2022 08-26 San Dimas Complaint SEIR3

Electronically FILED by Superior Court of California, County of Los Angeles on 08/26/2022 11:28 AM Sherri R.
Carter, Executive Officer/Clerk of Court, by N. Alvarez,Deputy Clerk

22STCP03161
Assigned for all purposes to: Stanley Mosk Courthouse, Judicial Officer:
1 ALESHIRE & WYNDER, LLP

JEFF M. MALAWY, State Bar No. 252428
2 [email protected]
ANTHONY R. TAYLOR, State Bar No. 208712
3 [email protected]
ALISON S. FLOWERS, State Bar No. 271309
4 [email protected]
18881 Von Karman Avenue, Suite 1700
5 Irvine, California 92612
Telephone: (949) 223-1170
6 Facsimile: (949) 223-1180
7 Attorneys for Petitioner, CITY OF SAN DIMAS
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
11 CITY OF SAN DIMAS, a municipal Case No.

corporation,
12 PETITION FOR WRIT OF MANDATE
Petitioner and Plaintiff, AND COMPLAINT FOR
13 DECLARATORY AND INJUNCTIVE
v. RELIEF
14
METRO GOLD LINE FOOTHILL (California Environmental Quality Act;
15 EXTENSION CONSTRUCTION Code of Civil Procedure Sections 1060 and
AUTHORITY; and DOES 1 to 30, Inclusive, 1085)
16
Respondents and Defendants.
17
18 CITY OF SAN DIMAS AS SUCCESSOR

AGENCY TO THE CITY OF SAN DIMAS
19 REDEVELOPMENT AGENCY,
20 Real Party in Interest.

21
22
23 INTRODUCTION
24 1. The Metro Gold Line Foothill Extension Construction Authority (the “Authority”)
25 is an independent transportation planning, design, and construction agency created by the California
26 State Legislature in 1998 to design, contract, and construct the Los Angeles to Pasadena Metro Gold
27 Line extension project (the “Gold Line Extension”). In 2013, the Board of Directors for the
28 Authority certified and approved the Final Environmental Impact Report (“2013 FEIR”), which was
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
01171.0024/807832.2
1 prepared in connection with the construction of the Gold Line Extension in general, and with the
2 segment connecting Azusa to Montclair in particular. Once completed, the Gold Line Extension
3 will connect the City of Los Angeles with the San Gabriel Valley and the Inland Empire.
4 2. As construction of the Gold Line Extension has progressed, the Authority has made
5 numerous changes to the original project detailed in the 2013 FEIR to account for changed and/or
6 unanticipated local conditions. These changes have been incorporated through several addendums
7 and supplemental environmental impact reports since certifying and adopting the 2013 FEIR.
8 3. This Petition for Writ of Mandate (“Petition”) seeks to invalidate the most recent
9 supplemental environmental impact report (abbreviated as “Final SEIR 3” below) to the Gold Line
10 Extension, certified and approved by the Authority’s Board of Directors on July 27, 2022 in
11 Resolution No. 2022-R-14, “Resolution of the Metro Gold Line Foothill Extension Construction
12 Authority Certifying the Final Supplemental Environmental Impact Report 3 regarding Metro Gold
13 Line Foothill Extension Project Phase 2B (Azusa to Montclair) San Dimas Parking Facility
14 Relocation.”
15 4. This Petition challenges Resolution No. 2022-R-14 on the following grounds:
16 a. The Final SEIR 3 violates CEQA because it does not consider an adequate range of
17 alternatives capable of reducing the project’s significant impacts;
18 b. The Final SEIR 3 does not adequately address the increased traffic and traffic
19 queuing on surrounding roadways, including small residential roads, to access the parking facility,
20 and the Authority’s conclusion that drivers will typically use major streets is not substantiated by
21 any evidence;
22 c. The Final SEIR 3 does not adequately address pedestrian or cyclist safety and relies
23 solely on the 2013 Final EIR for the unmodified project;
24 d. The aesthetics discussion in Final SEIR 3 is deficient, as the analysis only considers
25 the view impacts from some, but not all, of the residential properties in the area. Furthermore, the
26 analysis is limited to only a portion of the Project area and concludes that there is no significant
27 change in use; and
28 / / /
01171.0024/807832.2 -2-
1 e. The greenhouse gas mitigation measures are illusory and do not pass muster under
2 CEQA.
3 5. For these reasons, the Authority’s certification of the Final SEIR 3 constituted an
4 abuse of discretion and must be overturned. This Petition, thus, also seeks a writ of mandate: (1)
5 Directing Respondents to suspend all activities with respect to the parking facility relocation; (2)
6 directing Respondents to comply with CEQA with respect to the parking facility relocation; (3) a
7 stay of actions to carry out the parking facility relocation; and (4) an award of attorneys’ fees and
8 costs.
9 PARTIES
10 6. Petitioner City of San Dimas (“City” or “Petitioner”) is a municipal corporation and
11 general law city duly organized and legally incorporated as of August 4, 1960, and validly existing
12 under the laws of the State of California.
13 7. Respondent Metro Gold Line Foothill Extension Construction Authority (the
14 “Authority”) is an independent transportation, design, and construction agency created by the
15 California State Legislature through Senate Bill 1847 (1998) (later updated through Assembly Bill
16 706 (2011) and Assembly Bill 1600 (2012)), which were codified under the Public Utilities Code
17 sections 132400 et seq. The Authority was created to succeed the Los Angeles County Metropolitan
18 Transportation Authority (“LACMTA”) in designing, awarding contracts for, and constructing the
19 Gold Line Extension and as the lead agency for purposes of the California Environmental Quality
20 Act (“CEQA”), Public Resources Code sections 21000 et seq. review. The Authority has special
21 and limited jurisdiction and possesses only those powers that have been specifically granted to it by
22 statute and others necessarily implied.
23 8. Real Party in Interest City of San Dimas as Successor Agency to the City of San
24 Dimas Redevelopment Agency (the “Successor Agency”) is the successor agency to the former City
25 of San Dimas Redevelopment Agency, which was terminated by virtue of Assembly Bill ABX1-26.
26 The Successor Agency was formed to undertake the actions required pursuant to the Community
27 Redevelopment Law, including winding down the affairs of the Redevelopment Agency.
28 / / /
01171.0024/807832.2 -3-
1 9. Petitioner does not know the true names and capacities of the Respondents listed in
2 the caption as DOES 1 through 30. Petitioner is informed and believes, and alleges thereon, that
3 each DOE Respondent is in some way responsible for, participated in, or contributed to the wrongs
4 of which Petitioner complains and has legal responsibility to comply with CEQA with respect to the
5 relocation of the parking facility for the San Dimas station. Upon learning the names of any of these
6 respondents, Petitioner will file an amendment to the Petition identifying such respondent by name.
7 FACTUAL ALLEGATIONS
8 Metro Gold Line Foothill Extension Construction Authority
9 10. Public Utilities Code section 132400 defines the Gold Line Extension as a light rail
10 project along the rail right-of-way that connects Union Station in the City of Los Angeles with the
11 City of Montclair. The PUC authorizes the Authority to plan and construct any “fixed mass transit
12 guide way eastward to Claremont,” and includes the oversight and management of the Gold Line
13 Extension. The Gold Line Extension was amended to expand as far as the regional transit hub in the
14 City of Montclair (“Montclair Transcenter”). Once Project construction is complete, the Authority
15 will transfer operations of the Gold Line back to LACMTA, a relationship that is formalized in a
16 Master Cooperative Agreement approved by both agencies’ Boards of Directors in 2010.
17 Environmental Review of the Gold Line Extension
18 11. In 2003, after having taken over management of the Gold Line Extension from
19 LACMTA pursuant to legislative action, the Authority completed the first segment of the Gold Line
20 Extension, which extended the rail system from Union Station in the City of Los Angeles to the City
21 of Pasadena.
22 12. In 2006, the initial Draft Environmental Impact Report (“DEIR”) for the Gold Line
23 Extension was completed. This DEIR covered the entire corridor between the Sierra Madre Villa
24 station in the City of Pasadena through to the City of Montclair. However, the Final Environmental
25 Impact Report (“FEIR”) study analyzed two (2) alternative construction options: (1) a light-rail
26 transit (“LRT”) Full-Build option, which would complete the entire extension to the City of
27 Montclair; and (2) an LRT Phased-Build option, which would extend to the City of Azusa in the
28
01171.0024/807832.2 -4-
1 first phase (known as “Phase 2A”), and would extend to the City of Montclair in the second phase
2 (known as “Phase 2B”).
3 13. In 2007, the Authority’s Board of Directors certified and approved the FEIR, opting
4 for the LRT Phased Build option.
5 14. In 2010, the Authority began constructing the second segment of the Gold Line
6 Extension, which extended the rail system from the City of Pasadena to the City of Azusa. This
7 segment was completed in 2015.
8 15. In March 2013, the Authority’s Board of Directors certified the Final Environmental
9 Impact Review (“2013 FEIR”) for the next phase of the extension, pursuant to the California
10 Environmental Quality Act (“CEQA,” Public Resource Code sections 21000 et seq.), prepared in
11 connection with approval of the approximately 12.3-mile extension of the Gold Line Extension
12 segment connecting the Azusa-Citrus Station in the City of Azusa to the Montclair Transcenter in
13 the City of Montclair. This extension will include six new stations in the cities of Glendora, San
14 Dimas, La Verne, Pomona, Claremont, and Montclair.
15 Environmental Review of Modifications to the Gold Line Extension
16 16. In May 2014, the Authority considered certain refinements to the Gold Line
17 Extension associated with grade separation of Garey Avenue in the City of Pomona. The Authority’s
18 environmental review of these refinements took the form of an addendum (“Addendum No. 1) to
19 the 2013 FEIR.
20 17. In November 2014, the Authority considered certain additional refinements to the
21 Gold Line Extension, specifically addressing the construction of the segment between the City of
22 Pasadena and the City of Montclair in two phases, as well as technical changes to the engineering
23 design. The Authority’s environmental review of these refinements took the form of an addendum
24 (“Addendum No. 2) to the 2013 FEIR.
25 18. In March 2016, the Authority considered certain additional refinements to the Gold
26 Line Extension, specifically to evaluate whether implementation of the proposed Project changes
27 would result in new significant impacts or increase the severity of previously identified significant
28 environmental effects, or would otherwise require the preparation of a supplemental or subsequent
01171.0024/807832.2 -5-
1 EIR (“SEIR”) under CEQA. The Authority’s environmental review of these refinements again took
2 the form of an addendum (“Addendum No. 3”) to the 2013 FEIR. Advanced conceptual engineering
3 plans for the Project were also completed in 2016.
4 19. In September 2017, the Authority considered certain additional refinements to the
5 Gold Line Extension, specifically to evaluate modifications that include increasing the height and/or
6 footprint of some parking structures; closing an at-grade crossing and restructuring a grade
7 separation; relocating traction power supply substation facilities, and creating new access to city
8 facilities; as well as minor alignment shifts throughout the extension. The Authority’s
9 environmental review of these refinements again took the form of another addendum (“Addendum
10 No. 4”) to the 2013 FEIR.
11 20. In June 2019, the Authority prepared and considered a Supplemental Environmental
12 Impact Report to evaluate environmental effects of revisions to the 2013 FEIR and proposed project
13 modifications. The project modifications included revised phasing construction and operation of
14 the Project, as well as a new traffic mitigation measure. Specifically, the Authority proposed to
15 conduct and operation the Project in three construction phases, rather than the two construction
16 phases established in Addendum No. 2. The project modifications also included a new traffic
17 mitigation measure that would restripe a portion of a street, as well as a minor rail alignment
18 adjustment. The Supplemental Environmental Impact Report (“SEIR 1”) was certified in July 2019.
19 21. In January 2021, the Authority prepared and considered another Supplemental
20 Environmental Impact Report to evaluate environmental effects of further proposed project
21 modifications to the 2013 FEIR. The project modifications included a change from parking
22 structures to surface parking lots for the Glendora, San Dimas, La Verne, and Pomona locations, as
23 well as a parking structure at Claremont. The project modifications were prompted by the
24 Supportive Transit Parking Program Master Plan (“STPP”), adopted by the Metro Board in January
25 2018. The change to surface parking lots would reduce the total number of available parking spaces
26 at the stations so that the number of parking spaces aligned with the number of parking spaces
27 identified in the STPP, Appendix F, “Gold Line Foothill Extension Phase 2B Parking Analysis.” At
28
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1 some stations, the project modifications would also result in minor changes related to the
2 configuration of vehicle and pedestrian access.
3 22. With respect to San Dimas in particular, the number of parking spaces would be
4 reduced from 450 in the 2013 SEIR to 289 spaces as a result of the project modifications, a reduction
5 of 161 spaces. The project modifications caused concern with the City and its residents that there
6 may be insufficient parking at the station, which will lead to spill-over parking in the surrounding
7 commercial and residential areas, causing serious parking issues. These concerns were raised to the
8 Authority during both the written public comment period and the public hearing. While the
9 Authority responded to the City’s written comments, it did not commit to resolving the anticipated
10 parking issues. Nevertheless, the second Supplemental Environmental Impact Report (“SEIR 2”)
11 was certified in January 2021.
12 Environmental Review of Modifications to the Gold Line Extension in the City of San Dimas
13 in Supplemental Environmental Impact Report 3
14 23. The original location for station parking in San Dimas (reviewed in FEIR 2013 and
15 SEIR 2) was the City’s Maintenance Yard, a 2.18-acre property owned by the City and located at
16 301 S. Walnut Avenue. If the parking facility was located at the City’s Maintenance Yard, however,
17 the City would be forced to relocate its Yard site at significant cost to the City of approximately $25
18 million.
19 24. As a result, the City and the Authority began considering a different location for
20 station parking south of the Project right-of-way between Monte Vista Avenue and San Dimas
21 Avenue. Specifically, the City and the Authority considered the San Dimas Park & Ride, which is
22 owned by the City and operated as a commuter bus line by Foothill Transit, as well as two
23 neighboring parcels (owned by the Successor Agency) northwest of the Park & Ride to be
24 potentially utilized for access to the proposed parking facility in order to avoid traffic on Cataract
25 Avenue and other neighborhood streets (the Park & Ride and two neighboring parcels are referred
26 to as the “New Parcels”). The Park & Ride has 175 parking spaces, which are utilized not only by
27 commuters of the Foothill Transit bus line, but patrons of the City’s historic downtown, its
28 businesses, and the community at large. A true and correct copy of the site plan, which includes the
01171.0024/807832.2 -7-
1 original parking facility and the proposed parking facility, is attached hereto as Exhibit “A” and
2 incorporated herein.1
3 25. To document the City and the Authority’s intentions, the parties entered into a
4 binding Letter of Intent on June 17, 2021, under which the parties agreed to work together in good
5 faith toward execution of a mutually agreeable purchase and sale agreement for the purchase of the
6 New Parcels, subject to the Authority securing all CEQA approvals necessary for the Authority’s
7 contemplated use of the New Parcels.
8 26. To evaluate the environmental effects of the proposed new location of the parking
9 facility and its modification to the Project, the Authority prepared and considered another
10 supplemental environmental impact report. The draft supplemental environmental impact report
11 (“Draft SEIR 3”) was made available on February 18, 2022.
12 27. In addition to the proposed new parking facility, the project modifications also
13 considered in Draft SEIR 3 included the following:
14 a. A new access road to the parking facility along Commercial Street (south of the
15 proposed parking facility).
16 b. A “Kiss & Ride” area for pick-up and drop-off;
17 c. Bus drop-off for Foothill Transit services at the intersection of Bonita Avenue (north
18 of the proposed parking facility) and San Dimas Avenue (east of the proposed parking facility);
19 d. Redevelopment of the existing parking lot to accommodate the 289 parking spaces
20 identified in SEIR 2 for the original parking facility;
21 e. Proposed vehicular access from Commercial Street and Monte Vista Avenue (west
22 of the proposed parking facility);
23 f. Pedestrian access via a pedestrian crossing and signal on San Dimas Avenue, west
24 of the station platform and south of the Project right-of-way. Pedestrian access would no longer be
25
26
1
The site map does not highlight the two neighboring parcels owned by the Successor Agency,
27
but which are located in the upper left portion of the site map between Bonita Avenue and W.
28 Railway Street.
01171.0024/807832.2 -8-
1 provided from the eastern side of the station platform, and pedestrian and bicycle access would no
2 longer be provided from Walnut Avenue, east of the station platform;
3 g. Fencing and landscaping along the perimeter of the proposed parking facility, and
4 along the new access road on Commercial Street; and
5 h. “Crime Prevention Through Environmental Design” features to provide a safe,
6 secure, and comfortable transit system.
7 In the Draft SEIR 3, the Authority stated it would work with the City to install traffic calming
8 elements around the parking facility, such as speed humps/bumps and signage. The Authority also
9 claimed in the Draft SEIR 3 that the Project elements, “including alignment, stations, and grade
10 crossings, would be the same as presented in the 2013 FEIR and subsequent environmental actions,
11 with the exception of the revised parking configurations and associated changes to vehicle and
12 pedestrian access discussed herein.”
13 28. On April 1, 2022, the City served the Authority with a letter providing its comments
14 on the Draft SEIR 3 and raised numerous concerns about the Authority’s inadequate environmental
15 analysis. The City’s comment letter focused on deficiencies in the following areas: 1) Project
16 description; 2) transportation and parking; 3) aesthetics; 4) air quality and greenhouse emissions; 5)
17 community parks and open space; 6) cultural resources; 7) noise and vibration; 8) safety and
18 security; 9) water quality and resources; and 10) general comments. A true and correct copy of the
19 April 1, 2022 letter is attached hereto as Exhibit “B” and incorporated herein.
20 29. On July 14, 2022, the Authority served the City with a letter responding to the City’s
21 comments and concerns of April 1, 2022. While the response letter addressed some of the
22 deficiencies raised by the City, the response letter failed to address others. A true and correct copy
23 of the July 14, 2022 letter is attached hereto as Exhibit “C” and incorporated herein.
24 30. On July 21, 2022, the final SEIR 3 (“Final SEIR 3”) was made available on the
25 Authority’s official website, and the City was advised that the Authority would be considering
26 certification of the Final SEIR 3 and approval of the project modifications on July 27, 2022.
27 / / /
28 / / /
01171.0024/807832.2 -9-
1 31. The Final SEIR 3 did not correct the deficiencies raised by the City in the Draft SEIR
2 3. Specifically, the Final SEIR 3 maintained the following deficiencies and incomplete analyses of
3 concern to the City:
5 alternatives capable of reducing the Project’s significant impacts. Specifically, the Final SEIR 3
6 fails to adequately respond to potentially feasible alternatives previously studied, and contractually
7 agreed to between the Authority and the City (and the Successor Agency), including an alternative
8 wherein the Authority had agreed to the purchase of two additional parcels of land owned by the
9 Successor Agency. The acquisition of these parcels would result in significant changes to the Project
10 affecting access to the proposed parking facility from Cataract Avenue, ingress, egress, parking
11 availability, traffic on neighborhood streets, and other aspects of the Project. The Final SEIR 3
12 completely ignores this alternative. While the Authority will be gaining 289 parking spaces for its
13 own commuters, the City will be losing 175 parking spaces in the heart of its downtown for bus
14 commuters, businesses, patrons, and the community at large, which will have a cumulative impact
15 on traffic, air quality, greenhouse gas, noise, and other environmental impacts on the surrounding
16 residential and commercial properties which have not been adequately analyzed. The loss of this
17 available daily parking currently dedicated to ride share users will severely impact traffic patterns
18 and flows in the downtown area and restrict availability for commuters to take advantage of ride
19 sharing benefits.
23 any evidence. Additional studies are necessary to address the impacts on traffic on these adjacent
24 residential roads resulting from the Project.
26 solely on the 2013 Final EIR for the unmodified Project. Instead of studying the effects of the Project
27 on pedestrians or cyclists or developing any mitigation for such impacts, the Authority simply states
28 in its Response to Comments that they “will work with the City of San Dimas to identify and fund
01171.0024/807832.2 -10-
1 traffic control on Commercial Street and Monte Vista Avenue as warranted to reduce potential
2 automobile and pedestrian/bicycle conflicts.” The Final SEIR 3 itself, however, fails to adequately
3 address pedestrian or cyclist safety.
7 change in use. However, the analysis ignores the impacts created from another part of the Project
8 which develops a new access road within an existing park, and the removal and alteration of
9 vegetation and changed lighting impacts from such road. Furthermore, the Final SEIR 3 does not
10 address the impacts on the community resulting from the removal of this park space.
11 e. Greenhouse gas (“GHG”) mitigation measures are illusory and do not pass muster
12 under CEQA. The Final SEIR 3 concludes the Project would not result in a significant impact on
13 climate change, but this conclusion is not supported by adequate analysis or substantial evidence.
14 The Authority responds to the City regarding this deficiency in comments that, “[b]ased on
15 experience with Phase 2A of the Gold Line and other project openings, the traveling public quickly
16 adjusts to an understanding of available parking and will adjust their travel to/from stations
17 accordingly.” This type of conclusory opinion based on nothing more than a single prior experience
18 is not a sufficient study under CEQA of the potential impacts and does not appear to be seriously
19 designed to mitigate the Project’s GHG emissions.
20 f. All other concerns raised by the City and set forth in detail in Exhibit “A.”
21 32. As a result, on July 26, 2022, the City sent another letter to the Authority, advising
22 that it continued to have major concerns with the relocation of the parking facility and the
23 Authority’s environmental analysis, as several of the deficiencies and potential impacts raised by
24 the City were not adequately addressed. The City, thus, requested that the Authority delay the
25 certification action in order to address the appropriate mitigations for the Project. A true and correct
26 copy of the July 26, 2022 letter is attached hereto as Exhibit “D” and incorporated herein.
27 33. Notwithstanding the City’s ongoing concerns and request for delayed action, the
28 Authority’s Board of Directors proceeded with a public hearing to consider and certify the Final
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1 SEIR 3 on July 27, 2022. During the portion of the public hearing on the agenda item, the City
2 Manager and City’s consultant for the City provided comment on behalf of the City in opposition
3 to the certification of the Final SEIR 3. The Authority’s Board of Directors, however, voted to
4 certify the Final SEIR 3 and adopt Resolution No. 2022-R-14, “Resolution of the Metro Gold Line
5 Foothill Extension Construction Authority Certifying the Final Supplemental Environmental Impact
6 Report 3 regarding Metro Gold Line Foothill Extension Project Phase 2B (Azusa to Montclair) San
7 Dimas Parking Facility Relocation. On July 28, 2022, the Notice of Determination was filed.
8 PROCEDURAL BACKGROUND
9 34. Petitioner files this Petition for Writ of Mandate and Complaint for Declaratory and
10 Injunctive Relief pursuant to Code of Civil Procedure sections 526, 527, 1060, and 1085, as well as
11 Public Resources Code sections 21168, 21168.5, and 21168.9. Petitioner has no effective remedy
12 to challenge the certification at issue in this action other than by means of this lawsuit.
13 35. This action was timely filed within thirty (30) days of the Authority’s filing of the
14 Notice of Determination approving the SEIR 3 on July 28, 2022. Petitioner performed all conditions
15 precedent to filing this action by complying with the requirements of Public Resources Code section
16 22167.5 in serving notice of intent to file this action on August 24, 2022. A true and correct copy
17 of the Notice of Intent to File and its attached proof of service is attached hereto as Exhibit “E.”
18 36. The City will send a copy of this Petition and Complaint to the California Attorney
19 General within ten (10) days of filing, thereby complying with the requirements of Public Resources
20 Code section 21167.7 and Code of Civil Procedure section 388.
21 37. Pursuant to Public Resources Code section 21167.6(b)(2), the City elects to prepare
22 the record of proceedings in this action. Concurrently with this Petition and Complaint, the City is
23 filing a notice of election to prepare the administrative record.
24 38. The City has performed any and all conditions precedent to filing the instant action
25 and has exhausted any and all available administrative remedies to the extent possible and required
26 by law. The City submitted and made numerous objections highlighting the Final SEIR 3’s
27 inadequacy as an environmental document and the Authority’s failure to comply with CEQA.
28 / / /
01171.0024/807832.2 -12-
1 39. The City has no plain, speedy, or adequate remedy in the course of ordinary law
2 unless this Court grants the requested writ of mandate to require Respondents to set aside their
3 certification of the Final SEIR 3. In the absence of such remedies, Respondents’ project
4 modifications will remain in effect in violation of state law, and the City, the environment, residents,
5 and property owners of the City will be irreparably harmed. No money damages or legal remedy
6 could adequately compensate for that harm.
7 LEGAL BACKGROUND
8 40. The California Environmental Quality Act, Public Resources Code sections 21000-
9 21177, is a comprehensive statute designed to provide for long-term protection of the environment.
10 It accomplishes this in two ways.
11 41. First, CEQA is designed to inform decisionmakers and the public about the potential
12 significant environmental effects of a project. (CEQA Guidelines § 15002(a)(1).) Such disclosure
13 ensures that “long term protection of the environment . . . shall be the guiding criterion in public
14 decisions.” (Pub. Res. Code § 21001(d).) The EIR is the “heart” of this requirement. (See No Oil,
15 Inc. v. City of Los Angeles (1974) 13 Cal. 3d 68, 84.) The EIR has been described as “an
16 environmental ‘alarm bell’ whose purpose it is to alert the public and its responsible officials to
17 environmental changes before they have reached ecological points of no return.” (Co. of Inyo v.
18 Yorty (1973) 32 Cal.App.3d 795, 810.)
19 42. Second, CEQA requires public agencies to avoid or reduce environmental damage
20 whenever feasible by considering changes in projects through project alternatives or mitigation
21 measures. (CEQA Guidelines §15002(a)(2) and (3); see also Citizens of Goleta Valley v. Bd. of
22 Supervs. (1990) 52 Cal. 3d 553, 564; Laurel Heights Improvement Ass’n v. Regents of the Univ. of
23 Cal. (1988) 47 Cal. 3d 376, 399.) An accurate and complete project description is central to this
24 requirement so “affected outsiders and public decision-makers [can] balance the proposal’s benefit
25 against its environmental cost, consider mitigation measures, assess the advantage of terminating
26 the proposal (i.e., the ‘no project’ alternative), and weigh other alternatives in the balance.” (Co. of
27 Inyo v. City of Los Angeles (1977) 71 Cal.App.3d 185, 192-93.)
28 / / /
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1 43. As the lead agency for the Gold Line Extension, under Public Resources Code
2 section 21081 and CEQA Guidelines section 15091, the Authority is prohibited from approving a
3 project for which an EIR was prepared unless either the project will not have a significant effect on
4 the environment, or the agency has adopted findings that all significant environmental effects have
5 been eliminated or reduced substantially and that any remaining effects found to be unavoidable are
6 acceptable on the basis of overriding concerns.
7 FIRST CAUSE OF ACTION
8 (Petition for Writ of Mandate – Code of Civil Procedure § 1085)
9 44. Petitioner incorporates herein by reference the allegations of paragraphs 1 through
10 43 inclusive.
11 45. CEQA requires an EIR to include an accurate and complete project description that
12 fully discloses and fairly evaluates the nature and objectives of a project. (CEQA Guidelines §
13 15124.) An accurate and complete project description is necessary so that the lead agency and the
14 public have enough information to “ascertain the project’s environmentally significant effects,
15 assess ways of mitigating them, and consider project alternatives.” (Sierra Club v. City of Orange
16 (2008) 163 Cal.App.4th 523, 533; Save Round Valley Alliance v. Co. of Inyo (2007) 157 Cal.App.4th
17 1437, 1448.)
18 46. The Final SEIR 3 violates CEQA because it does not consider an adequate range of
19 alternatives capable of reducing the Project’s significant impacts. Specifically, the Final SEIR 3
20 fails to adequately respond to potentially feasible alternatives previously studied, and contractually
21 agreed to between the Authority and the City (and the Successor Agency), including an alternative
22 wherein the Authority had agreed to the purchase of two additional parcels of land owned by the
23 Successor Agency. The acquisition of these parcels would result in significant changes to the
24 Project, affecting access to the proposed parking facility from Cataract Avenue, ingress, egress,
25 parking availability, traffic on neighborhood streets, and other aspects of the Project. Final SEIR 3
26 completely ignores this alternative. While the Authority will be gaining 289 parking spaces for its
27 own commuters, the City will be losing 175 parking spaces in the heart of its downtown for bus
28 commuters, businesses, patrons, and the community at large, which will have a cumulative impact
01171.0024/807832.2 -14-
1 on traffic, air quality, greenhouse gas, noise, and other environmental impacts on the surrounding
2 residential and commercial properties which have not been adequately analyzed. The loss of this
3 available daily parking currently dedicated to ride share users will severely impact traffic patterns
4 and flows in the downtown area and restrict availability for commuters to take advantage of ride
5 sharing benefits.
6 47. By certifying the Final SEIR 3 with an incomplete analysis of the Project’s impacts,
7 the Authority committed a prejudicial abuse of discretion, failed to proceed in a manner required by
8 law, and acted without substantial evidentiary support.
9 SECOND CAUSE OF ACTION
12 47, inclusive.
13 49. When an EIR identifies significant environmental impacts that may result from a
14 project, the lead agency must make one or more specific findings for those impacts. (Pub. Res. Code
15 § 21081; CEQA Guidelines §§ 15091(a), 15121(b)). The CEQA Guidelines require an EIR to
16 identify and analyze the impacts of a project with “a sufficient degree of analysis to provide
17 decisionmakers with information which enables them to make a decision which intelligently takes
18 account of environmental consequences.” (CEQA Guidelines § 15151.)
19 50. The CEQA Guidelines add a requirement that each finding must be accompanied by
20 a brief explanation of the rationale for that finding. (CEQA Guidelines § 15091(a); see Village
21 Laguna of Laguna Beach, Inc. v. Board of Supervs. (1982) 134 Cal.App.3d. 1022, 1034; City of
22 Rancho Palos Verdes v. City Council (1976) 59 Cal.App.3d 869.) e omission of relevant
23 information is deemed prejudicial if it prevents informed decision making and public participation,
24 “regardless of whether a different outcome would have resulted if the public agency had complied
25 with those provisions.” (Washoe Meadows Community v. Dep’t of Parks & Rec. (2017) 17
26 Cal.App.5th 277, 290 (citing Pub. Resources Code, § 21005(a).)

