton Mendcino CA 95460 4/8/2021
Ron Hock FORT BRAGG CA 95437 4/8/2021
Margaret Roberts Fort Bragg CA 95437 4/8/2021
Jima Abbott Fort Bragg CA 95437 4/8/2021
Eric Stromberger Fort Bragg CA 95437 4/8/2021
Daney Dawson Fort Bragg CA 95437 4/8/2021
Elizabeth Swenson Fort Bragg CA 95437 4/8/2021
Thomas Grattan Mendocino CA 95460 4/8/2021
Catherine Hart Mendocino CA 95460 4/8/2021
Liz Helenchild Mendocino CA 95460 4/8/2021
David Gurney Fort Bragg CA 95437 4/8/2021
Anne Beck Fort Bragg CA 95437 4/8/2021
Annette Jarvie Mendocino CA 95460 4/8/2021
Eleanor Adams Fort Bragg CA 95437 4/8/2021
Barbara Metcalfe Los Angeles CA 90028 4/8/2021
Frank Letton Whitethorn CA 95589 4/8/2021
Anna Marie Stenberg Fort Bragg CA 95437 4/8/2021
Royce Loewen Albion CA 95410 4/8/2021
Sallie Richards Fort Bragg CA 95437 4/8/2021
Erif Thunen Albion CA 95410 4/8/2021
arnav chaturvedi Hillsborough 8844 4/8/2021
Cynthia Gair Mendocino CA 95460 4/8/2021
jennifer kreger Fort Bragg CA 95437 4/8/2021
Eric Kelly Tucson 85710 4/8/2021
janie rezner ft bragg CA 95437 4/8/2021
Lynn Derrick Albion CA 95410 4/8/2021
robert lorentzen fort bragg CA
95437-
8727 4/8/2021
Meredith Smith Mendocino CA 95460 4/8/2021
Laura Lind Fort Bragg CA 95437 4/8/2021
Janet Schlihs Fort Bragg CA 95437 4/8/2021
Donna LaForge West Monroe LA 71291 4/8/2021
Ashley Vandever Kansas city 64106 4/8/2021
MARC YASSKIN Roy WA 98580 4/8/2021
Marta MacKenzie Fort Bragg CA 95437 4/8/2021
Kandeda Trefil Albion CA 95410 4/8/2021
Catherine McMillan Mendocino CA 95460 4/8/2021
Paula Hale Fort Bragg CA 95437 4/8/2021
Judith Edwards Fort Bragg CA 95437 4/8/2021
Cecile Cutler Fort Bragg CA 95437 4/8/2021
Danleigh Spievak Fort Bragg CA 95437 4/9/2021
Don Taylor Fort Bragg CA 95437 4/9/2021
Dyana Sangraal Fort Bragg CA 95437 4/9/2021
Majd Ablahad Chicago 60634 4/9/2021
Sylvia Gilmour Fort Bragg CA 95437 4/9/2021
Paloma Carmona Fort Bragg CA 95437 4/9/2021
Jesus Renteria Fort Bragg CA 95437 4/9/2021
Sue Coulter Little River CA 95456 4/9/2021
merry winslow Fort Bragg CA 95437 4/9/2021
Susan McNeil Fort Bragg CA 95437 4/9/2021
Frank Martinez Arlington 76013 4/9/2021
Richard Rasmussen Fort Bragg CA 95437 4/9/2021
Joan Burleigh Fort Bragg CA 95437 4/9/2021
Cynthia Scott Mendocino CA 98626 4/9/2021
R Pearson 4/9/2021
Jacob Reynolds Quincy CA 95971 4/9/2021
sandy oppenheimer fort Bragg CA9 4/9/2021
Wendy Slevin Fort Bragg CA 95437 4/9/2021
Allie Sanchez Salem 1970 4/9/2021
Adrian Mendoza Maddison 1612 4/9/2021
N. Milano Fort Bragg CA 95437 4/9/2021
dennis jecmen Fort Bragg CA 95437 4/9/2021
Margaret Drake Albion CA 95410 4/9/2021
Brice Scanlon Stamford 6902 4/9/2021
Linda Perry Mendocino CA 95460 4/9/2021
Alanna Ayres Point Arena CA 95468 4/9/2021
Sandi Mosden Fort Bragg CA 95437 4/9/2021
Alfred Holston, Jr. Fort Bragg CA 95437 4/9/2021
Cornelia Gerken Fort Bragg CA 95437 4/9/2021
Natalia Smith Cheraw 29520 4/9/2021
lee alley Pacifica CA 94044 4/9/2021
Charlotte Agbeka Syosset 11791 4/9/2021
Shantel Burdette Rome 30165 4/9/2021
Freddy Reyes Bronx 10456 4/9/2021
Adriana Narro Fort Bragg CA 95437 4/9/2021
Elisha Moleski Sanford 32771 4/9/2021
Robert McMillin Abilene 79606 4/9/2021
Danielle Walsh Kennesaw 30152 4/9/2021
Dorothy Qurnell Grass Valley 95949 4/9/2021
Beth Goodwin Fort Bragg CA 95437 4/9/2021
Anthony Miksak Fort Bragg CA 95437 4/9/2021
Carole Freeman Comptche CA 95427 4/9/2021
Lonnie Mathieson Fort Bragg CA 95437 4/10/2021
Allisondra Coito San Lorenzo 94580 4/10/2021
Jerrilee Holtzapple Philadelphia PA 19144 4/10/2021
Hanna Levie 9963 4/10/2021
jaqavion jr demarcus Pomona 91766 4/10/2021
Chanira Andia Whittier 90604 4/10/2021
Zida Borcich Fort Bragg CA 9537 4/10/2021
Brooke Selapack Dana Point CA 92629 4/10/2021
katherine webster Fort Bragg CA 95437 4/10/2021
Kristine Reiber Caspar CA 94112 4/10/2021
Pamela Olson Chicago 60661 4/10/2021
John Fisher Fort Bragg CA 95437 4/10/2021
Gerald Zari Fort Bragg CA 95437 4/10/2021
Susana hennessey Lavery San Francisco CA 94123 4/10/2021 Katherine Haley Lower lake CA 95457 4/10/2021
Richard Lopez Indio 92203 4/10/2021
Suzi Lina Fort Bragg CA 95437 4/10/2021
Michele Wald San Anselmo CA 94960 4/10/2021
Steven Gravenites Fort Bragg CA 95437 4/10/2021
Aiden Hansen Troidl Nampa 83686 4/10/2021
Brian Edwards Monroe 28111 4/10/2021
Judy Tarbell Caspar CA 95420 4/10/2021
Jasmine Wylie Citrus Heights 95610 4/10/2021
James Barrett Rio Vista CA
94571-
2280 4/10/2021
Christian Sholtis Wilkes Barre 18702 4/10/2021
Deb Alan San Anselmo CA 94960 4/10/2021
Melanie Chavez Spring Valley 91977 4/10/2021
Scott Menzies Fort Bragg CA 95437 4/10/2021
Veda Connor Morgan Hill CA 95037 4/10/2021
Mich Par Redwood City 94063 4/10/2021
Ron Weimer 4/10/2021
Patti Ripple 4/10/2021
Megumin Sato Longview 75605 4/11/2021
Marilyn Lemos Mendocino CA 95460 4/11/2021
Steve Ritchie Point Arena CA 95468 4/11/2021
Andrea Moran Miami 33138 4/11/2021
Monica edman FortBragg CA 95437 4/11/2021
Lydia Rand Mendocino CA 95460 4/11/2021
Oscar Jaquez North Las Vegas 89030 4/11/2021
Moises Hernandez Carlsbad 92008 4/11/2021
Jay McMartinRosenquist Fort Bragg CA 95437 4/11/2021
Kristen Kemp Falls Church 22041 4/11/2021
cynthia sanborn-dubey Willits CA 95490 4/11/2021
Jacob Swang Raleigh 27604 4/11/2021
Tyler T Arcadia 91006 4/11/2021
Dillion Phillips San Jose 94589 4/12/2021
Jesus Renteria Fort Bragg CA 95437 4/12/2021
Gina Holdren Fort Bragg CA 95437 4/12/2021
Susan Sisk Fort Bragg CA 95437 4/12/2021
Susie Burks Corpus Christi 78412 4/12/2021
Austin Ballard Byron 82412 4/12/2021
Lanee Blankenship Sacramento 95842 4/12/2021
Morgan Hall Fort bragg CA 95437 4/12/2021
Sarah Thurber Fort Bragg CA 95437 4/12/2021
Jeff Laxier Fort Bragg CA 95437 4/12/2021
Jeanne Paula Trani Concord 94521 4/12/2021
Claudelle Zack Fort Bragg CA 95437 4/12/2021
Jose Lopez Santa Ana 92701 4/12/2021
Frida Rivera Houston 77035 4/12/2021
Nicole Sandoval Fort Bragg CA 95437 4/12/2021
lu ross MENDOCINO CA 95460 4/12/2021
Mary Chamberlin Fort Bragg CA 95437 4/12/2021
Kirk Melton Fort Bragg CA 95437 4/12/2021
Kayla Morgan Fort Bragg CA 95437 4/13/2021
Charisse Ballard Fort Bragg CA 95437 4/13/2021
Anthony Koller Fort Bragg CA 95437 4/13/2021
Dennak Murphy Fort Bragg CA 95437 4/13/2021
Kaya Kachigian Mendocino CA 95460 4/13/2021
K V Bunker Fort Bragg CA 95437 4/13/2021
Austin Ward Corvallis OR 97330 4/13/2021
B York Fort Bragg CA 95437 4/13/2021
Heather Brogan Gealey Fort Bragg CA 95437 4/13/2021
Morgan Peterson Fort Bragg CA 95437 4/13/2021
Olivia Clark Santa Rosa CA 95403 4/13/2021
Colby Jones Berkeley CA 94705 4/13/2021
Felicia Gealey Albion CA 95410 4/13/2021
Brittney Tuomala Fort Bragg CA 95437 4/13/2021
Sage Andersen Mendocino CA 95460 4/14/2021
Kerry Mertle Santa Rosa CA 95409 4/14/2021
Madeline Richards Fort Bragg CA 95437 4/14/2021
Sharon Peterson Fort Bragg CA 95437 4/14/2021
rebecca Gilgert Chico CA 95928 4/14/2021
Terrii Esiline Gladwin 48624 4/14/2021
Melissa Gonzalez Lakeside 92040 4/14/2021
Julie Burns Fort Bragg CA 95437 4/14/2021
Amethyst Douglas Fort bragg CA 95437 4/14/2021
River Wilder Fort Bragg CA 95437 4/14/2021
Ariana van Buuren Fort Bragg CA 95437 4/14/2021
Emma Gilchrist Fort Bragg CA 95437 4/14/2021
Mirna Hernandez Fort Bragg CA 95437 4/14/2021
Keri Ann Bourne Grants Pass OR 95437 4/14/2021
Chris Afton Lake Elsinore 92530 4/15/2021
Lorena Edmundson Portland OR 97214 4/15/2021
Rev. Robert Roseman Fort Bragg CA 95437 4/15/2021
Grace Hansen Fort bragg CA 95437 4/15/2021
Cathy Dostal Fort Bragg CA 95437 4/15/2021
joshua olanrewaju Springfield 45502 4/15/2021
Bria Darville Valdosta 31601 4/15/2021
Connor Lamont Ridley Park 19078 4/15/2021
Jared Peterson Anaheim 92805 4/15/2021
Kabir Arora Castro Valley 94546 4/15/2021
S French Fort Bragg CA 95437 4/15/2021
Marco Garcia Fort Worth 76137 4/16/2021
Brian Tovey Brookings 97415 4/16/2021
Patty Yanez CA 4/16/2021
Sarah Bradley Sacramento CA 95826 4/16/2021
Christie Dodgson Fort Bragg CA 95437 4/17/2021
Sharon Mullenaux Santa Cruz CA 95062 4/17/2021
Scott Miller Fort Bragg CA 95437 4/17/2021
Laura Kirby Portland OR 97217 4/18/2021
Luis Campps North Hollywood 91601 4/18/2021
Gunner John Meadville 16335 4/18/2021
Frank C Philadelphia 19124 4/18/2021
Mindy Bruchler Fort Bragg CA 95437 4/18/2021
Carol Steele Fort Bragg CA 95437 4/18/2021
Jose López Orlando 32828 4/19/2021
kathryn Rossum Fort Bragg CA 95437 4/19/2021
Randi Unroe Willits CA 95490 4/19/2021
Colleen Hooper Fort Bragg CA 95437 4/19/2021
Sandra Emery Fort Bragg CA 95437 4/20/2021
Eric Drechsel Santa Rosa CA 95401 4/20/2021
Rio Russell Elk CA 95432 4/20/2021
Kay Hayward Mendocino CA 95460 4/20/2021
Suzan Garcia-Wells Fort Bragg CA 95437 4/21/2021
Terri Beer Fort Bragg CA 95437 4/21/2021
Ron Rossiter Ukiah CA 95482 4/21/2021
Sue Klingler Fort Bragg CA 95437 4/22/2021
Nancy Crider Ft. Bragg CA 95437 4/22/2021
Ene Bender Fort Bragg CA 95437 4/24/2021
Rick Davis Fort Bragg CA 95437 5/4/2021
Jo Bradley Fort Bragg CA 95437 5/5/2021
Keith Stiver Fort Bragg CA 95437 5/5/2021
Tom Jelen Fort Bragg CA 95437 5/5/2021
Deborah Kvaka Laytonville CA 95454 5/6/2021
Juan J Venegas Fort Bragg CA 95437 5/6/2021
Laurie York Albion CA 95410 5/6/2021
Pearl Connell Fort Bragg CA 95437 5/6/2021
Jenafer Owen Fort Bragg CA 94707 5/7/2021
Laural Pope Fort Bragg CA 95437 5/7/2021
Laurel LeMohn Fort Bragg CA 95437 5/8/2021
Susan Lundgren Mendocino CA 96460 5/8/2021
Genesis Diaz-Meza Fort Bragg CA 95437 5/9/2021
John Richelson Fort Bragg CA 95437 5/9/2021
autumn faber mendocino CA 95460 5/10/2021
Derek Lockyer Mendocino CA 95460 5/10/2021
Devon Patel Fort Beagg CA 95437 5/10/2021
Terry Leedy Grapeview WA 98546 5/11/2021
Val Marshall Fort Bragg CA 95437 5/18/2021
Crystal Clements Fort Bragg CA 95437 5/19/2021
Anne Young Fort Bragg CA 95437 5/19/2021
Ron Hock Fort Bragg CA 95437 5/19/2021
Tracy DeLeeuw Lake Tahoe CA 97526 5/19/2021
Janet Aguilar Mendocino CA 95460 5/19/2021
Melissa Birch Eureka CA 95501 5/20/2021
Jeri Erickson Fort Bragg CA 95437 5/21/2021
Isabel Alcocer Fort Bragg CA 95437 5/21/2021
Rowan Gill Fort Bragg CA 95437 5/21/2021
John Adams Willits CA 95490 5/21/2021
Adriane Nicolaisen Fort Bragg CA 95437 5/21/2021
Tonilynn Montecino Upland 91786 5/21/2021
Rodney Garrison Fort Bragg CA 95437 5/21/2021
Robin Hamlin McKinleyville CA 95519 5/21/2021
Otimar Levitschnig Staten Island 10304 5/21/2021
Sarah Kennon Vacaville CA 95687 5/22/2021
Edward Rodriguez Houston 78237 5/22/2021
Lari Shea Fort Bragg CA 95482 5/22/2021
Jeffrey Wachtel Fort Bragg CA 95437 5/22/2021
Miranda Cottrill Lancaster 43130 5/22/2021
Eve Yeomans Fort Bragg CA 95437 5/22/2021
Mercedes Kennedy Fort Bragg CA 95437 5/22/2021
Kristy Tanguay Fort Bragg CA 95437 5/22/2021
Christopher Quezada Yucaipa 92399 5/22/2021
Doria Lewis Seattle WA 98117 5/23/2021
Chema Venegas Anaheim 92806 5/23/2021
Miomir Vujadinovic Chicago 60016 5/23/2021
Julie Castillo Fort Bragg CA 95437 5/23/2021
Shiela Cox-Dowdell Allen Park 48101 5/23/2021
Pahnia Yang
Rancho
Cucamonga 91730 5/23/2021
Allison McGoldrick Massapequa Park 11762 5/23/2021
Jacqueline Berg San Francisco 94110 5/23/2021
Riot Segura Encino 91316 5/23/2021
B Reyes Brooklyn 11208 5/23/2021
Michelle P Salida 95368 5/24/2021
Summer Fowler Tahoe City 96145 5/24/2021
Kevin Kern Santee 92071 5/24/2021
Julia Stahl Sacramento 95842 5/24/2021
Angela Ingram Flossmoor 60422 5/24/2021
Adam Kaluba Burleson 76028 5/24/2021
Rose Dones Orlando 32837 5/24/2021
Danielle Fontaine Grants Pass OR 97527 5/25/2021
Robert Ross Fort Bragg CA 95437 5/25/2021
Patricia Davis Little Rock 72209 5/25/2021
Kevin Rosser Portland 97212 5/25/2021
Mary Rose
KACZOROWSKI Fort Bragg CA 95437 5/25/2021
Julia Carson 5/25/2021
susan nutter Fort Bragg CA 95437 5/25/2021
Annemarie Weibel Albion CA 95410 5/25/2021
Kyle Norton Mendocino CA 95460 5/25/2021
sandy glickfeld Fort Bragg CA 95437 5/25/2021
Helen Van Gelder Annapolis MD 21409 5/25/2021
amanda dickinson Chapel Hill 27516 5/25/2021
Jude Thilman Fort Bragg CA 95437 5/25/2021
JANET HARRIS Charlotte 28215 5/25/2021
Ted Seymour Fort Bragg CA 95437 5/25/2021
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From: Harbor RV Park
To: City Clerk
Date: Monday, June 05, 2023 11:42:09 AM
Attachments: Grocery Outlet.pdf
Carolyn Morgan
Office Manager
Harbor RV Park
(707) 961-1512

