The URL can be used to link to this page

Home My WebLink About _ 9.4(a)--Redding Rancheria Fee-To-Trust and Casino Project Final Environmental Impact Statement � � �' � � � � � � ' � �' � � ' � ` CITY OF REDDING REPORT TO THE CITY COUNCIL MEETING DATE: April 16,2024 FROM: Jeremy Pagan, Development ITElVI NO. 9.4(a) Services Director/B1dg Official ***APPROVED BY*** ��`� � _. . r�, � � �� _,,�„�� ,w� � ��r��A Ryuy.y aF3d � � . 1cr,�i��a��+:tzw� �^nt��r�i� C)zr�ctcxrf3lci�t)[ticz�I �w ��)'°�tk?� �`' tp�ti2,��I ��2 t' ��f��'��{}7 �www�'� > jpagan@cityofredding.org btippin@cityofredding.org SUBJECT: 9.4(a)--Consider submission of comments regarding the Redding Rancheria Fee- To-Trust and Casino Pro�ect Final Environmental Im act Statement. Recommendation Authorize the Mayor to formally submit comments regarding the Redding Rancheria Fee-To- Trust and Casino Project Final Environmental Impact Statement to the U.S. Department of the Interior Bureau of Indian Affairs. Fiscal Impact There is no fiscal impact to the City of Redding (City)by submitting the letter. Alte�native Action The City Council could choose to not authorize the Mayor to submit comments relative to the Redding Rancheria Fee-To-Trust and Casino Project Final Environmental Impact Statement, or provide alternate direction. �ackgrou n d/f1 n alysis The Redding Rancheria is proposing to convert land from Fee-To-Trust and construct a Casino Project on a 232-acre property located adjacent to the City limits. The project site is located on Bechelli Lane, accessed via South Bonnyview Avenue, and is bound by private properties within the City to the north, private properties within the County of Shasta to the south, the Sacramento River to the west and Interstate 5 (I-5) to the east. A Draft Environmental Impact Statement (DEIS) was prepared and issued in 2019, purs�uant to the National Environmental Policy Act (NEPA), to assess the environmental impacts of the Redding Rancheria's proposed Fee-To-Trust and Casino Project. The NEPA stipulates that an Environmental Impact Statement be prepared for major federal actions that could significantly affect the quality of the environment. Pursuant to NEPA, a Notice of Availability (NOA) was issued for the referenced document. The City responded with a letter, dated May 22, 2019, from the Mayor with comments. This letter is attached to this staff report. Report to Redding City Council Apri111,2024 Re: 9.4(a)--Redding Rancheria Fee-To-Trust and Casino Project Final Environmental Impact Statement Page 2 Below is a list of actions taken by the Bureau of Internal Affairs (BIA) since that time. • May 20, 2019 - Public Hearing to collect verbal comments on the DEIS; • May 14, 2020 - Published a notice to suspend preparation of the EI�S; and • September 23, 2021 - Published a notice of resumption of the EIS. Subsequently, a Final Environmental Impact Statement (FEIS) was prepared. Pursuant to NEPA, the NOA was issued for the FEIS on March 29, 2024. A11 comments on the FEIS must be submitted by Apri128, 2024, 30 days from the date of publication. The following alternatives are considered in the FEIS: (1) Proposed Project; (2) Proposed Project with No Retail Alternative; (3) Reduced Intensity Alternative; (4) Non-Gaming Alternative; (5) Anderson Site Alternative; (6) Expansion of Existing Casino Alternative; and (7) No Action/No Development Alternative. The BIA has selected Alternative 1, the Proposed Project, as the Preferred Alternative as discussed in the FEIS. Staff has reviewed the FEIS and has drafted the attached comment letter. The comment letter addresses the following resource areas: 1. Socioeconomic Conditions 2. Transportation/Circulation 3. Land Use 4. Public Services 5. Aesthetics Council P�io�ity/City Manager Goals This agenda item is a routine operational item. Attachments ^DEIS COR Response Letter ^Draft Rancheria FEIS Comment Letter-Revised 4/15/24 � ,� i„�, � � , , i�, i � �1'�""�" �� ''F ��;�"7 �:vs��:�.�s ��t^�s�:�, F"�:3�rs;�iG, ��k ��£,tt39 l . ,"� .. F'.�3. �C3� =P"��'s�'7 t, F?EE'�CatP�dG:�. �:�... �fit)L4.°9-�a�}7; � � JULIE WtIVTER,MAYOR 530.225.4447 530.225.4463 FAX May 22, 2019 L-OI0-075-575 Ms. Amy Dutschke U.S. Department of the Interic�r Bureau of Indian Affairs Pacific Region Office 2800 Cottage Way Sacramento, CA 95825 Subject: Comments on the Draft Enviror�mental Impact Statement for the Redding Rancheria Fee-to-Trust and Casino Project T}ear Ms. Dutschke: As a Cooperating Agency pursuant to NEPA for the Redding Rancheria Fee-to-Trust and Casino Praject Environmental Impact Statement, the City af Redding appreciates this opportunity to provide comments on the Draft Environmental Impact Statement (DEIS}. Our comments are as follows: ECONC3MIC IMPACT The fallowing excerpts are from Section 4.7.1, Substitution Effects, of the DEIS: "Potential substitutian effects (the loss of custamers at existing commercial businesses ta the new business) of a tribal casino on existing gaming, restaurant, recreatian, and retail establishments have been considered when evaluating the magnitude of the casino's impact on the economy." "A portian af the substitution effects would come from spending on nan-gaming categories, such as food and beverage,retail, lodging, and entertainment that would have occurred at the competing gaming operations had the gaming spending accurred there rather than at Alternative A. A smaller portian would come from spending that would have accurred at non-gaming related businesses but went to Alternative A instead." Although the report identifies a potentially negative economic impact to existing sparting goods stores in the City of Redding, it does not identify how the impact wi11 be mitigated. The repart suggests the demand for sporting goods in Shasta County cannot support the propased store along Ms. Amy Dutschke Page 2 May 22, 2019 with the existing stores. Existing stores can expect to see a 24 percent decrease in sales as a result of the opening of a new store. The closure of existing stores in Redding will result in a decrease in sales tax revenue to the City of Redding, and vacant stares can lead to an increase in unemployment, erime, and blight. Furthermore,the DEZS fails to provide any analysis of haw the two new entertainment venues will impact the Civic Auditarium. The report simply states that the types of shows that wauld be held at the new venues would not be held at the Civic Auditorium; therefore, there would not be campetition among the sites for shows. This simplistic approach fails to recognize that the market for entertainment acts and shows is very limited based upon our population. The auditoriums proposed are nearly the same size as the Civic Auditorium and would certainly accommodate the same types of events and acts. The Civic Auditorium has a long history af operating at a deficit and thereby depleting valuable financial resources from the City's General Fund. It was not until recently that the Civic Auditorium became self-sufficient. Adding two venues of similar size will certainly lead to competition between the venues and could cause the Civic Auditorium to once again become a burden on the General Fund. TRANSPORTATION/CIRCULATIQN Review comments on the Traffic Impact Study prepared for the project by Kimley-Horn,provided in