27 51. The Final SEIR 3 does not adequately address the increased traffic and traffic
01171.0024/807832.2 -15-
2 any evidence. Additional studies are necessary to address the impacts on traffic on these adjacent
3 residential roads resulting from the Project.
4 52. The aesthetics discussion in Final SEIR 3 is also deficient, as the analysis only
5 considers the view impacts from some, but not all, of the residential properties in the area.
6 Furthermore, the analysis is limited to only a portion of the Project area and concludes that there is
7 no significant change in use. However, the analysis ignores the impacts created from another part
8 of the Project that develops a new access road within an existing park and the removal and alteration
9 of vegetation and changed lighting impacts from such road. Furthermore, the Final SEIR 3 does not
10 address the impacts on the community resulting from the removal of this park space.
11 53. Likewise, greenhouse gas (“GHG”) mitigation measures are illusory and do not pass
12 muster under CEQA. The Final SEIR 3 concludes the Project would not result in a significant impact
13 on climate change, but this conclusion is not supported by adequate analysis or substantial evidence.
14 The Authority responds to the City regarding this deficiency in comments that, “[b]ased on
15 experience with Phase 2A of the Gold Line and other project openings, the traveling public quickly
16 adjusts to an understanding of available parking and will adjust their travel to/from stations
17 accordingly.” This type of conclusory opinion based on nothing more than a single prior experience
18 is not a sufficient study under CEQA of the potential impacts and does not appear to be seriously
19 designed to mitigate the Project’s GHG emissions.
20 54. Respondents violated CEQA by adopting inadequate findings. The City’s findings
21 do not provide adequate reasoning or the analytic route from facts to conclusions, as required by
22 law. In certifying the Final SEIR 3 without a complete analysis of the impacts of the project
23 modifications, the Authority committed a prejudicial abuse of discretion, failed to proceed in a
24 manner required by law, and acted without substantial evidentiary support.
25 THIRD CAUSE OF ACTION

28 54, inclusive.
01171.0024/807832.2 -16-
1 56. Under the CEQA Guidelines, the lead agency is required to consult with other public
2 agencies in a variety of circumstances which are relevant here in light of the impacts the proposed
3 modifications to the Project will have on City streets and the safety of pedestrians and cyclists. (See
4 e.g., CEQA Guidelines §§ 15006, 15063, 15083, 15086.) One of those circumstances is when the
5 lead agency prepares a Supplemental or Subsequent EIR for changes to a project. Pub. Res. Code
6 § 21080.1.)
7 57. The Final SEIR 3 does not adequately address pedestrian or cyclist safety and relies
8 solely on the 2013 Final EIR for the unmodified Project. Instead of studying the effects of the Project
9 on pedestrians or cyclists or developing any mitigation for such impacts, the Authority simply states
10 in its Response to Comments that they “will work with the City of San Dimas to identify and fund
11 traffic control on Commercial Street and Monte Vista Avenue as warranted to reduce potential
12 automobile and pedestrian/bicycle conflicts.” The Final SEIR 3 itself, however, fails to adequately
13 address pedestrian or cyclist safety.
14 58. By wrongfully adopting a supplemental EIR without properly consulting with the
15 City, the Authority violated CEQA requirements to consult with the City about the environmental
16 impacts which would result from the project modifications, mitigations measures or changes to the
17 modifications which would eliminate, reduce, or mitigate those impacts. In doing so, the Authority
18 committed a prejudicial abuse of discretion, failed to proceed in a manner required by law, and acted
19 without substantial evidentiary support.
20 FOURTH CAUSE OF ACTION
21 (Declaratory Relief – Code of Civil Procedure § 1060)
23 58, inclusive.
24 60. An actual controversy has arisen and now exists relating to the rights and duties of
25 the parties herein. The City contends that, because of the Final SEIR 3’s fatal defects as an
26 environmental document, it does not satisfy the requirements of CEQA and that Respondents cannot
27 rely on the Final SEIR 3 to modify the Project and relocate the parking facility. In contrast,
28
01171.0024/807832.2 -17-
1 Respondents contend that the Authority may rely on the Final SEIR 3 to modify the Project and
2 relocate the parking facility.
3 61. There is an ongoing controversy between the parties regarding the legal effect of the
4 Final SEIR 3. The City, therefore, seeks declarations that the Final SEIR 3 is deficient as an
5 environmental document under CEQA, and that Respondents may not use the Final SEIR 3 to
6 modify the Project and relocate the parking facility.
7 FIFTH CAUSE OF ACTION
8 (Injunctive Relief – Code of Civil Procedure § 526, 527)
10 61, inclusive.
11 63. The Authority’s project modifications have the potential to cause significant effects
12 on the environment. Those effects must be properly reviewed in compliance with CEQA and
13 adequately mitigated to the extent feasible.
14 64. As a result of the Authority’s non-compliance with CEQA, certification of the Final
15 SEIR 3, and adoption of Resolution No. 2022-R-14, the City, the environment, residents, and
16 property owners of the City have and will continue to suffer irreparable injury, in that the adverse
17 environmental impacts of the project modifications have not been adequately analyzed and/or
18 mitigated.
19 65. The City has exhausted all administrative remedies, and further efforts would be
20 futile, resulting in irreparable harm.
21 66. A temporary stay; temporary restraining order; and preliminary and permanent
22 injunctions should issue restraining the Authority from constructing and operating the project
23 modifications contained in the Final SEIR 3 until the Authority fully complies with the requirements
24 of CEQA.
25 PRAYER FOR RELIEF
26 WHEREFORE, Petitioner and Plaintiff City of San Dimas prays for entry of judgment as
27 follows:
28 / / /
01171.0024/807832.2 -18-
1 1. For a peremptory writ of mandate directing that Respondents shall vacate and set
2 aside the certification of the Final SEIR 3 and adoption of Resolution No. 2022-R-14 on July 27,
3 2022;
4 2. For a peremptory writ of mandate directing that Respondents shall conduct a new
5 environmental review process that complies with CEQA’s requirements as set forth herein; and
6 prepare, circulate, and consider a new and legally adequate Supplemental EIR and otherwise comply
7 with CEQA in any subsequent action taken;
8 3. For a declaratory judgment stating that the Final SEIR 3 is inadequate as an
9 environmental document under CEQA;
10 4. For a declaratory judgment stating that the Authority violated CEQA by certifying
11 the Final SEIR 3 and that the Authority’s failure to prepare, consider, and certify an adequate
12 environmental analysis under CEQA is a prejudicial abuse of discretion;
13 5. For a temporary stay; temporary restraining order; and preliminary and permanent
14 injunctions restraining Respondents from constructing and operating the project modifications
15 contained in the Final SEIR 3 until the Authority fully complies with the requirements of CEQA;
16 6. For its costs of suit;
17 7. For an award of attorneys’ fees pursuant to Code of Civil Procedure section 1021.5
18 or other applicable law;
19 8. For other and further relief as the Court may deem just and proper.
20
21 DATED: August 26, 2022 ALESHIRE & WYNDER, LLP

JEFF M. MALAWY
22 ANTHONY R. TAYLOR
ALISON S. FLOWERS
23
24
25 By:
ALISON S. FLOWERS
27
28 DEEMED VERIFIED PURSUANT TO CODE OF CIVIL PROCEDURE SECTION 446
01171.0024/807832.2 -19-
EXHIBIT “A”
Figure 1-3: Proposed Project Modifications and Approved Parking Facility
1-10 Metro Gold Line Foothill Extension–Azusa to Montclair Supplemental Environmental Impact Report
July 2022
EXHIBIT “B”
City Council Director of
Emmett Badar, Mayor Administrative Services
Eric Weber, Mayor Pro Tem Michael O’Brien
Denis Bertone
John Ebiner Director of
Ryan A. Vienna Community Development
Henry K. Noh
City Manager
Chris Constantin Director of Parks and
Recreation
Assistant City Manager Scott Wasserman
Brad McKinney
Director of Public Works
City Attorney Shari Garwick
Jeff Malawy
April 1, 2022
Lisa Levy Buch, Chief Communications Officer

Metro Gold Line Foothill Extension Construction Authority
406 E. Huntington Drive, Suite 202
Monrovia, CA 91016-3633
Subject: Comments on Draft Supplemental EIR (DSEIR) Metro Gold Line Extension
Phase 2B – Evaluating Relocation of the San Dimas Parking Facility
Dear Ms. Buch:
Please allow this letter to serve as the City of San Dimas’ comments on the above-referenced
Draft Supplemental Environmental Impact Report 3 (“Draft SEIR 3”) for the relocation of the San
Dimas parking facility. This letter follows a letter previously submitted to Metro Gold Line Foothill
Extension Construction Authority (the “Authority”) on November 17, 2021 regarding the Notice of
Preparation of the Draft SEIR 3, which raised significant concerns about the relocation of the
parking facility from the City Yard to the proposed Park and Ride location on the City and its
community.
Despite our efforts to work with Metro Gold Line to address the impacts on the City and the
surrounding community, the Draft SEIR 3 does not adequately address our concerns, as detailed
below.
Project Description
1. The Draft SEIR 3 does not accurately describe the proposed Project Modifications. The
Project Description states the “Project Modifications also include roadway improvements
to accommodate vehicles accessing the parking facility along Commercial street”.
However, no specific information regarding these improvements is provided. Further, there
is no mention of the modifications to Freedom Park that are proposed. The Project
Modifications would result in a portion of the existing Freedom Park site to be improved
with an access road. Additionally, the Kiss and Ride Drop Area appears to further
encroach into Freedom Park, which is not disclosed in the Project Description.
Additionally, throughout the Draft SEIR 3, reference is made only to the existing Park &
Ride lot when discussing the Project Modifications. As a result, it is unclear if the Draft
SEIR 3 adequately assesses impacts as they relate to the proposed improvements and
245 East Bonita Avenue ∙ San Dimas ∙ California 91773-3002 ∙ (909) 394-6200 ∙ Fax (909) 394-6209  sandimasca.gov
Response to Draft SEIR Metro Gold Line Extension –Relocation of the San Dimas Parking Facility
San Dimas CA, 91773 2
April 1, 2022
the conversion of a portion of Freedom Park to an access road.
2. Draft SEIR 3, Page 3-20, Traffic Circulation, incorrectly states the primary entrance for
Park & Ride and Kiss & Ride access will shift from Walnut Avenue to San Dimas Avenue.
Entrances to the parking lot relocation are located on Commercial Street and Monte Vista
Avenue which are residential streets.
3. Draft SEIR 3, Page 4, Project Modifications, incorrectly states that “Access will occur only
from the western side (San Dimas Avenue) of the station platform. No access to the San
Dimas station will be provided from the eastern (Walnut Avenue) side of the platform as a
result of the station parking facility”. Pedestrian access from Walnut Avenue was not
directly connected to the Park and Ride located at the Maintenance Yard. In fact, the only
direct access to the station for Park and Ride patrons under that proposal design layout
was via a subterranean pedestrian tunnel (under the Metro Line track) that connected
directly to the center platform at the station.
While the project modification does not incorporate First/Last Mile Plan around the
relocated station parking, the City feels strongly that the Authority should reinstate the
pedestrian connection to the station from Walnut Avenue as originally planned because
the previous layout was independent of the station parking. In addition, this connectivity
to Walnut Avenue is within the Authority’s construction work areas and should be
constructed as part of the project because it provides access for residents living on the
east side of the station.
4. Figure 1-3 fails to identify the correct parking lot footprint as it does not depict the location
of the proposed access road or exit for the Kiss and Ride Area. In reviewing an EIR, a
paramount consideration is the right of the public to be informed in a manner that enables
it to intelligently weigh the environmental consequences of any contemplated action and
have an appropriate voice in the formulation of any decision. An accurate, stable and finite
project description is required for an informative and legally sufficient EIR. Because of the
importance of the project description, when the project changes significantly, the failure to
prepare a subsequent or supplemental EIR deprives the public, who relied on the EIR, of
information and meaningful participation. (City of San Jose v. Great Oaks Water Co.
(1987) 192 Cal.App.3d 1005, 1017.) The Draft SEIR 3 fails to meet these requirements.
In addition, the Draft SEIR 3 fails to include in its review the two parcels located at the
intersection of Bonita and Cataract, Assessor Parcel Numbers 8390-021-915 and 916. As
indicated by the Letter of Intent between the Authority and the City, these parcels are
included in the new parcels to be acquired and likewise subject to the requirement that
the Authority secure all CEQA approvals necessary for the use of the parcels. The
requirements of CEQA cannot be avoided by piecemeal review, which results from
chopping a large project into many little ones, which cumulatively may have substantial
impact and perhaps disastrous consequences. (Rio Vista Farm Bureau Center v. County
of Solano (1992) 5 Cal.App.4th 351, 370; Environmental Prot. Info. Ctr. v. Cal. Dept. of
Forestry and Fire Prot. (2008) 44 Cal. 4th 459, 503.)
Moreover, failure to purchase and utilize those two parcels for station parking/access is a
violation of the Letter of Intent, as the Letter of Intent requires the parties to “work together
in good faith toward execution of a mutually agreeable purchase and sale agreement” for
those two parcels.
April 1, 2022
By failing to include the two parcels on Bonita and Cataract, the Authority is piecemealing
its environmental review of the proposed modification without the legally required
environmental review of the project’s impacts. An inaccurate or incomplete project
description undermines CEQA’s purposes because it thwarts a full analysis of project
impacts, thus minimizing the project’s effects. (City of Santee v. County of San Diego
(1989) 214 Cal.App.3d 1438, 1454; San Joaquin Raptor Rescue Center v. County of
Merced (2007) 149 Cal.App.4th 645, 656.) Thus, when an EIR gives “conflicting signals
to decision-makers and the public about the nature and scope of the activity being
proposed,” the courts have found it “fundamentally inadequate and misleading.” (San
Joaquin Raptor Rescue Center, 149 Cal.App.4th at 655-56.) The Draft SEIR 3 has the
type of truncated project review that CEQA prohibits and creates uncertainty about the
project’s impacts.
Transportation and Parking