From: Mark Haydon
To: City Clerk
Subject: June 5 2023 Grocery Outlet Vote - Yes
Date: Monday, June 05, 2023 9:56:48 AM
Attachments: Grocery Outlet Letter to City Council.pdf
Please find attached concerning Geo Aggregates request for a "Yes" vote on the newly proposed Grocery Outlet in Fort Bragg.

Respectfully,
Mark Haydon
Facility and Quality Manager
Geo Aggregates
[email protected]
(707) 964-3077
Get Outlook for iOS
03 June 2023
Geo Aggregates
1221 North Main Street
Fort Bragg, CA 95437
707-964-4033 Fax: 707-964-7011
Subject: 05 June 2023 Fort Bragg City Council Vote - Fort Bragg Grocery Outlet Honorable Council Members,
Geo Aggregates of Fort Bragg would like to voice its support for the proposed Grocery Outlet project here in Fort Bragg.

Please vote “Yes” on this project.

Respectfully,
Mark Haydon
Facility and Quality Manager
Geo Aggregates
1221 No. Main Street
Fort Bragg, CA 95437
[email protected]
(707) 964-3077
From: Susan A.Anthony
To: City Clerk
Cc: Lemos, June; cdd
Subject: Comments on Grocery Outlet - June 5 hearing
Date: Monday, June 05, 2023 11:22:49 AM
Attachments: FBLBM_Ltr to City Counci re GO_6-5-21.pdf
Dear City Clerk:

Attached please find correspondence addressed to the City Council concerning the proposed Best Development Grocery Outlet Project, currently scheduled for a public hearing this evening. Please distribute to Councilmembers at your earliest convenience.

I would be grateful if you could confirm receipt of this email and its attachment.

Thank you very much.
________________________
Susan Anthony, Administrator
M. R. Wolfe & Associates, P.C. | Attorneys
Land Use | Environmental Law | Government
580 California Street | Suite 1200 | San Francisco, CA 94104 415.369.9400 | Fax: 415.369.9405 | www.mrwolfeassociates.com The information in this e-mail may contain information that is confidential and/or subject to the attorneyclient privilege. If you have received it in error, please delete and contact the sender immediately. Thank you.

June 5, 2023
By E-Mail
City Council
City of Ft. Bragg
c/o City Clerk
416 N. Franklin Street
Ft. Bragg, CA 95437
[email protected]
[email protected]
Re: Best Development Grocery Outlet at 825 S. Franklin St.

Dear Members of the City Council:

On behalf of FB Local Business Matters, an unincorporated association of Fort Bragg residents and businesses, we respectfully ask that you decline to certify the Final Environmental Impact Report (EIR) or approve development entitlements for the above-referenced Grocery Outlet project (Project) at this time. As previously explained in our May 10, 2023 letter to the Planning Commission, and as elaborated upon further below, the EIR does not meet CEQA’s requirements for good-faith, reasoned responses to public comments timely submitted on the Draft EIR, and also includes significant new information that requires recirculation for public review and comment before it can be certified as fully compliant with CEQA. Furthermore, just a few days ago even more new information has been added to the Final EIR at the last minute, none of which has been subjected to public scrutiny. As a result, the Final EIR does not adequately disclose, evaluate, or mitigate all of the Project’s potentially significant impacts.

Air Quality/Health Risk Assessment
In comments on the Draft EIR, we requested further information and analysis concerning the potential health impacts of diesel particulate matter (DPM) emissions on residents living immediately adjacent to the Project site from heavy-truck deliveries occurring over the lifetime of the Project. We noted that the Draft EIR reported 8 heavy-duty diesel truck deliveries per week, and 4 to 5 medium-duty diesel Fort Bragg City Council
June 5, 2023

truck deliveries per day, with many of these trucks with top-mounted refrigeration units that also generate DPM emissions. We also noted that the Draft EIR had acknowledged existing DPM emissions from trucks traveling on Highway 1 near the site, but had not provided any detail on this topic. Given that DPM has been listed by the California Air Resources Board (CARB) as a known carcinogenic toxic air contaminant (TAC), is important that the health risks to residential receptors living very close to the Project site from even a comparatively small number of diesel truck trips per week be quantified and evaluated.

In response, the Final EIR declined to provide further detail relating to existing and potential future risks from cumulative exposure to DPM emissions from the Project. Instead of preparing a health risk assessment that uses readily available, industry standard models , it doubles down on the Draft EIR’s unsupported assertion that the number of truck trips is too small to represent a significant health risk form TAC exposure. This response does not meet the standards of adequacy under CEQA for good faith, reasoned analysis in response to substantive public comments. (Berkeley Keep Jets Over the Bay Committee v. Board of Port Commissioners (2001) 91 Cal.App.4th 1344, 1371.) Under CEQA, lead agencies have to “receive and evaluate public reactions to environmental issues related to the agency’s activities.” (Guidelines, § 15201, emphasis added.) This means that a lead agency has to provide “a good faith reasoned analysis in response[ ]” to every public comment received and cannot simply dismiss concerns raised by the public. (Santa Clarita Org. for Planning v.

County of L.A. (2003) 106 Cal.App.4th 715, 723.)
There is no defensible reason why the EIR could not include a standard risk assessment that evaluates the Project’s diesel trucks’ incremental contribution to the existing health effects impacting residents near the Project and Highway 1. Caltrans publishes daily truck traffic data for all State highways, including Highway 1 near Fort Bragg. These data are available at https://dot.ca.gov/programs/trafficoperations/census. The most recent data show between 4,850 and 11,000 trucks traveling each day on Highway 1 at the junction with State Route 20 south of the Project site. See Attachment 1.

Using this data, it is a routine exercise to model DPM emissions and resulting health risks using the CARB’s publicly available EMFAC model,1 the AERMOD 1 Available at: https://arb.ca.gov/emfac/2017/
Fort Bragg City Council
June 5, 2023

dispersion model, and the Office of Environmental Health Hazard Assessment (OEHHA)’s HARP risk model.2 Indeed, OEHHA’s CalEnviroScreen mapping tool3) shows that DPM concentrations in Fort Bragg near the Project site are already above average, situated between the 50th and 60th percentile Statewide. See Attachment 2, which also includes CARB information documenting the health hazards associated with exposure to DPM emissions. This suggests there is an existing significant cumulative impact with respect to DPM emissions affecting the health of residents living near the Project and within 1,000 feet of Highway 1, even without the Project.

Section 15355 of the CEQA Guidelines defines “cumulative impacts” as the combined change in the environment resulting from a proposed project in combination with other “past,” “present” (i.e., existing) and foreseeable “future” impact sources. The Guidelines in turn set forth a lead agency’s obligations for evaluating a project’s cumulative impacts in an EIR. Cumulative analysis must be included in the draft EIR. Guidelines, §§ 15120(c), 15130.

Cumulative impact analysis is a two-step process that requires an agency to make the following determinations: (1) whether the impacts of the project in combination with those from other projects are cumulatively significant, and (2) if so, whether the project’s own effect is a considerable contribution. Guidelines, § 15130(a). Thus, the agency must first determine whether the combined effect of the project and other past, present and/or future projects “when considered together” is significant, because those impacts may be “individually minor but collectively significant.” Communities for a Better Environment v. California Resources Agency (“CBE”) (2002) 103 Cal.App.4th 98, 119-120. In step two, if there is a significant combined effect, the agency must then separately consider whether the project’s contribution to that effect is itself considerable, i.e., “whether ‘any additional amount’ of effect should be considered significant in the context of the existing cumulative effect.” CBE at 119. Thus, “the lead agency shall consider whether the cumulative impact is significant and whether the proposed project’s incremental effects are cumulatively considerable.” CBE at 120, emphasis added. Importantly, the analysis must consider all sources of “related impacts,” which in this case include traffic on Highway 1.