GHD's Noveml�er 17, 2017, memorandum (attached}, still applies to the Transportation/Circulation sectian of the I)EIS. Peak hour vehicle trip generatiQn is derived in the DEIS based on the peak hour of the generator instead of the peak hour of adjacent street traffic. This likely results in under-estimating the project's traffic impacts. In section 4.8.1, the Hotel trip generation is reduced by 75 percent for internal capture within the proposed development. This seems excessive, given that there would be many attractive options in the immediate area outside of the develapment. The DEIS needs to provide the supporting documentation for the high reductian rate or use a 50 percent reduction. Sectic�n 5.8.2 identifies mitigatian measures for year 2025. These mitigations are for the short- term plus project scenario, not for a cumulative scenario. As such, the proposed praject is 100 percent responsible for the identified short-term mitigation measures. Fair share calculations per Caltrans' guidelines apply to the cumulative year (2040) scenario. DEIS Appendix F provides the Traffic Impact Study for the Rancheria project. Page 15'7 of the Traffic Impact Study references an Appendix I with additional details of the cumulative analysis, which should include the cumulative fair share calculations. However, Appendix I is not provided. The DEIS shauld provide the cumulative fair share calculations in order to determine if appropriate cumulative mitigation has been identified. Additional City comments on the TransportatianiCirculation sectian of the DEIS are contained in the attached memarandum from GHD ta the City af Redding, dated May 13, 2019. Ms. Amy Dutschke Page 3 May 22, 2Q19 LAND USE The following excerpt is from Sectian 4.9.1, Land Use Plans, of the DEIS: "Planning documents currently in effect for the Strawherry Fields Site include the Shasta County General Plan{County General Plan) and the Shasta County Zoning Code." The DEIS fails ta acknowledge that the Strawberry Fields Site is within the City af Redding General P1an Area. The general plan land use classifications of this site consists of°`Greenway" and "Residential-1 Dwelling Unit per 5 Acres and Larger." Pursuant to the 201'7 State af Califarnia General Plan Guidelines, general plans must cover the territory within the boundaries of the adopting city or county, as we11 as "any lands outside its boundaries which in the planning agency's judgement bears relation to its planning" (California Government Code Section 653Q0}. PUBLIC SERVICES ELECTRICITY The following excerpt is from Section 4.10.1, Alternative A—Propased Project, of the DEIS: "The City of Redding's General Plan Policy CDD 1� states the following with respect to the provision of public services: "Require annexatian befare services are pravided by the City,except under extraardinary circumstances." As discussed in more detail below, it is anticipated that the City tnay provide several public services to the projeet, which could include water supply service, wastewater serviee, and electxicity. C�nce the property is taken inta trust, �acalland use regulations would not apply, and neither the County (nor the City, should it pursue annexation af the site) wauld have land use jurisdiction. This wauld constitute extraardinary circumstances as described by the City's General P1an Policy CDD1G. Therefore, it appears that the provision of public serviees to the site by the City would be in accordance with General Plan." The assumption that electrieity ta serve �he project under Alternative A wi�l be provided by REU is speculative since the subject property is located outside of the Redding city limits. �Vhether or not electricity is provided by REU to properties outside the city limits is at the discretion of the Redding City Cauncil. Therefore,the DEIS must also include an analysis of Alternative A withaut electricity provided by REU. WATER SUPPLY Under Alternative A, Water Supply Optian 1, the City af Redding's water supply system would be extended ta the Strawberry Fields Site. Althaugh the City's water service cantract with the U.S. Bureau of Reclamation does nQt permit the City to provide surface water autside of the City's service water contract boundaries, the City has the ability to provide groundwater to the site. Therefore, Alternative A, Water Supply Option l, is a patentially feasible option, althaugh any such service is at the discretion of the City Couneil. NIs. Amy Dutschke Page 4 May 22, 2019 WASTEWATER SERVICE As specified in Section 4.10.1, Wastewater Service, af the DEIS, additional capacity is needed in the City's wastewater system just north of the Clear Creek WWTP. The project that will address this capacity issue is the Westside Interceptor Phase III pipeline, which is scheduled far construction in FY20/21-FY21/22. Any service of wastewater wi11 be at the discretian of the City Council. Please make the following edits to the noted partions of the document: 1. First paragraph on page 4.3-'7, On-site Water Supply (Option 2): "Wastewater" shauld be Water Supply. 2. The following excerpt is from the last paragraph on page 4.3-13, Altemative D — Non- Gaming Alternative, Development at the Strawberry Fields Site, Stormwater Runoff: °`The vegetated swale would have an infiltration capacity of 182 cfs, which is significantly more than the projected l OQ-year storm event runoff flow of 117 cfs." Please elaborate on how the 182 cfs of infiltration will be achieved in the vegetated biaswale. AESTHETICS The foliowing excerpt is fram Section 4.13-1, Aesthetics-Operational Impacts, of the DEIS: "The propased develapment would substantially alter the visual character of the northern partion of the site by transforming it from rural, undeveloped greenspace along the Sacramento River ta commercial development. Hawever,the proposed development wauld not be out of character with typical roadside development adjacent to I-5 (such as large commercial developments, including the Mt. Shasta Ma11, located along I-5 within the City of Redding), nor would it impede views of scenic resources," We do not concur with the canclusion that the proposed develapment wauld not be out of character with typical roadside development adjacent to I-5 and wauld not impede views of scenic resources. Within the City of Redding, existing, approved, and proposed developments adjacent to I-5 differ substantially from the character of the proposed project with respect to building mass and height. The proposed 9-story hotel is substantially taller than any other existing, approved, or proposed building adjacent tQ I-5 within the City of Redding. Althaugh the proposed height of the parking structure is not specified, it appears to be four stories;there are no existing, approved, or proposed parking structures within the City of Redding adjacent to I-5. As illustrated in Exhibit 4.13-2,the proposed hotel and parking structure would substantially impede the visibility of the mountains, which are currently visible alang the west side of I-5 at the City's southern gateway. The propased sign plan must be mare clearly described; it is not clear if the five large panels depicted along the front of the parking structure are proposed signs and, if so, what type af signs are proposed. If these panels are proposed signs,then the project's signage wauld be substantially Ms. Amy Dutschke Page 5 May 22, 2019 � out of character with existing, appraved, and proposed signage adjacent to I-5 within the City af Redding. This issue would be further exacerbated if these signs would be electronic message board signs, which are prahibited within the City af Redding. The City of Redding looks forward to continued caaperation with the BIA regarding this project and would welcome the opportunity to meet with BIA staff, BIA consultants, andlor Redding Rancheria representatives to discuss our comments in further detail. Si cerely, ��..