City of Menifee Appeal - Attachment 1
Decision To Be Appealed: Appealing the Planning Commission's approval of the Menifee Boardwalk Project - Plot Plan No.
PLN24-0118, Conditional Use Permit No. PLN25-0112 and Tentative Parcel Map No. PLN26-0037 and adoption of the Initial Study/Mitigated Negative Declaration (IS/MND) dated March 2026.
Action & Date: Planning Commission April 8, 2026
Explain And Specify What Action Or Decision Is Being Appealed: The Planning Commission's approval of the project and adoption of the Initial Study/Mitigated Negative Declaration (IS/MND) are not supported by substantial evidence because the traffic and related environmental analyses rely on incorrect assumptions regarding trip generation and operational characteristics.
Foothill Arch, LLC, the appellant, raised several traffic and air quality issues in a letter to the Planning Commission, dated March 27, 2026. A copy of this letter is attached as Exhibit "A" and a summary of the issues set out in this letter is provided below. Since the comments in the letter were largely ignored, and/or summarily dismissed, we have taken the liberty to conduct a more comprehensive analysis to demonstrate the significance of these issues, which are attached hereto as Exhibit "B."
1. Inadequate Traffic Analysis:
The traffic analysis significantly understates the project's trip generation by applying assumptions that do not reflect the actual intensity and operational characteristics of the approved uses, particularly with respect to restaurant activity. High-turnover restaurant uses generate substantially greater trip volumes, especially during peak periods, than lower-intensity uses. The Alternate trip generation table was provided and shows a noticeable increase in traffic; those numbers were acknowledged by staff, but then inexplicably dismissed without any analysis. As a result, the analysis fails to accurately evaluate traffic conditions, site access, and circulation impacts.
This understatement of trips affects key conclusions regarding roadway performance on Newport and Menifee Road and intersection operations.
In addition, the City failed to evaluate whether a traffic signal is warranted at the main Newport project driveway.
Given the higher trip generation associated with restaurant uses, a signal warrant analysis is necessary to ensure safe and efficient traffic operations. The omission of this analysis results in incomplete findings related to public safety and circulation.
2. Violation of the California Environmental Quality Act (CEQA) The IS/MND fails to adequately analyze potential safety impacts. The absence of a traffic signal warrant analysis, despite the higher traffic volumes associated with restaurant uses, creates the potential for hazardous conditions affecting vehicles, pedestrians, and cyclists. These risks constitute a potentially significant impact that was not properly evaluated.
The understatement of trip generation may also affect related environmental impact areas, including Air Quality.
Increased vehicle trips can result in higher emissions than those disclosed in the IS/MND, undermining the validity of the conclusion that air quality impacts would be less than significant.
Because the environmental analysis relies on incorrect or unsupported assumptions regarding trip generation, the City's adoption of the IS/MND is not supported by substantial evidence and does not comply with CEQA.
Requested Action and Result:
The Appellant requests that the City Council grant the appeal, set aside the project approval and IS/MND, and require adequate analysis of trip generation, traffic safety, and air quality, or remand for further study.
APPEAL
EXHIBIT "A"
(To Attachment 1)
Addrass: 2910 S. Archibald Ave Sulte #A 350 Ontario, CA 91761 Foothill Arch, LIC PHONE #: (909)509-5090 FAX#: (909) 930-1204 March 27, 2026 PLANNIN
ITY OF MENIFE
MAR 27 2026
Desiree McGriff, Associate Planner
City of Menifee RECEIVED
29844 Haun Road
Menifee, CA 92586
SUBJECT: MENIFEE BOARDWALK - PLOT PLAN NO. PLN24-0118
Dear Ms. McGriff:
As a business and property owner adjacent to the proposed Boardwalk Project on Newport Road, I would like to respectfully share several concerns regarding traffic, circulation, and air quality. While I do not oppose the project, I believe additional evaluation is necessary before the project moves forward in the approval process.
After reviewing the site plan, I asked my traffic consultants to review the project's Traffic Impact Analysis (TIA) and the responses to the City's comments. Their review identified several areas where the analysis may underestimate potential impacts.
Key Concerns:
• The study evaluates the existing driveway intersection along Menifee Road, but docs not analyze the existing driveway along Newport Road. Because the proposed development will connect internally to the Archibald's site, some vehicles currently exiting the existing driveways may instead use the new Boardwalk driveway. This potential traffic redistribution does not appear to have been considered • The study does not evaluate whether adequate drive-through stacking is provided. High-demand tenants, particularly coffee or quick-service uses, could gencrate queues that exceed available storage and spill back into internal circulation areas, creating conflict points.
Third, trip generation estimates may be significantly understated. The study applied the "Strip Retail Plaza" land use category to buildings one through four, a classification primarily intended for traditional retail. While this assumption may be reasonable for one of the buildings, it does not adequately reflect the significantly higher trip generation expected from the other retail buildings, which have a majority of restaurant and medical uses, along with two proposed restaurant drive-throughs. The City addressed this issue in a comment. In the revised March 13, 2026, traffic study, trip generation remains unchanged from the prior study. A separate document, the Alternative Standalone Trip Generation Table, was provided; however, it was not included nor analyzed in the revised Traffic Impact Analysis. In addition, most of the commercial square footage (i.e., 25,650 SF of the 28,650 SF) is still calculated using the strip retail plaza trip generation rates. As such, even these updated standalone trip generation estimates are likely still understated
• Because trip generation rates appear to be underestimated, the associated air quality analysis is also likely understated, given the direct relationship between trip generation and emissions.
Menifee Boardwalk
• Additionally, as noted in the traffic study, Newport Road is already oversaturated. Given this condition and the close spacing of driveways along Newport Road, a traftic simulation analysis is recommended for the corridor from Calle Pompeii to Menifee Road. A basic HCM analysis may underestimate the difficulty vehicles will experience when exiting the site. • The proposed Newport Road driveway intersection is expected to operate at an unacceptable Level of Service (LOS F). As a result, some drivers may avoid this driveway and instead exit via one of the two Archibald's site drivewaysan outcome that was not accounted for in the traffic study. Additionally, internal queuing may occur within the site, potentially disrupting circulation and causing blockages at the internal three-way stop intersection.