Guidelines, § 15130(a)(1), (b).
2 Available at: https://oehha.ca.gov/air/crnr/notice-adoption-air-toxics-hot-spots-programguidance-manual-preparation-health-risk-0 3 Available at: https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40 Fort Bragg City Council
June 5, 2023

The cases are clear that an EIR may not conclude a cumulative impact is insignificant merely because the project’s own individual contribution to an unacceptable existing condition is, by itself, relatively small. Los Angeles Unified School Dist. v. City of Los Angeles (“LAUSD”)(1997) 58 Cal.App.4th 1019, 1025-1026 (rejecting EIR’s reasoning that because noise levels around schools already exceeded governing standards, new noise source would have insignificant impact); CBE, supra, 103 Cal.App.4th 98, 117-118, 121 (invalidating CEQA Guidelines provision that de minimis impacts are necessarily less than considerable); see also Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 718. On the contrary: “the greater the existing environmental problems are, the lower the threshold should be for treating a project’s contribution to cumulative impacts as significant.” CBE, supra, 103 Cal.App.4th at 120. Thus, even if a given project has only an “individually minor” impact, its contribution to an existing environmental problem may nevertheless be “cumulatively considerable,” hence significant, and hence requiring mitigation measures under CEQA. CBE at 120; see also Guidelines, §§ 15355(b), 15065(a)(3); LAUSD, supra, 58 Cal.App.4th at 1024-25 (“individually insignificant” noise increase may be cumulatively considerable).

Here, the EIR simply failed undertake any assessment of potential cumulative health risks result from exposure to the Project’s DPM emissions in combination with existing emissions from truck traffic on Highway 1. It is therefore inadequate under CEQA.

Noise Impacts
In earlier comments we observed that the Draft EIR’s noise analysis had omitted consideration of receptors at the Super 8 Motel immediately adjacent to the Project site to the west, and that the noise contours in Figures 3.5-1 through 7 of the Draft EIR suggest that Project-related noise levels exceeding applicable significance thresholds at this location. In response, the Final EIR asserts that the City’s General Plan’s indoor and outdoor residential noise standards of 45 Ldn and 60 Ldn respectively apply to hotels and motels, and that “these thresholds and standards were used to analyze Project impacts to the Super 8 Motel.” Fort Bragg City Council
June 5, 2023

The Final EIR’s response failed to show how these standards were applied to the Motel. We pointed this out to the Planning Commission, noting that the comment response again fails to meet CEQA’s standards of good faith, reasoned analysis in response to substantive public comments. This comment apparently prompted the EIR preparers to undertake a last-minute analysis of impacts on the Super 8 Motel, releasing it on May 31, 2023 – two business days before the final hearing. That analysis concluded that noise standards would not be exceeded inside the Motel as a result of Project operations.

This information should have been circulated for public comment. An agency must recirculate a revised Draft EIR for public comment whenever “significant new information” is added after public notice is given of the availability of the Draft EIR for public review but before certification. (CEQA Guidelines, § 15088.5(a).) “Significant new information” requiring recirculation includes information showing that the Draft EIR was “so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.” (Guidelines, § 15088.5(a)(4).) The purpose of recirculation is to subject the new information “to the same critical evaluation that occurs in the draft stage,” so that “the public is not denied an opportunity to test, assess, and evaluate the data and make an informed judgment as to the validity of the conclusions to be drawn therefrom.” (Laurel Heights Improvement Association v. U.C. Regents (1993) 6 Cal.4th 1112, 1132.). This purpose has not been fulfilled with respect to the new noise study only recently prepared for this Project. The fact that the Draft EIR wholly omitted this analysis indicates that it was “fundamentally and basically inadequate” with respect to its consideration of noise impacts on receptors in the Super 8 motel.

Regardless, the new analysis omits consideration of noise impacts at the Super 8 motel from construction of the project, focusing on operational impacts. As shown in the attached letter from noise expert Derek Watery, construction noise impacts to occupants of the adjacent motel will be significant and unmitigated.

Traffic
As we pointed out to the Planning Commission, several commenters raised significant, material concerns regarding the Draft EIR’s analysis of traffic impacts, emergency vehicle response impacts, and pedestrian safety. The Final EIR’s Fort Bragg City Council
June 5, 2023

responses to many of these comments consist of references to the same discussions in the Draft EIR that the commenters had questioned, with no new analysis provided. Such responses also do not meet CEQA’s standards for good faith, reasoned analysis in response to public comment.

Urban Decay
In response to our comments on the Draft EIR requesting an urban decay analysis, the City to its credit undertook to prepare one. The result, which concludes the Project will have no urban decay impacts resulting from closures of competing retailers in the market area, is appended to the Final EIR as a new appendix. As with the new noise study, this new urban decay study has not been circulated for review and comment, and accordingly has not been subjected to public scrutiny as required by CEQA. The omission of any analysis of urban decay from the Draft EIR triggered a duty to recirculate the late-prepared analysis for further public comment.

For the above reasons, the City Council should decline to certify the Final EIR as adequate under CEQA at this time, and should deny the requested land use entitlements for the Project until such time as the EIR can be brought into full compliance with CEQA.

Thank you for your consideration of these concerns.

Most sincerely,

M. R. WOLFE & ASSOCIATES, P.C
Mark R. Wolfe
On behalf of FB Local Business Matters
MRW:sa
attachments
ATTACHMENT 1
Truck traffic: Annual Average Daily Truck Traffic on California State Highways h#ps://dot.ca.gov/programs/traffic-operaNons/census
State Route 1 at JuncNon with Rte 20:

ATTACHMENT 2
h#ps://experience.arcgis.com/experience/11d2f52282a54ceebcac7428e6184203/page/CalEnvi roScreen-4_0/
h#ps://experience.arcgis.com/experience/ed5953d89038431dbf4f22ab9abfe40d/page/Indicato rs/?views=Diesel-ParNculate-Ma#er
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CATEGORIES
Health, Air Pollution, Cars & Trucks, Construction & Earthmoving Equipment, Environmental Justice, Oceangoing Vessels & Harbor Craft, Freight & Goods Movement, Trains & Railyards, Transit, VW Diesel Vehicles Exposure, Community Air Protection Program , Community Health, Zero-Emission Powertrain Certification, Alternative Diesel Fuels, In-Use Off-Road Diesel-Fueled Fleets Regulation, Study of Neighborhood Air near Petroleum Sources, School Buses Information

CONTACT
Research Division
[email protected]
(916) 445-0753
Overview: Diesel Exhaust & Health
Background
Diesel engines emit a complex mixture of air pollutants, including both gaseous and solid material.The solid material in diesel exhaust is known as diesel particulate matter (DPM).

More than 90% of DPM is less than 1 µm in diameter (about 1/70 the diameter of a human hair), and thus is a subset of particulate matter less than 2.5 microns in diameter (PM2.5). Most PM2.5 derives from combustion, such as use of gasoline and diesel fuels by motor vehicles, burning of natural gas to generate electricity, and wood burning. PM2.5 is the size of ambient particulate matter air pollution most associated with adverse health effects of the air pollutants that have ambient air quality standards. These health effects include cardiovascular and respiratory hospitalizations, and premature death. As a California statewide average, DPM comprises about 8% of PM2.5 in outdoor air, although DPM levels vary regionally due to the non-uniform distribution of sources throughout the state.

DPM is typically composed of carbon particles (“soot”, also called black carbon, or BC) and numerous organic compounds, including over 40 known cancer-causing organic substances. Examples of these chemicals include polycyclic aromatic hydrocarbons, benzene, formaldehyde, acetaldehyde, acrolein, and 1,3-butadiene. Diesel exhaust also contains gaseous pollutants, including volatile organic compounds and oxides of nitrogen (NO ). NO emissions from diesel engines are important because they can undergo chemical reactions in the atmosphere leading to formation of PM2.5 and ozone.

Most major sources of diesel emissions, such as ships, trains, and trucks operate in and th
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around ports, rail yards, and heavily traveled roadways. These areas are often located near highly populated areas. Because of this, elevated DPM levels are mainly an urban problem, with large numbers of people exposed to higher DPM concentrations, resulting in greater health consequences compared to rural areas. A large fraction of personal exposure to DPM occurs during travel on roadways. Although Californians spend a relatively small proportion of their time in enclosed vehicles (about 7% for adults and teenagers, and 4% for children under 12), 30 to 55% of total daily DPM exposure typically occurs during the time people spend in motor vehicles.

Diesel Particulate Matter and Health
The majority of DPM is small enough to be inhaled into the lungs. Most inhaled particles are subsequently exhaled, but some deposit on the lung surface. Although particles the size of DPM can deposit throughout the lung, the largest fraction deposits in the deepest regions of the lungs where the lung is most susceptible to injury.

In 1998, CARB identified DPM as a toxic air contaminant based on published evidence of a relationship between diesel exhaust exposure and lung cancer and other adverse health effects. In 2012, additional studies on the cancer-causing potential of diesel exhaust published since CARB’s determination led the International Agency for Research on Cancer (IARC, a division of the World Health Organization) to list diesel engine exhaust as “carcinogenic to humans”. This determination is based primarily on evidence from occupational studies that show a link between exposure to DPM and lung cancer induction, as well as death from lung cancer. Download the IARC report (external site).

Because it is part of PM2.5, DPM also contributes to the same non-cancer health effects as PM2.5 exposure. These effects include premature death, hospitalizations and emergency department visits for exacerbated chronic heart and lung disease, including asthma, increased respiratory symptoms, and decreased lung function in children. Several studies suggest that exposure to DPM may also facilitate development of new allergies. Those most vulnerable to non-cancer health effects are children whose lungs are still developing and the elderly who often have chronic health problems.

Estimated Health Effects of DPM in California
DPM has a significant impact on California’s population. It is estimated that about 70% of total known cancer risk related to air toxics in California is attributable to DPM. Based on 2012 estimates of statewide exposure, DPM is estimated to increase statewide cancer risk !"#$%&'()*+,
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by 520 cancers per million residents exposed over a lifetime. Non-cancer health effects associated with exposure to DPM (based on 2014 - 2016 air quality data) are shown in the table below.

Health Effect
Estimated Annual Number of
Cases*
Cardiopulmonary Death 730 (570 – 890)
Hospitalizations (Cardiovascular and
Respiratory)
160 (20 – 290)
Emergency Room Visits for Asthma 370 (240 – 510)
*Values in parenthesis indicate 95% confidence interval.

More Information
Trends in Outdoor Levels of DPM
The figure below shows the trend in ambient DPM. CARB regulations** of diesel engines and fuels have had a dramatic effect on DPM concentrations. Since 1990, DPM levels have decreased by 68%. The figure also shows which regulations have had the greatest impact on DPM.

DPM levels are expected to continue declining as additional controls are adopted, and the number of new technology diesel vehicles increases.
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**Abbreviations of CARB regulations used in table: HDV Engine STD = Heavy-duty diesel truck engine standard; HDV - Off road = Heavy-duty off-road diesel engines; Port rule = Port (drayage) trucks; PSIP = Periodic self-inspection program; Transit bus = Urban transit buses; ULSD = Clean diesel fuel
The figure below shows that despite the increased number of vehicle miles traveled by diesel vehicles (VMT, red line), and despite increases in statewide population (green line) and gross state product (GSP, a measure of growth in the state’s economy, light blue line), CARB’s regulatory programs still led to a decline in statewide cancer risk (dark blue line). !"#$ %&'()*+,
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Additional Information
CARB’s diesel programs
CARB’s diesel mobile vehicles and equipment activities
CARB’s freight transport, ports and rail programs
California's diesel fuel program
Other diesel-related programs
Selected references on diesel-related health effects
Environmental Effects of Diesel Exhaust
In addition to its health effects, diesel exhaust significantly contributes to haze that reduces visibility by obscuring outdoor views and decreasing the distance over which one can distinguish features across the landscape. Researchers have reported that in the San Joaquin Valley and in southern California, diesel engines contribute to a reduction in visibility. This decrease in visibility is caused by scattering and absorption of sunlight by particles and gases present in diesel emissions.

DPM also plays an important role in climate change. A large proportion of DPM is composed of BC. Recent studies cited in the Intergovernmental Panel on Climate Change !"#$%&'()*+,
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report estimate that emissions of BC are the second largest contributor to global warming, after carbon dioxide emissions. Warming occurs when BC particles absorb sunlight, convert it into infrared (heat) radiation, and emit that radiation to the surrounding air. A recent California-specific study showed that the darkening of snow and ice by BC deposition is a major factor in the rapid disappearance of the Sierra Nevada snow packs. Melting of the snow pack of the Sierra Nevada earlier in the spring is one of the contributing factors to the serious decline in California’s water supply. As additional DPM controls are adopted, and the number of new technology diesel vehicles increases, BC emissions will continue to decline.

Conclusions
Although progress has been made over the past decade in reducing exposure to diesel exhaust, diesel exhaust still poses substantial risks to public health and the environment.