�. ��`kz �� , � �J lie Winter ayor Attachments cc: Redding City Council Barry DeWalt, City Attorney Chuck Aukland, Public �orks Director/City Engineer Chief Roger Moore, Redding Police Department Chief Cu11en Kreider, Redding Fire Department Daniel Beans, Redding Electric Utility Director Larry Vaupel, Development Services Director John Abshier, Assistant Public Works Director � ( T Y F �ITY C?� � 1 C = 777 �ypress l�venue, Reddir�g, �A 96C}t�1 �' F�C� �(�X 4��C�71, F�edc�lr�g, CA �6�49-�071 ,- .-.'. C L 1 F � �� ci�yofredciir�g.org ,:�nY� . ..., Tenessa Audette,Mayor taudette@cityofredding.org 530.225.4447 April 16, 2024 Amy Dutschke,Regional Director Chad Broussard,Environmental Pro�ection Specialist Bureau of Indian Affairs Bureau of Indian Affair Pacific Regional Office Pacific Regional Offce 2800 Cottage Way 2800 Cottage Way, Room W-2820 Sacramento, CA 95825 Sacramento, CA 95825 via electronic mail: chad.broussard@bia.gov SUBJECT: FEIS COMMENTS,Redding Rancheria Project Dear Director Dutschke and Mr. Broussard, The City of Redding (City), as a Cooperating Agency, pursuant to NEPA for�he Final Environmental Impact Statement (FEIS) for the Redding Rancheria Win-River Casino Relocation Project (City) appreciates this opportunity to provide comments regarding this Project as follows: � � ECONOMIC IMPACT The following excerpts are from Section 4.7.1, Substitution Effects, of the FEIS: `Potential substitution effects (the loss of custoineNs a�existing comfneNcial businesses to the new business) of � �� a t�ibal casino on existinggaming, �estau�ant, rec�eation, and�etail establishments have been consideNed when'� �� evaluating the magnitude of the casino's impact on the economy." � � � � `A portion of the substitution effects would come fi�om spending on non-gaming categories, such as,food and beverage, retail, lodging, and entertain�nent that would have occurred at the corrzpeting gaming operations had the gaming spending occurred there rather than at Alternative A. A smaller portion�would come from spending � that would have occu�ed at non-gaming related businesses but went to Alternative A instead. " � �� The FEIS identifies a possible negative economic impact to existing sporting goods stores in the Cit�; yet dc�es not identify how these will be mitigated. The demand for sporting goods in Shasta County cannot s�pport the existing stores along with the additional store being proposed. Existing stores can expect to see a 24%decrease in sales as a result of the new store opening. The closure of existing stores in Redding wi11 result in a decrease in sales tax revenue to the City. Vacant stores can lead to an inerease in unemployment,'�erime;�and blight. �� Furthermore, the FEIS fails to provide any analysis of how the two proposed�entertainrr�ent venues wil] impact Civic Auditorium. The report simply states that the types of shows that.would.,be held at tl�e prop�sed new venues would not be the type held at the Civic Audit��iu�n; therefore, there would not be eompetitic�n among the sites. This simplistic approach fails to recogniz� that the.market for entertainment acts and shows is �ery limited based upon our population.The auditoriums:�ropos�d�re nearly identical in size to the Civic Auditorium FEIS'Comments,Redding Rancheria Project April 16, 2024 City of Redding Page 2 of 5 and would certainly accommodate the same types of events and acts. The Civic Auditorium has a long history of operating in a deficit, thereby depleting valuable financial resources froin the City's General Fund. It wasn't until very recently that the Civic Auditorium became self-sufficient.Adding two new venues of similar size will certainly lead to competition between the venues and could cause the Civic Auditorium to once again become a burden on the City's General Fund. TRANSPORTATION/CIRCULATION Section 4.8, Transportation/Circulation,of the FEIS summarizes the Traffic Impact Study- Redding Rancheria (TIS)prepared by Kimley-Horn(2023 Update)and attached to the FEIS as Appendix Q. The following excerpt is from Section 4.8.1, Transportation/Ci�culation—Analysis Methodology of the FEIS: "Typical F�iday PMand Saturday PMpeak hou�s were chosen fo�representative samples ofpeak hou�activity based on existing tr�affic volume info�mation and expected t�ip gene�ation of the Proposed P�oject." After detailed analysis (attached} and independent verification, the City has concluded that the Weekday AM and PM peak hours do not represent the peak hour activity. The City's analysis has indicated that the Saturday Mid-Day peak hour(not analyzed in the TIS)represents the peak hour activity. The City's independent analysis indicates that the Saturday Mid-Day peak hour is likely to generate 16.5%higher traffic volumes than either the Friday ar Saturday PM peak hours that were assumed as the peak hour activity, analyzed in the TIS and included in the FEIS. Although an inerease in traffie volume of ]6.5% �nay not seem signifieant, the addition of any traffic to roadway infrastructure that is eurrently operating at or near its eapaeity, can have signifieant impacts on operations and safety. Therefore, tl�e FEIS must include an evaluation on the Saturday Mid-Day peak hour traffic condition and update all corresponding analyses and mitigations, accordingly, in order to accurately identify impacts and determine appropriate mitigation measures. Additionally, Section 4.8, TNanspoNtation/Ci�culation, of the FEIS(including the TIS as included as Appendix Q)fails to accurately eval�uate either an Opening Year plus Project or a Cumulative and Cumulative plus Project� � �� scenario. These analyses are critical in detennining whether the existing in-place and programmed future transportation infrastructure have the capacity to accommodate the traffic generated by the Project.Furthermore,� �� the FEIS does not inelude an accurate representation of the current transportation infrastructure in the general, vieinity of the Projeet. Therefore, the FEIS must aceurately evaluate the omitted industry standard traffie analysis scenarios in order to aeeurately identify impaets and determine appropriate mitigation measures. Seetion 4.8, Transportation/Circulation, of the FEIS (ineluding the TIS as ineluded as Appendix Q) vehicle � queuing and operations were not evaluated along the South Bonnyview Road corridor. Given the closely spaced � � intersections (roundabouts, signals, on/off ramps, driveways, etc.) a high-level, detailed analysis is requ�red to estimate vehicular capacities, delays and queuing. The FEIS does not include such an analysis. Therefore, the FEIS must perform a high-level, detailed operational analysis of the South Bonnyview