In our prior letter, we expressed our significant concern regarding the reduction in the number of
parking spaces in the proposed relocated parking facility, as well as concerns regarding
pedestrian routes and the impact on traffic in the residential neighborhoods in the vicinity of the
proposed parking facility. The Draft SEIR 3 fails to adequately analyze and mitigate these
concerns.
Meaningful analysis of impacts effectuates one of CEQA’s fundamental purposes: To “inform the
public and responsible officials of the environmental consequences of their decisions before they
are made.” (Laurel Heights Improvement Ass’n v. Regents of the Univ. of Cal. (1993) 6 Cal.4th
1112, 1123.) To accomplish this purpose, an EIR must contain facts and analysis, not just an
agency’s bare conclusions. (Citizens of Goleta Valley v. Bd. of Supers. (1990) 52 Cal. 3d 553,
568.) An EIR’s conclusions must be supported by substantial evidence. (Laurel Heights
Improvement Ass’n, 47 Cal.3d at 409.) The Draft SEIR 3 is vague and lacks supporting
documentation to adequately assess Transportation impacts. The items detailed in the City’s
response below address concerns, but the City cannot fully evaluate the Draft SEIR 3 without
additional studies and information that was not provided.
5. The Draft SEIR 3, under Section 3.2.7, Long Term Parking Impact, indicates that no
parking impact will result from the station parking relocation. On the contrary, relocating
the Gold Line Station’s proposed 289 parking spaces to the existing Park and Ride
location would result in the loss of an additional 175 valuable parking spaces (existing
spaces not being accommodated or accounted for with the Gold Line Parking relocation
to the City’s Park and Ride) in the heart of San Dimas’ historic downtown.
This loss of crucial and irreplaceable parking spaces in the downtown area would not only
adversely and negatively affect the downtown businesses, but also impact the community
at large. The City hosts various annual parades, car shows, bike races, as well as the
Memorial Day and Veterans Day observance days at Freedom Park. With the immediate
loss of this daily available critical parking to the community any time of year, where do
these patrons, visitors and attendees park?
The Draft SEIR 3 fails to address the adverse and negative impact on the loss of this
critical and daily available parking and its subsequent affect to the immediate
neighborhood, businesses, community, and community at large.
April 1, 2022
As previously mentioned, the Draft SEIR 3 acknowledges that the existing Park & Ride
facility with 175 parking spaces serves as the patron parking for the bus lines, but does
not discuss the removal of the parking spaces during construction. Thus, the short-term
impacts on the circulation system have not been considered. In addition, the Draft SEIR
3 fails to consider the current use of the parking facility by patrons of the Downtown
businesses and the businesses themselves. The Draft SEIR 3 does not adequately
analyze the impacts resulting from the loss of these parking spaces, narrowly relying on
its use by patrons of Foothill Transit only.
In addition, the Draft SEIR 3 does not adequately address the increased traffic on
surrounding residential roadways to access the parking facility, and the Authority’s
conclusion that drivers will typically use major streets is not substantiated. “To facilitate
CEQA’s informational role, an EIR must contain facts and analysis, not just the agency’s
bare conclusions or opinions.” (Habitat & Watershed Caretakers v. City of Santa Cruz
(2013) 213 Cal.App.4th 1277, 1303.) An EIR’s conclusions must be supported by
substantial evidence. (Laurel Heights Improvement Ass’n v. Regents of the Univ. of Cal.
(1988) 47 Cal.3d 376, 409.)
Moreover, there is a potential design hazard related to vehicles queueing at the San Dimas
Avenue/Commercial Street traffic signal, which needs to be fully analyzed and addressed.
The preparation and function of an EIR is to ensure that government officials who decide
to build or approve a project do so with a full understanding of the environmental
consequences. Equally important, the public is assured those consequences have been
taken into account. (Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho
Cordova (2007) 40 Cal.4th 412, 449; Citizens Against Airport Pollution v. City of San Jose,
supra, 227 Cal.App.4th at 796.)
Additionally, traffic delays with the proposed relocation of the parking facility, as well as
deficiencies and inaccuracies related to pedestrian access need to be analyzed and
mitigated. CEQA requires the Authority to evaluate the project’s traffic safety impacts on
pedestrians, cyclists, and transit riders. (See City of Maywood v. Los Angeles Unified Sch.
Dist. (2012) 208 Cal. App. 4th 362, 392-95 (holding EIR was inadequate because it failed
to analyze and mitigate project impacts on pedestrians).)
6. The loss of an approximately 2.25-acre Park and Ride property in the City’s downtown
would also result in the City losing its potential to develop this land for housing needs or
TOD. A development that provides a balance of both community parking and housing
provides more vibrancy to the downtown. Quite likely, based on current development
proposals, this property may be developed with up to 52 residential units with ample
parking available for the community.
7. The Authority states that, based on coordinated internal discussions between them and
Foothill Transit, commuter bus lines 492 and 499 would not operate to downtown Los
Angeles once Phase 2B is completed and operational to Pomona.
a. The planned projected completion of Phase 2B is estimated to be mid-2025, plus

another 6 months or more for Metro to render the service fully operational (which
is approximately 4 years away). In the meantime, where do patrons of the
community park or get picked up during the construction of the station parking?
April 1, 2022
Has the Authority made any parking provisions for these commuters during this
interim period as part of so-called coordinated arrangement with Foothill Transit?
What are the short-term impacts on the circulation system associated with vehicles
that currently utilize the San Dimas Park & Ride facility being diverted to a different
location within the City?
b. With the Authority stating that Foothill will cease bus lines 492 and 499, does this
imply that commuters will now have only one mode of public transportation to
Downtown Los Angeles to choose from? With the opening of the I-10 Freeway
express lane projected by end of 2023, the estimated commute time to Los
Angeles will be much shorter than Metro’s projected time to Downtown Los
Angeles. Why will this alternative bus mode of transportation cease and, if so,
where do these commuters park during the two-year gap of Phase 2B opening?
In addition, this parking facility is not limited or restricted to patrons of Foothill

Transit and is available to rideshare, vanpool, etc., as well as serving as additional
parking for the Downtown businesses and patrons. Without replacement of the
existing 175 spaces, parking will be constrained, impacting Downtown businesses
and adjacent residential neighborhoods. The reduced parking provided for the
station is already likely to result in overflow parking onto adjacent residential
neighborhoods, as acknowledged by the need for Parking Management Plans
(PMPs). The removal of existing parking spaces that would occur with the Project
Modifications would exacerbate this impact. The Draft SEIR 3 does not adequately
analyze the impacts resulting from the loss of these parking spaces, narrowly
relying on its use by patrons of Foothill Transit only.
c. The Authority has stated that an internal coordination or agreement has been
concluded with Foothill Transit to cease operation of lines 492 and 499. Has this
been discussed with the Foothill Transit Board? Are there any formal approvals in
place? Why was the City not involved as part of this discussion? In fact, according
to a June 25, 2021 Foothill Transit Board Executive Board Meeting staff report, the
report states that the use of the City’s Park and Ride for station parking will
necessitate Line 499 being realigned to an alternate location for customers who
currently utilize Line 499 at the park and ride. No action has or is being considered
to cease operations of the lines, but rather, the consideration of the City’s Park and
Ride for Project parking will impact the location, traffic, and parking impacts for
Foothill Transit passengers and as such has not been considered in the Draft SEIR
3. Further, according to the Foothill Transit leadership, Foothill Transit is waiting
to see what occurs at the Park and Ride to initiate coordination. Thus, the Draft
SEIR 3 does not properly analyze the impacts resulting from changes to lines or
worse is premised on faulty assumptions of changes to the lines.
d. The need for parking specifically at the City’s Park and Ride is not just driven by
the needs of Foothill Transit commuters. As noted, during the lockdown due to the
pandemic, Foothill was operating with minimal bus service – possibly due to when
a lot of commuters opted to stay and work from home. However, even during those
times, the City’s Park and Ride was heavily used on a daily basis. The daily patrons
parking there are part of car pools, local business customers, employees, as well
as transit riders, too. Currently, the Feed and Grain Store uses the Park and Ride
for offloading supplies. This use will be eliminated in the proposed modifications,
April 1, 2022
with no mention of any mitigation measures.
The heavy daily use of the Park and Ride shows the latent need of parking in the
heart of downtown. How does the Authority plan to replace this critically needed
parking in the downtown?
Again, the Draft SEIR 3 fails to address the adverse and negative impact from the loss of this
critical and daily available parking and its subsequent affect to immediate neighborhood,
businesses, community, and the community at large.
In addition to the Park and Ride serving Foothill Transit riders, rideshare, vanpool, as well as
serving as additional parking for the Downtown businesses and patrons, it provides parking
for employees of the Curative Lab located at 430 S. Cataract Avenue. Employees are then
shuttled to their location of employment. The loss of the availability to park at the Park and
Ride will create impacts to the surrounding residential neighborhoods. Eliminating the parking
for Curative Lab would result in traffic and parking impacts not reasonably contemplated when
looking at just the Park & Ride. The Draft SEIR 3 does not address this or analyze the
impacts. In addition, the Authority’s analysis of parking during construction is deficient, and
the loss of daily parking for commuters and patrons has not been adequately analyzed or
mitigated. The Authority must also identify and adopt feasible mitigation measures to reduce
those impacts, if feasible. (Pub. Res. Code § 21083(b)(2); CEQA Guidelines § 15064(h)(1)).)
As a further example, the negative impact to the housing development located at San Dimas
Avenue and Commercial Street has not been analyzed or mitigated. Not only will parking be
reduced, but vehicle queueing will become an issue, which was an issue raised with the
Authority in our prior response letter. Consequently, the Authority must consider feasible
mitigation measures in a revised and recirculated Draft SEIR 3.
8. The Draft SEIR 3 does not adequately address the increased traffic on surrounding
residential roadways in order to access the parking facility. The statement that “typically,
drivers would use major streets such as San Dimas Avenue and would choose a more
direct route to the station parking facility” is not substantiated. Access to the station parking
would occur from residential streets. With the permanent street closure to vehicular traffic
on Monte Vista Avenue, vehicles accessing the parking facility from Monte Vista Avenue
have no other option but to travel through residential neighborhoods.
9. The Project Modifications propose a new access road from Commercial Street. This
access road would be located just west of an existing driveway providing access to the
residential and live/work development located at the southwest corner of Commercial
Street and San Dimas Avenue. The interaction of vehicles exiting the parking lot and
queuing on Commercial Street at the San Dimas Avenue/Commercial Street traffic signal
could potentially impede vehicles attempting to turn left from Commercial Street into the
existing driveway causing vehicles to queue into the intersection; however, no mitigations
are proposed. How will this impact emergency vehicle responses? Currently the
businesses and residents park within the Park and Ride or on Commercial Street.
Reference is made to a Parking Management Plan; however, it is unclear how the Gold
Line Authority will develop the plan, and as it is a limited life organization, how will the
parking plan be managed after the Gold Line Authority is dissolved? This potential design
hazard needs to be addressed in the Draft SEIR 3.
April 1, 2022
10. Draft SEIR 3 Page 3-19 references “controlled parking entrances and exits”. What kind of
controls will be utilized? Depending upon the types of controls and location, there could
be a potential for vehicles to queue onto neighboring residential streets. This potential
needs to be addressed.
11. The approved SEIR 2 incorporates bus drop off and onboarding within the station parking
lot. The proposed configuration in the Draft SEIR 3 eliminates buses in the parking lot.
This has significant impacts on:
a. The ability to provide cross connection with other bus lines.

b. The potential increase in bus stops on Bonita Avenue creates a potential backup
on Bonita Avenue that may impact the freight crossing at Cataract Ave.
c. Eliminates bus staging which currently occurs in the Park and Ride Lot.
12. No mitigations or improvements were proposed for the Bonita/San Dimas Ave bus stops
to accommodate additional ridership.
13. The intersection of San Dimas Avenue and Commercial Street will be severely impacted,
including creating traffic back-ups at the northbound left turn lane to access the Park and
Ride. This should be further studied and require mitigation measures to prevent
northbound vehicles from turning into the Grove Station development to turn around and
bypass the back-up created at the northbound left turn lane.
14. 3.1.4 Mitigation Measures and Recommendations - LTR-1 states that the Authority shall
cooperate with the City and contribute funding for a new traffic signal at the intersection of
San Dimas Avenue at Second Street when warranted.
a. The relocation of the station parking to the City Park and Ride will result in an
exponential increase in traffic delays because all the commuters parked at the Park
and Ride will cross San Dimas Avenue at the railroad crossing – both during peak
AM and PM hours and intermittently during the off-peak hours. On page 3-8 it
states that “a traffic evaluation was completed in May 2021 for the proposed east-
west crosswalk just south of the Project ROW… The results of the operation and
queueing analysis for the northbound and southbound approaches at San Dimas
Avenue indicated that the Project with Project Modifications would not result in a
substantial increase in traffic delay, and signal operations for the crosswalk at San
Dimas Avenue would result in minimal delays compared to the delays experienced
at the nearby intersections.”
Almost 90% of the commuters will opt to cross at this crosswalk – it’s only ingrained
human nature to cross at the shortest and closest point. The increase in pedestrian
crossing frequency and activities will further compound and add to delays already
experienced by drivers when the train is stopping or leaving the station. This
additional delay, in particular for southbound San Dimas Avenue north of Bonita
Avenue, will initiate driver behavior to take “short cuts” through the residential
streets. Neighborhoods were not designed for cut through traffic in order to avoid
delays as traffic backs up at Bonita Avenue. Why was the traffic evaluation which
was completed in May 2021 not provided for review?
With the relocation of the station parking lot to the Park and Ride, the Authority
April 1, 2022
must consider installing a traffic signal as part of the current project now, rather
than when fully warranted. Secondly, when it’s fully warranted, how does the City
collect its contribution? Upon completion of Phase 2B, the Authority is dissolved
and non-existent. Again, how does the City collect the contributions?
b. The Draft SEIR 3 states that additional traffic would be expected on Monte Vista
Avenue and Commercial Street to enter and exit the parking lot. Any subsequent
impacts will be addressed by a Parking Management Plan (PMP) – a PMP that
states it would prohibit on-street parking for transit patrons and any of the
neighborhoods that are impacted by traffic would be addressed by means of the
Authority working with City to install traffic calming elements around the parking lot
such as speed humps/bumps and signage. This statement completely disregards
and ignores the City’s initial comments in the NOP to consider various traffic
calming mitigation measures that would mitigate transit patrons traffic flow from
the residential neighborhood.
Again, we reemphasize the City’s NOP comments recommending various traffic

calming measures, which would mitigate the traffic flow of transit patrons in and
out of the residential neighborhood as a result of the Gold Line’s proposal to
relocate station parking to the Park and Ride, which will result in a substantial
increase in traffic volume within the existing quiet neighborhood along Cataract
Avenue, Railway Street, and Commercial Street. Therefore, to deter and restrict
traffic entering Commercial Street from Cataract Avenue or Railroad Street, and/or
turning right onto Commercial Street when exiting from the station parking primary
driveway/aisle, it is recommended that the following specific mitigation measures
be considered and reviewed for implementation by the Authority:
I. Restrict commuter traffic from entering and exiting at Railway

Street/Monte Vista Avenue/Park and Ride and allow access for
emergency vehicles only.
II. The acquisition of Successor Agency properties on Cataract Avenue

and utilization of Metro Gold Line’s right-of-way south of the rail lines to
create a vehicular bypass to Railway Street and Commercial Street,
thereby potentially reducing traffic impacts on surrounding residential
streets.
III. Extend Park and Ride driveway/aisle approximately 4 to 6 feet south of

the center line of Commercial Street leaving approximately 12 to 13-
foot-wide lane open for eastbound traffic only.
IV. Extend this restricted eastbound lane up to Shirlmar Street by means

of landscaped curb extensions with entry and exit allowing for street
parking for the two residents on the north side of Commercial, adjacent
to the Park and Ride.
V. The eastbound approach of Commercial Street at San Dimas Avenue

should be modified to provide two eastbound lanes.
VI. The segment of Commercial Street between Shirlmar Street and the
April 1, 2022
Park and Ride’s primary entrance will be restricted to allow eastbound

traffic only, thereby also providing emergency and vehicular
connectivity for residents of this neighborhood to downtown and San
Dimas Avenue.
VII. Extension of the primary Park and Ride driveway/aisle allows for
smooth flow of traffic in and out of the station parking lot without much
delay.
VIII. Traffic signal timing and intersection improvements at San Dimas

Ave/Commercial Street to mitigate impacts to the entrance of the HOA
south of Commercial Street/west of San Dimas Ave resulting from
queuing associated with the relocated station parking access.
The combination of the extended entrance and curb extension will minimize traffic
from the station’s Park and Ride entering into the neighborhood because patrons
using the facility will be forced to use the main entrance which will keep the
separation of traffic flow to the major arterials and off residential streets as
intended.
15. In Section 4.13.3.4 Long - Term Safety Impacts, the Draft SEIR 3 details that the relocation
of the station parking has the potential to result in increased safety impacts for motorists,
bicyclists, and pedestrians as a result of the additional parking spaces provided, and
potential additional vehicular activity associated with station access from the relocated
parking facility. It further expounds that the Construction Authority will work with the City
of San Dimas to identify and fund traffic and speed control devices, including traffic
calming devices such as additional signage, active speed identification signs, speed
humps/bumps and other devices … to recue potential automobile and pedestrian/bicycle
conflicts. However, none of these have been studied or proposed as mitigations. The Draft
SEIR 3, in fact, ignores the conclusion of this section and indicates no mitigations are
required. As referenced above, CEQA requires the Authority to evaluate a project’s traffic
safety impacts on pedestrians, cyclists, and transit riders. (See City of Maywood v. Los
Angeles Unified Sch. Dist. (2012) 208 Cal. App. 4th 362, 392-95 (holding EIR was
inadequate because it failed to analyze and mitigate project impacts on pedestrians).)
16. The realignment of the public alley north of Commercial Street to meet the Park and Ride’s
primary drive aisle restricts the eastbound right turn for residents, trash service, other utility
vehicles and fire safety equipment. This layout needs to be redesigned in order to allow
access for the residents. Also, these residents would need access rights to use the new
access road.
17. Tables 3-6 and 3-7 show the level of service for the AM and PM peak hours for the
following intersections:
• San Dimas Avenue/Bonita Avenue