• Finally, the study assumes two outbound right-turn lanes at the Newport Road driveway. However, the City's peer review indicates dual right-turn lanes will not be permitted. In the revised traffic study, the site plan has been modified to include only one outbound lane. However, based on Appendix D, it appears that the two outbound lanes are still being assumed in the LOS calculation. If the driveway is reduced to a single right-turn lanc, delays and queue backup will likely be worse than currently projected. Given the right-tum-only restriction, a signal warrant analysis should be considered.
Before the project proceeds, I respectfully request consideration of the following:
1. Expansion of the traffic study to analyze the Newport Road driveway and potential redistribution of traffic.
2. Reevaluation of drive-through stacking capacity.
3. Analyze correct trip generation assumptions for medical, drive-through, and restaurant uses in TIA.
4. Analyze air quality based on updated trip generation rates.
5. A traffic simulation analysis for Newport Road between Calle Pompeii and Menifee Road.
6. Analyze Archibald's site driveways.
7. A signal warrant analysis for the proposed Newport Road driveway.
Thank you for your time and consideration. I would welcome the opportunity to discuss these concerns further.
Andy Sehremelis
Managing Member, Foothill Arch, LLC
Cc: Ryan Fowler, Planning Manager
Michael Knighten, District 2 Planning Commissioner
Tammy Ramirez, Planning Commissioner
Randy Madrid, District 4 Planning Commissioner
Ivan Holler, District 1 Planning Commissioner
Chris Thomas, District 3 Planning Commissioner
APPEAL
EXHIBIT "B"
(To Attachment 1)
RK ENGINEERING
GROUP INC.
APRIL 16, 2026
Mr. Andy Schremelis
FOOTHILL ARCH, LLC
2910 S. Archibald Avenue, Suite #A350
Ontario, CA 91761
SUBJECT: MENIFEE BOARDWALK PROJECT TRAFFIC IMPACT ANALYSIS, CITY OF MENIFEE (PEER REVIEW OF BEHALF OF FOOTHILL ARCH, LLC)
Dear Mr. Schremelis:
INTRODUCTION
RK ENGINEERING GROUP, INC. (RK) is pleased to provide this review of the Traffic Impact Analysis (TIA) Report for the proposed Menifee Boardwalk Project. Due to the project's proximity and shared access with the adjacent Rite Aid/Archibald's commercial development to the east, RK has reviewed this traffic analysis report on behalf of that site's ownership group (Foothill Arch, LLC).
The proposed Project site is located on the southwest quadrant of the intersection of Menifee Road at Newport Road in the City of Menifee, California. The proposed Project will consist of a mixed-use development with 28,650 square-foot (SF) of retail within four (4) buildings, of which Building 3 is proposed as a drive-through use, and a 10,000 SF Day Care Center. The proposed Project is anticipated to be completed by the Year 2027.
Primary access to the proposed Project is proposed via one (1) right-turn in/right-turn out only unsignalized driveway located along Newport Road (i.e. Project Driveway No. 1) and via one (1) existing shared right-turn in/right-turn out only unsignalized driveway located along Menifee Road (i.e. Project Driveway No. 2).
The Traffic Impact Analysis reports were prepared by Linscott, Law & Greenspan, Engineers. The initial report was dated September 10, 2025, and the revised (most recent) report is dated March 13, 2026.
The City of Menifee's consultant traffic engineer (Mr. Rob Blough and Mr. Philip Wragg of STC Traffic, Inc.) provided comments on the initial TIA in a memorandum dated January 26, 2026. Additionally, a public review letter from Foothill Arch, LLC dated March 27, 2026 was included in the City of Menifee's April 8, 2026 Planning Commission Agenda, along with corresponding responses from the City.
Attachment A, located at the end of this letter, contains these different comment letters.
RK has reviewed the March 2026 Traffic Impact Analysis in accordance with City of Menifee traffic engineering standards and thresholds and has identified several key issues that warrant further evaluation. The following comments summarize RK's primary concerns. www rkengineer.com
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EXECUTIVE SUMMARY
RK Engineering Group, Inc. (RK) has completed a peer review of the revised March 13, 2026 Traffic Impact Analysis (TIA) for the proposed Menifee Boardwalk Project. This review builds upon prior comments submitted by Foothill Arch, LLC (included as Attachment A) and evaluates both the most current version of the traffic study and the City's responses to those earlier concerns.
While the revised TIA and responses attempt to address prior comments, RK finds that several key issues remain unresolved. The responses rely primarily on qualitative statements, such as asserting that higher trip generation "would not change the results" or that the study assumptions are "conservative," without providing supporting analysis. A Traffic Impact Analysis is intended to provide a factual and quantitative basis for decision making and to determine whether the transportation system can safely and efficiently accommodate new traffic demand. In this case, several conclusions appear to be based on assumptions that are not substantiated through detailed analysis or consistent application of accepted methodologies.
One of the most significant concerns relates to trip generation. The traffic study acknowledges that higher trip generation is likely through its own alternate analysis, yet those higher volumes were not actually incorporated nor analyzed as part of the TIA. RK's independent evaluation demonstrates that project trip generation is likely substantially higher than both the original and alternate estimates.
Despite this, the City's response concludes that no changes to the analysis are necessary and that traffic volumes may be overstated. This conclusion is not supported given the magnitude of the differences identified and the direct relationship between trip generation and traffic operations. As a result, the study likely understates traffic demand, which affects conclusions related to congestion, access, and safety. Comment #1 in the Technical Comments section below provides a more detailed technical evaluation of this issue and further quantifies the extent to which trip generation has been understated.
In addition, RK has identified concerns regarding the project's assumed traffic distribution, which represent a new issue not previously addressed. The current study relies on circulation patterns that appear unrealistic and depend on future roadway improvements that are not currently constructed.
These assumptions may underestimate traffic impacts at key locations, including shared access points with the adjacent Rite Aid and Archibald's site. Comment #2 in the Technical Comments section below provides a more detailed discussion of these issues.
Finally, the City's responses suggest that more advanced analytical methods, such as traffic simulation, would result in improved operations and therefore conclude that the current analysis is conservative.
However, no such analysis was performed to support this conclusion. At the same time, the TIA identifies that the proposed Newport Road driveway would operate at unacceptable conditions, yet concludes that no significant operational issues would occur. Given the combination of high traffic volumes, existing congested conditions along Newport Road, restricted access, and the absence of supporting queueing or signal warrant analysis, a more robust evaluation is necessary to understand how traffic will actually function, including delay, queueing, and access limitations. Comment #3 in
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the Technical Comments section below provides a more detailed technical evaluation of these operational concerns.