Road corridor in order to accurately identify impacts and determine appropriate mitigation measures. � � � The following excerpt is from Section 5.8, Transportation, of the FEIS: "Whe�e t�anspo�tation infrastructu�e is shown as having an unacceptable level of seyvice� (LOS), with the addition of traffzc from the Project alternatives (and caused at least in part froin Project tra�c), the T�ibe shall pay for a fair share of costs for the recommended mitigation (including �ight-of-way and any other environmental mitigation). In such cases, the Tribe shall be responsible for the incrementaZ impact that the added Project t�ips generate, calculated as a percentage of the costs involved foN conrtr�uction of the rr2itzgation measure (�efe�^ed to as the fai� share). The fai� share is calculated using the �reethodology��esented in t�ie Calt�ans Guide for the Prepa�ation of T�a�c Im,�a�t�'�z�di�s (2002; Appendix:F). The Ti^ibe.shall �nake fair share contributions available p�io�to initiation a��?r�je�t ea�st�uction." �_; � FEIS'Comments,Redding Rancheria Project April 16, 2024 City of Redding Page 3 of 5 The City contests the FEIS, as it failed to follow standard industry practices regarding Traffic Impact Studies by not considering the appropriate peak hour activity, using faulty assumptions in critical analysis scenarios (Opening Day plus Project as well as Cumulative and Cumulative plus Project) and inadequately evaluating vehicular operations along the South Bonnyview Road corridor. As a result, the impacts identified in the FEIS and assumption of a fair share contribution are not founded on the appropriate analyses. Therefore, the FEIS must adjust the analyses to include the highest peak hour activity, use appropriate assumptions in critical scenarios and perform a detailed analysis of the South Bonnyview Road corridor in arder to accurately identify impacts and determine appropriate mitigation measures. PUBLIC SERVICES ELECTRICITY The following excerpt is from Section 4.10.1,Alternative A—P�oposed Project, of the FEIS: "The City of Redding's Gene�al Plan Policy CDDI G states the following with respect to the provision ofpublic services "Require annexation before services are provided by the City, except under extraordinary ci�cuinstances."As discussed in mo�e detail below, it is anticipated that the City may provide several public services to the project, which could include water supply service, wastewater service, and electricity. Once the p�opeNty is taken into trust, local land use �egulations would not apply, and neither the County (no� the City, should it pu�sue annexation of the site) would have land use ju�isdiction. This would constitute extraoNdinary ci�cumstances as described by the City's Gene�al Plan Policy CDDI G. Therefore, it appears that the provision ofpublic services to the site by the City would be in accordance with General Plan." The assumption that electricity to serve the project under Alternative A will be provided by the City's Electric � Utility (REU) is speculative since the subject property is located outside of the City Limits. Whether or not � � electricity is provided by REU to properties outside the City Limits is at the discretion of tbe Redding City� � �� Council. Therefore, the FEIS must also include an analysis of Alternative A without electricity provided by REU. WATER SUPPLY As specified in Volume II Appendices, Appendix M, 4.3 Off-Site Option: City af Redding WateN Service,°�� 4.3.1 City of Redding Water System Design Criteria,the City's water supply system would need to be extended to the Project Site. Although the City's water service contract with the U.S. Bureau of Reclamation does not permit the City to provide surface water outside of the City's service water contract boundaries,the City�ias the ability to provide groundwater to the Project site. Therefore,4.3 Off-Site Option: City Provided D�inking Wate� Service, is a potentially feasible option, although any such service is at the discretion of the Redding City Council. � � � Detailed analysis of the City's water system capacity and adjacent infrastructure is required at final des�gn stages for acYual capacity and fuYure needs. WASTEWATER SERVICE As specified in Volume II Appendices,Appendix M, 3.4 Off-Site Option:�City Provided SeweN Services, 3.4:1, City of Redding Wastewater Design Criteria, additional capacity is needed in the`�City's��waste�ater s�stern ji�st north of the Clear Creek Wastewater Treatment Plant. The project that will address tl�is cap�city is�ue is the Westside Intereeptor Phase IlI pipeline projeet, whic�i's��c�rently in design and�is anticipated�for constructic�n FEIS'Comments,Redding Rancheria Project April 16, 2024 City of Redding Page 4 of 5 in 2025. The FEIS references the City's 2012 Wastewater 1Vlaster Plan. There is a new 2022 Wastewater Master P1an available and sha11 be used for current and future analysis. Detailed analysis of the City's Sunnyhill Lift Station and adjacent upstream and downstream collection system is required at final design stages for actual capacity and future needs. 5.1 Onsite Wastewate� Management, 5.1.1, includes a reference to "dewatered solids for proper landfill disposal." Per AB 341, landfills will no longer accept wastewater biosolids by 2025. Similar reference was found in section 5.1.5. Whether or not wastewater service is provided to properties outside the City Limits is at the discretion of the Redding City Council. AESTHETICS The following excerpt is from Section 4.13-1,Aesthetics-Operationallmpact.s, of the FEIS: "The pNoposed developinent would substantially alte�the visual charac�eN of the noNthern poNtion of�he site by transfo�ming it frorr� �ural, undeveloped g�eenspace along the Sac�amento Rive� to con�mercial developsnent. However the proposed development would not be out of character with typical roadside development adjacent to I-5(such as large comn�ercial d�velopnzents, including the Mt.Shasta Mall, located alongl-S within the Czty), nor would it impede views of scenic resources." We do not concur with the conclusion that the proposed development would not be out of character with typical roadside development adjacent to I-5 and would not impede views of scenic resources. Within the City,existing, approved, and proposed developments adjacent to I-5 differ substantially from the character of the proposed project with respect to building mass and height. The proposed nine-story hotel is substantially taller than any other existing, approved, or proposed building adjacent to I-5 within the City. Although the proposed height of the parking strueture is not speeified, it appears to be four stories; there are no existing, approved, or proposed parking structures within the City adj aeent to I-5. As illustrated in Exhibit 4.13-2,the proposed hotel and parking � strueture would substantially impede the visibility of the mountains which are eurrently visible along the west� �� side of I-5 at the City's southern gateway. � �� The proposed sign plan must be more clearly described; it is not clear if the five large panels depicted along the: front of the parking structure are proposed signs and, if so, what type of signs are proposed. If these panels are proposed signs, then the project's signage would be substantially out of