• San Dimas Avenue/Arrow Highway
• Walnut Avenue/Arrow Highway
• San Dimas Avenue/Railway Street
• San Dimas Avenue/Commercial Street
April 1, 2022
With the relocation of the parking to the Park and Ride, motorists coming from the west
ends of the City and adjacent cities to the west will travel through and add delays to the
intersections of Cataract Avenue/Arrow Highway and Cataract Avenue/Bonita Avenue.
The level of service analysis should include these additional two intersections.
18. On page ES-3, the Draft SEIR 3 states that the proposed San Dimas parking facility would
also include a Kiss and Ride area to allow for pick-ups and drop-offs. Buses would no
longer enter the parking lot. Instead, the bus drop-off for Foothill Transit would now be
located at the intersection of Bonita Avenue and San Dimas Avenue. An intersection that
would now be more congested since there are two existing Foothill Transit stops, located
at the northeast and southeast of the intersection of Bonita Avenue at San Dimas Avenue
for bus line 492. Where would the bus stop for commuter bus line 499 be located? The
existing intersection was modified due to the Gold Line and is already congested, thus the
addition of two new bus stops would compound further delays at an intersection that is
already experiencing substantial delays. In addition, increased pedestrian crossing on San
Dimas Ave south of the tracks will add to the delays at Bonita/San Dimas Ave, potentially
backing up eastbound traffic across the freight tracks at Bonita/Cataract Ave.
19. The impacts to Cataract Avenue/Bonita Ave and Cataract Ave/Arrow Highway were not
studied. These intersections are closest to the freeways and the entire west side of City.
Much of the parking commuters will be approaching from this direction. These
intersections will be severely impacted and need to be studied.
20. Where is the traffic study from May 2021 that was referenced in the Draft SEIR 3? Why
was this not available for review?
Aesthetics
21. The Draft SEIR 3 Aesthetics discussion identifies eight residences located along the
border of Commercial Street and states the fronts of these residences face away from the
Project site and views of the Project site from the back are buffered. However, the analysis
does not take into consideration the residential property located south of Commercial
Street that directly faces Freedom Park and the proposed location of the new access road.
Therefore, the aesthetics discussion is deficient, as the analysis only considers some of
the residential properties in the area. An EIR’s description of the environmental setting
must be contain sufficient information to “permit the significant effects of the project to be
considered in the full environmental context.” CEQA Guidelines, § 15125(c). “If the
description of the environmental setting ‘is inaccurate, incomplete or misleading, the EIR
does not comply with CEQA.’” (Cleveland Nat’l Forest Found. v. San Diego Assn. of
Governments (2017) 17 Cal.App.5th 413, 439.) An accurate description of the
environmental setting is critical, because the significance of an activity may vary with the
setting. CEQA Guidelines, § 15064(b). A “project that is ordinarily insignificant in its impact
on the environment may in a particularly sensitive environment be significant.” (Kings
County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 718, 721; CEQA
Guidelines, § 15300.2(a)).)
22. In addition, the Draft SEIR 3 fails to consider views of the Project site from pedestrians
utilizing Commercial Street, fails adequately address the impacts of the portion of
Freedom Park that is proposed to be removed in order to construct an access road, and
fails to address the introduction of lighting from vehicle headlights which will impact certain
April 1, 2022
residences. Because the Draft SEIR 3 fails to properly study these significant impacts on
aesthetics, the Draft SEIR 3 fails to live up to its role as an informational document. The
Authority’s failure here “precludes informed decision making and informed public
participation, thereby thwarting the statutory goals of the EIR process.” (Ass'n of Irritated
Residents v. County of Madera (2003) 107 Cal.App.4th 1383, 1391.)
23. The Draft SEIR 3 focuses the discussion and associated impact conclusions on the portion
of the Project site that is comprised of the current San Dimas Park & Ride facility, relying
on the fact that it is currently a parking facility and would continue to be a parking facility:
“As discussed, the vividness, intactness, and unity of the Project Site would remain similar
to existing conditions with the implementation of the Project Modifications as the parcel
would continue to be used as a paved parking facility”. However, the Project Site extends
beyond the existing San Dimas Park & Ride facility. The Draft SEIR 3 does not adequately
address the portion of Freedom Park that is proposed to be removed in order to construct
an access road or the Kiss and Ride Area. Views of Freedom Park in this area are intact
with large mature trees and landscaping that provide visual relief from the surrounding
development. The 2013 FEIR did not contemplate the removal of a similar resource, as a
similar resource is not located within the previously considered parking location.
24. The Draft SEIR 3 does not discuss the Project’s introduction of lighting associated with
the headlights of vehicles exiting the parking lot from the proposed access road that would
directly impact the residence located south of Commercial Street that fronts Commercial
Street and Freedom Park; this condition does not currently exist and would not have
occurred at the previously considered parking location.
Air Quality/Greenhouse Gas Emissions
25. The Draft SEIR 3 does not fully analyze the air quality impacts to surrounding residents
and does not propose proper mitigation (i.e. upgrading residential air filtration systems
and enhancing First/Last Mile improvements) to reduce the potential air quality impacts.
The proximity of the relocated Gold Line station parking lot to the existing Park and Ride
will result in an increase of traffic to the surrounding residential neighborhoods and if
proper parking is not provided, these future riders will circulate and park within surrounding
private and public parking lots or along residential or commercial streets. The result of
these vehicles circulating around the surrounding residential neighborhoods looking for
parking will increase emissions/air pollutions and therefore increase Green House Gas
(GHG) Emissions and air quality impacts.
26. In this regard the Gold Line Authority (GLA) should also evaluate, quantify and mitigate
the effects of greenhouse gas (GHG) emissions as part of the overall air quality
assessment. This topic was not clearly addressed in the 2013 FEIR.
Community Parks and Open Space

27. The Draft SEIR 3 is deficient as it discounts the importance of the portion of Freedom Park
proposed for acquisition because it does not contain park facilities or features. However,
this area is vegetated, including mature trees and serves as an open space resource for
the surrounding community. The removal of a portion of Freedom Park is a long-term
impact which was not contemplated in the 2013 FEIR, and the Draft SEIR 3 fails to
describe the magnitude and severity of this impact, including in communities and
April 1, 2022
neighborhoods located in this area. The Draft SEIR 3 fails to identify feasible mitigation
measures that would effectively reduce the Project’s impacts on the visual character and
quality.
Cultural Resources
28. The Draft SEIR 3 indicates the AB 52 consultation process is ongoing and will be further
documented as part of future CEQA documentation, but fails to identify what future CEQA
documentation is being referenced. Under AB 52, if consultation has begun, an EIR
cannot be certified unless the consultation process between the tribe and the lead agency
has concluded. Thus, the Draft SEIR 3 inadequately describes the AB 52 consultation
process.
Noise and Vibration

29. The Draft SEIR 3 inaccurately states that, when compared to the SEIR 2 location,
residential structures abutting the relocated San Dimas parking facility are farther away
from potential noise and vibration-intensive construction activities and concludes a
reduction in both construction noise and construction vibration levels at adjacent
receptors. SEIR 2 Table 4.11-4 shows a distance of 45 feet from the closest sensitive
receptor to the reconfigured parking facility. Construction activities associated with the
Project Modifications (new access road) would occur immediately adjacent to the
residential property that abuts Freedom Park; the residence is located at a distance of less
than 45 feet and should be analyzed accordingly.
Similar to the construction impacts discussion, the long-term impacts discussion identifies
the closest noise-sensitive receptor as 60 feet. This measurement is to the parking area.
The Draft SEIR 3 should also address the noise associated with the proposed access road
which would be located immediately adjacent to a sensitive receptor.
.
30. No mitigations were proposed for the house adjacent to the new entrance onto
Commercial Street. There will be significant queuing of vehicles exiting the station parking
onto Commercial Street. This will create noise concerns for this residence.
31. The 2013 FEIR (page 3.11-17) states noise control measures when working near
residences would be required, which includes conformance with the noise requirements
of each City. "Limiting construction activities to weekday daytime hours (typically 7 a.m. to
6 p.m.) and employing typical measures for minimizing noise during construction
requirement, combined with the mitigation described in Section 3.11.5, would mitigate
construction impacts to a less than significant level." This is contradictory to the Draft SEIR
3 (Section 3.1.2.3), which states short-term construction impacts from temporary lane
closures and detours "…would be limited by scheduling certain construction activities
during night hours, outside of the AM and PM peak commuting periods, and through the
use of clearly signed detour routes where necessary." The Draft SEIR 3 Noise analysis
does not analyze nighttime construction activities. This inconsistency needs to be
addressed and remedied. If nighttime construction activities will occur, the noise analysis
needs to identify any resulting noise impacts to sensitive receptors. To “inform the public
and responsible officials of the environmental consequences of their decisions before they
are made.” (Laurel Heights Improvement Ass’n v. Regents of the Univ. of Cal. (1993) 6
Cal.4th 1112, 1123.) Again, the Authority must analyze noise impacts and potentially
feasible mitigation measures for the significant nighttime construction noise impacts
April 1, 2022
caused by the Project.
Safety and Security

32. As acknowledged in the Draft SEIR 3 “[t]he relocated and reconfigured parking facility
would be located in a more residential area than previously approved, with adjacent
residential land to the west and south. Therefore, the facility would be located in an area
with a different safety and security setting than what was previously analyzed.” As we had
previously noted, there are safety and security concerns with relocating the parking facility
to the Park & Ride. Specific attention should be provided to the interface between the
Project site, the alley, and the residential uses located south of the alley and that currently
there is a clear line of site across the alley between Monte Vista Avenue and San Dimas
Avenue, as well as visibility from the existing Park & Ride facility. This visibility could be
limited with the introduction of the access road and other improvements, resulting in
security and safety concerns within the alley. The Draft SEIR 3 does not adequately
address safety and security concerns. The Authority is legally required to mitigate or avoid
the significant impacts of the projects it approves whenever it is feasible to do so. (Pub.
Res. Code § 21002.1(b).) “In the case of the adoption of a plan, policy, regulation, or other
public project, mitigation measures can be incorporated into the plan, policy, regulation,
or project design.” (CEQA Guidelines § 15126.4(a)(2).).
33. With the Station Parking being so close to residential properties, the frequency of calls to
law enforcement will increase and the expected response time will be immediate. Draft
SEIR 3 provides no details of how the Gold Line Authority will mitigate these requirements.
This will impact local law enforcement and impact their ability to respond to other calls
through the City. The Draft SEIR 3 must provide a detailed plan for Metro and LASD
Transit Services Bureau response to mitigate impacts to local safety and law enforcement.
SS-4 security mitigations indicates a security plan for LRT operations shall be
implemented but the mitigation measure references surveillance by law enforcement
including local jurisdiction security personnel. Gold Line Authority is proposing the use of
local enforcement without cost mitigations.
Water Quality and Resources

34. The Draft SEIR 3 long-term Impacts discussion states “[t]here would be a decreased
amount of impervious surface compared to the Approved Project since the proposed San
Dimas parking location is a smaller site than the approved location.” This is not an accurate
characterization. The approved location is already impervious and although the acreage
of the parking facility may be reduced with the Project Modifications, the amount of
impervious surface as a result of the Project Modifications would not be decreased. The
Project Modifications would acquire a portion of Freedom Park for an access road,
converting an existing pervious surface to impervious conditions. When an EIR gives
“conflicting signals to decision-makers and the public about the nature and scope of the
activity being proposed,” the courts have found it “fundamentally inadequate and
misleading.” (San Joaquin Raptor Rescue Center v. County of Merced, 149 Cal.App.4th
645, 655-56.).
General Comments
35. The station parking design standards require the parking lot to meet local landscape
design standards. The configuration of the parking lot as proposed does not comply with
April 1, 2022
City Code requirements. The increased landscaping requirements will result in the
elimination of several parking stalls. This combined with the ADA requirements which were
also not addressed will likely reduce the number of stalls available to less than 289.
36. The project calls for trees to be relocated. What trees will be relocated and to what
location?
37. Construction emissions will now be closer to residential homes than previous.
Construction parking will impact the neighborhood and mitigation was not addressed.
The Draft SEIR 3’s lackluster approach to impact analysis and mitigation violates CEQA. A lead
agency cannot simply conclude that an impact is significant and unavoidable and move on. A
conclusion of residual significance does not excuse the agency from (1) performing a thorough
evaluation and description of the impact and its severity before and after mitigation, and (2)
proposing all feasible mitigation to “substantially lessen the significant environmental effect.”
(CEQA Guidelines § 15091(a)(1); see also id. § 15126.2(b) (requiring an EIR to discuss “any
significant impacts, including those which can be mitigated but not reduced to a level of
insignificance” (emphasis added).) Consequently, the Authority cannot legally certify the Draft
SEIR 3 until it satisfies all the above CEQA requirements and, instead, it must consider further
feasible mitigation measures in a revised and recirculated Draft SEIR 3.
Sincerely,
Chris Constantin Jeff Malawy

City Manager City Attorney
Cc: City Council

Henry K. Noh, Director of Community Development
Shari Garwick, Director of Public Works
Attachment:
City of San Dimas NOP Letter, November 17, 2021
Denis Bertone
Henry K. Noh
City Manager
Recreation
Brad McKinney
Jeff Malawy
November 17, 2021

Subject: Comments on Notice of Preparation of Draft Supplemental EIR (DSEIR) Metro Gold Line
Extension Phase 2B – San Dimas Parking Lot Relocation
Dear Ms. Buch:
The City of San Dimas appreciates the opportunity to provide comments on the referenced DSEIR. The
City of San Dimas continues to support the completion of the Gold Line Foothill Extension to Montclair,
as long as the City’s and our community’s concerns are fully mitigated to our satisfaction. The following
comments are based on the Notice of Preparation of a Draft Supplemental Environmental Impact Report
received on October 15, 2021. The DSEIR needs to address and fully mitigate the following potential
impacts regarding the proposed relocation of the San Dimas Gold Line Station parking lot to the existing
Park and Ride lot.

1. The City is extremely concerned about the impact to the surrounding residents and downtown
businesses caused by the reduction in number of parking spaces provided in the proposed relocated
station parking design. The original 2013 FEIR requirement of 450 parking spaces was reduced to 289
parking spaces (Supplemental EIR, 2021) due to implementing Metro’s Supportive Transit Parking
Program Management Plan constrained parking model. Relocating the Gold Line Station parking into
the existing Park and Ride location would result in the loss of an additional 175 valuable parking spaces
(existing 175 Park and Ride parking spaces not being reconstructed or accounted for with the Gold
Line parking relocation to the Park and Ride) in the heart of our downtown. Such a reduction in the
number of parking spaces in downtown would negatively impact our downtown business community.
Under parking the station and reducing valuable downtown parking capacity will result in impacts to
private property, as well as, Municipal parking lots and public streets in the vicinity of the Gold Line
station parking lot. These impacts and mitigation measures must be evaluated and assessed as a part
of the Draft SEIR and clearly indicate how the project will not have an impact on the City’s streets,
residential neighborhoods, and nearby businesses.
NOP Draft SEIR Metro Gold Line Extension – San Dimas Parking Lot Relocation 2
November 17, 2021
2. A Parking Management Study is needed to fully address overflow parking onto adjacent commercial
and residential neighborhoods. The study must include a discussion related to the anticipated impacts
and mitigation measures (i.e. required parking enforcement, fully funding additional City staffing and
costs related to mitigating parking related impacts associated with the Gold Line, etc.) to offset the
impacts of the overflow parking and traffic created by the Gold Line Station.
3. Currently, the existing Park and Ride is developed with 175 parking spaces, in addition to a dedicated
bus stop and bus shelter for Foothill Transit which supports regional transportation. The City is
concerned about the potential impact to the Foothill Transit bus services and the need to provide
additional bus patron parking, in addition to the approximately proposed 289 parking spaces to only
accommodate the future Gold Line Station patrons. The bus service provides a critical mode of public
transportation and the proposed alternative would potentially eliminate this mass transit alternative.
In the 2013 FEIR, the Gold Line Authority (GLA) committed to conduct a Bus Interface Study by
completion of the Design Phase. To date, no study has been completed. This is an area of concern for
the City given the change to the project scope and the elimination of Foothill Transit within the
existing City Park and Ride Facility. This study will require Foothill Transit to reroute or eliminate
valuable mass transit services. The GLA should complete this study without further delay.
4. The pedestrian routes from the relocated Gold Line parking within the proposed Park and Ride lot
location need to be fully analyzed. The previous Gold Line parking location (City Yard) provided a
direct and safe pedestrian pathway that went underneath the light rail tracks to the station. The
relocated parking lot within the Park and Ride will result in a pedestrian conflict at San Dimas Avenue
and will result in significant vehicular traffic impacts on north and south bound San Dimas Avenue, in
addition to east and west bound traffic on Bonita Avenue and Arrow Highway. This will be the result
of the number of peak hour pedestrian traffic crossing at San Dimas Avenue, in addition to the number
of train crossing signals that are activated approximately twice (trains travelling east and west bound)
every 6 minutes. Mitigation needs to be provided to prevent pedestrians from jaywalking across San
Dimas Avenue and the longer traffic delays from the number of pedestrian crosswalk signals and the
number of train signals disrupting the vehicular traffic movement along San Dimas Avenue.
Studies need to be conducted to fully analyze the impact to this crossing that simulate and evaluate
the traffic impacts on San Dimas Avenue, in addition to the pedestrian safety and liability due to the
increase in pedestrian crossing along this crossing intersection.
5. The proposed Gold Line parking relocation to the Park and Ride will result in an increase of traffic
volumes within existing quiet single-family residential neighborhoods along Railway Street and
Commercial Street. Therefore, traffic calming mitigation measures need to be fully analyzed that will
fully mitigate and divert this traffic away from these residential neighborhood streets. These
mitigation measures could include, but are not limited to:
a. Closure of the Monte Vista ingress/egress of Park and Ride;

b. Traffic calming mitigation measures on Railway and Commercial Streets, such as installation
of cul-de-sac(s), speed humps, or other potential traffic calming mitigation measures;
c. Consider an additional vehicular ingress/egress along San Dimas Avenue to reduce traffic
related impacts to the surrounding residential neighborhoods.
November 17, 2021
d. The acquisition of Successor Agency properties on Cataract and utilization of Metro Gold
Line’s right-of-way south of the rail lines as a bypass to Railway and Commercial reducing
traffic loads on those residential streets.
6. Mitigation measures shall be implemented to reduce the vehicular queuing exiting the proposed
relocated Gold Line parking lot.
7. All ADA pedestrian pathway concerns within the proposed relocated parking lot and the surrounding
rights-of-way shall be fully analyzed and mitigated.
Tree Preservation, Landscaping and Water Quality

8. The City of San Dimas is a Tree USA City and preservation of the mature trees is a priority. Any City-
owned trees proposed for removal shall be evaluated per City’s Tree Preservation Ordinance per
Chapter 13.36. A Tree Removal Permit Application will be required to be submitted to the Parks and
Recreation Department for review.
9. The proposed station and parking lot landscape and irrigation shall comply with the City’s Water
Efficient Landscapes Chapter 18.14.
10. The City is concerned with the thermal effects of the parking lot as proposed and its contribution to
an urban heat island. The project must incorporate large shade trees, vegetation/landscape and
lighter colored pavement to mitigate these impacts.
11. The proposed station and parking lot shall provide Low Impact Development (LID) proposal to comply
with City, County and State water quality requirements.

12. The air quality impacts to surrounding residents shall be fully analyzed and mitigated (i.e. upgrading
residential air filtration systems and enhancing First/Last Mile improvements). The proximity of the
relocated Gold Line station parking lot to the existing Park and Ride will result in an increase of traffic
to the surrounding residential neighborhoods and if proper parking is not provided, these future riders
will circulate and park within surrounding private and public parking lots or along residential or
commercial streets. The result of these vehicles driving around looking for parking will increase
emissions/air pollutions and therefore increase Green House Gas (GHG) Emissions.
13. Revised and updated estimates to circulation, land use, ridership and traffic/parking are necessary to
prepare an appropriate analysis of the environmental effects on air quality with the revised project.
Utilizing the FEIR 2013 data will result in an inadequate analysis especially in light of the availability of
new ridership data and changes in Metro policies regarding parking, parking fees and First/Last Mile
improvements.
14. In this regard the Gold Line Authority (GLA) should also evaluate, quantify and mitigate the effects of
greenhouse gas (GHG) emissions as part of the overall air quality assessment. This topic was not
clearly addressed in the 2013 FEIR.
Noise and Vibration

15. The impact to the surrounding residences from the additional traffic related noise shall be fully
mitigated including but not limited to:
November 17, 2021
a. Construction of new sound walls; and

b. Retrofitting all surrounding affected residence windows with dual pane glass and other
treatments to reduce the noise impact with special emphasis to residences experiencing the
highest traffic and noise flows.
Public Service/Safety Concerns

16. There are safety and security concerns by relocating the Gold Line parking to the existing Park and
Ride due to it being surrounded by and in close proximity to single-family residences. There is some
evidence that terminus or near-terminus stations are affected negatively by increased criminal
activity. Such impacts have been evident with the opening of the Gold Line Phase 2B project.
Mitigation measures need to be incorporated to address these concerns including but not limited to:
a. Funding and providing law enforcement presence, preferably a new satellite law enforcement
office located within the new parking lot;
b. Installation of camera systems in all parking facilities and use of security software which is
compatible with local law enforcement needs and enhanced ability for cameras to pan, tilt,
zoom and record, providing clear, high quality observation during night and day, as well as
providing needed hardware and viewing capability at the local law enforcement offices; and
c. Installation of city approved parking lot and alley lighting that is shielded and does not spill
over or impact surrounding residences.