In summary, RK's review indicates that the current TIA does not fully evaluate the project's likely traffic impacts and relies on assumptions that are not adequately supported by analysis. The technical comments that follow provide a more detailed discussion of these issues and identify additional analysis that should be completed to ensure the project can operate safely and efficiently without adversely affecting the surrounding transportation network or adjacent properties.
TECHNICAL COMMENTS
Comment #1: Trip Generation Methodology and Underestimation of Project Traffic The trip generation methodology utilized in the Traffic Impact Analysis (TIA) substantially underestimates the project's traffic impacts and does not reflect the likely operational characteristics of the proposed development. The TIA applies ITE Land Use Code 822 (Strip Retail Plaza) to the majority of the commercial square footage, which does not adequately capture the higher trip generation typically associated with restaurant and drive-through uses.
ITE trip generation methodology is explicitly based on matching a project to the most representative land use category, as different uses exhibit substantively different trip-making behavior. Applying a generalized category such as Strip Retail Plaza in lieu of known or anticipated restaurant and drive- through uses masks higher-intensity trip generation and does not reflect real-world conditions. As such, use of specific restaurant-based ITE land use codes is more appropriate and necessary to accurately estimate project traffic impacts.
As part of the March 2026 traffic study submittal, the project traffic consultant also provided an Alternate Trip Generation Table incorporating more appropriate land use categories (e.g., fast food restaurant and coffee/donut shop with drive-through). While this supplemental analysis acknowledges that higher trip generation is likely, these increased volumes were not specifically analyzed in the March 2026 traffic study. Instead, all study conclusions (including level of service (LOS), site access, and circulation) continue to rely on the original lower trip generation scenario. Table A below shows a comparison of the trips analyzed in both versions of the traffic study vs. the trips calculated as part of the alternate trip generation calculation. Attachment B, located at the end of this letter, contains both versions of LLG's trip generation calculations.
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Table A | Traffic Study vs Alternate Trip Generation Comparison Weekday
Scenario AM Peak Hour PM Peak Hour
Daily
In Out Total In Out Total
[A] Traffic Study Trip Generation Forecast'
Total Gross Trip Generation (No Reductions) 99 79 178 147 153 300 | 2,036 Net Total Trip Generation (With Pass-By Reductions) 66 51 117 100 103 203 1,527 [B] Alternate Project Trip Generation Forecast?
Total Gross Trip Generation (No Reductions) 160 140 300 179 182 361 2,987 Net Total Trip Generation (With Pass-By Reductions) 88 73 161 108 111 219 1,891 Trip Generation Comparison [B] - [A]
Total Gross Trip Generation (No Reductions) +61 +61 +122 +32 +29 +61 +951 Net Total Trip Generation (With Pass-By Reductions) +22 +22 +44 +8 +8 +16 +364 1 Source: Table 5-1 from the Menifee Boardwalk Traffic Impact Analysis, dated March 13, 2026, prepared by LLG 2 Source: Table A- Alternate Project Trip Generation Rates & Forecast, prepared by LLG As shown above in Table A, the alternate trip generation (compared to the values analyzed in the TIA) results in an increase of approximately 951 additional gross daily trips, which include approximately 122 additional gross AM peak hour trips and approximately 61 additional gross PM peak hour trips at the project driveways (prior to pass-by reductions). Similarly, this comparison results in an increase of approximately 364 additional net daily trips, which include approximately 44 additional net AM peak hour trips and approximately 16 additional net PM peak hour trips at the external/off-site study intersections (after application of pass-by reductions).
This represents a meaningful increase in traffic demand, particularly with respect to driveway operations, queuing, and internal circulation. The qualitative conclusion that these additional trips would not affect the results of the analysis is not supported by any quantitative evaluation.
Furthermore, even the alternate trip generation appears to remain understated when you consider the proposed individual tenants. Table B below shows a land use breakdown per building as detailed on the site plan provided within the traffic study.
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Table B | Menifee Boardwalk Project Land Use Breakdown by Building Land Use (ITE Code) Quantity Units
Building 1(100% Food)
Fast Casual Restaurant (930) 6.000 TSF
Building 2 (67% Restaurant & 33% Retail)
Strip Retail Plaza (<40k) (822) 3.581 TSF
Fast Casual Restaurant (930) 5.269 TSF
Fast-Food Restaurant with Drive-Through Window (934) 2.000 TSF Building 3(100% Coffee Shop)
Coffee/Donut Shop with Drive-Through Window & No Indoor Seating (938) 1.000 TSF Building 4 (33% Restaurant, 33% Medical, & 33% Retail)
Medical-Dental Office Building (720) 3.600 TSF
Strip Retail Plaza (<40k) (822) 3.600 TSF
Fast Casual Restaurant 930) 3.600 TSF
Building 5 (100% Daycare)
Day Care Center (565) 10.000 TSF
As shown in Table C below, RK has prepared a refined trip generation calculation utilizing more representative ITE land use categories for restaurant and drive-through uses anticipated within the project, consistent with the land use breakdown presented in Table B above.