Efforts to reduce DPM exposure through use of cleaner-burning diesel fuel, retrofitting engines with particle-trapping filters, introduction of new, advanced technologies that reduce particle emissions, and use of alternative fuels are approaches that are being explored and implemented. CARB anticipates that newly adopted diesel exhaust control measures will reduce population exposure even further, and that as the sustainable freight program expands, population exposure to diesel exhaust pollution will decrease even further. It is estimated that emissions of DPM in 2035 will be less than half those in 2010, further reducing statewide cancer risk and non-cancer health effects.

RELATED RESOURCES
Public Workshop
Notice on March 16,
2021 - Espanol
Public Workshop
Notice on March 16,
2021
SNAPS Lost Hills
Newsletter - February
2021 !"#$
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Letter EMY
2 June 2023
Mark R. Wolfe, Esq.

M. R. Wolfe & Associates, P.C.
580 California Street, Suite 1200
San Francisco, CA 94104
SUBJECT: Best Development Grocery Outlet, City of Fort Bragg Revised Final Environmental Impact Report
Review of Noise Analysis
Dear Mr. Wolfe,
As requested, we have reviewed the information and noise impact analyses in the following documents:

Best Development Grocery Outlet
Draft Environmental Impact Report (“DEIR”), SCH No. 2022050308 City of Fort Bragg, California
September 2022
Best Development Grocery Outlet
Revised Final Environmental Impact Report (“RFEIR”), SCH No. 2022050308 City of Fort Bragg, California
May 2023
Wilson, Ihrig & Associates, Acoustical Consultants, has practiced exclusively in the field of acoustics since 1966. During our 55 years of operation, we have prepared hundreds of noise studies for Environmental Impact Reports and Statements. We have one of the largest technical laboratories in the acoustical consulting industry. We also utilize industry-standard acoustical programs such as Environmental Noise Model (ENM), Traffic Noise Model (TNM), SoundPLAN, and CADNA. In short, we are well qualified to prepare environmental noise studies and review studies prepared by others.

ATTACHMENT 3

WILSON IHRIG
Grocery Outlet, Ft. Bragg – RFEIR Noise Review

Comments on RFEIR Noise Analysis
Issue #1: Construction Noise Analysis Unsubstantiated
The full description of the construction noise analysis is presented in the DEIR:

The Federal Highway Administration’s (FHWA) Roadway Construction Noise Model (RCNM) was used to predict noise levels for standard construction equipment used for roadway improvement projects. The assessment of potential significant noise effects due to construction is based on the standards and procedures described in the Federal Transit Authority (FTA) guidance manual and FHWA’s RCNM.

The RCNM is a Windows-based noise prediction model that enables the prediction of construction noise levels for a variety of construction equipment based on a compilation of empirical data and the application of acoustical propagation formulas. It enables the calculation of construction noise levels in more detail than the manual methods, which eliminates the need to collect extensive amounts of project-specific input data. RCNM allows for the modeling of multiple pieces of construction equipment working either independently or simultaneously, the character of noise emission, and the usage factors for each piece of equipment. [DEIR at p. 3.6-12]
The RCNM has become a de facto standard for construction noise analyses, and Table 3.6-8 of the DEIR presents calculations to determine the hourly average (Leq) noise level at a standardized distance of 50 feet for each phase of construction. I have corroborated these calculations to be correct.

The next step in the RCNM methodology would be to project these noise levels to various distances representing noise-sensitive receivers. In a situation like the one here where the distances are relatively close, the ground is flat, the roadway is paved, and there are not natural barriers, the RCNM uses the attenuation rate for a point source, 6 dB per doubling of distance. The distance for each construction phase is measured from the center of the construction activity.

The analysis in the DEIR deviates from the RCNM methodology and, instead, uses a commerciallyavailable acoustical analysis program called SoundPLAN to estimate noise levels at nearby receptors.

Presumably, the calculated levels provided in DEIR Table 3.6-8 were somehow utilized, but this is not explicitly stated. More importantly from a technical perspective, there is no description of how the sound pressure levels produced by the RCNM methodology are converted to sound power levels which are the requisite input for SoundPLAN calculations.

If we take the construction noise analysis at Table 3.6-8 and carry on with the standard RCNM analysis, we see levels that are several decibels higher than those reported in RFEIR Table 3.6-9 (these are the output of the SoundPLAN model). Table 1 below compares the standard RCNM calculated level with those from the RFEIR for Receptor R3. Figure 1 below shows the proximity of the various construction stages to Receptor R3.

WILSON IHRIG
Grocery Outlet, Ft. Bragg – RFEIR Noise Review

Table 1 Comparison of RCNM and RFEIR Calculations
Construction Phase
Hourly Average Leq at 50 ft (RFEIR Table 3.6-8)Distance from Activity Center to R3Attenuation at 6 dB per doubling of distanceRCNM-Calculated Hourly Leq at R3RFEIR-Reported Hourly Leq at R3 (RFEIR Table 3.6-9)Difference dBA feet dB dBA dBA dBA
Demolition - Building Demolition 79.8 123 ─ 7.8 72.0 68.1 3.9 Demolition - Foundation 84.4 123 ─ 7.8 76.6 72.9 3.7
Site Preparation 84.6 158 ─ 10.0 74.6 70.0 4.6
Grading 85.9 158 ─ 10.0 75.9 70.9 5.0
Building Construction 84.7 160 ─ 10.1 74.6 70.0 4.6
Figure 1 Geometry for Construction Noise Analysis
R3
Center of New Bldg Construction
Center of Old Bldg Demo
Center of Prep/Grading

WILSON IHRIG
Grocery Outlet, Ft. Bragg – RFEIR Noise Review

As can be seen in Table 1, the SoundPLAN results reported in the RFEIR are 3.7 to 5.0 dBA lower than those calculated using the standard RCNM methodology.

The next step in the construction noise analysis is to compare the construction noise levels with the existing ambient. The DEIR establishes through measurements that the existing ambient is 56.0 dBA [see, e.g., RFEIR Table 3.6-9]. The adopted threshold of significance for construction noise is an “increase in temporary construction noise levels of more than 12 dBA at existing residential receptors located around the project site”. [RFEIR at p. 3.0-16] Finally, the RFEIR proposes an 8-foot temporary noise barrier between the project site and Receptor R3. By comparing the estimated construction noise levels in RFEIR Table 3.6-9 (no sound wall) and RFEIR Table 3.6-10 (includes a sound wall), one can ascertain that the wall will provide up to 5.2 dB of noise reduction, a reasonable expectation. Table 2 below shows the construction noise levels at R3 with and without the temporary wall and computes the increase over the ambient. Levels that exceed the adopted threshold of significance are shown in boldface type.

Table 2 Assessment of Construction Noise at R3 Using RCNM Noise Levels Construction Phase
RCNM-Calculated Hourly Leq at R3 without wallIncrease over 56 dBANo wallRCNM-Calculated Hourly Leq at R3 with wallIncrease over 56 dBAWith wall dBA dBA dBA dBA
Demolition - Building Demolition 72.0 16.0 66.8 10.8
Demolition - Foundation 76.6 20.6 71.4 15.4
Site Preparation 74.6 18.6 69.4 13.4
Grading 75.9 19.9 70.7 14.7
Building Construction 74.6 18.6 69.4 13.4
As can be seen in Table 2, using the construction noise level values produced by the RCNM results in the conclusion that noise levels will exceed the threshold of significance – exceeding the existing ambient by more than 12 dBA – even with the temporary noise barrier for four of the five construction phases.

Construction noise level calculations in this situation are so straightforward, it’s unclear why SoundPLAN was incorporated into the RFEIR analysis. Additionally, because there is a lack of transparency in the SoundPLAN analysis, it is impossible to ascertain why the levels produced by SoundPLAN are so much lower than those produced by the RCNM methodology. What is clear is that

WILSON IHRIG
Grocery Outlet, Ft. Bragg – RFEIR Noise Review

the SoundPLAN results lead to the conclusion that the construction noise levels for the Foundation Demolition and Grading phases are only 0.1 and 0.3 dBA, respectively, below the threshold of significance. I believe it is not just a matter of expert disagreement to assert that the levels produced by the RCNM methodology support the conclusion that, in fact, construction noise levels from the subject project will cause a significant noise impact.

Issue #2: Construction Noise Analysis Neglects Super 8 Motel Until the latest Revised FEIR was released a matter of days ago, the noise assessment had never included the Super 8 Motel in any manner. The latest RFEIR does address operational noise inside the motel, but does not address construction noise. As the construction workday tends to start early and as least some lodgers at the Super 8 may reasonably be presumed to be on vacation, it incumbent upon the RFEIR to consider the impact of construction noise on the motel. Noise can disturb sleep by making it more difficult to fall asleep, by waking someone after they are asleep, or by altering their sleep stage, e.g., reducing the amount of rapid eye movement (REM) sleep. Noise exposure for people who are sleeping has also been linked to increased blood pressure, increased heart rate, increase in body movements, and other physiological effects. Not surprisingly, people whose sleep is disturbed by noise often experience secondary effects such as increased fatigue, depressed mood, and decreased work performance.

Using the same methodology as used above for the residence across Franklin Street but the closer distances to the Super 8 results in the assessment shown in Table 3. As before, levels that are more than 12 dBA above the existing ambient are shown in boldface type.

Table 3 Assessment of Construction Noise at Super 8 Motel Using RCNM Noise Levels Construction Phase
Hourly Average Leq at 50 ft (RFEIR Table 3.6-8)Distance from Activity Center to Super 8 Attenuation at 6 dB per
doubling of distance
RCNM-Calculated Hourly Leq
Increase over 56 dBA
No wall
dBA feet dB dBA dBA
Demolition - Building Demolition 79.8 95 ─ 5.6 74.2 18.2 Demolition - Foundation 84.4 95 ─ 5.6 78.8 22.8
Site Preparation 84.6 78 ─ 3.9 80.7 24.7
Grading 85.9 78 ─ 3.9 82.0 26.0
Building Construction 84.7 78 ─ 6.2 78.5 22.5
Not surprisingly because it is closer to the project site, construction noise levels at the exterior of the motel will exceed the adopted threshold of significance.

WILSON IHRIG
Grocery Outlet, Ft. Bragg – RFEIR Noise Review

Conclusion
The construction noise analysis set out using the FHWA Roadway Construction Noise Model (RCNM) but diverted to a commercially-available outdoor sound propagation program. This introduced technical complications into the analysis that are not explained and – inexplicably – produced noise level results that are substantially lower than those produced by the RCNM (as completed by me for this analysis). Using the standard RCNM methodology produces noise levels that exceed the adopted threshold of significance at both residential receptors across Franklin Street and at the Super 8 Motel which shares a property line with the project site.
* * * * *
Very truly yours,

WILSON IHRIG
Derek L. Watry
Principal
2023-06-02_grocoutlet_ftbragg_feir_noise_comments_wilson-ihrig.docx Wilson Ihrig Resume – Derek Watry – Page 1
DEREK L. WATRY
Principal
Since joining Wilson Ihrig in 1992, Derek has gained experienced in many areas of practice including environmental, construction, forensic, architectural, and industrial. For all of these, he has conducted extensive field measurements, established acceptability criteria, and calculated future noise and vibration levels. In the many of these areas, he has prepared CEQA and NEPA noise technical studies and EIR/EIS sections. Derek has a thorough understanding of the technical, public relations, and political aspects of environmental noise and vibration compliance work. He has helped resolve complex community noise issues, and he has also served as an expert witness in numerous legal matters.

Education
• M.S. Mechanical Engineering, University of California, Berkeley • B.S. Mechanical Engineering, University of California, San Diego • M.B.A. Saint Mary’s College of California
Project Experience
12th Street Reconstruction, Oakland, CA
Responsible for construction noise control plan from pile driving after City received complaints from nearby neighbors. Attendance required at community meetings. 525 Golden Gate Avenue Demolition, San Francisco, CA
Noise and vibration monitoring and consultation during demolition of a multi-story office building next to Federal, State, and Municipal Court buildings for the SFDPW. 911 Emergency Communications Center, San Francisco, CA
Technical assistance on issues relating to the demolition and construction work including vibration monitoring, developing specification and reviewing/recommending appropriate methods and equipment for demolition of Old Emergency Center for the SFDPW.

Central Contra Costa Sanitary District, Grayson Creek Sewer, Pleasant Hill, CA Evaluation of vibration levels due to construction of new sewer line in hard soil.

City of Atascadero, Review of Walmart EIR Noise Analysis, Atascadero, CA Review and Critique of EIR Noise Analysis for the Del Rio Road Commercial Area Specific Plan.

City of Fremont, Ongoing Environmental Services On-Call Contract, Fremont, CA Work tasks primarily focus on noise insulation and vibration control design compliance for new residential projects and peer review other consultant’s projects.

City of Fremont, Patterson Ranch EIR, Fremont, CA
Conducted noise and vibration portion of the EIR.

Wilson Ihrig Resume – Derek Watry – Page 2
City of King City, Silva Ranch Annexation EIR, King City, CA Conducted the noise portion of the EIR and assessed the suitability of the project areas for the intended development. Work included a reconnaissance of existing noise sources and receptors in and around the project areas, and long-term noise measurements at key locations.