17. The impact to the existing Freedom Park by reducing the parkland area and removing existing
mature trees and landscaping in order to facilitate the construction of new vehicular ingress/egress
shall be fully mitigated.
a. Installing and maintaining adequate camera systems as specified in 16b to provide for
observation and response to Freedom Park as this location will be unduly impacted by
activity coming from the Park and Ride.
Land Use
18. The proposed project relocation will affect surrounding land uses especially as they relate to both
traffic, parking, air quality, noise and safety impacts. There is clear evidence that surrounding land
uses are severely impacted when station parking and access are inadequate or poorly designed. These
impacts can severely affect nearby parking facilities, businesses and residences.
Furthermore, the State legislature is mandating major land use changes around transit stations in both
adopted and anticipated legislation. These changes in growth are induced by and directly related to
the station location. These changes are intended to supersede existing zoning resulting in a growth
inducing impact not considered at all by any of the EIRs for the project. These changes likely render
much of the traffic and related analysis invalid.
Economic
19. Relocating the Gold Line parking to the Park and Ride will negatively impact the heart of our
downtown businesses by losing 175 valuable parking spaces. Due to this loss of parking, this not
only effects the current businesses and their economic vitality but will affect the economics and
viability of the future expansion and development of the new San Dimas Downtown that the City is
November 17, 2021
currently in the process of generating a new Specific Plan for.
20. The proposed Park and Ride parking lot site plan eliminates and negatively impacts the existing Feed
and Grain business (located within the barn at 150 S. Monte Vista) by eliminating their ability to use
the existing Park and Ride lot to offload merchandise. The impact to this business shall be fully
mitigated.
21. Analyze the property value impacts to the surrounding residential and commercial uses with the
relocation of the Gold Line parking to the Park and Ride lot.
22. The elimination of the Park and Ride lot used for bus parking, would negatively impact the City’s
Proposition C funds by reducing the amount of funds the City receives and which can be utilized to
support regional transportation improvements. This impact shall be fully mitigated.
The City of San Dimas looks forward to working cooperatively to address these major issues as part of the
revised project in order to maximize the benefits for Metro, the GLA, the surrounding residents,
businesses and property owners. You are welcome to contact the City for assistance or further explanation
of any of these comments.
Sincerely,
Henry K. Noh
Director of Community Development
Cc: City Council

Chris Constantin, City Manager
Jeff Malawy, City Attorney
EXHIBIT “C”
EXHIBIT “D”
City Council Director of Administrative
Emmett Badar, Mayor Services
John Ebiner, Mayor Pro Tem - District 3 Michael O’Brien
Ryan A. Vienna - District 4
Eric Weber - District 1 Director of Community
Eric Nakano - District 2 Development
Henry K. Noh
City Manager
Assistant City Manager Recreation
Brad McKinney Scott Wasserman
City Attorney Director of Public Works
Jeff Malawy Shari Garwick
July 26, 2022

Subject: Comments on Final Supplemental EIR 3 (FSEIR3) Metro Gold Line Foothill
Extension Phase 2B – Evaluating Relocation of the San Dimas Parking Facility
Dear Ms. Buch:
The City of San Dimas (“City”) is in receipt of Metro’s Foothill Gold Line Supplemental EIR 3 -
Response to City Comments dated July 13, 2022. The City appreciates the response; however,
the City continues to have major concerns with the relocation of the parking facility from the City
Yard to the proposed Park and Ride locations, as several of the potential impacts raised by the
City were not adequately addressed. These concerns have been raised in previous letters
submitted to Metro Gold Line Foothill Extension Construction Authority (the “Authority”) on
November 17, 2021 and on April 1, 2022. Please see below for outstanding concerns.
The City has been proceeding in good faith with the Authority on this proposed location which
would result in savings and efficiencies for the Authority as well as alleviate significant concern
with the Walnut Avenue site. While it may be the Authority’s intent to consider the evaluation and
mitigations requested by the City in any subsequent action or property negotiation, until this point,
the City has not received affirmative agreement on its communications of November 17, 2021
and April 1, 2022. This concerns the City as it is not in keeping with the good faith entered into
when this location was initially contemplated.
The Authority can address most of the items identified by the City, can consider and accommodate
the impact of removing the existing 175 parking spaces in the existing Park and Ride, and
ensuring that the interests in protecting the surrounding neighborhood and businesses has
primacy in the Authority and City approach to facilitating a Metro Station in San Dimas. Such is
a mutual interest as this proposed location avoids costly and time-delaying action to acquire the
multiple private and public properties at the Walnut site, removes the necessity and cost for
Response to Foothill Gold Line Final SEIR3 – Relocation of the San Dimas Parking Facility
San Dimas, CA 91733 2
July 26, 2022
demolishing multiple structures, and most importantly, demonstrates the good faith intended when
this location was initially considered.
The City requests the Authority Board delay the certification action, direct Authority staff to work
with the City to address the appropriate mitigations for this project, and to continue the good faith
efforts undertaken by the Authority and City. Absent working together on this mutually beneficial
approach, the City would be left with only adversarial approaches to protect its rights and interests
in this process.
Allgemein
Several of the responses to comments reference revised language in sections of the Draft SEIR
3 and additional analysis to address the comments. However, these additional documents were
not made available to the City when the Responses to Comments to the Draft SEIR 3 were
provided by the Authority on July 14, 2022. Further, when accessing the Foothill Gold Line official
website, as late as July 21, 2022 at approximately 8:00 AM (see attached), the Final SEIR 3 and
associated documents were not available. The City was notified of the availability of the 2022
Final SEIR 3 by the Authority on July 21, 2022 at 2:53 PM, and that the Authority will be
considering certification of the Final SEIR 3 and approval of the Project Modifications on July 27,
2022. The additional analyses and revisions to the Draft SEIR are a critical component of the
responses to comments. To receive this information less than four business days before its
consideration by the Authority is not adequate time for the City to thoroughly review. As evidenced
in the City’s comment letter regarding the Notice of Preparation of the Draft SEIR 3 dated
November 17, 2021 and the City’s comment letter regarding the Draft SEIR3 on April 1, 2022, the
City has raised significant concerns about the relocation of the parking facilities from the City Yard
to the proposed Park & Ride location on the City and its community which needed to be fully
considered, analyzed, and addressed.
The Final SEIR 3 states that a letter of intent between the Authority and City was approved on
June 17, 2021. Our understanding is that the intent of the letter was to explore the feasibility of
relocating the project’s parking facility to the City owned Park and Ride instead of the City Yard
parcel as designated. While the Final SEIR3 tries to find a workable solution to mitigate the traffic
impact to surrounding community, it fails to adequately address several areas including loss of
existing parking.
Relative to the loss of parking, the City has significant concerns regarding the reduction in the
number of parking spaces in the relocated parking facility. The Authority states that the existing
parking would be redeveloped to accommodate the same number of parking spaces, i.e., a total
number of 289 parking spaces for LRT commuters, however the Final SEIR3 fails to adequately
address the loss or replacement of the existing 175 parking spaces currently available to bus
commuters, local businesses, community, and visitors. This permanent loss of existing parking is
quite detrimental to the community, especially the downtown area.
The significance of the relocation and its perpetual impact to the adjoining residential
neighborhood, to businesses and their patrons – as well as to the community at large – would be
very adverse and negatively impact the City’s downtown and the surrounding area.
July 26, 2022
Response to Gold Line’s Comment 5-3
New text provided in the Final SEIR 3 Project Description describes the new access road as
including two-lanes, one in each direction, to allow vehicles to turn right into the parking facility
from Commercial Street and left or right when exiting onto Commercial Street. Will vehicles
eastbound on Commercial Street be prohibited from making a left turn into the parking facility? If
not, the Project Description seems to deliberately omit the fact that vehicles can turn left from
Commercial Street into the parking facility (essentially driving through the residential
neighborhood to access the parking lot).
The new text also states the Construction Authority “anticipates” prohibition of right turns from the
parking lot westbound onto the alleyway via signage and a bulb out on the curb. What would be
the circumstances where this would not be prohibited? The alley provides access to the garages
of residences fronting onto Commercial Street and parking lot patrons potentially accessing the
alleyway would increase the number of vehicles in the alleyway and the potential for vehicle
conflicts; this is a significant safety concern.
First/last mile plan around the station is quite essential for improving access to and from the
station for a wider breadth of people which ultimately leads to better catchment for transit
ridership. The availability of a pedestrian connection to the station from Walnut Avenue is
invaluable to the community residing in this part of the City. With a wider right-of-way (100 feet),
the Authority should consider constructing a pathway within the northerly or southerly right-of-way
as part of the project. This will provide a direct connection to the station for residents of all ages
and abilities from this part of town.
The City may have engaged with a developer to utilize Parcels 8390-021-915 and 8390-021-916
as part of possible development; however, access rights for any vehicle can be reserved for
access to the Authority’s 50 feet wide surplus right-of-way between Monte Vista Avenue and
Cataract Avenue. Reserving access rights thru these parcels still does not negate what is
indicated by the letter of intent between the Authority and the City to secure all CEQA approval
necessary for use of the parcels. Further, the Authority’s response fails to recognize that in the
City’s June 8, 2021 action taken to approve the Letter of Intent included the two parcels specified
and for which were intended to be considered in mitigating the impacts of this proposed project.
The City’s developer had agreed to the City negotiating with the Authority for use of these parcels,
and the City retains full control to remove these properties when determined beneficial to alleviate
impacts of the proposed project on the surrounding neighborhoods. To remove these two parcels
from consideration and environmental analysis when included in the Letter of Intent would be a
material deficiency in the analysis, implementation of the Letter of Intent, and most importantly,
removes a potential option to mitigate impacts to the neighborhood which were fundamental to
the City’s intent with this proposed location.
July 26, 2022
Refer to Comment 5-7.
Refer to Comment 5-7.
Response to Gold Line’s Comment 5-9 and 5-10
The City has expressed significant concerns regarding the reduction in the number of parking
spaces in the relocated parking facility. Comment 5-10 states that the existing parking would be
redeveloped to accommodate the same number of parking spaces; i.e., a total number of 289
parking spaces for LRT commuters. How does the Authority plan to replace the loss of the existing
175 parking spaces currently available to bus commuters, local businesses, community and
visitors? The loss of existing parking is quite detrimental to the community.
With good faith and in a spirit of cooperation, the Authority, must recognize this loss and work
with the City to construct a new parking lot potentially within its surplus 50-foot right-of-way to
mitigate and reduce the parking impact. Availability of access rights (from city parcels 8390 -021-
915 and 8390-021-916) and connectivity and conversion of the surplus right-of-way to parking
and would replace loss of some parking and provide merchants and visitors connectivity to and
from downtown.
The Gold Line is operational 7 days a week from approximately 4:00 am to just past midnight.
Based on the LRT’s stated schedule, and relocation of the Gold Line Station’s proposed parking
with its dedicated 289 parking spaces for LRT commuters, when is the shared parking available
for the general public?
It’s paramount and vital that provision be made to construct/provide parking as part of project
modification now where possible rather than responding with comments like “City will be
compensated for the parking lot by the Authority.” Where is the spirit of cooperation and mutually
working together to solve problems and permanent impacts caused by the displacement of 175
parking in the residential neighborhood, businesses, and community at large?
It’s inconceivable to keep stating that in accordance with SB 743, CEQA does not qualify parking
in an environmental impact study. The City does understand and asserts that during
reconstruction of the Park and Ride, circulation and parking will be temporarily impacted.
However, this does not address the long-term impact from the loss of 175 parking spaces
dedicated to the bus commuters, merchants, residents, and visitors. This loss of parking is not
acceptable to the community and the City.
July 26, 2022
The Authority states that “the traffic analysis results indicate that LOS on San Dimas Avenue will
be acceptable which indicates that drivers will reasonably be expected to use San Dimas Avenue
(and major crossing streets like Bonita Avenue and Arrow Highway) without cutting through
neighborhood streets. Therefore, additional analysis on side streets is not deemed necessary.”
The City strongly disagrees with this assessment and findings. The City has asserted in both their
response to the NOP of the draft SEIR dated November 17, 2021, and their comments to the
Draft SEIR (3) dated April 1st 2022, that they are committed to retaining to restrict any commuter
traffic from entering or exiting at Railway Street/Monte Vista Avenue/Park and Ride but allowing
access only for emergency vehicles or for use in the event of emergency.
Based on the statement “without cutting through neighborhood streets”, then Monte Vista Avenue
access should be closed since the only way to the access is to go through the neighborhood.
For example, in order to mitigate traffic impacts prior to the closure of Monte Vista Avenue at the
railroad crossing, traffic exiting the Park and Ride at Monte Vista Avenue was channelized by
means of a concrete median island to head north (turn right) toward Bonita Avenue. The
channelization permanently prevented traffic from either entering or exiting at Railway Street. It’s
critical to understand that this permanent closure will substantially impact the traffic on Railway
Street. In reality, all traffic coming from the west and south sides of the City, and from the SR-57
Freeway exiting at Covina Boulevard and continuing north on Cataract Avenue, will turn right onto
Railway Street to enter the parking lot.
For the intersection of San Dimas Avenue/Commercial Street, the LOS analysis shows a
favorable LOS A with ample capacity. Therefore, the traffic flows and impacts should be
reassessed to have all traffic enter the relocated Park and Ride facility only via the new San Dimas
Avenue/Commercial Street driveway through Freedom Park.
The queuing analysis that we have reviewed only shows queuing for the unsignalized
intersections. Please provide the analysis showing the queuing for all locations.
The Authority states that 95% of the queues for all approaches to the intersection are expected
to be accommodated within the existing available storage; therefore, the vehicle queue at the San
Dimas Avenue/Commercial Street intersection is not anticipated to cause potential design
hazards. The City strongly disagrees with this assessment, especially when considering that all
traffic entering and exiting the Park and Ride will be via the San Dimas Avenue/Commercial Street
driveway through Freedom Park rather than from Monte Vista Avenue. The City also has concerns
that the eastbound queue will block the ingress/egress of the residential site on the southwest
corner of the intersection. The City recommends two lanes eastbound (one shared thru/left turn
lane and one right turn lane) on Commercial Street along with a KEEP CLEAR pavement legend
and signage to prevent any queue from blocking access to the residential site.
July 26, 2022
The City requests that the Authority reevaluate and re-model the traffic analysis for the delay,
queuing and available storage on San Dimas Avenue and Commercial Street.
Please clarify the statement that the Authority will work with the City to identify and fund traffic
controls on Commercial Street and Monte Vista Avenue. Is it warranted in order to reduce
potential vehicle, pedestrian, and bicycle conflicts? How would you justify a possible unwarranted
traffic signal within this short block of the residential neighborhood?
The comment states that this land could be developed to include a shared subterranean parking
facility incorporated into a TOD. Why can’t this project accommodate a dedicated subterranean
parking for the City to address the loss of 175 parking spaces as a result of relocated parking for
Metro Gold Line LRT station? The construction of dedicated subterranean parking would resolve
all long-term environmental issues related to parking, circulation, and neighborhood parking
overflows.
Response to Gold Line’s Comments 5-13, 5-18, 5-20, 5-21
Although CEQA does not consider the adequacy of parking or potential impacts on parking, CEQA
does require a review of potential secondary effects on the physical environment. As noted,
construction activities, including the removal of parking spaces, will reduce the number of
available Park & Ride spaces. This will result in potential impacts on the circulation system as
vehicles would be forced to drive through the residential neighborhoods to find parking on
adjacent residential streets, in proximity to downtown. The responses state “Additional
consolidated information related to the analysis of secondary effects is provided in Appendix A
Attachment C of the Final SEIR 3”. However, this additional information does not address this
issue. This response does not address the potential secondary effects on the physical
environment, namely the impacts on adjacent residential neighborhoods associated with the loss
of parking spaces during construction activities. Vehicles who would have previously used the
Park & Ride lot will now be rerouted to the adjacent residential neighborhoods to find parking,
increasing traffic within these neighborhoods and potential conflicts with pedestrians. The
response references the Parking Management Plans (PMPs), which would focus on parking once
operational, but it does not address the immediate impacts.
Response to Gold Line’s Comment 5-22 to 5-24
Current Gold Line parking demand at existing stations is often at capacity during the weekday
early morning hours. It is expected that spillover parking will occur and impact the adjacent
residential community. The Parking Management Plan (PMP) should be addressed within the
traffic analysis.
July 26, 2022
See response to Comment 5-15
The assessment that the effect of traffic on residential roadways surrounding the parking facility
was based on the location of the Park and Ride facility on San Dimas Avenue with access points
on Monte Vista Avenue and Commercial Street near San Dimas Avenue. To state that it is a
standard traffic engineering premise that drivers will use a higher classification street like San
Dimas Avenue is nonsensical, especially when considering that a free parking lot is the
destination point for commuters coming from all directions.
It’s also vital to understand that the permanent closure to traffic turning north from the parking lot
will substantially impact traffic on Railway Street. In fact, all traffic coming from the west and south
sides of City, and the SR-57 Freeway exiting at Covina Boulevard and continuing north on
Cataract Avenue, will likely turn right onto Railway Street to enter the parking lot. To mitigate this
traffic impact in the neighborhood prior to closure, traffic exiting the Park and Ride at Monte Vista
Avenue was channelized by means of a concrete median island to go north (turn right) toward
Bonita Avenue. The channelization permanently prevented traffic from entering or exiting on
Railway Street.
As mentioned in both the response to NOP of draft SEIR dated November 17, 2021, and the
comments to Draft SEIR3 dated April 1, 2022, the City is committed to retaining and restricting
any commuter traffic from entering or exiting at Railway Street/Monte Vista Avenue/Park and
Ride. The traffic flows and impact should be reassessed to prevent traffic from entering or exiting
through Railway by installing traffic mitigation such as a cul-de-sac.
The response states the Construction Authority is proposing enhancements to bus stop facilities,
including expanding and rebuilding the bus shelters at the two bus stops on Bonita Avenue, just
east of San Dimas Avenue. It then contradicts this statement, saying “improvements to bus stops
are not included as part of the Project Modifications and therefore not discussed in the SEIR”.
Where are these improvements discussed? CEQA Guidelines define a project under CEQA as
“the whole of the action” that may result either directly or indirectly in physical changes to the
environment. The Project Modifications assessed in the Draft SEIR 3 eliminates buses in the
parking lot, thereby resulting in the need to provide alternative locations for buses. To account for
this change associated with the Project Modifications, the Authority seems to be proposing
enhancements to bus stop facilities. These improvements need to be considered as part of the
Draft SEIR 3, as they are directly related to the Project Modifications and elimination of buses in
the station parking lot, as had been previously considered and analyzed in approved SEIR 2. Any
impact on circulation or creation of delays in the intersection at Bonita/San Dimas Ave needs to
be analyzed to determine the nature and extent of the enhancements.
The City recognizes that the bus drop off cannot be accommodated on site due to the limitation
of the Park and Ride lot size which was redesigned to accommodate 289 parking spaces. Instead
July 26, 2022
of enhancing the existing bus stop to accommodate the future transit service, the Authority should
provide an alternate off street location for a bus stop and associated parking. A bus stop and
parking lot provides for the cross connection with other lines at LRT and allows for possible
staging/waiting for buses.
Secondly, the addition of enhanced bus stops/parking on Bonita Avenue east of San Dimas
Avenue will likely compound and increase the potential backup on Bonita Avenue resulting in
additional delays. This is in addition to any backup and delays caused by the freight train crossing
Cataract Avenue. In fact, to mitigate and possibly overcome delays caused by the freight train,
the existing striping for east Bonita Avenue at San Dimas Avenue was changed from left/thru/right
turn to left/thru/thru lanes. Therefore, additional bus stop/parking will result in increased delays.
In addition, northbound right-turn traffic will be delayed/restricted when buses are parked or
staging at the southeast corner of the intersection. Similarly, buses staged on the northwest
corner of Bonita Avenue/San Dimas Avenue will also cause delays and impact traffic flows.
Further, any traffic flow delays on northbound San Dimas Avenue will impact the crossing gate
and further exacerbate the traffic flow and congestion at the most critical area of the crossing.
To minimize the impact of additional traffic delays and congestion at the intersection of San Dimas
and Bonita Avenue, the City is not supportive or in agreement with the Authority’s proposal that
would result in an increase in bus frequency at the Bonita/San Dimas Ave bus stops. Additionally,
while SEIR 3 mentions modifications to these bus stops, no details were provided.
Again, this response states the Construction Authority is proposing enhancements to bus stop
facilities; however, proposed improvements, specifically to bus stops on Bonita Avenue, are not
analyzed as part of the Draft SEIR 3.
With the Authority affirming its commitment to contribute funding if a signal is warranted at the
San Dimas Avenue/Second Street intersection, how will the Authority fund or have a mechanism
to fund the costs when it’s disbanded after completion of Phase 2B to Pomona?
Secondly, with City’s concern about additional delay being experienced, particularly from
southbound San Dimas Avenue north of Bonita Avenue, will that likely initiate driver behavior to
take shortcuts through the residential streets which are not designed for cut-through traffic in order
to avoid delays at Bonita Avenue? It would be prudent to create a baseline by assessing traffic
flows through the neighborhoods upon completing improvements at Bonita Avenue. This baseline
in traffic counts and traffic flows will aid in addressing possible cut-through traffic issues in the
future, as well as aiding with the determination and assessment of a future signal at San Dimas
Avenue and Second Street.
See response to Comment 5-26.
July 26, 2022
As mentioned previously, in order to reduce and mitigate any traffic exiting on Monte Vista
Avenue, traffic was channelized to go north only, thereby restricting any traffic entering or exiting
on Railway Street or Monte Vista Avenue. Since the station will become a destination for a wide
range of commuters using LRT, it’s highly likely that traffic from the west and south sides of the
City will use Cataract Avenue and then Railway Street to enter and exit the Park and Ride.
Therefore, traffic flows and impact should be reassessed and mitigation measures must be
developed to prevent traffic from using Railway to enter the station parking lot.
See response to Comment 5-16.
See response to Comments 5-26 and 5-33.
For the record, Monte Vista Avenue was to be an access point for the existing Park and Ride
facility; however, as previously stated, current traffic exiting the Park and Ride is channeled to go
north or turn right on Monte Vista Avenue to Bonita Avenue and the City wants to retain this
restriction. With an entrance through Monte Vista Avenue at Railway traffic will now enter and exit
the new LRT parking lot on Railway Street, Cataract Avenue, and Monte Vista Avenue. This will
severely impact the quiet neighborhood on a permanent and long-term basis. The City requests
that the Authority reassess the traffic as requested and mitigate impacts as necessary.
See response to comment 5-7,5-9 and 5-10
Response to Gold Line’s Comment 5-37,5-38,5-39.5-40 and 5-41
The City is pleased that the Authority will work to provide signs, design, and construct features
that improve transit patron access to the parking facility while reducing effects and impacts of cut-
through traffic in this quiet residential neighborhood. Traffic enhancements need to be thoroughly
explored in order to make continued access to the LRT parking lot through Monte Vista a viable
option.
See responses to Comments 5-26, 5-33, and 5-35 regarding exiting traffic being restricted at
Monte Vista Avenue. The City requests that the Authority reassess the traffic as requested and
mitigate impacts as necessary.
The City requests that all identified traffic calming measures such as landscaped medians, bulb
outs, traffic restriction and signage, be fully constructed as part of the project modification
July 26, 2022
measures in order to improve parking access for transit patrons which will reduce overflow
impacts and improve the local resident’s daily quality of life.
With the proposed changes to the Park and Ride, more traffic will enter Cataract Avenue from the
south and west sides of the City; however, Cataract Avenue is not a major street and it runs
through a quiet, tree-lined, and older established neighborhood. Hence the need to restrict access
to the LRT parking from Monte Vista Avenue. See response to comment 5-26.
Response to Gold Line’s Comments 5-50, 5-51, 5-52, 5-53, 5-56, 5-87
This response does not fully address the comment. The responses discuss aesthetic impacts
associated with construction activities. However, the Draft SEIR 3 analysis does not take into
consideration the long-term impacts associated with removal of a portion of Freedom Park and
introduction of the new access road. Although the area planned for the new roadway area does
not contain park amenities, it does provide open green space with landscaping and mature trees
that serve as passive park space for the community and provides visual relief from the surrounding
urban environment. Residential properties south of Commercial Street directly face Freedom Park
and experience the landscaping, greenspace and large mature trees. Views of this open green
space would be substantially altered with the Project Modifications. Replacement of a portion of
the park with an improved access roadway is not consistent with the existing use – a park and
greenspace. The response mischaracterizes the park and its benefits to the surrounding
community and does not adequately account for and analyze the loss of passive park space within
the community.
Similarly, the response does not address the direct impact associated with vehicle headlights
exiting the driveway and illuminating the windows of the residences directly to the south of the
driveway, that front onto Commercial Street. The response states the lighting will be buffered by
proposed wall/fence and landscaping and existing trees and vegetation that border Freedom
Park. However, none of these will occur at the driveway access and Commercial Street. The multi-
family residential uses fronting Commercial Street are located within a residential portion of the
Downtown area and are not located along a roadway with extensive businesses or traffic. Again,
this response mischaracterizes the existing environmental setting specific to this area and in
relation to the proposed access road. Headlights from vehicles accessing the current Park & Ride
lot and businesses in the Downtown do not, under existing conditions, shine directly into the
residential properties directly south of Commercial Street across from Freedom Park. This would
be a condition directly resulting from the proposed Project Modifications. Lights will continually
shine into the windows of the residences directly across Commercial Street in the evening hours
from parking patrons exiting the site at this location. This impact has not been adequately
addressed in the Draft SEIR 3 or the responses to comments.
The current Park and Ride is surrounded by mature trees and dense landscaping around the
perimeter which reduces the impact of headlights shining into residents’ homes during the
evenings. Currently, the operation of the existing bus lines generally ends about 6:00 pm;
July 26, 2022
thereafter, the parking lot is quiet and virtually empty. Because the LRT will be operational from
4:00 am to past midnight 7 days a week, the impact of headlights to the residents will be more
severe and prolonged. Additional mitigations are be needed to block the impact of the lights.
It’s assuring to know that the Park and Ride facility will be designed to Metro Rail Design criteria
and that the Authority will comply with local landscape codes to the extent practicable. Similarly,
on good faith and as a collaborative City partner, why doesn’t the Authority work with the City’s
parking standards and codes for parking within the town core to the extent practicable?
This Comment states that the Authority will prepare a Parking Management Plan (PMP). What is
the status of it? How does the plan address or mitigate parking issues? The City needs to see
this plan before it can comment on this matter!
The statement that replacement of bus service with LRT service is considered a transit
enhancement is self-serving. On the contrary, bus service is an alternate mode of transportation
which is available to both the community and commuters.
See response comment 5-16
The Authority adamantly states that it is not subject to local ordinances, yet it has opted to
voluntarily comply with local tree protection to the extent possible. Similarly, in good faith, working
in partnership with the City during the construction of the much-needed LRT and subsequent
infrastructure improvements is critical.
The Authority should also consider complying with City’s code for parking design standards as
trees are essential for the parking lots. Trees provide shade and transpiration for lower
temperatures, better air quality, improved water quality, slows deterioration of parking lot
pavement and mitigate urban heat islands. The City standards for median islands and perimeter
landscaping buffers would make the new parking lot more attractive and an asset to all parties.
The Authority is encouraged to be more progressive and adopt the City requirements in the design
of the new Park and Ride.
The Final SEIR3 has failed to address the potential impacts related to the relocation of the parking
facility from the City Yard to the proposed Park and Ride parking, as previously raised in the City’s
comment letters dated April 1, 2022, and November 17, 2021. The City understands that while
CEQA does not consider parking or potential impacts on parking, CEQA does require a thorough
review of potential secondary effects that result from the project, which the Final SEIR3 has
July 26, 2022
neglected to do. As such, the Authority’s intent to certify the Final SEIR3 on July 27, 2022 violates
CEQA. All the concerns raised in this and previous City letters must be completely mitigated to
substantially lessen the significant environmental effect.
Sincerely,