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Table C | Refined Project Trip Generation Rates & Forecast Weekday
Quant PM Peak Hour
Land Use (ITE Code)' Units? AM Peak Hour
ity Daily
In Out Total In Out Total
Trip Generation Rates
Day Care Center (565) - TSF 53% 47% 10.88 47% 53% 10.75 39.30 Medical-Dental Office Building (720) - TSF 78% 22% 3.21 30% 70% 3.42 34.03 Strip Retail Plaza (<40k) (822) TSF 55% 45% 3.93 50% 50% 6.29 54.45 Fast Casual Restaurant (930) TSF 64% 36% 1.58 53% 47% 14.35 225.89 Fast-Food Restaurant with TSF 51% 49% 33.24 52% 48% 31.60 448.12 Drive-Through Window (934)
Coffee/Donut Shop with Drive-Through Window DT Lane 50% 50% 39.81 50% 50% 15.08 179.00 & No Indoor Seating (938)
Trip Generation Forecast
Day Care Center (565) 10.000 TSF 58 51 109 51 57 108 393 Pass-By Trip Reduction3 -23 -21 -44 -22 -26 -48 -98
Day Care Center Net Trip Generation Subtotal 35 30 65 29 31 60 295 Medical-Dental Office Building (720) 3.600 TSF 12 4 8 12 123 Strip Retail Plaza (<40k) (822) 7.181 TSF 15 13 28 23 22 45 391 Pass-By Trip Reduction4 -4 -3 -7 -6 -5 -11 -98
Strip Retail Net Trip Generation Subtotal 11 10 21 17 17 34 293 Fast Casual Restaurant (930) 14.869 TSF 15 23 113 100 213 3,359 Pass-By Trip Reductions -4 -2 -6 -28 -25 =53 -840
Fast Casual Restaurant Net Trip Generation Subtotal 11 6 17 85 75 160 2,519 Fast-Food Restaurant w/ DT Window (934) 2.000 TSF 34 32 66 33 30 63 896 Pass-By Trip Reduction® -17 -16 -33 - 18 =17 -35 -448
Fast-Food Restaurant w/ DT Window Net Trip Generation Subtotal 17 16 33 15 13 28 448 Coffee Show W/ DT W/O Indoor Seating (938) 1 DT Lane 20 20 40 8 7 15 179 Pass-By Trip Reduction' -18 -18 -36 -8 =15 = 161
2 2 4 0 18
Coffee Show W/ DT W/O Indoor Seating Net Trip Gen. Subtotal Total Gross Trip Generation (No Reductions) 151 127 278 232 224 456 5,341 Net Total Trip Generation (With Pass-By Reductions) 85 67 152 150 144 294 3,696 ' Source: ITE Trip Generation Manual (12th Edition, 2025). 2 TSF = Thousand Square Feet; DT Lane = Drive-Through Lane 3 The ITE Trip Generation Manual (12th Edition, 2025) provides the following pass-by rates for Land Use 565: AM = 40% (Estimated); PM = 44%; Daily = 25% (Estimated)
4 The following pass-by rates have been assumed for Land Use 822: AM = 25% (Estirated); PM = 25% (Estimated); Daily = 25% (Estimated) 5 The following pass-by rates have been assumed for Land Use 930: AM = 25% (Estimated); PM = 25% (Estimated); Daily = 25% (Estimated) 6 The ITE Trip Generation Manual (12th Edition, 2025) provides the following pass-by rates for Land Use 934: AM = 50%; PM = 55%; Daily = 50% ' The ITE Trip Generation Manual (12th Edition, 2025) provides the following pass-by rates for Land Use 938: AM = 90%; PM = 98%; Daily = 90% (Estimated)
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As shown above in Table C, the refined trip generation results in approximately 5,341 gross daily trips, which include approximately 278 gross AM peak hour trips and approximately 456 gross PM peak hour trips at the project driveways (prior to pass-by reductions). Similarly, this refined trip generation results in approximately 3,696 net daily trips, which include approximately 152 net AM peak hour trips and approximately 294 net PM peak hour trips at the external/off-site study intersections (after application of pass-by reductions).
Table D below shows a comparison of the trips analyzed in both versions of the traffic study vs. the refined trips calculated by RK.
Table D | Traffic Study vs Refined Trip Generation Comparison Weekday
Scenario AM Peak Hour PM Peak Hour
Daily
In Out Total In Out Total
[A] Traffic Study Trip Generation Forecast'
Total Gross Trip Generation (No Reductions) 99 79 178 147 153 300 2,036 Net Total Trip Generation (With Pass-By Reductions) 66 51 117 100 103 203 1,527 [B] Refined Trip Generation Forecast - See Table C
Total Gross Trip Generation (No Reductions) 151 127 278 232 224 456 5,341 Net Total Trip Generation (With Pass-By Reductions) 85 67 152 150 144 294 3,696 Trip Generation Comparison [B] - [A]
Total Gross Trip Generation (No Reductions) +52 +48 +100 +85 +71 +156 +3,305 Net Total Trip Generation (With Pass-By Reductions) +19 +16 +35 +50 +41 +91 +2,169 ' Source: Table 5-1 from the Menifee Boardwalk Traffic Impact Analysis, dated March 13, 2026, prepared by LLG As shown above in Table D, the refined trip generation (compared to the values analyzed in the TIA) results in an increase of approximately 3,305 additional gross daily trips, which include approximately 100 additional gross AM peak hour trips and approximately 156 additional gross PM peak hour trips at the project driveways (prior to pass-by reductions). Similarly, this comparison results in an increase of approximately 2,169 additional net daily trips, which include approximately 35 additional net AM peak hour trips and approximately 91 additional net PM peak hour trips at the external/off-site study intersections (after application of pass-by reductions). This further illustrates the extent to which the analyzed volumes are understated. This analysis results in trip generation that generally exceeds both the original study assumptions and the alternate scenario provided by the project consultant.
It should be noted that a cursory review of potential internal capture reductions was also conducted.
While some level of internal capture may occur between the proposed retail, office, and restaurant uses, these reductions are expected to be modest and do not change the overall conclusions. Even when accounting for reasonable internal capture, the trip generation utilized in the LLG TIA remains
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significantly understated, particularly with respect to driveway volumes and impacts at adjacent intersections.
Given that the TIA's operational analyses are based on a knowingly understated trip generation assumption, the resulting findings regarding intersection performance, site access, and circulation are not representative of expected real-world conditions. • A revised traffic analysis incorporating appropriate land use assumptions and corresponding trip generation is warranted to accurately assess project impacts.
Correspondingly, the Air Quality analysis should also be updated to reflect the higher and more representative trip generation estimates.
Comment #2: Trip Distribution Assumptions and Lack of Supporting Analysis The trip distribution assumptions presented in Figure 5-1 of the March 2026 Traffic Impact Analysis (TIA) include several unrealistic and unsupported routing assumptions that materially affect the accuracy of the study's findings. Of particular concern is the assumption that the assumed 28 percent of exiting project traffic desiring to head west (towards the 1-215 freeway) would not travel westbound directly, but instead would turn eastbound onto Newport Road, proceed through multiple signalized intersections, and ultimately complete a U-turn at the Laguna Vista Road/Newport Road intersection.
This routing requires vehicles to travel nearly one mile, pass through five (5) signalized intersections, effectively return to the same driveway location from which they originated. This is not a reasonable or likely driver behavior pattern and appears to underestimate the potential for alternative routing choices that would impact nearby intersections and shared access points.
Further, the analysis assumes that these U-turn movements can be accommodated at the Laguna Vista Road/Newport Road intersection using an eastbound left-turn pocket that does not currently exist.