Conoco Phillips Community Study and Expert Witness, Rodeo, CA Investigated low frequency noise from exhaust stacks and provided expert witness services representing Conoco Phillips. Evaluated effectiveness of noise controls implemented by the refinery.

Golden Gate Park Concourse Underground Garage, San Francisco, CA Noise and vibration testing during underground garage construction to monitor for residences and an old sandstone statue during pile driving for the City of San Francisco.

Laguna Honda Hospital, Clarendon Hall Demolition, San Francisco, CA Project manager for performed vibration monitoring during demolition of an older wing of the Laguna Honda Hospital.

Loch Lomond Marina EIR, San Rafael, CA
Examined traffic noise impacts on existing residences for the City of San Rafael. Provided the project with acoustical analyses and reports to satisfy the requirements of Title 24.

Mare Island Dredge and Material Disposal, Vallejo, CA
EIR/EIS analysis of noise from planned dredged material off-loading operations for the City of Vallejo.

Napa Creek Vibration Monitoring Review, CA
Initially brought in to peer review construction vibration services provided by another firm, but eventually was tapped for its expertise to develop a vibration monitoring plan for construction activities near historic buildings and long-term construction vibration monitoring.

San Francisco DPW, Environmental Services On-Call, CA
Noise and vibration monitoring for such tasks as: Northshore Main Improvement project, and design noise mitigation for SOMA West Skate Park.

San Francisco PUC, Islais Creek Clean Water Program, San Francisco, CA Community noise and vibration monitoring during construction, including several stages of pile driving. Coordination of noise and ground vibration measurements during pile driving and other construction activity to determine compliance with noise ordinance. Coordination with Department of Public Works to provide a vibration seminar for inspectors and interaction with Construction Management team and nearby businesses to resolve noise and vibration issues.

San Francisco PUC, Richmond Transport Tunnel Clean Water Program, San Francisco, CA Environmental compliance monitoring of vibration during soft tunnel mining and boring, cut-andcover trenching for sewer lines, hard rock tunnel blasting and site remediation. Work involved long-term monitoring of general construction activity, special investigations of groundborne vibration from pumps and bus generated ground vibration, and interaction with the public (homeowners).

Wilson Ihrig Resume – Derek Watry – Page 3
Santa Clara VTA, Capitol Expressway Light Rail (CELR) Bus Rapid Transit (BRT) Update EIS, CA Reviewed previous BRT analysis and provide memo to support EIS.

Shell Oil Refinery, Martinez, CA
Identified source of community noise complaints from tonal noise due to refinery equipment and operations. Developed noise control recommendations. Conducted round-the-clock noise measurements at nearby residence and near to the property line of the refinery and correlated results. Conducted an exhaustive noise survey of the noisier pieces of equipment throughout the refinery to identify and characterize the dominant noise sources that were located anywhere from a quarter to three-quarters of a mile away. Provided a list of actions to mitigate noise from the noisiest pieces of refinery equipment. Assisted the refinery in the selection of long-term noise monitoring equipment to be situated on the refinery grounds so that a record of the current noise environment will be documented, and future noise complaints can be addressed more efficiently.

Tyco Electronics Corporation, Annual Noise Compliance Study, Menlo Park, CA Conducted annual noise compliance monitoring. Provided letter critiquing the regulatory requirements and recommending improvements.

University of California, San Francisco Mission Bay Campus Vibration Study, CA Conducted measurements and analysis of ground vibration across site due to heavy traffic on Third Street. Analysis included assessment of pavement surface condition and propensity of local soil structure.

From: Annemarie
To: City Clerk; cdd
Subject: public comments Grocery Outlet EIR meeting 6-5-2023 Date: Monday, June 05, 2023 9:59:06 AM
Attachments: public comments GO EIR 6-5-2023.pdf
To City Council,
Please accept my public comments and City staff please post them online today.

Thanks, Annemarie Weibel
Public comment EIR GO 6-5-2023
To City Council,
Under the California Environmental Quality Act (CEQA) if mitigation measures are included to reduce impacts to a less-than significant level, the resulting document is called a Mitigated Negative Declaration (MND). You approved the MND for the Grocery Outlet (GO) project. Challenged by a law suit you are tasked again to evaluate a slightly changed environmental document, the Environmental Impact Report (EIR).

This below quote from the book “Understanding Environmental Impact Assessment, A Layperson’s Guide to Environmental Impact Documents & Processes written by Grosetti Environmental Consulting” points out that “Impact assessment requires projection, which by its very nature can be subjective. Even quantative models that profess to provide definitive analytical data often have large margins of error and can be manipulated by “tweaking” the inputs to result in the desired output.

Further subjectivity enters into the process in determining the significance of an impact”. In other words, opinion.

James G. Moose of the law firm Remy Moose Manley on behalf of Best Properties, the Applicant for the proposed Best Development GO project, responded to comments submitted by Mark Wolf (attorney for Fort Bragg Business Matters), Jacob Patterson, Leslie Kashiwada, North Bay Labor Council and I.

These comments are encouraging you to believe that much expertise went into preparing this Final EIR for a project that, in their legal opinion, could have been eligible for a CEQA Class 32 categorical exemption for infill development. The Class 32 exemption applies to qualifying infill projects that are on sites within cities that are not greater that five acres in size.

There must have been a reason that the City of Fort Bragg was in favor of an EIR! GO, a discount (bargain) store buys goods from consumer packaged goods (CPG) manufacturers that have excess inventory or the packaging is damaged, for pennies on the dollar. Pepsi, Coca-Cola, and Nestle are such companies. Nestle is the world's biggest CPG with a market cap value of $349.20 Billion (2023). This makes Nestle the world's 23th most valuable company. Their revenue approaches $2.13 billion. The goal of the 77 year old GO business is to sell as many products to as many consumers as possible. They have 449 stores now compared to 300 in 2017 across the nation and more than 1.5 million shoppers. What about future prognosis as many franchise stores including fast food/franchise restaurants are going under? Will we end up with another empty building? Does GO uses Electronic Benefits Transfer (Cards) used by CalFresh. I believe the farmer’s markets do and Harvest Market does (a B Corporation). Safeway has a union, but GO does not. GO’s headquarters take 50% of the income from the independent operators. Representatives from GO did not explain if employees would be paid California’s minimum wage $15.50 or less. How much less? Does it depend where the headquarter is and what the going rate is there (Emeryville is higher, Pennsylvania is lower)? Do employees get medical/dental/vision benefits? What about maternity leave/sick leave? We are not told if the store will use 15 or 25 employees. Will they be replaced by self check out stands? Do we need more products by huge corporations? Are these mostly prepackaged items including salty and sweet items and products containing cancer causing red, yellow, and green dyes healthy for us? This might not be relevant as far as the EIR is concerned, but # 7 of the Standard Conditions addresses that “this permit shall be subject to revocation or modification upon a finding of any one or more of the following: (c) That the use for which the permit was granted is so conducted as to be detrimental to the public health, welfare, or safety or as to be a nuisance. In my mind this GO, especially at this location is detrimental to the public health, welfare, safety and is a nuisance.

I understand that many of our citizens are barely able to survive and that they are begging you to approve this EIR. They want cheap food and are not aware of the legalities with environmental documents. It is unfortunate that the EIR is a piecemeal project, describes the setting incompletely, has unsupported analysis, fails to adequately address long term aspects (sustainability issues), fails to adequately address cumulative impacts, is listing an inadequate range of alternatives (straw man alternatives), was providing an inadequate public review period with all the changes, and did not allow a new opportunity for the public to review substantial new information like the supplemental Urban Decay Study. This study should be circulated for public review and comment. Both shopping centers (Boatyard & the DMV mini mall) have vacancies. Also downtown has had close to 20 vacancies for almost 10 years causing blight/urban decay. Now we want to squeeze more and more development on the South Side, the gateway to Fort Bragg causing many new problems not addressed in the EIR.

Policy LU-3.5 of the Coastal General Plan was not considered in the EIR.

GO, the national discount grocery chain would provide full time work for 15 to 25 full time staff. The CA minimum wage is $15.50 per hour with no benefits (no health care, no sick leave, no maternity leave). GO does not support nonprofits like our other stores do. In the meanwhile the profits the company makes go sailing out of the county to their headquarter in Emeryville. These employees can not find a rental or afford to pay for a rental with their paycheck. The socioeconomic effects have not been analyzed in this EIR. Maybe the two managers can find and afford housing. Why does GO not build housing here for their employees or buy housing for them? Why is the city not asking developers to do that as we all know how serious the situation is here. These land use and planning issues have not been addressed in the EIR. Most businesses are looking for employees and they have to reduce their services as they can not find them. The proposed project will hurt our downtown and existing businesses and their employees. Not only will GO make it harder for other businesses that provide good wages and benefits in our community to compete with this cheap labor, it will also likely result in the loss of several better paying positions for our members in our community. A net loss of these better paying positions will also directly impact other businesses in our community. It is possible that a smaller store like Purity Supermarket will not survive.

The power point presentation at the October 24, 2019 Special City Council meeting listed all top 25 sales tax producers (marked in yellow were the 16 formula businesses). In addition to these top 25 sales producers we have formula businesses like Mountain Mike's Pizza, Starbucks, Sears, Rite Aide, Subway Sandwiches & Salads, SHN Consulting Engineers & Geologists, Edward Jones Investments and Sinclair Gas. Certain Starbucks, Rite Aide’s, and CVS are closing nationally. Don’t we have enough formula businesses already? Why was the regulations about formula businesses in the Coastal Zone never submitted to the Coastal Commission? We would have it approved by now if we would have applied in 2019. The aesthetic and visual resources of GO with their signs has not been properly addressed in the EIR. Policy LU-4-1 & CD-1.1 & CD-1.4 & CD-1-10 of the Coastal General Plan were not considered in the EIR.

While GO is increasing their wealth we might find ourselves in the position that we will have empty shelves if oil/gasoline/diesel prices change dramatically, and/or food prices increase. We might not be able to rely on trucks coming here, but should rather see how we can become self sufficient, grow our own food, barter and trade and run our own businesses. It can happen that we would be cut off form the outside world if rivers are flooded, bridges collapse in an earthquake, and storms make it impossible to go anywhere, etc. These issues in regards to transportation have not been properly addressed in the EIR.

There is a pending diesel fuel shortage. We could have no diesel fuel. Last October it was said the United States had only a 25-day supply of diesel left. If there’s no change, around Election Day we’ll see trucks parked throughout much of the country. https://finance.yahoo.com/news/us-now-just-25- days-160000619.html
Bloomberg says the east coast is already running out. Shipments on the way to Europe have been turned back. https://www.bloomberg.com/news/articles/2022-10-25/the-us-diesel-shortage-is-rapidlydevolving-one-supplier-says https://www.realclearpolitics.com/video/2022/10/26/
nsc_spokesman_there_was_no_meltdown_over_saudi_oil_production_cuts.html https://www.realclearinvestigations.com/articles/2022/10/27/ zero_emissions_from_electric_vehicles_heres_why_that_claim_has_zero_basis_860938.html Idaho Grocery Store Shelves Could be Bare in a Matter of Weeks https://newsradio1310.com/idaho-grocery-store-shelves-could-be-bare-in-a-matter-of-weeks/? utm_source=tsmclip&utm_medium=referral
Not only could we have a problem getting diesel, but the risk is high for residents living close by to be severely affected by the diesel emissions. The air quality/greenhouse gas emissions have not been analyzed in the EIR. Policy LU-10.5 of the Coastal General Plan was not considered in the EIR.

The outdated traffic study from 2019 and two updates do not take into consideration the traffic associated with summer months and holidays, areas south and north that were not evaluated, and a change in traffic control at “SR 1/N. Harbor Drive intersection. It is interesting that there was hardly any information from Caltrans in regards to this intersection. Apparently there were telephone conversations between the City and Caltrans. Doesn’t the public has a right to be informed as well? Is a left turn authorized at this intersection or did we just loose a traffic sign? In Albion, Caltrans wants to reconfigure how the two roads (Albion-Little River Rd. and Albion River N. Side Rd.) can be aligned differently to prevent accidents on SR 1 next to the Albion River Bridge. Why not in Fort Bragg? The left turn from westbound N. Harbor Dr. onto Main St. is apparently a Caltrans issue. Why was this not addressed? James G. Moose indicates that “time will tell.” Do we need to wait until people get seriously hurt or die before we come up with a better traffic situation? That is only one of the issues that cause this project to be problematic at this site.

The Mendocino County Coastal Element adopted by the BOS and certified by the Coastal Commission in 1985 indicated in “4.4-3 The County shall develop an evacuation route for the Noyo Harbor area, in addition to North Harbor drive, by re-opening the road west of Agostino's (AP# 18-120-19) for emergency use only. The County shall coordinate evacuation procedures with the U.S. Coast Guard and all concerned law enforcement agencies.” As others mentioned including a City Council member this would be necessary in order for this project to be built at this site.

The parking situation is less than appropriate. No other big store in town includes the delivery area in their parking lot for the public. A RV park is not sufficient. What about 5th wheels, etc. The parking is not safe for pedestrians or cars. Nowhere is discussed where parking would be for the employees.