Cc: City Council

Attachments:
1. City of San Dimas Draft SEIR Letter, April 1, 2022

2. City of San Dimas NOP Letter, November 17, 2021
3. Foothill Gold Line Website Screenshot
Denis Bertone
Henry K. Noh
City Manager
Recreation
Brad McKinney
Jeff Malawy
April 1, 2022

Subject: Comments on Draft Supplemental EIR (DSEIR) Metro Gold Line Extension
Phase 2B – Evaluating Relocation of the San Dimas Parking Facility
Dear Ms. Buch:
Please allow this letter to serve as the City of San Dimas’ comments on the above-referenced
Draft Supplemental Environmental Impact Report 3 (“Draft SEIR 3”) for the relocation of the San
Dimas parking facility. This letter follows a letter previously submitted to Metro Gold Line Foothill
Extension Construction Authority (the “Authority”) on November 17, 2021 regarding the Notice of
Preparation of the Draft SEIR 3, which raised significant concerns about the relocation of the
parking facility from the City Yard to the proposed Park and Ride location on the City and its
community.
Despite our efforts to work with Metro Gold Line to address the impacts on the City and the
surrounding community, the Draft SEIR 3 does not adequately address our concerns, as detailed
below.
Project Description
1. The Draft SEIR 3 does not accurately describe the proposed Project Modifications. The
Project Description states the “Project Modifications also include roadway improvements
to accommodate vehicles accessing the parking facility along Commercial street”.
However, no specific information regarding these improvements is provided. Further, there
is no mention of the modifications to Freedom Park that are proposed. The Project
Modifications would result in a portion of the existing Freedom Park site to be improved
with an access road. Additionally, the Kiss and Ride Drop Area appears to further
encroach into Freedom Park, which is not disclosed in the Project Description.
Additionally, throughout the Draft SEIR 3, reference is made only to the existing Park &
Ride lot when discussing the Project Modifications. As a result, it is unclear if the Draft
SEIR 3 adequately assesses impacts as they relate to the proposed improvements and
ATTACHMENT 1
April 1, 2022
the conversion of a portion of Freedom Park to an access road.
2. Draft SEIR 3, Page 3-20, Traffic Circulation, incorrectly states the primary entrance for
Park & Ride and Kiss & Ride access will shift from Walnut Avenue to San Dimas Avenue.
Entrances to the parking lot relocation are located on Commercial Street and Monte Vista
Avenue which are residential streets.
3. Draft SEIR 3, Page 4, Project Modifications, incorrectly states that “Access will occur only
from the western side (San Dimas Avenue) of the station platform. No access to the San
Dimas station will be provided from the eastern (Walnut Avenue) side of the platform as a
result of the station parking facility”. Pedestrian access from Walnut Avenue was not
directly connected to the Park and Ride located at the Maintenance Yard. In fact, the only
direct access to the station for Park and Ride patrons under that proposal design layout
was via a subterranean pedestrian tunnel (under the Metro Line track) that connected
directly to the center platform at the station.
While the project modification does not incorporate First/Last Mile Plan around the
relocated station parking, the City feels strongly that the Authority should reinstate the
pedestrian connection to the station from Walnut Avenue as originally planned because
the previous layout was independent of the station parking. In addition, this connectivity
to Walnut Avenue is within the Authority’s construction work areas and should be
constructed as part of the project because it provides access for residents living on the
east side of the station.
4. Figure 1-3 fails to identify the correct parking lot footprint as it does not depict the location
of the proposed access road or exit for the Kiss and Ride Area. In reviewing an EIR, a
paramount consideration is the right of the public to be informed in a manner that enables
it to intelligently weigh the environmental consequences of any contemplated action and
have an appropriate voice in the formulation of any decision. An accurate, stable and finite
project description is required for an informative and legally sufficient EIR. Because of the
importance of the project description, when the project changes significantly, the failure to
prepare a subsequent or supplemental EIR deprives the public, who relied on the EIR, of
information and meaningful participation. (City of San Jose v. Great Oaks Water Co.
(1987) 192 Cal.App.3d 1005, 1017.) The Draft SEIR 3 fails to meet these requirements.
In addition, the Draft SEIR 3 fails to include in its review the two parcels located at the
intersection of Bonita and Cataract, Assessor Parcel Numbers 8390-021-915 and 916. As
indicated by the Letter of Intent between the Authority and the City, these parcels are
included in the new parcels to be acquired and likewise subject to the requirement that
the Authority secure all CEQA approvals necessary for the use of the parcels. The
requirements of CEQA cannot be avoided by piecemeal review, which results from
chopping a large project into many little ones, which cumulatively may have substantial
impact and perhaps disastrous consequences. (Rio Vista Farm Bureau Center v. County
of Solano (1992) 5 Cal.App.4th 351, 370; Environmental Prot. Info. Ctr. v. Cal. Dept. of
Forestry and Fire Prot. (2008) 44 Cal. 4th 459, 503.)
Moreover, failure to purchase and utilize those two parcels for station parking/access is a
violation of the Letter of Intent, as the Letter of Intent requires the parties to “work together
in good faith toward execution of a mutually agreeable purchase and sale agreement” for
those two parcels.
ATTACHMENT 1
April 1, 2022
By failing to include the two parcels on Bonita and Cataract, the Authority is piecemealing
its environmental review of the proposed modification without the legally required
environmental review of the project’s impacts. An inaccurate or incomplete project
description undermines CEQA’s purposes because it thwarts a full analysis of project
impacts, thus minimizing the project’s effects. (City of Santee v. County of San Diego
(1989) 214 Cal.App.3d 1438, 1454; San Joaquin Raptor Rescue Center v. County of
Merced (2007) 149 Cal.App.4th 645, 656.) Thus, when an EIR gives “conflicting signals
to decision-makers and the public about the nature and scope of the activity being
proposed,” the courts have found it “fundamentally inadequate and misleading.” (San
Joaquin Raptor Rescue Center, 149 Cal.App.4th at 655-56.) The Draft SEIR 3 has the
type of truncated project review that CEQA prohibits and creates uncertainty about the
project’s impacts.

In our prior letter, we expressed our significant concern regarding the reduction in the number of
parking spaces in the proposed relocated parking facility, as well as concerns regarding
pedestrian routes and the impact on traffic in the residential neighborhoods in the vicinity of the
proposed parking facility. The Draft SEIR 3 fails to adequately analyze and mitigate these
concerns.
Meaningful analysis of impacts effectuates one of CEQA’s fundamental purposes: To “inform the
public and responsible officials of the environmental consequences of their decisions before they
are made.” (Laurel Heights Improvement Ass’n v. Regents of the Univ. of Cal. (1993) 6 Cal.4th
1112, 1123.) To accomplish this purpose, an EIR must contain facts and analysis, not just an
agency’s bare conclusions. (Citizens of Goleta Valley v. Bd. of Supers. (1990) 52 Cal. 3d 553,
568.) An EIR’s conclusions must be supported by substantial evidence. (Laurel Heights
Improvement Ass’n, 47 Cal.3d at 409.) The Draft SEIR 3 is vague and lacks supporting
documentation to adequately assess Transportation impacts. The items detailed in the City’s
response below address concerns, but the City cannot fully evaluate the Draft SEIR 3 without
additional studies and information that was not provided.
5. The Draft SEIR 3, under Section 3.2.7, Long Term Parking Impact, indicates that no
parking impact will result from the station parking relocation. On the contrary, relocating
the Gold Line Station’s proposed 289 parking spaces to the existing Park and Ride
location would result in the loss of an additional 175 valuable parking spaces (existing
spaces not being accommodated or accounted for with the Gold Line Parking relocation
to the City’s Park and Ride) in the heart of San Dimas’ historic downtown.
This loss of crucial and irreplaceable parking spaces in the downtown area would not only
adversely and negatively affect the downtown businesses, but also impact the community
at large. The City hosts various annual parades, car shows, bike races, as well as the
Memorial Day and Veterans Day observance days at Freedom Park. With the immediate
loss of this daily available critical parking to the community any time of year, where do
these patrons, visitors and attendees park?
The Draft SEIR 3 fails to address the adverse and negative impact on the loss of this
critical and daily available parking and its subsequent affect to the immediate
neighborhood, businesses, community, and community at large.
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As previously mentioned, the Draft SEIR 3 acknowledges that the existing Park & Ride
facility with 175 parking spaces serves as the patron parking for the bus lines, but does
not discuss the removal of the parking spaces during construction. Thus, the short-term
impacts on the circulation system have not been considered. In addition, the Draft SEIR
3 fails to consider the current use of the parking facility by patrons of the Downtown
businesses and the businesses themselves. The Draft SEIR 3 does not adequately
analyze the impacts resulting from the loss of these parking spaces, narrowly relying on
its use by patrons of Foothill Transit only.
In addition, the Draft SEIR 3 does not adequately address the increased traffic on
surrounding residential roadways to access the parking facility, and the Authority’s
conclusion that drivers will typically use major streets is not substantiated. “To facilitate
CEQA’s informational role, an EIR must contain facts and analysis, not just the agency’s
bare conclusions or opinions.” (Habitat & Watershed Caretakers v. City of Santa Cruz
(2013) 213 Cal.App.4th 1277, 1303.) An EIR’s conclusions must be supported by
substantial evidence. (Laurel Heights Improvement Ass’n v. Regents of the Univ. of Cal.
(1988) 47 Cal.3d 376, 409.)
Moreover, there is a potential design hazard related to vehicles queueing at the San Dimas
Avenue/Commercial Street traffic signal, which needs to be fully analyzed and addressed.
The preparation and function of an EIR is to ensure that government officials who decide
to build or approve a project do so with a full understanding of the environmental
consequences. Equally important, the public is assured those consequences have been
taken into account. (Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho
Cordova (2007) 40 Cal.4th 412, 449; Citizens Against Airport Pollution v. City of San Jose,
supra, 227 Cal.App.4th at 796.)
Additionally, traffic delays with the proposed relocation of the parking facility, as well as
deficiencies and inaccuracies related to pedestrian access need to be analyzed and
mitigated. CEQA requires the Authority to evaluate the project’s traffic safety impacts on
pedestrians, cyclists, and transit riders. (See City of Maywood v. Los Angeles Unified Sch.
Dist. (2012) 208 Cal. App. 4th 362, 392-95 (holding EIR was inadequate because it failed
to analyze and mitigate project impacts on pedestrians).)
6. The loss of an approximately 2.25-acre Park and Ride property in the City’s downtown
would also result in the City losing its potential to develop this land for housing needs or
TOD. A development that provides a balance of both community parking and housing
provides more vibrancy to the downtown. Quite likely, based on current development
proposals, this property may be developed with up to 52 residential units with ample
parking available for the community.
7. The Authority states that, based on coordinated internal discussions between them and
Foothill Transit, commuter bus lines 492 and 499 would not operate to downtown Los
Angeles once Phase 2B is completed and operational to Pomona.
a. The planned projected completion of Phase 2B is estimated to be mid-2025, plus

another 6 months or more for Metro to render the service fully operational (which
is approximately 4 years away). In the meantime, where do patrons of the
community park or get picked up during the construction of the station parking?
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Has the Authority made any parking provisions for these commuters during this
interim period as part of so-called coordinated arrangement with Foothill Transit?
What are the short-term impacts on the circulation system associated with vehicles
that currently utilize the San Dimas Park & Ride facility being diverted to a different
location within the City?
b. With the Authority stating that Foothill will cease bus lines 492 and 499, does this
imply that commuters will now have only one mode of public transportation to
Downtown Los Angeles to choose from? With the opening of the I-10 Freeway
express lane projected by end of 2023, the estimated commute time to Los
Angeles will be much shorter than Metro’s projected time to Downtown Los
Angeles. Why will this alternative bus mode of transportation cease and, if so,
where do these commuters park during the two-year gap of Phase 2B opening?
In addition, this parking facility is not limited or restricted to patrons of Foothill