While this movement may be contemplated as part of a future improvement associated with the Menifee Village TTM development identified in the TIA, that project is not currently entitled, and the assumption that this movement will be available is premature. The TIA does not evaluate interim conditions prior to construction of this improvement, nor does it address how these U-turning vehicles would operate under existing geometry. Notably, Figures 5-4 and 5-5 (Existing Plus Project conditions) do not reflect the presence of this future movement or account for the associated traffic volumes, further indicating that this critical circulation assumption has not been consistently incorporated into the analysis.
Even if such an improvement were ultimately constructed, it is unlikely to be in place concurrent with the opening of the Menifee Boardwalk project. As such, the TIA should evaluate near-term conditions without reliance on unconstructed infrastructure. Additionally, the feasibility of this movement is questionable even under future conditions. As shown in Figure 6-7, the eastbound U-turn movement at Laguna Vista Road/Newport Road is forecast to serve over 500 peak hour vehicles, which would likely exceed its practical storage capacity and create significant operational challenges, including spillback into adjacent through lanes.
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A more realistic distribution pattern may include a portion of westbound-oriented traffic exiting via the shared Menifee Road driveway, traveling southbound on Menifee Road, completing a U-turn at the Menifee Road/Rockport Road signal, and returning northbound to access westbound Newport Road via a protected left-turn movement at Menifee Road/Newport Road. This alternative routing would shift traffic impacts to different locations than those evaluated in the TIA and would also reroute a substantial portion of project traffic through the shared Menifee Road access, increasing circulation through the adjacent Rite Aid/Archibald's site. As such, this redistribution should be evaluated in the analysis.
Finally, the TIA does not include a queueing analysis to validate whether the assumed circulation patterns can be accommodated within available storage at project driveways or adjacent intersections. Given the constrained access configuration, high traffic volumes, and reliance on indirect routing (including U-turn movements), a comprehensive queueing analysis is necessary. This analysis should evaluate all project driveway movements, key intersection approaches (particularly at Menifee Road/Newport Road), and critical U-turn locations to ensure that project traffic will not result in internal circulation issues, blockage of adjacent driveways, or spillback into the public right-of-way.
In summary, the trip distribution assumptions rely on unsupported future conditions and unrealistic driver behavior, and they have not been adequately tested through supporting operational or queueing analyses. A revised evaluation incorporating realistic routing patterns and appropriate supporting analysis is warranted.
Comment #3: Deficient Operations and Evaluation of the Newport Road Project Driveway.
The TIA identifies that the proposed project driveway along Newport Road is projected to operate at an unacceptable level of service (LOS F). This finding is of particular concern and warrants further evaluation, especially given the constrained access configuration and existing corridor conditions.
The project driveway is proposed as a right-turn in/right-turn out only access point, yet it is still projected to operate well beyond acceptable LOS thresholds. This alone indicates that the access configuration is inadequate to accommodate projected demand. Additionally, review of the LOS calculation worksheets in the appendix indicates that the analysis assumes two exiting right-turn lanes, whereas the proposed site plan appears to provide only a single right-turn exit lane. As such, the reported LOS likely understates the true level of delay, and actual operations would be expected to degrade further under the proposed configuration.
This concern is compounded by the trip generation issues discussed above. When more appropriate and higher trip generation estimates are applied, driveway demand would increase, resulting in additional delay, longer queues, and further deterioration of operations at the project access point.
Despite these constraints, the TIA does not include a queueing analysis to evaluate whether vehicle storage can be accommodated within the site. Given the deficient LOS, high demand, and right-turn- only restriction, there is a substantial likelihood that queues could extend into on-site circulation aisles, creating internal conflicts, blocking access to parking and drive-through facilities, and potentially
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spilling back onto Newport Road. Such conditions could also disrupt operations at the adjacent Archibald's/Rite Aid property.
The TIA also concludes that a traffic simulation analysis is not necessary, asserting that such analysis would produce better results than the HCM methodology. This conclusion is not substantiated. The HCM methodology evaluates intersections in isolation and does not account for upstream congestion, signal coordination, or limited gap availability, all of which are critical factors along Newport Road, which is identified in the TIA as operating under oversaturated conditions (LOS E/F). Under these conditions, a microsimulation analysis is more appropriate to capture corridor-level dynamics, including queuing, spillback, and access limitations. Without such analysis, the study likely underrepresents the severity of operational constraints at the project driveway.
Lastly, a signal warrant analysis was not conducted for the proposed project driveway. Given the identified operational deficiencies, this represents a critical omission. Installation of a full-access traffic signal at this location could substantially improve operations by:
• Reducing delay and improving LOS at the project access point • Providing controlled gaps for safe ingress and egress • Improving internal circulation by reducing queue spillback into the site • Allowing direct westbound access via a protected left-turn movement, rather than requiring indirect routing through multiple downstream intersections and U-turn maneuvers.
RK's cursory review indicates that a traffic signal at the proposed Newport Road driveway would likely satisfy the Peak Hour signal warrant. The March 13, 2026 TIA identifies the Newport Road access as a right-turn in/right-turn out driveway on a 45 mph major street, and still reports this driveway operating at LOS F during the PM peak hour under Year 2027 Cumulative Plus Project conditions. Based on Figure 6-7 (Year 2027 Cumulative Plus Project PM Peak Hour Traffic Volumes), the driveway is forecast to generate approximately 92 exiting vehicles during the PM peak hour with a combined 5,915 PM peak hour volumes along Newport Road. Conservatively, this volume is derived from the lower trip generation assumptions used in the TIA, which have been shown to underestimate project demand.
When compared against the higher and more representative trip generation estimates discussed above, this exiting volume would increase further, thereby strengthening the basis for signalization.
When evaluated against MUTCD Figure 4C-4 (Warrant 3, 70%), and considering the substantial through volumes on Newport Road, the projected driveway volumes appear to comfortably satisfy the peak hour signal warrant. Given the combination of a high-speed arterial, elevated major-street volumes, and concentrated project-generated exiting traffic (particularly when accounting for more appropriate trip generation assumptions), a traffic signal at this location is likely warranted. At a minimum, a formal signal warrant analysis should be prepared to confirm whether signalization is justified
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The following illustrates the Year 2027 Cumulative Plus Project PM Peak Hour Traffic volumes (without accounting for the higher trip generation estimates) against the MUTCD Warrant 3: Peak Hour (70% Factor) graph. As shown, even with these lesser volumes, a signal would still satisfy this signal warrant.