Policy CD-5.1 of the Coastal General Plan was not considered in the EIR. Neither were Policy LU-5.6 & 5.7 & OS-16.7 of the Coastal General Plan.

The mostly elderly pedestrians that would want to shop at GO do not have sufficient safe sidewalks.

Policy C-6.2 & C-9.3 & C-9.7 of the Coastal General Plan were not considered in the EIR.

In addition we have noise (from trucks backing up, from sirens by emergency vehicles, demolition, construction, increased traffic) in a residential neighborhood that is also affecting visitors attracted by the harbor. These visitors do not come here to find yet another City that looks like what they left behind. Aren’t we shooting ourselves in the foot? Is the City really going to benefit financially from the tax dollars? The 20% that GO will gain from alcohol will cause more issues with the population indulging in it. Other businesses would also bring in less tax dollars to the City.

The Assessment of Alternatives did not address that maybe this store should not be at this site (maybe north of town); or a vacant building could be used to prevent increased blight in the neighborhood; or the Planning Commission could ask for a modern, less cookie cutter corporate building as we have seen in a picture from the Chico GO. What we need to do is invest in small businesses, fill the gaps, tap local anchors to get involved and help, plant community gardens, follow the Blue Zone guidelines, and build community pride.

Policy CD-2.5 of the Coastal General Plan was not considered in the EIR. There is more than a “distant keyhole view of the ocean that is interrupted by two large trees now” (at least the horizon) and should have been addressed and evaluated more in the Assessment of Alternatives. The view is being described as being “very small, distant and fragmented.” This description makes me reflect what we heard from the City with the Hare Creek mall that the ocean could only be seen from SR 1 if one would jerk the head around while driving and even then could only see a sliver. By placing the building next to South street that view is gone. To argue that down the road there might be another building there is ridiculous at best. I wonder how badly the city wants the tax money from this development and is willing to help push a project such as this forward.

Policy CD 2.1 of the Coastal General Plan was not considered in the EIR. It addresses the Design Review.

If you should approve the Special Conditions please consider accepting the Special Condition that Jacob Patterson suggested in his comments in regards to Special Condition 1A. Policy OS-5.2 of the Coastal General Plan also indicates the need to preserve existing healthy trees.

Also see his comments in regards to Special Condition #23, Optional condition #24, and Special Condition #34. As suggested by Jacob Patterson please add a new Special Condition prohibiting adding another extra sign on the visually prominent west facade. Add that any future signs need to be approved by the Planning Commission.

Unfortunately the Initial Study (the terribly deficient Mitigated Negative Declaration) by LACO Associates was not included for the public. The new Initial Study 2022 by the DeNovo Planning Group informed the DEIR and FEIR in addition to several new technical studies and reports.

Why was the school district not notified of the DEIR?
Why was Davey Beak, emergency manager at the AH hospital not consulted as a responsible agency instead of GO’s lawyer blaming Leslie Kashiwada for not officially submitting his comments? I urge you not to recommend this project as currently proposed for approval by you for all the above listed reasons. It will not help Fort Bragg in the long run. It is not your job, or the City Council’s job to determine if the GO is favored by people or not. Your job is to examine the potential impacts of the project according to the California Environmental Quality Act (CEQA) and whether or not they can be mitigated enough to reduce it down to an acceptable (or less-than-significant) level. The approximately 36 Special Conditions are an indication that no matter how much lipstick you put on this pig, it is still a pig!
As you can see the General Plan Policies are not consistent with the EIR and the code provisions, and the EIR is not adequate as far as the Analysis of the Alternatives are concerned.

Sincerely, Annemarie Weibel
6-5-2023
From: dcalvert
To: City Clerk
Subject: CDP 2-22,DR 7-22, MGR 1-22 GROCERY OUTLET
Date: Monday, June 05, 2023 11:28:00 AM
I support the Grocery Outlet application and urge the City Council to certify the EIR and approve CDP 2-22, DR 7-22 and MGR 1-22.

This is an excellent location for the store in close proximity to the highest housing density in Fort Bragg.

It removes a long vacant decaying building and adds assessed valuation on the parcel to the city's tax rolls.

It provides another option for coastal grocery shoppers with a different price point.

It will reduce trips "over the hill" by people who travel to Willits just to go to Grocery Outlet.

While groceries are not taxed, Grocery Outlet also sells a number of items such as brooms that are taxed. Those tax dollars should be kept in Fort Bragg.

Thank you for your consideration of these comments.

Karen Calvert
PO Box 70
Albion CA 95410
Sent from my Verizon, Samsung Galaxy smartphone
From: Mary Kilgos
To: City Clerk
Subject: For June 5th city council meeting-Grocery Outlet-vote yes Date: Friday, June 02, 2023 6:36:17 PM
Affordable grocery prices will help many.

Mary Jane Kilgos
32200 Highway 20
Fort Bragg, CA 95437
Sent from my iPad
From: John
To: City Clerk; "John"
Subject: Grocery Outler
Date: Sunday, June 04, 2023 12:08:07 AM
6-3-2023
Hi...I would like to see the store approved.

I have visited the stores in Ukiah and Willits. They have a variety of products that other stores do not have.

Kind of like the Dollar Store. I wouldn't do my main shopping there, but they do have some interesting products.

Also this would help people on fixed incomes. If you haven't noticed.....This inflation is very real and damaging the buying power of the Dollar.

I'm 75 and am still working part time, so it doesn't affect me as much as some people who are retired and on a fixed income with costs for
all things that they use going up.

I vote for approving the store now.

Thanks, John Ruczak.

From: Linda Jupiter
To: Lemos, June
Subject: Grocery Outlet agenda item June 5
Date: Sunday, June 04, 2023 2:15:38 PM
Dear City Council members,
I’d like to add my voice to those who are against the proposed Grocery Outlet (GO) in Fort Bragg.

We do need to encourage businesses to open up here in Fort Bragg but GO is not one of them.

They will not enhance quality of life for most of our citizens on the coast.

Yes, we need more jobs here in town, however, GO pays full-time people less than the state minimum (is that even legal?) and gives no medical benefits. Meanwhile, GO will take business away from other local businesses so folks with decent paying jobs will be out of work. If they’re desperate enough to look for work at GO, they’ll be making less money with no benefits.

In addition, traffic, noise pollution, and difficulty to access the health clinics and hospitals will increase.

If it’s true that Grocery Outlet had a pre-existing business relationship with the EIR consultant, and that they failed to provide adequate study and analysis on a number of project impact issues, this should be grounds for the EIR being rejected by you tonight.

Thank you for your great work,
Linda (she/her)
Uninvited dweller on Northern Pomo land
-----------
Linda Jupiter
P.O. Box 2822
Fort Bragg, CA 95437
phone 707-964-8985
From: Kathy Orsi
To: City Clerk
Subject: Grocery Outlet letter of support
Date: Monday, June 05, 2023 9:48:07 AM
Dear Council Members,
Thank you for taking the time to read all letters regarding the Grocery Outlet and having an open mind.

I continually express my views on Facebook when given the opportunity supporting Grocery Outlet coming to Fort Bragg. A store on the outskirts of town, will bring value to residents, particularly those on a budget. Young families and the elderly need more shopping choices. Young families are already going out of town to shop at Grocery Outlet so they can make ends meet, most living pay check to pay check. That gas money should stay in their wallets and their grocery money should stay on the Coast! In addition, the jobs this store will create will help so many in our community.

I hear great things about Grocery Outlet stores in other areas….always supporting and donating to the Community.

A brand new building will be a welcome sight on the corner of South and Franklin streets.

Your sincere and thoughtful objectivity is most appreciated when considering Grocery Outlet’s application. I ask you to approve their application. I guarantee our lovely Harvest Market will continue to do fine. I will continue to shop at all the stores, as each meet different needs.

Sincerely,
Kathy Orsi
Lifelong Fort Bragg Resident
From: Mary Rose Kaczorowski
To: City Clerk
Subject: Grocery Outlet Public Comment for City Council special meeting June 5, 2023 Date: Monday, June 05, 2023 8:48:31 AM
Attachments: image.png
Dear Fort Bragg City Council,
I applaud that the you and the City of Ft. Bragg has pledged to work to keep our streets safe, and to a well-planned framework for sustainable development and prosperity.

I would like to remind the Council of their commitment to the City of Ft. Bragg Draft 2012 Climate Action Plan which states:
“Our commitment to sustainability should be integrated into our everyday decisionmaking processes at City Council, within City departments, and throughout the community. We should all identify specific measures to work on each year. The implementation of sustainability measures, such as energy efficiency, water conservation, waste reduction, localization of goods, and alternative transportation methods, should become part of the normal evaluative criteria in work plans, budgets, construction contracts, and proposals.”- City of Ft. Bragg Draft 2012 Climate Action Plan
https://www.city.fortbragg.com/home/showpublisheddocument/380/6377099899957 53660
The Fort Bragg City Council rejected a formula business/ big box store Auto Zone. One of the key reasons and facts was that this Auto Zone commercial establishment would detract from the overall economic and cultural vitality of the City per recommendation by the Planning Commission as it would compete with the other Auto Parts Supply shops already established in the City.

See screenshot from City of Fort Bragg Planning Commission Resolution PC08-2019 Has the City and Planning Commission gone backwards? I hope not.

The Grocery Outlet Corporate formula Store is a commercial establishment and will result in an over-concentration of grocery business establishments in its immediate vicinity or in the City.

Do we REALLY need another grocery store competing with our local stores and adding more traffic? Grocery Outlet is a formula business and a publicly traded company. From an economic perspective, there is much data that exists that indicates that corporate owned big box chain stores --even if a franchise or with independent owners owning the business (the operators do not own the building/infrastructure) may not be the best value for a community in terms of how they undercut all the community-based and independently owned markets already in place such as:

Harvest Market, (B Corporation)
Purity Market,
Safeway (Union shop)
Down Home Foods,
B&G Grocery,
Roundman's Smoke House,
Columbi’s Market,
El Yucca,
Nello’s Market and
Deli,
La Mexicana Market,
Fort Bragg Farmer’s Market,
Corners of the Mouth,
Harvest at Mendosa’s.

The Dollar Store
CVS
Cucina Verona's Mercado
Rite Aide
and gas station convenience stores that now carry food items Several local grocery stores every week take their overstock, imperfections, or looming expiration date items to our local food bank. Local farms also supply our food bank. Food waste is not an issue here. Now we want a Formula Store to charge people for what they can get for free at the Food Bank distribution Centers? I would like to cite 18.46.070 Burden of Proof from the City of Ft. Bragg's Ordinances:
"If the City determines that a permit application or permit is subject to this Chapter for a formula business, the permit applicant or holder bears the burden of proving to the City that the proposed or existing use does not constitute a formula business." If the City approves the GO application it is another great way to knock out your local businesses and support another Formula Corporate Business entity.

Traffic, Safety and Pollution
The EIR is flawed and biased.

This project will add to the already high traffic in the area and generate hundreds of new vehicle and delivery truck trips per day along S. Main Street, S. Franklin St., N. Harbor Drive, River Drive, Cypress Street and South Street. These streets are also the entryways to the busy: medical offices, Round Table Pizza, TACO Bell, several gas stations, auto repair
shops, Parents and Friends buildings, Mendocino Coast Pharmacy, Adventist Health Mendocino Coast Hospital’s Emergency Room & several hospital facilities, Mendocino Coast Clinics, Mendocino County Social Services, Mendocino Superior Court Ten Mile Branch, Fort Bragg Police Station, Mendocino Sports Club, various dental and physical therapy offices, other medical offices along the 510 Cypress St. Medical complex and the now opened Crisis Respite Center (517 Cypress Street) .

This is not about just local resident trips-- These are also ongoing coastal residents and tourist
trips along with assorted vendors servicing the high profile and already dense neighborhood businesses
including: U.S. Postal Service, private express delivery vendors, pharma and lab vendors to the hospital and medical offices, Fed Ex, UPS, PG&E, AT&T, Comcast.

Verizon, Public Works,
electricians, plumbers, carpenters, yard and landscape services, Emergency Ambulance, CHP, Sheriff and Police vehicles, Waste transfer vehicles, and vehicles that go through Lyme Timber Logging gates off Cypress St.

Let’s not forget the past COVID Vaccine testing and vaccine delivery vehicle line ups and some still occur.

We will have more bottle necks to these areas and to the entry down to the Noyo Harbor businesses, restaurants and shops.

It’s hard enough already, to try to get down to Noyo Harbor or navigate the traffic around South Main Street, South Street, S. Franklin St. and Cypress Street.

Vehicle accidents and near misses with pedestrians and other vehicles are common.

This neighborhood is already one of the highest traffic areas compared to the rest of the City of
Ft. Bragg neighborhoods.Walking and biking is already and will become more hazardous.

The traffic going down to the Harbor on South Harbor Drive is already an unmitigated and ignored problem.