character with existing, approved, and proposed signage adjacent to I-5 within the City. This issue would be further exacerbated if these signs are electronic message board signs, which are prohibited within the City. � " �� CULTURAL RESOURCES � � �� Cultural pedestrian surveys were conducted on a large area that includes the Alternative "A" development site, the utility corridor, and the northern and southern access routes. However, Extended Phase I or Phase II subsurface testing was not performed within the proposed water and wastewater utility corridors. As discussed in the FEIS, CA-SHA-4413 lies immediately south of the proposed utility corridor. While the studies concludes that CA-SI-IA-4413 is not eligible for listing in the National Register and development of Alternative "A" (Strawberry Fields Site) would not result in direct adverse effects to 'known historic properties, the FEIS also indicates that unknown aspects of CA-SI-IA-4413 may��be uncovered during construction, which would change the evaluation ca��e site's National Register of Historic Places'(NRHP) eligibility. � �� FEIS'Comments,Redding Rancheria Project April 16, 2024 City of Redding Page 5 of 5 If the City were to consider a utility agreement with the Redding Rancheria, additional studies and information regarding potential cultural impacts would be required. Extended Phase I, and possibly Phase I�I, studies will be required to determine if CA-SHA-4413 extends into the utility corridor and if any newly discovered resources would change the evaluation of the site's NRI IP eligibility. The FEIS mitigation measures were updated to include preparation of an Unanticipated Discovery Plan to address the treatment of any newly discovered resources. While this type of plan is always beneficial, it does not negate the need to perform all necessary technical studies required to eval�uate the project's impact on the environment. The City has determined that the cultural studies are incomplete, as testing was not performed in a proposed area of direct impact (utility corridor) that is immediately adjacent to a known cult�ural site. Pursuant to Section 21001.1 of the California Environmental Quality Act (CEQA) Guidelines, it is the policy of the State of California, that projects to be carried out by public agencies be subject to the same level of review and consideration as that of private projects required to be approved by public agencies. Accordingly, any agreements ar projects involving City infrastructure would be subject to environmental. review under CEQA. The City looks forward to continued cooperation with the BIA regarding this project and welcomes the opportunity to meet with BIAs staff and/or its consultants, and/or Redding Rancheria representatives to discuss our comments in further detail. Sincerely, Tenessa Audette Mayor ` City of Redding � � � �� Attachment—Technical Memarandum(GHD, 202�) � �� Technical Memorandum Apri I 11, 2024 • Michael Webb, PE Director of Public Works, City of Redding •• • Russell Wenham, PE, TE, PTOE •• • Joshua Anthony, City of Redding • Kamesh Vedula, PE,TE • • - • 12639045 • • - Redding Rancheria Strawberry Fields Final EIS Review • - Review of the Transportation/Circulation Sections of the Final EIS for the Redding Rancheria Fee-to-Trust and Casino Project(Casino Project) Executive Summary This memorandum documents GHD's review of the Traffic lmpact Study Redding Rancheria, February 2023 prepared by Kimley-Horn for the Redding Rancheria Casino Project's Final Environmental impact Statement (FEIS). The review was performed at the request of the City of Redding (City)for the purpose of assisting the City with their assessment of the adequacy of the FEIS as related to the determination of transportation/circulation impacts and mitigation measures that will be necessary for the Casino Project. GHD's key findings are summarized below: 1. An industry standard Weekday AM Peak Hour analysis was not perFormed. • GHD concludes that the Weekday AM Peak Hour is not a controlling condition and therefore, omitting the standard analysis does not create issues for the City. No additional work related to the Weekday AM Peak Hour condition is required for the City to have the information needed to determine impacts and mitigation measures for the Casino Project. 2. An industry standard Weekday PM Peak Hour analysis was not performed. • The industry standard is to analyze the Weekday PM Peak Hour, which is the one hour with the highest traffic volume between 4:00 PM and 6:00 PM, on a typical weekday (Tuesday, Wednesday, or Thursday). This analysis period was requested in the City's May 22, 2019 written comments on the Draft EIS. • The FEIS asserts that the Friday PM Peak Hour, in the Plus Casino Project condition, is a controlling condition as opposed to the industry standard Tuesday, Wednesday, or Thursday. • GHD used available traffic data, and collected new traffic data, to assess the impact of analyzing the Friday PM Peak Hour vs the standard Weekday PM Peak Hour. • Based on GHD's analysis, the Weekday PM Peak Hour in Opening Year(2025) Plus Casino Project conditions are approximately equivalent to the Friday PM Peak Hour in Opening Year(2025) Plus Casino Project conditions. This Technical Memorandum is provided as an interim output under our agreement with City of Redding.It is provided to foster discussion in relation to technical matters associated with the project and should not be relied upon in any way. � The Power of Commitment 12639045 1 • GHD concludes that the Weekday PM Peak Hour conditions are not expected to resuit in new impacts that have not already been identified under the Friday PM Peak Hour. No additional work related to the Weekday PM Peak Hour condition is required for the City to have the information needed to determine impacts and mitigation measures for the Casino Project. 3. An industry standard Saturday Mid-Day Peak Hour analysis was not performed. • The industry standard is to analyze the Saturday Mid-Day Peak Hour, in the Plus Casino Project condition, which is the one hour with the highest traffic volumes between 11:00 AM and 3:00 PM, on a typical Saturday. This analysis period was requested in the City's May 22, 2019 written comments on the Draft EIS. • GHD used available traffic data, and collected new traffic data, to assess the impact of analyzing the Saturday PM Peak Hour vs the standard Saturday Mid-Day Peak Hour. • Based on GHD's analysis, Saturday Mid-Day Peak Hour in Opening Year(2025) Plus Casino Project conditions are estimated to have 16.5% higher traffic volumes than the Saturday PM Peak Hour in Opening Year(2025) Plus Casino Project conditions. • The FEIS incorrectly asserts that the Saturday PM Peak Hour is a controlling condition. • As such, the FEIS significantly underestimates the controlling Saturday Peak Hour traffic conditions and thus does not provide the information needed to determine impacts and mitigation measures for the Casino Project. 