Figure 4C-4. Warrant 3, Peak Hour (70% Factor)
(COMMUNITY LESS THAN 10,000 POPULATION OR ABOVE 40 MPH ON MAJOR STREET) 400 72 OR MORE LANES & 2 OR MORE LANES —
MINOR 2 OR MORE LANES & 1 LANE
STREET 300
HIGHER- /I LANE & 1 LANE
VOLUME
APPROACH - 200
VPH
100 100*
75°
92 5,915
300 400 500 600 700 800 900 1000 110D 1200 1300
MAJOR STREET—TOTAL OF BOTH APPROACHES-
VEHICLES PER HOUR (VPH)
*Note: 100 vph applies as the lower threshold volume for a minor-street approach with two or more lanes and 75 ph applies as the lower threshold volume for a minor-street approach with one lane.
While signal spacing along Newport Road may be a consideration, it is important to note that existing intersection spacing east of Menifee Road is comparable and, in some cases, more constrained (e.g., Menifee Road / Stater Way / Laguna Vista Drive).
In summary, the currently proposed driveway configuration is inadequate given the projected demand and existing corridor conditions. A more robust evaluation, including revised trip generation, queueing analysis, microsimulation, and signal warrant analysis, is necessary to ensure that the project can operate safely and efficiently without adversely impacting the surrounding transportation network or internal circulation & ingress/egress operations for the adjacent Rite Aid/Archibald's site.
RK
rkengineer.com
RK21357 // 2942-2026-01 12
RK Engineering Group, Inc., appreciates this opportunity to assist Foothill Arch, LLC with revieing the traffic-related documents for this project. If you have any questions regarding this review or need further clarification, please contact us at (949) 474-0809.
Sincerely,
RK ENGINEERING GROUP, INC.
Gangu
Justin Tucker, P.E., T.E.
Principal
EXP. 03/31/28
Registered Civil Engineer 92866 *
Registered Traffic Engineer 3055 TRAFFIC
Attachment
XC: Ms. Melissa Beeler, Parkcrest Inc.
XC: Mr. Joseph A. Cardella, Esq., Law Office of Joseph A. Cardella
RK ENGINEERING
GROUP INC.
rkengineer.com
Attachments
rkengineer.com
Attachment A
Comment Letters
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•
M
MENIFEE
CITY OF MENIFEE
MEMORANDUM
PUBLIC WORK/ENGINEERING DEPARTMENT
DATE: January 26, 2026
TO: Jorge Augilar, Assistant Engineer, City of Menifee
FROM: Rob Blough, STC Traffic, Inc.
Philip Wragg, STC Traffic, Inc
SUBJECT: Menifee Boardwalk Traffic Impact Analysis Review 1 Traffic Engineering has completed the review of the Menifee Broadway TIA report dated September 10, 2025, located at the southwest corner of Newport Road and Menifee Road intersection and have the following comments:
Figure 3-2 Existing AM Peak Hour Traffic Volumes AND Intersection Analysis
1. Please verify the EB through volume. The count sheet shows 1332 but 2332 is shown in the figure and used for the intersection analysis.
Intersection LOS Analysis
2. Please confirm if traffic signal timing sheets from the city were used for signal timing inputs for intersection analysis. Newport Road will be coordinated in the future with most likely 140 seconds cycle length. Please use coordination along Newport Road for all the future scenarios. Please use yellow and all-red times from signal timing sheets.
3. Menifee Road at Loire Valley Lane/Tres Lagos Drive Intersection Analysis - Please confirm if signal timing sheets were used to evaluate the intersection condition. One of the reasons for the intersection failure is less green time for the southbound through movement which seems insufficient and a longer green time is likely used in the field. When recreated in Synchro, the intersection condition resulted in LOS D with a delay less than 50 seconds.
Figure 3-2 and Figure 3-3 Existing Peak Hour Traffic Volumes
4. Please add the Project Driveway No2/Menifee Road existing traffic volumes in the figure.
Project Driveway Volumes and Peak Hour LOS Analysis (Table 10-1)
5. Pass-by trips should not be excluded from the project driveways. Project driveways should be analyzed with total gross trips.
6. Please revise all figures to show correct volumes at the project driveways.
7. Revise the project driveway peak hour LOS analysis.
1 Figure 5-1 Project Traffic Distribution Pattern
8. At Menifee Rd/ Newport Rd, it should be noted that the EB U-Turn is currently prohibited due to the SB right turn overlap. The U-turners must travel to the next signal.
Figure 5-2 and Figure 5-3 Peak Hour Project Traffic Volumes
9. At the project driveway and intersection #3, pass-by trips are shown in parenthesis. It is not clear how the numbers were derived. Please provide an explanation.
Cumulative Projects Traffic Characteristics (Figure 6-2 and Figure 6-3)
10. To verify the cumulative volumes within the study area, please provide information on how the trips for each cumulative project were distributed. A rough sketch of the distribution and trip assignment can be included in the appendix.
Peak Hour Roadway Segment Analysis
11. Please provide a discussion on the methodology including how the link capacity was established. Is the capacity based on HCM?
11.2.2 Year 2027 Cumulative Plus Project Recommended Improvements (Intersections)
12. Intersection No.1 - Antelope Road at Newport Road - Widening the Antelope Road may not be feasible as its fully built and constrained by developments on either side. Please provide conceptual drawings to show how the proposed improvements will work or recommend feasible alternatives.
13. Intersection No. 3 - Menifee Road and Newport Road - The recommended restriping may not be feasible at this location as widening may be required. Please provide a conceptual drawing to show how the proposed improvements will work or recommend feasible alternatives.
14. Intersection No. 6 - Menifee Road at Loire Valley Lane/Tres Lagos Drive - Please reevaluate if improvements are needed following the updated LOS analysis.
Site Plan Comments (Figure 2-2)
15. Please show the full extent of the median on Newport Road to confirm that the westernmost access (between buildings 1 and 2) will be right-in-right-out.
16. Dual exit lanes will not be permitted, please reduce to one lane. It may not be necessary to have the driveway this wide. Please check standards and confirm.
Please provide response to comments including references to additional/ updated text. Please contact Rob Blough ([email protected]) or Phil Wragg ([email protected]) with any questions on this review.