Big rigs already transporting goods to other stores stay overnight at motels in that area and park their rigs on
the property or along the Grocery Outlet proposed site.

There are now eight existing apartment complexes and townhouses along Cypress St. and Kempe Way, including the 69-unit DANCO subdivision that utilize N.

Harbor Drive and South Street.

Emissions of pollutants from motor vehicles, are injurious to people's health.

Again the associated big rig delivery trucks (that park and even stay overnight at the adjacent motels in this neighborhood) are already impacting this area.

Burning gasoline and diesel fuel creates harmful byproducts like nitrogen dioxide, carbon monoxide, hydrocarbons, benzene, and formaldehyde. In addition, vehicles emit carbon dioxide, the most common greenhouse gas.

Consider how much more traffic will be added to the mix and the road wear is considerable on our already deteriorating roads if we add hundreds of cars going in and out of this Grocery Outlet at
these busy intersections every day. The local taxpayers bears that burden of repair! People already complain about all the delivery trucks, big rigs, giant motor home vacation campers, etc. on HWY 20 -
Please reject this project - it will not create more lucrative jobs in a town that is already trying to hire and house more workers.

The traffic nightmare is not needed that will impact on getting private vehicles or ambulances to the various medical and emergency services nearby.

This is so obvious.

My Best Regards,
Mary Rose Kaczorowski
https://muckrack.com/mary-rose-kaczorowski
Chronicles from the Redwood Coast: https://redwoodmary.substack.com/ Connect with me on LinkedIn linkedin.com/in/mrk2008
and
https://www.artsmendocino.org/artist/mary-rose-redwood-mary-kaczorowski/ How to pronounce my name? https://www.youtube.com/watch?v=5SIk7LKiJTY Remember Unity in Community.

T.E.A.M.: "Together Everyone Achieves More"
Rev. Dr. Martin Luther King said our lives begin to end the day we become silent on things that matter.

From: jaclyn moura
To: City Clerk
Subject: Grocery Outlet vote in favor of
Date: Thursday, June 01, 2023 9:07:50 PM
For the June 5th meeting considerations.

Greeting counsel and thank you for your time to review these matters from all perspectives.

Vote yes for grocery outlet
Vote yes for affordable & accesable food for all.

Vote yes for jobs.

Vote yes for local growth.

I am here to represent my personal support in favor of Grocery Outlet being here on our coastal town by the sea. local grocery business competition will do some good for the food costs of local families. Especially those whom are paycheck to paycheck.

I would appreciate an open mind to the BIG picture of what it means for one more business such as a grocery store named, Grocery Outlet to come to the coast for all locals. Not just the perspective of some but the perspective of community development, job opportunity and growth on all levels of expansion! our community is growing! We need more food to support growth. Our markets service Rock Port to Point Arena and anyone visiting/camping/ all tourism needs. We need more affordable Food options.

My understanding is Grocery Outlet is a publicly owned entity with the option to be employee owned. Sounds like a community benefit already! I have not heard of grocery outlet employees disliking their jobs because I do inquire when I have shopped at other grocery outlet branches. Everyone seems happy and very content and appreciated at their place of work. What is the difference between Grocery Outlet and Rite Aid or CVS or Safeway?! What are people against exactly?!
We have 5 grocery stores currently servicing our area. Down Home Foods, Purity, The Mexican Market, Safeway (nicknamed/referred to by locals as 'slaveway'), and Harvest/ Markup Market, I shop are all 5 as a local. Why do we not believe that there will be other locals who choose to do the same, if given the choice?
choice and voting with your dollars has a lot of power in a local community. I believe more options and FOOD COST competition will help reduce food costs here on the coast and prevent people from doing large mark ups to food for locals. (I hear tourists AND locals complain about the HIGH cost of food here locally)
I know ALOT of locals who currently GO OUT OF TOWN for big shops because they can't afford food here on the coast. Especially families**** They shop local to supplement what they ran out of till they go out of town to shop again.

Alot of folks/just about everyone has a Costco card.

Those are dollars leaving the coast. people VOTE with their dollars here and I can SEE where is goes. The dollars used to go to Costco in Santa Rosa and NOW it goes to Costco in Ukiah!!! And sometimes to Willits Groceey Outlet.

AND guess what?!?! I shop out of town too!!! Because FOOD IS EXPENSIVE HERE!!!!!! And guess what?! I love going to grocery outlets all over Cali. You never know what your going to find for a deal! The Cloverdale one is lovely and very new still! Willits is also an amazing option to shop for deals.

Confessions of a local: I SHOP EVERYWHERE! Who doesn't? I literally don't know of any family who does not utilize Costco bulk savings.

I am asking the counsel to consider how often THEY themselves do these kinds of shopping patterns for the benefit or their families and their wallets.

Currently we have a large amount of baby boomers whom are in retirement at this time and or forced out of the work world and are retiring on one leg of income called social security.

Currently that single source of income is not enough to retire on. We have a huge population of people in this community on the brink of homelessness or already there as a direct result of high cost of living, and lack of LOW INCOME housing opportunity. Add the cost of medications/medical bills, food, bills, and toiletries etc. and just off social security income your making choices like do I get my meds or do I eat this month?!?!?!? THANK GOD FOR OUR LOCAL FOOD BANK!!!!!
The food banks brings us to our 6th option for food sources on the coast.

Please consider supporting the 7th grocery store- grocery outlet so we can make sure we are not a food dessert in the event of and emergency where all roads closed off for several days creating a panic for emergency food storage & basic food supply needs for families.

Please think about this financial burden gap within the population. I am seeing the baby boomers retire on social security alone as a financial crisis we do not have enough housing or benefit programs to accommodate for everyone's current needs. These are the demographic of people getting Dollar Store food to survive. Are those people being equally represented in this demographic of individuals saying no to Grocery Outlet? I say YES! DO it! Let it happen!
POINT IS: Food should be accessible
Food should be affordable
Food should be healthy for all and not just who can afford to shop at Harvest Market. I know people in this community who can't afford to shop at Harvest Market. I don't think that is very acceptable for our community to deny Grocery Outlet when so many people in this community need and deserve access to quality healthy AFFORDABLE food.

Thank you for your time and considerations.

Sincerely,
Jaclyn Moura
P.S.

I asked Angelina Moura what she thinks of Grocery Outlet on the coast and she said, "Oh, I would love to have that store here! So nice and good prices!" Please counts us as 2 votes for YESSSSS PLEASE!!!!!!!!
I SEE MORE PRO'S than CONS!!!!!
From: Scott Roat
To: City Clerk
Subject: Grocery Outlet, for for the June 5th City Council meeting Date: Friday, June 02, 2023 5:07:45 PM
Thank you for your service.

I am in support of the proposed Grocery Outlet. Not only is the county plan already zoned for that development, I think it would ultimately be a boon for the Coast, offering alternative and possibly more economical shopping solutions in a Community that is made up by a fair amount of low income and elderly residents. Please vote to approve it - thank you.

Sott Roat
Scott Roat Realty
Your Number One Broker
on the Beautiful Mendocino Coast
- since 2005 -
Real Life. Real People. Real Estate.
c: 707.331.4120
http://www.MendocinoAgent.com
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From: sam G
To: City Clerk
Cc: cdd
Subject: Grocery outlet
Date: Friday, June 02, 2023 1:33:11 PM
I fully support the approval of the Grocery outlet project. Sam Gitchel 40 year resident voter on the Mendocino coast Thank You From: Jannis Fetters
To: City Clerk
Subject: Grocery outlet
Date: Saturday, June 03, 2023 4:27:46 PM
June 5th city council meeting, grocery outlet, I wish to vote yes. Having shopped at three Grocery Outlets, I am very impressed by their cleanliness and products available. Fort Bragg can use a grocery store that is available and convenient for the locals. Thank you for your support. Donald and Jannis Fetters, 32250 Highway 20, Fort Bragg, telephone 707.964.5751.

From: Larry Robinson
To: City Clerk
Subject: Grocery outlet
Date: Saturday, June 03, 2023 9:01:54 PM
We approve of the Grocery Outlet in Fort Bragg for the following reasons:

1. New revenue for the city.

2. Competition should lower prices.

3. Job opportunities.

4. Save gas and time driving over the hill to shop.

5. Although Grocery Outlet is a corporation each is individually owned.

6. Provide selection of products not currently on the coast.

7. LAST people who oppose Grocery Outlet do not have to shop there.

Larry and Marsha Robinson, 32051 Airport Rd., Fort Bragg, CA Larry and Marsha Robinson
From: Kate Hee
To: City Clerk
Subject: Grocery outlet
Date: Sunday, June 04, 2023 8:54:36 PM
I'm writing to encourage you to approve the Grocery Outlet for Fort Bragg. My husband and I are over 65 and on a fixed income. We were both born in Fort Bragg, and we have seen the cost of living go sky high in our community. We drive to Willits to buy affordable groceries, but we would much rather spend our money in our town. Please approve this much needed discount Grocery store.

Thank you
Kathryn and Wesley Hee
From: Josh Margerison
To: City Clerk
Subject: June 5 City Council Meeting Vote YES for Grocery Outlet Date: Monday, June 05, 2023 8:36:05 AM
Fort Bragg, and especially its most vulnerable residents, needs more competition to apply downward pressure to the costs of living.

Grocery Outlet will provide this needed competition and will result in downward pressure on costs.

Best Regards,
Joshua C Margerison, Estimator/PM
Fort Bragg Electric Inc.

Mail & Shipping:
489 S. Harrison Street
Fort Bragg, Ca 95437
Main Tel: (707)964-9118
Desk Tel: (707)964-1012
Fax No: (707)964-1404
Web Site: www.fbelectric.com
From: Erica Fielder
To: City Clerk
Subject: No to Grocery Outlet Proposal
Date: Saturday, June 03, 2023 7:10:14 AM
Dear Fort Bragg City Council,
I urge you to deny the application for the proposed Grocery Outlet (GO) on Franklin Street.

Fort Bragg has two large grocery stores that will be undermined economically by one that sells low-cost items. Don’t dilute their contribution to our town.

The proposed GO will provide poor-paying jobs with no benefits. Instead, encourage industry and commerce that genuinely benefits and lifts our citizens.

The proposed GO will cause undue traffic stress to the neighborhood, especially hospital access. I urge you to deny the application for the proposed GO.

Sincerely,
Erica Fielder
*******************************************
Erica Fielder
[email protected]
707-671-4072
See unique interpretive displays on our new website:
https://www.ericafielderstudio.com
From: Marta MacKenzie
To: City Clerk; cdd
Subject: Opposed to Grocery Outlet
Date: Saturday, June 03, 2023 6:23:38 PM
I am not opposed to having lower grocery prices in Fort Bragg. However, I am opposed to the location and to an organization in financial difficulties. The traffic at the proposed site would be extremely detrimental for access to the hospital and for the nearby residents. Any financial involvement by the city to mitigate disturbance in the area would be extremely foolhardy if Grocery Outlet is to go under in the near future. Additionally, the purported wages and benefits given to employees are disgraceful.

Marta MacKenzie, Mendocino County resident in 95437 zip code area.

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From: Julie
To: City Clerk
Subject: Proposed Grocery Outlet
Date: Sunday, June 04, 2023 9:41:14 AM

6.4.23 Fort Bragg City Council:

I would like to express my strong opposition to the proposed Grocery Outlet.

We don’t need any more big-box stores in our community.

We have a lot of struggling small businesses, which only increased during the pandemic. A store like Grocery Outlet would create unwanted competition with our local businesses.

In addition, the EIR for this proposed store has not been done properly and the local impacts of increased noise and increased traffic needs to be studied and addressed. It seems that the increased traffic would pose a problem for the ambulance service from the nearby hospital, which should be investigated.

In addition, former employees of Grocery Outlet in Ukiah say that, though the positions are full-time, the pay ($13 an hour) is less than the state minimum ($15 an hour) and they do not provide medical benefits. Grocery Outlet Corporate takes 50% of the profits out of the business. Local owners, who make all decisions related to personnel, are disincentivized to pay well and provide benefits. If Grocery Outlet takes business away from other local businesses, it will result in the loss of better-paying full time jobs with benefits.

We should be protecting the interests of the businesses that are already here. We have several grocery stores and drugstores that serve the needs of our residents and tourists.

In small rural towns, local grocery supermarkets have reported a 30% decline in sales after the introduction of a bigbox store to an area. Another large store would just take profit away from the businesses that have already established themselves as part of our community. Our community should be focusing on finding a way to fill all the empty store fronts downtown and polishing up that area to increase its appeal to residents and tourists.

If Fort Bragg wishes to attract tourists, the sight of another large store does nothing to enhance our desirability as a tourist destination. It makes us look poor and destitute. It would be a blight on our community.