4. An Existing (or Opening/Baseline Year) Plus Casino Project impact analysis is required. = This scenario is needed to determine the impacts and transportation solutions necessary if the Casino Project proceeds as proposed (occupancy in year 2025 as stated in the FEIS)and no other roadway improvements are in place for the greater freeway interchange area. This is a critical analysis scenario since the City currently does not have funding for major freeway interchange upgrades to accommodate City, County, and Casino Project traffic. • The FEIS did not include an accurate representation of the baseline conditions as it pertains to the roadway infrastructure. In November 2022, major freeway ramp improvements and the construction of the Bechelli Lane multi-lane roundabout were substantially completed and open to traffic. An analysis that models the interplay of the closely spaced intersections along the South Bonnyview Road corridor was not performed for the FEIS. As such, the FEIS does not provide the information that the City needs to determine impacts and mitigation measures for the Opening Year(2025) Plus Casino Project conditions. 5. A Cumulative and a Cumulative Plus Casino Project analysis is required for the in-place roadway infrastructure in the greater freeway interchange area. • This scenario is needed to determine the impacts and transportation solutions necessary if the Casino proceeds as proposed and no other roadway infrastructure improvements are in place for the greater freeway interchange area. • The FEIS does not include analysis of the in-place roadway infrastructure nor the impact of the Casino Project on the current in-place roadway infrastructure. An analysis that models the interplay of the closely spaced intersections along the South Bonnyview Road corridor was not performed. As such, GHD concludes that the FEIS does not provide the information that the City needs to determine impacts and mitigation measures for the Cumulative Year Plus Casino Project conditions. 6. The FEIS does not provide the required traffic modeling to determine vehicle queues. • In the freeway interchange area, the closely spaced intersections along the South Bonnyview Road corridor present unique interplay between intersections. The combination of closely spaced roundabouts and traffic signals requires the highest-level traffic modeling to estimate vehicular capacities, delays, and queuing. The FEIS does not provide this analysis. This Technical Memorandum is provided under our agreement with City of Redding.It is provided to foster discussion in relation to technical matters associated with the Casino Project and should not be relied upon for other purposes. 12639045 2 • As such, the FEIS does not provide the information that the City needs to determine impacts and mitigation measures for the Opening Year(2025) Plus Casino Project conditions or for the Cumulative Plus Project conditions. 7. The mitigations proposed in the FEIS are incomplete. • As stated above: o The Saturday Mid-Day Peak Hour conditions need to be analyzed to determine impacts and mitigation measures. o An analysis of the Casino Project traffic on the actual in-place roadway conditions was not perFormed. o Traffic modelling that addresses capacities, delays, and queuing, in the context of closely spaced roundabouts and traffic signals, has not been perFormed. • The future Cumulative condition freeway interchange improvements, shown in the October 30, 2017 Project Study Report are very conceptual in nature when considering the cumulative impact of the Casino Project. Additionally, these same conceptual improvements are presented in the year 2020 River Crossing Marketplace Specific Plan Final Environmental Impact Report(EIR)associated with approval of the Costco project. The conceptual improvements (along with the development of the Casino Project)were presented with the EIR, but were considered speculative. Said conceptual improvements will require significant vetting with additional traffic analysis and preliminary designs to determine viability. � A funding mechanism for the Diverging Diamond Interchange and second roundabout is not in place. Pursuant to Anderson First Coalition vs. City of Anderson (June 30, 2005), the environmental document should not count on "...speculative traffic mitigation measures..."that are not reasonably funded/programmed. Put another way, an approving agency should not assume a future road improvement will be in place unless the assertion can be supported by actual funding mechanisms and plans. With the very significant traffic impacts anticipated from the Casino Project, mitigation measures that require the construction of the improvements, as opposed to simply a "fair-share" payment, are required. The details of reimbursements and cost sharing can be deferred beyond the approval of the environmental document, but the fact that the mitigation improvements need to be constructed cannot be overlooked. This Technical Memorandum is provided under our agreement with City of Redding.It is provided to foster discussion in relation to technical matters associated with the Casino Project and should not be relied upon for other purposes. 12639045 3 1 . Weekday AM Peak Hour Introduction A Weekday AM Peak Hour analysis was requested in the City's written comments on the Draft EIS (May 22, 2019). The industry standard is to analyze the Weekday AM Peak Hour, which is the one hour with the highest traffic volumes between 7:00 PM and 9:00 AM, on a typical weekday (Tuesday, Wednesday, or Thursday). The FEIS does not include a Weekday AM Peak Hour analysis, asserting that the Friday PM Peak Hour is a controlling condition as opposed to the industry standard Weekday AM Peak Hour. The City requested GHD to provide further analysis to determine if the Weekday AM Peak Hour is likely to cause new impacts that have not already been identified. Findings Based on the available data, the industry standard Weekday AM Peak Hour volumes are approximately 12% less than the Friday PM Peak Hour volumes presented in the FEIS. Based on this investigation, the Weekday AM Peak Hour conditions are not expected to result in new impacts that have not already been identified and therefore, omitting the standard analysis does not create issues for the City. No additional work related to this Peak Hour condition is required for the City to have the information needed to determine impacts and mitigation measures for the Casino Project. Analysis Casino Project Trips Based on trip making characteristics at the Win-River casino, it was concluded that the Casino trips for the Weekday AM Peak Hour were found to be 56% lower than the Friday PM Peak Hour Casino trips. Opening Year(2025) Plus Casino Project Conditions The associated Casino Project trips were added to the Opening Year volumes consistent with the methodologies identified in the FEIS to estimate the Opening Year(2025) Plus Casino Project conditions. Refer to Table 1.1 Error! Reference source not found. for the comparison of the estimated (derived)Weekday AM Peak Hour volumes and the FEIS Friday PM Peak Hour volumes. Given that the Weekday AM Peak Hour volumes are around 12% lower than the FEIS Friday PM Peak Hour volumes, the Weekday PM Peak Hour conditions are not expected to result in new impacts that have not already been identified. This Technical Memorandum is provided under our agreement with City of Redding.It is provided to foster discussion in relation to technical matters associated with the Casino Project and should not be relied upon for other purposes. 