Addrass: 2910S. Archibald Ava Sulte #A #A350 Ontario, CA 81761 Foothill Arch, LIC PHONE#: (909)509-5080 FAX#: (909) 930-1204 March 27, 2026
Desiree McGritt, Associate Planner
City of Menifee
29844 Haun Road
Menitee, CA 92586
SUBJECT: MENIFEE BOARDWALK - PLOT PLAN NO. PLN24-0118
Dear Ms. McGriff:
As a business and property owner adjacent 1o the proposed Boardwalk Project on Newport Road, I would like to respectfully share several concerns regarding traffic, circulation, and air quality. While I do not oppose the project, 1 believe additional evaluation is necessary before the project moves forward in the approval process.
After reviewing the site plan, 1 asked my traffic consultants to review the project's Traffic Impact Analysis (TIA) and the responses to the City's comments. Their review identified several areas where the analysis may underestimate potential impacts.
Key Concerns:
• The study evaluates the existing driveway intersection along Menifee Road, but does not analyze the existing driveway along Newport Road. Because the proposed development will connect internally to the Archibald's site, some vehicles currently exiting the existing driveways may instead use the new Boardwalk driveway. This potential traffic redistribution does not appear lo have been considered. • The study does not evaluate whether adequate drive-through stacking is provided. High-demand tenants, particularly coffee or quick-service uses, could generate queues that exceed available storage and spill • Third, trip generation estimates may be significantly understated. The study applied the "Strip Retail Plaza" land use category to buildings one through four, a classification primarily intended for traditional retail. While this assumption may be reasonable for one of the buildings, it does not adequatly reflect the significantly higher trip gencration expected from the other retail buildings, which have a majority of restaurant and medical uses, along with two proposed restaurant drive-throughs. The City addressed this issue in a comment. In the revised March 13, 2026, traffic study, trip generation remains unchanged from the prior study. A separate document, the Alternative Standalone Trip Generazion Table, was provided; however, it was not included nor analyzed in the revised Traffic Impact Analysis. In addition, most of the commercial square footage (i.e., 25,650 SF of the 28,650 SF) is still calculated using the strip retail plaza trip generation rates. As such, even these updated standalone trip generation estimates are likcly still understated.
Because trip generation rates appear to be underestimated, the associated air quality analysis is also likely understated, given the direct relationship between trip generation and emissions.
Menifee Boardwalk
• Additionally, as noted in the traffic study, Newport Road is already oversaturated, Given this condition and the close spacing of driveways along Newport Road, a traffic simulation analysis is reconmended for the corridor from Calle Pompeii to Menifee Road. A basic HCM analysis may underestimate the difficulty vehicles will experience when exiting the site.
The proposed Newport Road driveway intersection is expected to operate at an unacceptable Level of Service (LOS F). As a result, some drivers may avoid this driveway and instead exit via one of the two Archibald's site driveways—an outcome that was not accounted for in the traffic study. Additionally, internal queuing may occur within the site, potentially disrupting circulation and causing blockages at the internal three-way stop intersection.
• Finally, the study assumes two outhound right-turn lanes at the Newport Road driveway. However, the City's peer review indicates dual right-turn lanes will not be permitted. In the revised traffic study, the site plan has been modified to include only one outbound lane. However, based on Appendix D, it appears that the two outbound lanes are still being assumed in the LOS calculation. If the driveway is reduced to a single right-tum lane, delays and queue backup will likely be worse than currently projected. Given the righl-tum-only restriction, a signal warrant analysis should be considered.
Before the project proceeds, I respectfully request consideration of the following:
1. Expansion of the traffic study to analyze the Newport Road driveway and potential redistribution of traffic.
2. Reevaluation of drive-through stacking capacity.
3. Analyze correct trip generation assumptions for medical, drive-through, and restaurant uses in TIA.
4. Analyze air quality based on updated trip generation rates.
5. A traffic simulation analysis for Newport Road between Calle Pompeii and Menifee Road.
6. Analyze Archibald's site driveways.
7. A signal warrant analysis for the proposed Newport Road driveway.
Thank you for your time and consideration. I would welcome the opportunity to discuss these concerns further.
Andy Schremelis
Managing Member, Foothill Arch, LLC
Cc: Ryan Fowler, Planning Manager
Michael Knighten, District 2 Planning Commissioner
Tammy Ramirez, Planning Commissioner
Randy Madrid, District 4 Planning Commissioner
Ivan Holler, District 1 Planning Commissioner
Chris Thomas, District 3 Planning Commissioner
City's Response
• Based on the proposed Project site plan circulation layout and existing adjacent development circulation layout, it is very unlikely that a measurable volume of customers would back track and circulate through the proposed site to make the same right turn movement that could be completed more conveniently from the Archibald's site.
• While a specific Coffee Shop user has not yet been identified, the proposed Project site plan shows a drive-through lane storage of 18 vehicles, which is greater than the minimum standard required by Starbucks (12 - 14 vehicle storage), Dutch Bros (15 vehicle storage), or Better Buzz (12 vehicle storage) which would generate the greatest queue. Furthermore, there is significant storage within the drive aisles that could be utilized during the 15 to 30 minutes in the AM peak hour that vehicles could potentially queue beyond the drive-through lanes, such that the public ROW would never be impacted.
• The explanation provided with the Alternate Trip Generation Table sufficiently addresses this issue as the trip generation difference would not change the results of the traffic analysis. Furthermore, both trip generation estimates are likely conservative in our experience and does not take into account the internal capture that would occur between the proposed uses therefore reducing the trip generation. Lastly, as shown in the TIA, the 2027 Project completion year traffic volumes reflect future traffic volumes from 15 cumulative projects totaling 3,281 AM peak hour trips and 4,643 PM peak hour trips, such that the traffic volumes analyzed in the TIA are very likely significantly overstated regardless of the potential slight difference between two Project trip generation forecasts.
• The AQ/GHG modeling and analyses are based on the trip generation rates. Because no changes to the trip generation rates within the TIA are occurring, no revisions to the AQ or GHG analyses are warranted or required. Additionally, because no changes to the maximum net daily vehicles generated by the project or to the cumulative plus project peak hour conditions, no changes to the CO hotspot would be required either.
Furthermore, the total cumulative traffic volume forecast is very likely significantly overstated. Emissions modeled on these traffic volumes would have correspondingly overstated results.