Transit and is available to rideshare, vanpool, etc., as well as serving as additional
parking for the Downtown businesses and patrons. Without replacement of the
existing 175 spaces, parking will be constrained, impacting Downtown businesses
and adjacent residential neighborhoods. The reduced parking provided for the
station is already likely to result in overflow parking onto adjacent residential
neighborhoods, as acknowledged by the need for Parking Management Plans
(PMPs). The removal of existing parking spaces that would occur with the Project
Modifications would exacerbate this impact. The Draft SEIR 3 does not adequately
analyze the impacts resulting from the loss of these parking spaces, narrowly
relying on its use by patrons of Foothill Transit only.
c. The Authority has stated that an internal coordination or agreement has been
concluded with Foothill Transit to cease operation of lines 492 and 499. Has this
been discussed with the Foothill Transit Board? Are there any formal approvals in
place? Why was the City not involved as part of this discussion? In fact, according
to a June 25, 2021 Foothill Transit Board Executive Board Meeting staff report, the
report states that the use of the City’s Park and Ride for station parking will
necessitate Line 499 being realigned to an alternate location for customers who
currently utilize Line 499 at the park and ride. No action has or is being considered
to cease operations of the lines, but rather, the consideration of the City’s Park and
Ride for Project parking will impact the location, traffic, and parking impacts for
Foothill Transit passengers and as such has not been considered in the Draft SEIR
3. Further, according to the Foothill Transit leadership, Foothill Transit is waiting
to see what occurs at the Park and Ride to initiate coordination. Thus, the Draft
SEIR 3 does not properly analyze the impacts resulting from changes to lines or
worse is premised on faulty assumptions of changes to the lines.
d. The need for parking specifically at the City’s Park and Ride is not just driven by
the needs of Foothill Transit commuters. As noted, during the lockdown due to the
pandemic, Foothill was operating with minimal bus service – possibly due to when
a lot of commuters opted to stay and work from home. However, even during those
times, the City’s Park and Ride was heavily used on a daily basis. The daily patrons
parking there are part of car pools, local business customers, employees, as well
as transit riders, too. Currently, the Feed and Grain Store uses the Park and Ride
for offloading supplies. This use will be eliminated in the proposed modifications,
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with no mention of any mitigation measures.
The heavy daily use of the Park and Ride shows the latent need of parking in the
heart of downtown. How does the Authority plan to replace this critically needed
parking in the downtown?
Again, the Draft SEIR 3 fails to address the adverse and negative impact from the loss of this
critical and daily available parking and its subsequent affect to immediate neighborhood,
businesses, community, and the community at large.
In addition to the Park and Ride serving Foothill Transit riders, rideshare, vanpool, as well as
serving as additional parking for the Downtown businesses and patrons, it provides parking
for employees of the Curative Lab located at 430 S. Cataract Avenue. Employees are then
shuttled to their location of employment. The loss of the availability to park at the Park and
Ride will create impacts to the surrounding residential neighborhoods. Eliminating the parking
for Curative Lab would result in traffic and parking impacts not reasonably contemplated when
looking at just the Park & Ride. The Draft SEIR 3 does not address this or analyze the
impacts. In addition, the Authority’s analysis of parking during construction is deficient, and
the loss of daily parking for commuters and patrons has not been adequately analyzed or
mitigated. The Authority must also identify and adopt feasible mitigation measures to reduce
those impacts, if feasible. (Pub. Res. Code § 21083(b)(2); CEQA Guidelines § 15064(h)(1)).)
As a further example, the negative impact to the housing development located at San Dimas
Avenue and Commercial Street has not been analyzed or mitigated. Not only will parking be
reduced, but vehicle queueing will become an issue, which was an issue raised with the
Authority in our prior response letter. Consequently, the Authority must consider feasible
mitigation measures in a revised and recirculated Draft SEIR 3.
8. The Draft SEIR 3 does not adequately address the increased traffic on surrounding
residential roadways in order to access the parking facility. The statement that “typically,
drivers would use major streets such as San Dimas Avenue and would choose a more
direct route to the station parking facility” is not substantiated. Access to the station parking
would occur from residential streets. With the permanent street closure to vehicular traffic
on Monte Vista Avenue, vehicles accessing the parking facility from Monte Vista Avenue
have no other option but to travel through residential neighborhoods.
9. The Project Modifications propose a new access road from Commercial Street. This
access road would be located just west of an existing driveway providing access to the
residential and live/work development located at the southwest corner of Commercial
Street and San Dimas Avenue. The interaction of vehicles exiting the parking lot and
queuing on Commercial Street at the San Dimas Avenue/Commercial Street traffic signal
could potentially impede vehicles attempting to turn left from Commercial Street into the
existing driveway causing vehicles to queue into the intersection; however, no mitigations
are proposed. How will this impact emergency vehicle responses? Currently the
businesses and residents park within the Park and Ride or on Commercial Street.
Reference is made to a Parking Management Plan; however, it is unclear how the Gold
Line Authority will develop the plan, and as it is a limited life organization, how will the
parking plan be managed after the Gold Line Authority is dissolved? This potential design
hazard needs to be addressed in the Draft SEIR 3.
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10. Draft SEIR 3 Page 3-19 references “controlled parking entrances and exits”. What kind of
controls will be utilized? Depending upon the types of controls and location, there could
be a potential for vehicles to queue onto neighboring residential streets. This potential
needs to be addressed.
11. The approved SEIR 2 incorporates bus drop off and onboarding within the station parking
lot. The proposed configuration in the Draft SEIR 3 eliminates buses in the parking lot.
This has significant impacts on:
a. The ability to provide cross connection with other bus lines.

b. The potential increase in bus stops on Bonita Avenue creates a potential backup
on Bonita Avenue that may impact the freight crossing at Cataract Ave.
c. Eliminates bus staging which currently occurs in the Park and Ride Lot.
12. No mitigations or improvements were proposed for the Bonita/San Dimas Ave bus stops
to accommodate additional ridership.
13. The intersection of San Dimas Avenue and Commercial Street will be severely impacted,
including creating traffic back-ups at the northbound left turn lane to access the Park and
Ride. This should be further studied and require mitigation measures to prevent
northbound vehicles from turning into the Grove Station development to turn around and
bypass the back-up created at the northbound left turn lane.
14. 3.1.4 Mitigation Measures and Recommendations - LTR-1 states that the Authority shall
cooperate with the City and contribute funding for a new traffic signal at the intersection of
San Dimas Avenue at Second Street when warranted.
a. The relocation of the station parking to the City Park and Ride will result in an
exponential increase in traffic delays because all the commuters parked at the Park
and Ride will cross San Dimas Avenue at the railroad crossing – both during peak
AM and PM hours and intermittently during the off-peak hours. On page 3-8 it
states that “a traffic evaluation was completed in May 2021 for the proposed east-
west crosswalk just south of the Project ROW… The results of the operation and
queueing analysis for the northbound and southbound approaches at San Dimas
Avenue indicated that the Project with Project Modifications would not result in a
substantial increase in traffic delay, and signal operations for the crosswalk at San
Dimas Avenue would result in minimal delays compared to the delays experienced
at the nearby intersections.”
Almost 90% of the commuters will opt to cross at this crosswalk – it’s only ingrained
human nature to cross at the shortest and closest point. The increase in pedestrian
crossing frequency and activities will further compound and add to delays already
experienced by drivers when the train is stopping or leaving the station. This
additional delay, in particular for southbound San Dimas Avenue north of Bonita
Avenue, will initiate driver behavior to take “short cuts” through the residential
streets. Neighborhoods were not designed for cut through traffic in order to avoid
delays as traffic backs up at Bonita Avenue. Why was the traffic evaluation which
was completed in May 2021 not provided for review?
With the relocation of the station parking lot to the Park and Ride, the Authority
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must consider installing a traffic signal as part of the current project now, rather
than when fully warranted. Secondly, when it’s fully warranted, how does the City
collect its contribution? Upon completion of Phase 2B, the Authority is dissolved
and non-existent. Again, how does the City collect the contributions?
b. The Draft SEIR 3 states that additional traffic would be expected on Monte Vista
Avenue and Commercial Street to enter and exit the parking lot. Any subsequent
impacts will be addressed by a Parking Management Plan (PMP) – a PMP that
states it would prohibit on-street parking for transit patrons and any of the
neighborhoods that are impacted by traffic would be addressed by means of the
Authority working with City to install traffic calming elements around the parking lot
such as speed humps/bumps and signage. This statement completely disregards
and ignores the City’s initial comments in the NOP to consider various traffic
calming mitigation measures that would mitigate transit patrons traffic flow from
the residential neighborhood.
Again, we reemphasize the City’s NOP comments recommending various traffic

calming measures, which would mitigate the traffic flow of transit patrons in and
out of the residential neighborhood as a result of the Gold Line’s proposal to
relocate station parking to the Park and Ride, which will result in a substantial
increase in traffic volume within the existing quiet neighborhood along Cataract
Avenue, Railway Street, and Commercial Street. Therefore, to deter and restrict
traffic entering Commercial Street from Cataract Avenue or Railroad Street, and/or
turning right onto Commercial Street when exiting from the station parking primary
driveway/aisle, it is recommended that the following specific mitigation measures
be considered and reviewed for implementation by the Authority:
I. Restrict commuter traffic from entering and exiting at Railway

Street/Monte Vista Avenue/Park and Ride and allow access for
emergency vehicles only.
II. The acquisition of Successor Agency properties on Cataract Avenue

and utilization of Metro Gold Line’s right-of-way south of the rail lines to
create a vehicular bypass to Railway Street and Commercial Street,
thereby potentially reducing traffic impacts on surrounding residential
streets.
III. Extend Park and Ride driveway/aisle approximately 4 to 6 feet south of

the center line of Commercial Street leaving approximately 12 to 13-
foot-wide lane open for eastbound traffic only.
IV. Extend this restricted eastbound lane up to Shirlmar Street by means

of landscaped curb extensions with entry and exit allowing for street
parking for the two residents on the north side of Commercial, adjacent
to the Park and Ride.
V. The eastbound approach of Commercial Street at San Dimas Avenue

should be modified to provide two eastbound lanes.
VI. The segment of Commercial Street between Shirlmar Street and the
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April 1, 2022
Park and Ride’s primary entrance will be restricted to allow eastbound

traffic only, thereby also providing emergency and vehicular
connectivity for residents of this neighborhood to downtown and San
Dimas Avenue.
VII. Extension of the primary Park and Ride driveway/aisle allows for
smooth flow of traffic in and out of the station parking lot without much
delay.
VIII. Traffic signal timing and intersection improvements at San Dimas

Ave/Commercial Street to mitigate impacts to the entrance of the HOA
south of Commercial Street/west of San Dimas Ave resulting from
queuing associated with the relocated station parking access.
The combination of the extended entrance and curb extension will minimize traffic
from the station’s Park and Ride entering into the neighborhood because patrons
using the facility will be forced to use the main entrance which will keep the
separation of traffic flow to the major arterials and off residential streets as
intended.
15. In Section 4.13.3.4 Long - Term Safety Impacts, the Draft SEIR 3 details that the relocation
of the station parking has the potential to result in increased safety impacts for motorists,
bicyclists, and pedestrians as a result of the additional parking spaces provided, and
potential additional vehicular activity associated with station access from the relocated
parking facility. It further expounds that the Construction Authority will work with the City
of San Dimas to identify and fund traffic and speed control devices, including traffic
calming devices such as additional signage, active speed identification signs, speed
humps/bumps and other devices … to recue potential automobile and pedestrian/bicycle
conflicts. However, none of these have been studied or proposed as mitigations. The Draft
SEIR 3, in fact, ignores the conclusion of this section and indicates no mitigations are
required. As referenced above, CEQA requires the Authority to evaluate a project’s traffic
safety impacts on pedestrians, cyclists, and transit riders. (See City of Maywood v. Los
Angeles Unified Sch. Dist. (2012) 208 Cal. App. 4th 362, 392-95 (holding EIR was
inadequate because it failed to analyze and mitigate project impacts on pedestrians).)
16. The realignment of the public alley north of Commercial Street to meet the Park and Ride’s
primary drive aisle restricts the eastbound right turn for residents, trash service, other utility
vehicles and fire safety equipment. This layout needs to be redesigned in order to allow
access for the residents. Also, these residents would need access rights to use the new
access road.
17. Tables 3-6 and 3-7 show the level of service for the AM and PM peak hours for the
following intersections:
• San Dimas Avenue/Bonita Avenue

• San Dimas Avenue/Arrow Highway
• Walnut Avenue/Arrow Highway
• San Dimas Avenue/Railway Street
• San Dimas Avenue/Commercial Street
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With the relocation of the parking to the Park and Ride, motorists coming from the west
ends of the City and adjacent cities to the west will travel through and add delays to the
intersections of Cataract Avenue/Arrow Highway and Cataract Avenue/Bonita Avenue.
The level of service analysis should include these additional two intersections.
18. On page ES-3, the Draft SEIR 3 states that the proposed San Dimas parking facility would
also include a Kiss and Ride area to allow for pick-ups and drop-offs. Buses would no
longer enter the parking lot. Instead, the bus drop-off for Foothill Transit would now be
located at the intersection of Bonita Avenue and San Dimas Avenue. An intersection that
would now be more congested since there are two existing Foothill Transit stops, located
at the northeast and southeast of the intersection of Bonita Avenue at San Dimas Avenue
for bus line 492. Where would the bus stop for commuter bus line 499 be located? The
existing intersection was modified due to the Gold Line and is already congested, thus the
addition of two new bus stops would compound further delays at an intersection that is
already experiencing substantial delays. In addition, increased pedestrian crossing on San
Dimas Ave south of the tracks will add to the delays at Bonita/San Dimas Ave, potentially
backing up eastbound traffic across the freight tracks at Bonita/Cataract Ave.
19. The impacts to Cataract Avenue/Bonita Ave and Cataract Ave/Arrow Highway were not
studied. These intersections are closest to the freeways and the entire west side of City.
Much of the parking commuters will be approaching from this direction. These
intersections will be severely impacted and need to be studied.
20. Where is the traffic study from May 2021 that was referenced in the Draft SEIR 3? Why
was this not available for review?
Aesthetics
21. The Draft SEIR 3 Aesthetics discussion identifies eight residences located along the
border of Commercial Street and states the fronts of these residences face away from the
Project site and views of the Project site from the back are buffered. However, the analysis
does not take into consideration the residential property located south of Commercial
Street that directly faces Freedom Park and the proposed location of the new access road.
Therefore, the aesthetics discussion is deficient, as the analysis only considers some of
the residential properties in the area. An EIR’s description of the environmental setting
must be contain sufficient information to “permit the significant effects of the project to be
considered in the full environmental context.” CEQA Guidelines, § 15125(c). “If the
description of the environmental setting ‘is inaccurate, incomplete or misleading, the EIR
does not comply with CEQA.’” (Cleveland Nat’l Forest Found. v. San Diego Assn. of
Governments (2017) 17 Cal.App.5th 413, 439.) An accurate description of the
environmental setting is critical, because the significance of an activity may vary with the
setting. CEQA Guidelines, § 15064(b). A “project that is ordinarily insignificant in its impact
on the environment may in a particularly sensitive environment be significant.” (Kings
County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 718, 721; CEQA
Guidelines, § 15300.2(a)).)
22. In addition, the Draft SEIR 3 fails to consider views of the Project site from pedestrians
utilizing Commercial Street, fails adequately address the impacts of the portion of
Freedom Park that is proposed to be removed in order to construct an access road, and
fails to address the introduction of lighting from vehicle headlights which will impact certain
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residences. Because the Draft SEIR 3 fails to properly study these significant impacts on
aesthetics, the Draft SEIR 3 fails to live up to its role as an informational document. The
Authority’s failure here “precludes informed decision making and informed public
participation, thereby thwarting the statutory goals of the EIR process.” (Ass'n of Irritated
Residents v. County of Madera (2003) 107 Cal.App.4th 1383, 1391.)
23. The Draft SEIR 3 focuses the discussion and associated impact conclusions on the portion
of the Project site that is comprised of the current San Dimas Park & Ride facility, relying
on the fact that it is currently a parking facility and would continue to be a parking facility:
“As discussed, the vividness, intactness, and unity of the Project Site would remain similar
to existing conditions with the implementation of the Project Modifications as the parcel
would continue to be used as a paved parking facility”. However, the Project Site extends
beyond the existing San Dimas Park & Ride facility. The Draft SEIR 3 does not adequately
address the portion of Freedom Park that is proposed to be removed in order to construct
an access road or the Kiss and Ride Area. Views of Freedom Park in this area are intact
with large mature trees and landscaping that provide visual relief from the surrounding
development. The 2013 FEIR did not contemplate the removal of a similar resource, as a
similar resource is not located within the previously considered parking location.
24. The Draft SEIR 3 does not discuss the Project’s introduction of lighting associated with
the headlights of vehicles exiting the parking lot from the proposed access road that would
directly impact the residence located south of Commercial Street that fronts Commercial
Street and Freedom Park; this condition does not currently exist and would not have
occurred at the previously considered parking location.
25. The Draft SEIR 3 does not fully analyze the air quality impacts to surrounding residents
and does not propose proper mitigation (i.e. upgrading residential air filtration systems
and enhancing First/Last Mile improvements) to reduce the potential air quality impacts.
The proximity of the relocated Gold Line station parking lot to the existing Park and Ride
will result in an increase of traffic to the surrounding residential neighborhoods and if
proper parking is not provided, these future riders will circulate and park within surrounding
private and public parking lots or along residential or commercial streets. The result of
these vehicles circulating around the surrounding residential neighborhoods looking for
parking will increase emissions/air pollutions and therefore increase Green House Gas
(GHG) Emissions and air quality impacts.
26. In this regard the Gold Line Authority (GLA) should also evaluate, quantify and mitigate
the effects of greenhouse gas (GHG) emissions as part of the overall air quality
assessment. This topic was not clearly addressed in the 2013 FEIR.

27. The Draft SEIR 3 is deficient as it discounts the importance of the portion of Freedom Park
proposed for acquisition because it does not contain park facilities or features. However,
this area is vegetated, including mature trees and serves as an open space resource for
the surrounding community. The removal of a portion of Freedom Park is a long-term
impact which was not contemplated in the 2013 FEIR, and the Draft SEIR 3 fails to
describe the magnitude and severity of this impact, including in communities and
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April 1, 2022
neighborhoods located in this area. The Draft SEIR 3 fails to identify feasible mitigation
measures that would effectively reduce the Project’s impacts on the visual character and
quality.
Cultural Resources
28. The Draft SEIR 3 indicates the AB 52 consultation process is ongoing and will be further
documented as part of future CEQA documentation, but fails to identify what future CEQA
documentation is being referenced. Under AB 52, if consultation has begun, an EIR
cannot be certified unless the consultation process between the tribe and the lead agency
has concluded. Thus, the Draft SEIR 3 inadequately describes the AB 52 consultation
process.
Noise and Vibration

29. The Draft SEIR 3 inaccurately states that, when compared to the SEIR 2 location,
residential structures abutting the relocated San Dimas parking facility are farther away
from potential noise and vibration-intensive construction activities and concludes a
reduction in both construction noise and construction vibration levels at adjacent
receptors. SEIR 2 Table 4.11-4 shows a distance of 45 feet from the closest sensitive
receptor to the reconfigured parking facility. Construction activities associated with the
Project Modifications (new access road) would occur immediately adjacent to the
residential property that abuts Freedom Park; the residence is located at a distance of less
than 45 feet and should be analyzed accordingly.
Similar to the construction impacts discussion, the long-term impacts discussion identifies
the closest noise-sensitive receptor as 60 feet. This measurement is to the parking area.
The Draft SEIR 3 should also address the noise associated with the proposed access road
which would be located immediately adjacent to a sensitive receptor.
.
30. No mitigations were proposed for the house adjacent to the new entrance onto
Commercial Street. There will be significant queuing of vehicles exiting the station parking
onto Commercial Street. This will create noise concerns for this residence.
31. The 2013 FEIR (page 3.11-17) states noise control measures when working near
residences would be required, which includes conformance with the noise requirements
of each City. "Limiting construction activities to weekday daytime hours (typically 7 a.m. to
6 p.m.) and employing typical measures for minimizing noise during construction
requirement, combined with the mitigation described in Section 3.11.5, would mitigate
construction impacts to a less than significant level." This is contradictory to the Draft SEIR
3 (Section 3.1.2.3), which states short-term construction impacts from temporary lane
closures and detours "…would be limited by scheduling certain construction activities
during night hours, outside of the AM and PM peak commuting periods, and through the
use of clearly signed detour routes where necessary." The Draft SEIR 3 Noise analysis
does not analyze nighttime construction activities. This inconsistency needs to be
addressed and remedied. If nighttime construction activities will occur, the noise analysis
needs to identify any resulting noise impacts to sensitive receptors. To “inform the public
and responsible officials of the environmental consequences of their decisions before they
are made.” (Laurel Heights Improvement Ass’n v. Regents of the Univ. of Cal. (1993) 6
Cal.4th 1112, 1123.) Again, the Authority must analyze noise impacts and potentially
feasible mitigation measures for the significant nighttime construction noise impacts
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April 1, 2022
caused by the Project.
Safety and Security

32. As acknowledged in the Draft SEIR 3 “[t]he relocated and reconfigured parking facility
would be located in a more residential area than previously approved, with adjacent
residential land to the west and south. Therefore, the facility would be located in an area
with a different safety and security setting than what was previously analyzed.” As we had
previously noted, there are safety and security concerns with relocating the parking facility
to the Park & Ride. Specific attention should be provided to the interface between the
Project site, the alley, and the residential uses located south of the alley and that currently
there is a clear line of site across the alley between Monte Vista Avenue and San Dimas
Avenue, as well as visibility from the existing Park & Ride facility. This visibility could be
limited with the introduction of the access road and other improvements, resulting in
security and safety concerns within the alley. The Draft SEIR 3 does not adequately
address safety and security concerns. The Authority is legally required to mitigate or avoid
the significant impacts of the projects it approves whenever it is feasible to do so. (Pub.
Res. Code § 21002.1(b).) “In the case of the adoption of a plan, policy, regulation, or other
public project, mitigation measures can be incorporated into the plan, policy, regulation,
or project design.” (CEQA Guidelines § 15126.4(a)(2).).
33. With the Station Parking being so close to residential properties, the frequency of calls to
law enforcement will increase and the expected response time will be immediate. Draft
SEIR 3 provides no details of how the Gold Line Authority will mitigate these requirements.
This will impact local law enforcement and impact their ability to respond to other calls
through the City. The Draft SEIR 3 must provide a detailed plan for Metro and LASD
Transit Services Bureau response to mitigate impacts to local safety and law enforcement.
SS-4 security mitigations indicates a security plan for LRT operations shall be
implemented but the mitigation measure references surveillance by law enforcement
including local jurisdiction security personnel. Gold Line Authority is proposing the use of
local enforcement without cost mitigations.
Water Quality and Resources

34. The Draft SEIR 3 long-term Impacts discussion states “[t]here would be a decreased
amount of impervious surface compared to the Approved Project since the proposed San
Dimas parking location is a smaller site than the approved location.” This is not an accurate
characterization. The approved location is already impervious and although the acreage
of the parking facility may be reduced with the Project Modifications, the amount of
impervious surface as a result of the Project Modifications would not be decreased. The
Project Modifications would acquire a portion of Freedom Park for an access road,
converting an existing pervious surface to impervious conditions. When an EIR gives
“conflicting signals to decision-makers and the public about the nature and scope of the
activity being proposed,” the courts have found it “fundamentally inadequate and
misleading.” (San Joaquin Raptor Rescue Center v. County of Merced, 149 Cal.App.4th
645, 655-56.).
General Comments
35. The station parking design standards require the parking lot to meet local landscape
design standards. The configuration of the parking lot as proposed does not comply with
ATTACHMENT 1
April 1, 2022
City Code requirements. The increased landscaping requirements will result in the
elimination of several parking stalls. This combined with the ADA requirements which were
also not addressed will likely reduce the number of stalls available to less than 289.
36. The project calls for trees to be relocated. What trees will be relocated and to what
location?
37. Construction emissions will now be closer to residential homes than previous.
Construction parking will impact the neighborhood and mitigation was not addressed.
The Draft SEIR 3’s lackluster approach to impact analysis and mitigation violates CEQA. A lead
agency cannot simply conclude that an impact is significant and unavoidable and move on. A
conclusion of residual significance does not excuse the agency from (1) performing a thorough
evaluation and description of the impact and its severity before and after mitigation, and (2)
proposing all feasible mitigation to “substantially lessen the significant environmental effect.”
(CEQA Guidelines § 15091(a)(1); see also id. § 15126.2(b) (requiring an EIR to discuss “any
significant impacts, including those which can be mitigated but not reduced to a level of
insignificance” (emphasis added).) Consequently, the Authority cannot legally certify the Draft
SEIR 3 until it satisfies all the above CEQA requirements and, instead, it must consider further
feasible mitigation measures in a revised and recirculated Draft SEIR 3.
Sincerely,

Cc: City Council

Attachment:
City of San Dimas NOP Letter, November 17, 2021
ATTACHMENT 1
Denis Bertone
Henry K. Noh
City Manager
Recreation
Brad McKinney
Jeff Malawy
November 17, 2021

Subject: Comments on Notice of Preparation of Draft Supplemental EIR (DSEIR) Metro Gold Line
Extension Phase 2B – San Dimas Parking Lot Relocation
Dear Ms. Buch:
The City of San Dimas appreciates the opportunity to provide comments on the referenced DSEIR. The
City of San Dimas continues to support the completion of the Gold Line Foothill Extension to Montclair,
as long as the City’s and our community’s concerns are fully mitigated to our satisfaction. The following
comments are based on the Notice of Preparation of a Draft Supplemental Environmental Impact Report
received on October 15, 2021. The DSEIR needs to address and fully mitigate the following potential
impacts regarding the proposed relocation of the San Dimas Gold Line Station parking lot to the existing
Park and Ride lot.