12639045 4 '�alad�9.2 �hl�'s��dirrrat�e�(�erive�)��ra±rag 1��ar(2Q2�)Plaas�asira�Pr��d @l�lu �s f�r VV��ic��r A P��lr hfour . .. �- -. �- -. .. � . .. .. .- . . . - . . . - •. . . - . • •. . . . . . . i Bechelli Lane&South ; 3,383 ; 637 ; 4,020 '�� 4,780 � -15.9°/o � Bonnyview Road Southbound I-5 Ramps ; 3,376 483 3,859 4,666 -17.3% &South Bonnyview ; Road � Northbound I-5 Ramps ? 3,185 ` 248 i 3,433 �� 3,640 : -5.7% &South Bonnyview ; Road ; Churn Creek Road& 2,533 24 2,557 '. 2,633 -2.9°/o South Bonnyview Road ; Total Entering Traffic ; 12,477 ; 1,392 ; 13,869 ° 15,719 -11,8% , Volume i 1 Peak Hour fotals are the sum of all fraffic entering the infersection 2 Source:"Year 2020 Plus Project Weekday AM and PM Peak Hour Traffic Voiumes';River Crossing Marketpiace Specific Pian TIAR, September 2019 _ ; 3 Estimated to be approximately 56%of the FEIS'Friday PM Peak hour project trips ;.. 4 Estimated to be Weekday AM Peak Hour total plus derived Weekday AM Casino Project Trips i 5 Source:Figure 36, "Year 2025 plus Project Friday/Safurday Peak Hour Volumes(1A)';FEIS 2. Weekday PM Peak Hour Introduction A Weekday PM Peak Hour analysis was requested in the City's written comments on the Draft EIS (May 22, 2019). The industry standard is to analyze the Weekday PM Peak Hour, which is the one hour with the highest traffic volumes between 4:00 PM and 6:00 PM, on a typical weekday (Tuesday, Wednesday, or Thursday). The FEIS does not include a Weekday PM Peak Hour analysis, asserting that the Friday PM Peak Hour is a controlling condition as opposed to the industry standard Weekday PM Peak Hour. The City requested GHD to provide further analysis to determine if the Weekday PM Peak Hour is likely to cause new impacts that have not already been identified. Findings Based on the available data, the industry standard Weekday PM Peak Hour volumes are only around 1°/a higher than the Friday PM Peak Hour volumes presented in the FEIS. Based on this investigation, the Weekday PM Peak Hour conditions are not expected to result in new impacts that have not already been identified and therefore, omitting the standard analysis does not create issues for the City. This Technical Memorandum is provided under our agreement with City of Redding.It is provided to foster discussion in relation to technical matters associated with the Casino Project and should not be relied upon for other purposes. 12639045 5 Analysis Casino Project Trips Based on trip making characteristics at the Win-River casino, it was concluded that the Casino trips for the Weekday PM Peak Hour are 9% lower than the Friday PM Peak Hour Casino trips. Opening Year(2025) Plus Casino Project Conditions The associated Casino Project trips were added to the Opening Year volumes consistent with the methodologies identified in the FEIS to estimate the Opening Year(2025} Plus Casino Project conditions. Refer to Table 2.1 Error! Reference source not found. for the comparison of the estimated (derived)Weekday PM Peak Hour volumes and the FEIS Friday PM Peak Hour volumes. Given that the Weekday PM Peak Hour volumes are only around 1% higher than the FEIS Friday PM Peak Hour volumes, the Weekday PM Peak Hour conditions are not expected to result in new impacts that have not already been identified. 7"a�(�2.A �tf�'��f/r�e�f��rf��c8}��raieag Y�ar��)�Ic�.��a�ino�r��e�t Ef�(ae �s f�t� ��k�ay� �eaYc F6our . •. •- -• •- -• •. � . •. •. •- . . . - . . . - •. . • . . •. . . . . . � Bechelli Lane& ; 3,786 ; 1,038 �� 4,824 ; 4,780 , 0,9% ; South Bonnyview Road i Southbound I-5 3,949 ; 788 � 4,737 ; 4,666 �� 1,5% Ramps&South Bonnyview Road Northbound I-5 3,272 ; 404 3,676 3,640 1.0% Ramps&South Bonnyview Road Churn Creek Road , 2,596 39 '' 2,635 2,633 ; 0.1% &South Bonnyview ' Road Total Entering ��, 13,603 ; 2,269 '�� 15,872 ` 15,719 ' 0.97% Traffic Volume 1 Peak Hour totals are the sum of all traffic entering the intersection � 2 Source:"Year 2020 Pfus Project Weekday AM and PM Peak Hour Traffic Volumes';River Crossing Marketplace Specific Pfan TIAR, ` September 2019 3 Estimated to be approximately 91%of the FEIS'Friday PM Peak hour project trips � 4 Esfimafed to be Weekday PM Peak Nour tofaf plus derived Weekday PM Casino Project Trips . . ... ... ... ... 5 Source:Figure 36, "Year 2025 plus Project Friday/Saturday Peak Hour Volumes(1A)'; FEIS This Technical Memorandum is provided under our agreement with City of Redding.It is provided to foster discussion in relation to technical matters associated with the Casino Project and should not be relied upon for other purposes. 12639045 6 3. Saturday Peak Hour Introduction A Saturday Mid-Day Peak Hour analysis was requested in the City's written comments on the Draft EIS (May 22, 2019). The industry standard is to analyze the Saturday Mid-Day Peak Hour, which is the highest one hour between 11:00 PM and 3:00 PM, on a typical Saturday. The FEIS does not include a Saturday Mid-Day Peak Hour analysis, asserting the Saturday PM Peak Hour is a controlling condition as opposed to the industry standard Saturday Mid-Day Peak Hour. The City requested GHD to provide further analysis to determine if the Saturday Mid-Day Peak Hour is likely to cause new impacts that have not already been identified. Findings Based on this investigation, the industry standard Saturday Mid-Day Peak Hour represents a worse condition than the Saturday PM Peak Hour analysis presented in the FEIS. Therefore, the FEIS underestimates the controlling Saturday Peak Hour conditions and thus does not provide the information needed to determine impacts and mitigation measures for the Casino Project. Analysis Peak Hour Determination Saturday intersection counts in the greater freeway interchange area were performed on Saturday, April 30, 2024, by Counts Unlimited (subconsultant to GHD). The counts at these intersections were for a 6-hour period, from 11:00 AM to 5:00 PM and provide GHD with the information necessary to determine the hourly traffic loading on the freeway interchange area. In addition, 24-hour traffic counts (with 15-minute subtotals)were collected at the following locations: — Redding Rancheria Road,just north of the Canyon Road intersection, in Redding, California • This count data provided GHD with the hourly distribution of traffic at the Redding Rancheria, which includes the Win-River Casino complex — Everett Freeman Way,just south of Liberal Avenue, in Corning, California • This count data provided GHD with the hourly distribution of the traffic at the Rolling Hilis Casino complex Note: GHD collected traffic counts at Redding Rancheria and at Rolling Hills Casino in 2019 in addition to the counts listed above. These traffic counts were reviewed by GHD and used in support of this Memorandum. The Saturday Mid-Day Peak Hour for the adjacent street traffic was determined to be at 12:30 PM, per intersection and daily counts in the greater interchange area. Casino Project Trips Based on trip making characteristics at the Win-River casino, it was concluded that the Casino Project trips between 12:30 PM and 1:30 PM when the adjacent street traffic peaks (Saturday Mid-Day Peak Hour)are 12% lower than the Saturday PM Peak Hour Casino trips. This Technical Memorandum is provided under our agreement with City of Redding.It is provided to foster discussion in relation to technical matters associated with the Casino Project and should not be relied upon for other purposes. 