• Contrary to the comment, traffic simulation would take into account gaps created by the adjacent traffic signals and platooning, such that the driveway level of service (LOS) would show a better LOS. Therefore, the HCM calculation utilized in the TIA represents a more conservative result.
• As indicated in the TIA on Page 38, it is not uncommon for private unsignalized driveways, such as that of the Project, to experience a longer delay due to the heavy volumes on the major streets, like Newport Road and likely occurs at all existing driveways along Newport Road. Furthermore, due to the unsignalized driveway being in close proximity to the signalized intersection of Menifee Lakes Drive/Calle Pompeii at Newport Road as well as Menifee Road at Newport Road, it is expected that gaps in traffic would occur and actual vehicular delay experienced would be lower than what is being reported within the HCM methodology. As indicated above in the first response, based on the proposed site plan circulation layout and the fact that the existing Archibald driveway on Newport Road is forecast to operate at a worse LOS F, (we conducted an estimated 2027 LOS calculation for the PM peak hour) than the Project driveway, but in reality probably does not experience significant delays, it is unlikely a measurable volume of traffic would use the Archibald driveway on Newport Road. Also, the Archibald's driveway along Menifee Road is analyzed in the TIA. • Comment noted. The driveway LOS calculation has been updated to reflect only one northbound right turn lane at the Project driveway on Newport Road. While the delay increase measurably, the findings remain the same.
Attachment B
Linscott, Law & Greenspan, Engineers (LLG)
Trip Generation Calculations
ricengineer.com
TABLE 5-1
PROJECT TRIP GENERATION RATES AND FORECASTS
Daily AM Peak Hour PM Peak Hour
ITE Land Use Code /
Project Description 2-Way Enter Exit Total Enter Exit Total Generation Rates:
822: Strip Retail Plaza Less Than 40K (TE/TSF) 54.45 60% 40% 2.36 50% 50% 6.59 • 565: Day Care Center (TE/TSF) 47.62 53% 47% 11.00 47% 53% 11.12 Proposed Project Generation Forecast:
• Retail Plaza (28,650 SF) 1,560 41 27 68 95 94 189
Pass-By (Daily: 25%, AM: 25%, PM: 25%)6 -390 -10 -7 -17 -24 -24 -48 Subtotal 1,170 31 20 51 71 70 141
Day Care Center (10,000 SF) 476 58 52 110 52 59 111
Pass-By (Daily: 25%, AM: 40%, PM: 44%)6 =119 -23 -21 -44 -23 -26 -49 Subtotal 357 35 31 66 29 33 62
Total Gross Proposed Project Trip Generation Forecast 2,036 99 79 178 147 153 300 Total Pass-by -509 -33 -28 -61 -47 -50 -97
Total Net Proposed Project Trip Generation Forecast 1,527 66 51 117 100 103 203 Note:
• TE/TSF = Trip End per Thousand Square Feet
Source: Trip Generation, 11th Edition, Institute of Transportation Engineers, (ITE) [Washington, D.C. (2021)].
Pass-By Trips are trips made as intermediate stops on the way from an origin to a primary trip destination. Pass-by trips are attracted from traffic passing the site on adjacent streets, which contain direct access to the generator. For this analysis, the following pass-by reduction factors were used (Source: Trip Generation Manual, 11th Edition, ITE 2021):
- 822: Strip Retail Plaza: Daily/AM peak hour/PM peak hour - 25% (assumed)/25% (assumed)/25% (assumed) • 565: Day Care Center: Daily/AM peak hour/PM peak hour - 25% (assumed)/40% (assumed)/44% (ITE) LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 2-25-4968-1 Menifee Boardwalk, Menifee
19 N: 49002254968 - Menifee Boankwalk, Menifee\TIAM4 - Report LLG
TABLE A
ALTERNATE PROJECT TRIP GENERATION RATES AND FORECAST'
MENIFEE BOARDWALK, MENIFEE
Daily AM Peak Hour PM Peak Hour
ITE Land Use Code /
Project Description 2-Way Enter Exit Total Enter Exit Total Generation Rates:
• 934: Fast Food Restaurant With Drive Through Window 467.48 49% 44.61 52% 48% 33.03 51%
(TE/TSF)
• 938: Coffee Donut Shop With Drive Through Window and No 179.00 50% 50% 39.81 50% 50% 15.08 Indoor Seating (TE/Drive-Through Lane)
822: Strip Retail Plaza Less Than 40K (TE/TSF) 54.45 60% 40% 2.36 50% 50% 6.59 565: Day Care Center (TE/TSF) 47.62 53% 47% 11.00 47% 53% 11.12 Proposed Project Generation Forecast:
• Fast Food Restaurant With Drive-Through Window (2,000 SF) Pass-By (Daily: 50%, AM: 50%, PM: 55%)2
Subtotal
Coffee Donut Shop With Drive-Through Window and No
Indoor Seating (1 Drive-Through Lane)
Pass-By (Daily: 90%, AM: 90%, PM: 98%)
Subtotal 18
• Retail Plaza (25,650 SF)
Pass-By (Daily: 25%, AM: 25%, PM: 25%)2
Subtotal
- Day Care Center (10,000 SF)
Pass-By (Daily: 25%, AM: 40%, PM: 44%)?
Subtotal
Total Gross Proposed Project Trip Generation Forecast 160 300 179 361 Total Pass-by -139 -71 -142
Total Net Proposed Project Trip Generation Forecast 161 108 219 Note:
• TE/TSF = Trip End per Thousand Square Feet
Source: Trip Generation, 11th Edition, Institute of Transportation Engineers, (ITE) [Washington, D.C. (2021)]. asS-By Trips are trips made as intermediate stops on the way from an origin to a primary trip destination. Pass-by trips are attracted fro affic passing the site on adjacent streets, which contain direct access to the generator. For this analysis, the following pass-by reductic factors were used (Source: Trip Generation Manual, 11th Edition, ITE 2021):
• 934: Fast Food Restaurant With Drive Through Window: Daily/AM peak hour/PM peak hour - 50% (assumed)/50% (1TE)/55% * 822: Coffee Donut Shop With Drive Through Window and No Indoor Seating: Daily/AM peak hour/PM peak hour - 90% 822: Strip Retail Plaza: Daily/AM peak hour/PM peak hour - 25% (assumed)/25% (assumed)/25% (assumec 565: Day Care Center: Daily/AM peak hour/PM peak hour - 25% (assumned)/40% (assumed)/44% (ITI