Thank you for your time,
Sincerely,
Julie Rogers
Fort Bragg, CA
From: Jacob Patterson
To: City Clerk
Subject: Public Comment -- 6/5/23 CC Mtg., Response to Letter Comment from RMM about prior comments Date: Friday, June 02, 2023 11:31:25 AM
City Council,
Although I didn't bother to respond to RMM's prior letter about my DEIR comments, I noticed they submitted a public comment for the special meeting responding to some comments submitted as part of the Planning Commission public hearing on 5/10/23. This includes a response to my comments for that hearing and I want to point out an important inaccuracy in RMM's new letter. Their letter asserts that my prior comment incorporating linked documents included documents incorporated by reference "as URLs, many of which are broken" but all of the hyperlinks in my original public comment email are functional. Unfortunately, whatever the City did to generate a PDF of my email comment to include in the published public comments agenda item attachment for your special meeting on 6/5/23 apparently resulted in non-functional hyperlinks within that combined PDF file. It is important to note that each URL links to a specific downloadable document available in the City's Granicus legistar meeting software. I will not address whether or not the hyperlinked documents contain content that is relevant to this technically distinct entitlement review other than to state I disagree with RMM's stated position. In particular, I want to emphasize that the successor project details are basically identical to those in the prior application concerning the site layout, building design, etc., so prior comments concerning the project's consistency with applicable Coastal General Plan policies remain relevant to the current application under review.

Regardless, I have included relevant excerpts from that prior consistency analysis again to highlight those issues even though they are already available for anyone to read in the published public comments from the successor project's entitlement review. Importantly, the proposed project's consistency with applicable Coastal General Plan policies is not primarily a CEQA issue; instead, it is a planning issue relevant to both the CDP and Design review analysis for this project and the City's ability to make the required findings of approval. Of course, some applicable policies present CEQA issues in addition to permit planning issues, primarily because many relevant policies provide the qualitative or quantitative significance criteria that when paired with the relevant Initial Study Appendix G checklist questions, constitute the thresholds of significance for those areas of inquiry--hint: that is what I meant when I shared my opinion/position that the Initial Study Checklist questions ALONE are not adequate and complete thresholds of significance even though the checklist questions themselves are a necessary component of developing reasonable thresholds of significance.

Regards,
--Jacob
------------------------------------------------------------------------------------------------------------------ -----------------------------
Policy LU-3.5: Re-Use of Existing Buildings: Encourage the adaptive re-use and more complete utilization of buildings in the Central Business District and other commercial districts.

Consistency: Rather than adaptively reusing the vacant existing building on the site with almost the same floor area as the new building, this project, which is in a commercial district, proposes to demolish the existing building. The IS/MND includes no explanation or analysis of the viability of the existing building to serve the project objectives rather than a new structure.
[Note: The applicant presented a supplemental feasibility "analysis" about why the building (arguably) isn't feasible to be reused as a grocery store that did not exist for the first application review; that said, the Applicant's potentially biased analysis provided by an interested insider does not need to be accepted by the City Council, who are free to determine the project is inconsistent with the CGP policy.]
Policy LU-5.6: The use of private lands suitable for visitor-serving and commercial recreational facilities designed to enhance public opportunities for coastal recreation shall have priority over private residential, general industrial, or general commercial development, but not over agriculture or coastal-dependent industry.

Consistency: This project involves the development of the southern parcel into a parking lot for general commercial development, the proposed Grocery Outlet store. That currently vacant parcel is frequently used for parking of large vehicles (e.g., big rig trucks and recreational vehicles) of transient visitors staying at the adjacent lodging facilities (i.e., the Harbor Light Lodge and Super 8) as well as visitors and locals seeking coastal access to the Noyo Harbor and Noyo Beach via the existing public access trail and stairs across North Harbor Drive and adjacent to the Harbor Light Lodge. In short, this project seeks to convert a visitorserving use (i.e., an informal parking area) that provides public opportunities for coastal recreation through the adjacent access trail and stairs. Because general commercial development (the proposed use) is disfavored compared to visitor-serving uses that provide and enhance public opportunities for coastal recreation (the existing use of the southern parcel) this project is not consistent with LU-4.1
Policy LU-5.7: Adequate parking should be provided to serve coastal access and recreation uses to the extent feasible. Existing parking areas serving recreational uses shall not be displaced unless a comparable replacement area is provided.

Consistency: Same as LU-4.1, see consistency analysis []. Moreover, the proposed parking lot will displace an existing, albeit informal, parking area serving recreational uses and public access to the coastal resources of Noyo Harbor and Noyo Beach without providing a “comparable replacement area” thus it is not consistent with LU-5.7.

Policy OS-5.2: To the maximum extent feasible and balanced with permitted use, require that site planning, construction, and maintenance of development preserve existing healthy trees and native vegetation on the site.

Consistency: OS-5.2 requires that the site planning and construction of this project preserve existing healthy trees “to the maximum extent feasible.” However, the proposed site layout shifts the new building closer to the existing healthy trees in the northwest portion of the site and includes a bioretention basin within the area where the root system of the cypress tree will have the maximum impacts and damage due to the construction of the bioretention basin. The locations of the proposed building or the northwestern bioretention basin do not have any demonstrated connection to the permitted use or the project’s economic viability so they could easily be relocated to locations that reduce the conflicts with the existing healthy cypress tree. Thus, this project is inconsistent with LU 5.2 because it does not preserve the existing healthy cypress tree “to the maximum extent feasible” nor does it retain the existing healthy pine tree to the north of the cypress tree, instead proposing its removal and replacement with new landscaping.

Policy OS-11.6: Use Permeable Pavement Materials. To enhance stormwater infiltration capacity, development shall use permeable pavement materials and techniques (e.g., paving blocks, porous asphalt, permeable concrete, and reinforced grass or gravel), where appropriate and feasible. Permeable pavements shall be designed so that stormwater infiltrates into the underlying soil, to enhance groundwater recharge and provide filtration of pollutants. All permeable pavement that is not effective in infiltrating as designed will be replaced with effective stormwater detention and infiltration methods.

Consistency: This project involves a significant amount of hardscaping and paved areas but no indication that the hardscaping and pavement proposed for this project “shall use permeable pavement materials and techniques” anywhere on the project site. Although there are nonpaved landscaping areas that will be permeable, there is no analysis indicating that permeable pavement materials were considered at all for the paved areas, let alone rejected as infeasible. Thus, this project is inconsistent with OS-11.6 because it neither incorporates permeable paving materials nor analyzes and rejects such materials and infeasible in accordance with OS-11.6
Policy OS-16.7: Mitigation measures required for impacts to public access and recreational opportunities shall be implemented prior to or concurrent with construction of the approved development. Mitigation shall not substitute for implementation of a feasible project alternative that would avoid impacts to public access.

Consistency: As discussed in the consistency analysis for LU-5.6 and LU-5.7 above, this project includes the replacement of an existing unimproved parking area providing public access to recreational opportunities with a parking lot to serve a general commercial use but it does not include any mitigation measures (e.g., an off-site replacement of the existing parking area that provides relatively equivalent access to the coastal resources) to address or reduce these impacts. Thus, the lack of mitigation required by OS-16.7 prevents this project from being consistent with OS-16.7 so such mitigation should be included and analyzed in the IS/MND.

Policy C-1.4: Include specific time frames for the funding and completion of roadway improvements for projects which cause adopted roadway and intersection Level of Service standards to be exceeded. Require security, bonding or other means acceptable to the City to ensure the timely implementation of roadway mitigations.

Consistency: This project is not consistent with C-1.4 because there are no time frames established for the completion of roadway improvements and the project causes the LOS to exceed the applicable standards.
[Note: The EIR and permit review attempt to dismiss this policy as not applicable, claiming (falsely IMO) that this policy doesn't apply to fair share contributions even though nearly all such roadway improvements triggered by LOS metrics involve fair-share contributions and that exclusion is not actually part of the language of the policy or its related goal. This project is a classic case of the developer having to contribute funding for Caltrans' future projects on Hwy One due to LOS changes but there is no plan to actually implement anything so the impacts aren't really mitigated at all, the developer just effectively pays an in-lieu fee. The plan language of this policy indicates it was specifically intended to avoid that kind of situation.] Policy C-1.5: Traffic Impact Fees. When traffic impact fees are collected, establish a schedule from the date of collection of said fee for the expenditure of funds to construct roadway improvements that meets project needs. Where a project would cause a roadway or intersection to operate below the adopted traffic Level of Service standards, the roadway or intersection improvements should be completed in a timely manner but no later than five years after project completion.

Consistency: (See consistency analysis for C-1.4; see also C-9.3.) In addition, although this project results in intersections projected to operate below LOS standards, no roadway or intersection improvements are proposed. Because roadway and intersection improvements are necessary per the traffic study as well as relevant Coastal General Plan policies discussed herein, the project must also incorporate a timeline for such improvements that ensures completion within the maximum five years permitted by C-1.5. Thus, the project is not consistent with C-1.5 absent these revisions to the project and corresponding revision of the draft IS/MND.

Policy CD-1.1: Visual Resources: Permitted development shall be designed and sited to protect views to and along the ocean and scenic coastal areas, to minimize the alteration of natural landforms, to be visually compatible with the character of surrounding areas, and, where feasible, to restore and enhance scenic views in visually degraded areas.

Consistency: The project is not consistent with CD-1.1 because it is not “designed and sited to protect views to and along the ocean” since the site layout and design shifts the new building further north on the project site compared to the existing building to a location that includes the only current blue water ocean views through the site from the public rights-of-way. The draft IS/MND attempts to dismiss this inconsistency by describing the existing ocean views as “keyhole” views through the existing gas station to the west of the project but CD-1.1 is mandatory based on the use of “shall” and CD-1.1 does not make any exceptions to the requirement to protect views for partially-obstructed or keyhole views. The draft IS/MND should be revised to incorporate visual analysis of the project’s potentially significant impacts of the existing ocean views that will be blocked. (See the documents in the record for the recent proposed but denied application for an Auto Zone project on Todd’s Point, which incorporated visual analysis of ocean views through the project site and through intervening development that partially obstructed the ocean views through that project site. Similar visual analysis of partially obstructed ocean views through the northern portion of the project site should be incorporated into a revised draft IS/MND along with a corresponding mitigation measure to prevent future development within the view corridors through the site.) [Note: The agenda materials appear to try to distract reviewers from this issue by pointing to a similar but different policy, Policy CD-1.4, that doesn't apply to this project because "public viewing area" is a defined term and doesn't include S. Franklin Street, even though this similar policy applies and does not include the defined term "public viewing area". This basically conflates the two policies and incorrectly concludes that because 1.4 doesn't apply, then 1.1 wouldn't apply either but that is not accurate, IMO, based on the plain language of 1.1. Instead of trying to achieve the objectives of this policy as much as is feasible, it is just rejected altogether resulting in a project that conflicts with this Policy CD-1.1 as much as it possibly could. In short, if the project can't get 100% compliance, the City appears to just pretend it is not feasible or necessary to considernot even partial compliance.] From: Fort Bragg Local Business Matters
To: City Clerk
Cc: Peters, Sarah; cdd
Subject: Re: Public Comment in Opposition to the Proposed Grocery Outlet Matter for Consideration at the City Council Hearing on June 5, 2023
Date: Monday, June 05, 2023 9:28:31 AM
Hello,
I am confirming receipt of our Petition and email to the City Council on the Grocery Outlet matter for tonight's hearing. We also wanted to note that the number of signers has increased to 767, since we submitted our Petition in opposition to the development on Saturday. We look forward to hearing from someone soon. Thank you for your time and assistance.

Sincerely,
Fort Bragg Local Business Matters
On Sat, Jun 3, 2023 at 4:05 PM Fort Bragg Local Business Matters <[email protected]> wrote:

June 3, 2023
To the Honorable Fort Bragg City Council:

Attached, please find a copy of the online Petition from Fort Bragg Local Business Matters (FBLBM), in opposition to the proposed Grocery Outlet development at 851 S. Franklin Street, for the City Council's consideration of this matter, at their June 5, 2023 hearing.

As noted in the attached document, we have received over 756 digital signatures (and growing) to date from Fort Bragg residents, activists, families and workers, who have strong concerns about the proposed project impacts and the flawed EIR, that we had hoped would be comprehensive and conducted impartially by independent experts, but that was not the case.

We will share separate comments relating to our concerns about the EIR, and a respectful request that the Council strongly consider not certifying the proposed Final EIR for this development, in separate correspondence through our group's legal representative.

In the interim, please accept this Petition in Opposition to the proposed Grocery Outlet development on behalf of FBLBM, for the public record and for the Council's consideration of this important issue at their hearing on June 5th.

Please also confirm receipt of this email, and attached Petition, and certify that it will be included in the public record and shared with the City Council in a timely manner, prior to the hearing on this matter.

Sincerely,
Fort Bragg Local Business Matters
From: Mitzi Rider
To: City Clerk
Subject: We oppose grocery outlet coming to Fort Bragg
Date: Monday, June 05, 2023 10:05:10 AM
Hello, I am sorry that we are not able to attend the meeting today regarding the decision to let Grocery Outlet come to Fort Bragg. We OPPOSE grocery outlet coming to our small community. Please protect our local vendors and keep our Fort Bragg charm.

Sincerely, Lee and Mitzi Rider
27811 North Hiway 1, Fort Bragg, CA 95437
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