1. The City is extremely concerned about the impact to the surrounding residents and downtown
businesses caused by the reduction in number of parking spaces provided in the proposed relocated
station parking design. The original 2013 FEIR requirement of 450 parking spaces was reduced to 289
parking spaces (Supplemental EIR, 2021) due to implementing Metro’s Supportive Transit Parking
Program Management Plan constrained parking model. Relocating the Gold Line Station parking into
the existing Park and Ride location would result in the loss of an additional 175 valuable parking spaces
(existing 175 Park and Ride parking spaces not being reconstructed or accounted for with the Gold
Line parking relocation to the Park and Ride) in the heart of our downtown. Such a reduction in the
number of parking spaces in downtown would negatively impact our downtown business community.
Under parking the station and reducing valuable downtown parking capacity will result in impacts to
private property, as well as, Municipal parking lots and public streets in the vicinity of the Gold Line
station parking lot. These impacts and mitigation measures must be evaluated and assessed as a part
of the Draft SEIR and clearly indicate how the project will not have an impact on the City’s streets,
residential neighborhoods, and nearby businesses.
ATTACHMENT 2
November 17, 2021
2. A Parking Management Study is needed to fully address overflow parking onto adjacent commercial
and residential neighborhoods. The study must include a discussion related to the anticipated impacts
and mitigation measures (i.e. required parking enforcement, fully funding additional City staffing and
costs related to mitigating parking related impacts associated with the Gold Line, etc.) to offset the
impacts of the overflow parking and traffic created by the Gold Line Station.
3. Currently, the existing Park and Ride is developed with 175 parking spaces, in addition to a dedicated
bus stop and bus shelter for Foothill Transit which supports regional transportation. The City is
concerned about the potential impact to the Foothill Transit bus services and the need to provide
additional bus patron parking, in addition to the approximately proposed 289 parking spaces to only
accommodate the future Gold Line Station patrons. The bus service provides a critical mode of public
transportation and the proposed alternative would potentially eliminate this mass transit alternative.
In the 2013 FEIR, the Gold Line Authority (GLA) committed to conduct a Bus Interface Study by
completion of the Design Phase. To date, no study has been completed. This is an area of concern for
the City given the change to the project scope and the elimination of Foothill Transit within the
existing City Park and Ride Facility. This study will require Foothill Transit to reroute or eliminate
valuable mass transit services. The GLA should complete this study without further delay.
4. The pedestrian routes from the relocated Gold Line parking within the proposed Park and Ride lot
location need to be fully analyzed. The previous Gold Line parking location (City Yard) provided a
direct and safe pedestrian pathway that went underneath the light rail tracks to the station. The
relocated parking lot within the Park and Ride will result in a pedestrian conflict at San Dimas Avenue
and will result in significant vehicular traffic impacts on north and south bound San Dimas Avenue, in
addition to east and west bound traffic on Bonita Avenue and Arrow Highway. This will be the result
of the number of peak hour pedestrian traffic crossing at San Dimas Avenue, in addition to the number
of train crossing signals that are activated approximately twice (trains travelling east and west bound)
every 6 minutes. Mitigation needs to be provided to prevent pedestrians from jaywalking across San
Dimas Avenue and the longer traffic delays from the number of pedestrian crosswalk signals and the
number of train signals disrupting the vehicular traffic movement along San Dimas Avenue.
Studies need to be conducted to fully analyze the impact to this crossing that simulate and evaluate
the traffic impacts on San Dimas Avenue, in addition to the pedestrian safety and liability due to the
increase in pedestrian crossing along this crossing intersection.
5. The proposed Gold Line parking relocation to the Park and Ride will result in an increase of traffic
volumes within existing quiet single-family residential neighborhoods along Railway Street and
Commercial Street. Therefore, traffic calming mitigation measures need to be fully analyzed that will
fully mitigate and divert this traffic away from these residential neighborhood streets. These
mitigation measures could include, but are not limited to:
a. Closure of the Monte Vista ingress/egress of Park and Ride;

b. Traffic calming mitigation measures on Railway and Commercial Streets, such as installation
of cul-de-sac(s), speed humps, or other potential traffic calming mitigation measures;
c. Consider an additional vehicular ingress/egress along San Dimas Avenue to reduce traffic
related impacts to the surrounding residential neighborhoods.
ATTACHMENT 2
November 17, 2021
d. The acquisition of Successor Agency properties on Cataract and utilization of Metro Gold
Line’s right-of-way south of the rail lines as a bypass to Railway and Commercial reducing
traffic loads on those residential streets.
6. Mitigation measures shall be implemented to reduce the vehicular queuing exiting the proposed
relocated Gold Line parking lot.
7. All ADA pedestrian pathway concerns within the proposed relocated parking lot and the surrounding
rights-of-way shall be fully analyzed and mitigated.
Tree Preservation, Landscaping and Water Quality

8. The City of San Dimas is a Tree USA City and preservation of the mature trees is a priority. Any City-
owned trees proposed for removal shall be evaluated per City’s Tree Preservation Ordinance per
Chapter 13.36. A Tree Removal Permit Application will be required to be submitted to the Parks and
Recreation Department for review.
9. The proposed station and parking lot landscape and irrigation shall comply with the City’s Water
Efficient Landscapes Chapter 18.14.
10. The City is concerned with the thermal effects of the parking lot as proposed and its contribution to
an urban heat island. The project must incorporate large shade trees, vegetation/landscape and
lighter colored pavement to mitigate these impacts.
11. The proposed station and parking lot shall provide Low Impact Development (LID) proposal to comply
with City, County and State water quality requirements.

12. The air quality impacts to surrounding residents shall be fully analyzed and mitigated (i.e. upgrading
residential air filtration systems and enhancing First/Last Mile improvements). The proximity of the
relocated Gold Line station parking lot to the existing Park and Ride will result in an increase of traffic
to the surrounding residential neighborhoods and if proper parking is not provided, these future riders
will circulate and park within surrounding private and public parking lots or along residential or
commercial streets. The result of these vehicles driving around looking for parking will increase
emissions/air pollutions and therefore increase Green House Gas (GHG) Emissions.
13. Revised and updated estimates to circulation, land use, ridership and traffic/parking are necessary to
prepare an appropriate analysis of the environmental effects on air quality with the revised project.
Utilizing the FEIR 2013 data will result in an inadequate analysis especially in light of the availability of
new ridership data and changes in Metro policies regarding parking, parking fees and First/Last Mile
improvements.
14. In this regard the Gold Line Authority (GLA) should also evaluate, quantify and mitigate the effects of
greenhouse gas (GHG) emissions as part of the overall air quality assessment. This topic was not
clearly addressed in the 2013 FEIR.
Noise and Vibration

15. The impact to the surrounding residences from the additional traffic related noise shall be fully
mitigated including but not limited to:
ATTACHMENT 2
November 17, 2021
a. Construction of new sound walls; and

b. Retrofitting all surrounding affected residence windows with dual pane glass and other
treatments to reduce the noise impact with special emphasis to residences experiencing the
highest traffic and noise flows.
Public Service/Safety Concerns

16. There are safety and security concerns by relocating the Gold Line parking to the existing Park and
Ride due to it being surrounded by and in close proximity to single-family residences. There is some
evidence that terminus or near-terminus stations are affected negatively by increased criminal
activity. Such impacts have been evident with the opening of the Gold Line Phase 2B project.
Mitigation measures need to be incorporated to address these concerns including but not limited to:
a. Funding and providing law enforcement presence, preferably a new satellite law enforcement
office located within the new parking lot;
b. Installation of camera systems in all parking facilities and use of security software which is
compatible with local law enforcement needs and enhanced ability for cameras to pan, tilt,
zoom and record, providing clear, high quality observation during night and day, as well as
providing needed hardware and viewing capability at the local law enforcement offices; and
c. Installation of city approved parking lot and alley lighting that is shielded and does not spill
over or impact surrounding residences.

17. The impact to the existing Freedom Park by reducing the parkland area and removing existing
mature trees and landscaping in order to facilitate the construction of new vehicular ingress/egress
shall be fully mitigated.
a. Installing and maintaining adequate camera systems as specified in 16b to provide for
observation and response to Freedom Park as this location will be unduly impacted by
activity coming from the Park and Ride.
Land Use
18. The proposed project relocation will affect surrounding land uses especially as they relate to both
traffic, parking, air quality, noise and safety impacts. There is clear evidence that surrounding land
uses are severely impacted when station parking and access are inadequate or poorly designed. These
impacts can severely affect nearby parking facilities, businesses and residences.
Furthermore, the State legislature is mandating major land use changes around transit stations in both
adopted and anticipated legislation. These changes in growth are induced by and directly related to
the station location. These changes are intended to supersede existing zoning resulting in a growth
inducing impact not considered at all by any of the EIRs for the project. These changes likely render
much of the traffic and related analysis invalid.
Economic
19. Relocating the Gold Line parking to the Park and Ride will negatively impact the heart of our
downtown businesses by losing 175 valuable parking spaces. Due to this loss of parking, this not
only effects the current businesses and their economic vitality but will affect the economics and
viability of the future expansion and development of the new San Dimas Downtown that the City is
ATTACHMENT 2
November 17, 2021
currently in the process of generating a new Specific Plan for.
20. The proposed Park and Ride parking lot site plan eliminates and negatively impacts the existing Feed
and Grain business (located within the barn at 150 S. Monte Vista) by eliminating their ability to use
the existing Park and Ride lot to offload merchandise. The impact to this business shall be fully
mitigated.
21. Analyze the property value impacts to the surrounding residential and commercial uses with the
relocation of the Gold Line parking to the Park and Ride lot.
22. The elimination of the Park and Ride lot used for bus parking, would negatively impact the City’s
Proposition C funds by reducing the amount of funds the City receives and which can be utilized to
support regional transportation improvements. This impact shall be fully mitigated.
The City of San Dimas looks forward to working cooperatively to address these major issues as part of the
revised project in order to maximize the benefits for Metro, the GLA, the surrounding residents,
businesses and property owners. You are welcome to contact the City for assistance or further explanation
of any of these comments.
Sincerely,
Henry K. Noh
Director of Community Development
Cc: City Council

Chris Constantin, City Manager
Jeff Malawy, City Attorney
ATTACHMENT 2
ATTACHMENT 3
EXHIBIT “E”
1 ALESHIRE & WYNDER, LLP
JEFF M. MALAWY, State Bar No. 252428
2 [email protected]
ANTHONY R. TAYLOR, State Bar No. 208712
3 [email protected]
ALISON S. FLOWERS, State Bar No. 271309
4 [email protected]
18881 Von Karman Avenue, Suite 1700
5 Irvine, California 92612
Telephone: (949) 223-1170
6 Facsimile: (949) 223-1180
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
11 CITY OF SAN DIMAS, a municipal Case No.

corporation,
12 PETITIONER CITY OF SAN DIMAS’S
Petitioner, NOTICE OF INTENT TO FILE CEQA
13 PETITION
v.
14
METRO GOLD LINE FOOTHILL
15 EXTENSION CONSTRUCTION
AUTHORITY; and DOES 1 to 30, Inclusive,
16
Respondents.
17
18 CITY OF SAN DIMAS AS SUCCESSOR

AGENCY TO THE CITY OF SAN DIMAS
19 REDEVELOPMENT AGENCY,
20 Real Party in Interest.

21
22
23 TO METRO GOLD LINE FOOTHILL EXTENSION CONSTRUCTION

24 AUTHORITY:
25 PLEASE TAKE NOTICE that Petitioner City of San Dimas (the “City” or “Petitioner”)
26 intends to file a petition under the provisions of the California Environmental Quality Act
27 (“CEQA”), Public Resources Code section 21000 et seq., against Metro Gold Line Foothill
28 Extension Construction Authority (the “Authority” or “Respondent”), challenging the Authority’s

1 July 27, 2022 certification of the final Supplemental Environmental Impact Report 3 (“Final SEIR
2 3”) and adoption of Resolution No. 2022-R-14.
3 Specifically, the City will challenge the Authority’s certification of the Final SEIR 3 and
4 adoption of Resolution No. 2022-R-14, on the following grounds:
6 alternatives capable of reducing the project’s significant impacts;
10 any evidence;
12 solely on the 2013 Final EIR for the unmodified project;
16 change in use; and
17 e. The greenhouse gas mitigation measures are illusory and do not pass muster under
18 CEQA.
19 The Petition will be timely, in that it will be filed within thirty (30) days of the Authority’s
20 filing of the Notice of Determination. The City will seek a writ of mandate (1) vacating and setting
21 aside the Authority’s certification of the Final SEIR 3 and adoption of Resolution No. 2022-R-14,
22 and (2) directing the Authority to conduct a new environmental review process that complies with
23 CEQA’s requirements, and prepare, circulate, and consider a new and legally adequate supplemental
24 EIR and otherwise comply with CEQA in any subsequent action taken. The Petition will also seek
25 a declaratory judgment that the Final SEIR 3 is deficient as an environmental document under
26 CEQA, and that Respondents may not use the Final SEIR 3 to modify the Project and relocate the
27 parking facility. In addition, the Petition will seek a temporary stay; temporary restraining order;
28 and preliminary and permanent injunctions should issue restraining the Authority from constructing
-2-
1 and operating the project modifications contained in the Final SEIR 3 until the Authority fully
2 complies with the requirements of CEQA.
4 DATED: August 24, 2022 ALESHIRE & WYNDER, LLP

JEFF M. MALAWY
5 ANTHONY R. TAYLOR
ALISON S. FLOWERS
6
8 By:
ALISON S. FLOWERS
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-3-
1 PROOF OF SERVICE
3 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
4 At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of Los Angeles, State of California. My business address is 2361 Rosecrans
5 Ave., Suite 475, El Segundo, CA 90245.
6 On August 24, 2022, I served true copies of the following document(s) described as
PETITIONER CITY OF SAN DIMAS’S NOTICE OF INTENT TO FILE CEQA PETITION
7 on the interested parties in this action as follows:
8 SEE ATTACHED SERVICE LIST
9 BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the

persons at the addresses listed in the Service List and placed the envelope for collection and mailing,
10 following our ordinary business practices. I am readily familiar with the practice of Aleshire &
Wynder, LLP for collecting and processing correspondence for mailing. On the same day that
11 correspondence is placed for collection and mailing, it is deposited in the ordinary course of business
with the United States Postal Service, in a sealed envelope with postage fully prepaid. I am a
12 resident or employed in the county where the mailing occurred. The envelope was placed in the
mail at El Segundo, California.
13
BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the document(s)
14 to be sent from e-mail address [email protected] to the persons at the e-mail addresses
listed in the Service List. I did not receive, within a reasonable time after the transmission, any
15 electronic message or other indication that the transmission was unsuccessful.
16 I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.
17
Executed on August 24, 2022, at El Segundo, California.
18
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20 Lilia E. Madrid
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-4-
1 Service List
2 Chris Lowe RESPONDENT METRO GOLD LINE

Clerk of the Board FOOTHILL EXTENSION CONSTRUCTION
3 406 East Huntington Drive, Suite 202 AUTHORITY
Monrovia, California 91016
4 Email: [email protected]
5 Habib F. Balian
Chief Executive Officer
6 406 East Huntington Drive, Suite 202
8 Mitchell S. Purcell, Esq.

In-House Counsel
9 406 East Huntington Drive, Suite 202
11 Debra Black CITY OF SAN DIMAS AS SUCCESSOR

Agency Secretary AGENCY TO THE CITY OF SAN DIMAS
12 245 E. Bonita Avenue REDEVELOPMENT AGENCY
San Dimas, CA 91773
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01171.0024/813355.1
NOTICE OF INTENT TO FILE CEQA PETITION

2022 08-26 San Dimas Complaint SEIR3

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Electronically FILED by Superior Court of California, County of Los Angeles on 08/26/2022 11:28 AM Sherri R.

Carter, Executive Officer/Clerk of Court, by N. Alvarez,Deputy Clerk

1 ALESHIRE & WYNDER, LLP

7 Attorneys for Petitioner, CITY OF SAN DIMAS

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT

11 CITY OF SAN DIMAS, a municipal Case No.

18 CITY OF SAN DIMAS AS SUCCESSOR

20 Real Party in Interest.

15 4. This Petition challenges Resolution No. 2022-R-14 on the following grounds:

17 alternatives capable of reducing the project’s significant impacts;

23 solely on the 2013 Final EIR for the unmodified project;

10 6. Petitioner City of San Dimas (“City” or “Petitioner”) is a municipal corporation and

12 under the laws of the State of California.

13 7. Respondent Metro Gold Line Foothill Extension Construction Authority (the

14 “Authority”) is an independent transportation, design, and construction agency created by the

22 statute and others necessarily implied.

8 Metro Gold Line Foothill Extension Construction Authority

16 Master Cooperative Agreement approved by both agencies’ Boards of Directors in 2010.

17 Environmental Review of the Gold Line Extension

2 (known as “Phase 2B”).

4 for the LRT Phased Build option.

7 segment was completed in 2015.

14 Dimas, La Verne, Pomona, Claremont, and Montclair.

15 Environmental Review of Modifications to the Gold Line Extension

19 the 2013 FEIR.

24 (“Addendum No. 2) to the 2013 FEIR.

28 environmental effects, or would otherwise require the preparation of a supplemental or subsequent

3 plans for the Project were also completed in 2016.

10 No. 4”) to the 2013 FEIR.

20 Environmental Impact Report to evaluate environmental effects of further proposed project

2 configuration of vehicle and pedestrian access.

11 was certified in January 2021.

13 in Supplemental Environmental Impact Report 3

7 contemplated use of the New Parcels.

11 (“Draft SEIR 3”) was made available on February 18, 2022.

13 considered in Draft SEIR 3 included the following:

15 proposed parking facility).

16 b. A “Kiss & Ride” area for pick-up and drop-off;

20 identified in SEIR 2 for the original parking facility;

22 of the proposed parking facility);

2 longer be provided from Walnut Avenue, east of the station platform;

4 along the new access road on Commercial Street; and

5 h. “Crime Prevention Through Environmental Design” features to provide a safe,

6 secure, and comfortable transit system.

12 pedestrian access discussed herein.”

3 concern to the City:

24 residential roads resulting from the Project.

3 address pedestrian or cyclist safety.

19 designed to mitigate the Project’s GHG emissions.

20 Code section 21167.7 and Code of Civil Procedure section 388.

23 filing a notice of election to prepare the administrative record.

6 could adequately compensate for that harm.

10 It accomplishes this in two ways.

12 significant environmental effects of a project. (CEQA Guidelines § 15002(a)(1).) Such disclosure

18 Yorty (1973) 32 Cal.App.3d 795, 810.)

20 whenever feasible by considering changes in projects through project alternatives or mitigation

6 acceptable on the basis of overriding concerns.

7 FIRST CAUSE OF ACTION

8 (Petition for Writ of Mandate – Code of Civil Procedure § 1085)

9 44. Petitioner incorporates herein by reference the allegations of paragraphs 1 through

8 law, and acted without substantial evidentiary support.