12639045 7 Opening Year(2025) Plus Casino Project Conditions The associated Casino Project trips were added to the Opening Year volumes consistent with the methodologies identified in the FEIS to estimate the Opening Year(2025) Plus Casino Project conditions. Refer to Table 3.1 Error! Reference source not found. for the comparison of the estimated (derived) Saturday Mid- Day Peak Hour volumes and the FEIS Saturday PM Peak Hour volumes. Given that the Saturday Mid-Day Peak Hour volumes were approximately 16.5% higher than the FEIS' Saturday PM Peak Hour volumes, an updated Opening Year(2025)and Opening Year(2025) Plus Casino Project analysis is recommended for the Saturday Mid-Day Peak Hour of the adjacent street. 'T��6�3e 1 �l�t�'s��fi�rra#�cf��r°ived)��aerrirr��°�ar(2025)�lu��in��r�je��s�6crra��f�a��a�srrc��y ia'-�a��ak tf��r . .. �- -. �- -. .. � . �, ., . ., . .- . �. . �. . . .. . . . . . . - . �, . . . .. . . . . ; Bechelli Lane&South ; 2,877 ; 1,199 ; 4,076 �'� 3,419 ; 19,2% : Bonnyview Road Southbound I-5 Ramps i 3,090 i 912 ; 4,002 '�� 3,366 � 18,9% ; &South Bonnyview Road i Northbound I-5 Ramps 2,610 ` 465 3,075 �� 2,591 ; 18,7% &South Bonnyview ; Road ; Churn Creek Road& ; 1,925 � 45 � 1,970 ', 1,886 4,5% South Bonnyview Road � Total Entering Traffic ` 10,502 ; 2,621 ; 13,123 '^ 11,262 ; 16.5% Volume , ; 1 Peak Hour totals are the sum of all traffic entering the intersection 2 Source:"Year 2020 Plus Project Saturday Mid-Day Peak Hour Traffic Volumes"River Crossing Marketplace Specific Plan TIAR, September 2019 3 Estimated to be approximately 88%of the FEIS'Saturday peak hour trips plus the 2024 intersection peak hour volumes 4 Estimated to be Saturday Mid-Day Peak Hour total plus derived Saturday Mid-Day Casino Project Trips ______� ; � 5 Source:Figure 36, "Year 2025 plus Project Friday/Safurday Peak Hour Volumes(1A)",FEIS 4. Existing (or Opening/Baseline Year) Plus Casino Project Analysis Introduction Baseline Plus Casino Project analysis is needed to determine the impacts and transportation solutions necessary if the Casino Project proceeds as proposed (occupancy in year 2025 as stated in the FEIS)and no other roadway improvements are in place for the greater freeway interchange area. This is a critical analysis scenario, since the City currently does not have funding for major freeway interchange upgrades to accommodate City, County, and Casino Project traffic. This Technical Memorandum is provided under our agreement with City of Redding.It is provided to foster discussion in relation to technical matters associated with the Casino Project and should not be relied upon for other purposes. 12639045 8 Findings The FEIS did not include an accurate representation of the baseline conditions as it pertains to the roadway infrastructure. In November 2022, major freeway ramp improvements and the Bechelli Lane multi-lane roundabout were substantially completed and open to traffic. An analysis that models the interplay of the closely spaced intersections along the South Bonnyview Road corridor was not performed for the FEIS. GHD concludes that the FEIS does not provide the information that the City needs to determine impacts and mitigation measures for the Opening Year(2025 Plus Casino Project Conditions in the Friday PM Peak Hour. 5. Cumulative Plus Casino Project Analysis Introduction The Cumulative and Cumulative Plus Casino Project conditions are needed to determine the impacts and transportation solutions necessary if the Casino proceeds as proposed and no other improvements are in place for the greater freeway interchange area. Findings GHD concludes the following for the Cumulative and Cumulative Plus Casino Project conditions. • The Weekday AM Peak Hour analysis is not a controlling condition and therefore, omitting the standard analysis does not create issues for the City. • The Weekday PM Peak Hour analysis will likely result in similar impacts to the Friday PM Peak Hour analysis and therefore, omitting the standard analysis does not create issues for the City. • The FEIS does not include analysis of the in-place roadway infrastructure nor the impact of the Casino Project on the current in-place roadway infrastructure. An analysis that models the interplay of the closely spaced intersections along the South Bonnyview Road corridor was not performed. As such, GHD concludes that the FEIS does not provide the information that the City needs to determine impacts and mitigation measures for the Cumulative Plus Casino Project Conditions in the Friday PM Peak Hour. • The Saturday Mid-Day Peak Hour is required to provide the information that the City needs to determine impacts and mitigation measures for this condition. Additionally, the analysis should also be performed to reflect in-place roadway infrastructure and the interplay of the closely spaced intersections along the South Bonnyview Road corridor. Analysis The Saturday Peak Hour volumes in the FEIS for Cumulative Plus Casino Project conditions at the intersections in the greater freeway interchange area were established by applying a factor to the Friday PM Peak Hour volumes derived from the 2017 River Crossing Marketplace Specific Plan TIAR. Table 3.1 concludes that the Saturday Mid-Day Peak Hour volumes were approximately 16.5% higher than the FEIS' Saturday PM Peak Hour volumes. Based on this data, an updated Cumulative and Cumulative Plus Casino Project with a Saturday Mid-Day Peak Hour in the afternoon (between 11:00 AM and 3:00 PM)are expected to result in new impacts and mitigations. The FEIS did not include an accurate representation of the baseline conditions as it pertains to the roadway infrastructure. Furthermore, an analysis that documents an interplay on the closely spaced intersections along the Bonnyview Corridor was not performed. As such, GHD concludes that the FEIS does not provide the This Technical Memorandum is provided under our agreement with City of Redding.It is provided to foster discussion in relation to technical matters associated with the Casino Project and should not be relied upon for other purposes. 12639045 9 information that the City needs to determine impacts and mitigation measures for the Cumulative Pius Casino Project Conditions. 6. Further Traffic Modeling In the freeway interchange area, the closely spaced intersections along the South Bonnyview Road corridor present unique interplay between intersections. The combination of closely spaced roundabouts and traffic signals requires the highest-level traffic modeling to estimate vehicular capacities, delays, and vehicle queuing. The FEIS does not provide this analysis. As such, the FEIS does not provide the information that the City needs to determine impacts and mitigation measures for the Opening Year(2025) Plus Casino Project conditions or for the Cumulative Plus Project conditions. 7. Mitigation Identification As stated previously: • The Saturday Mid-Day Peak Hour conditions need to be analyzed to determine impacts and mitigation measures. � An analysis of the Casino Project traffic on the actual in-place roadway conditions was not performed. � Traffic modelling that addresses capacities, delays, and queuing, in the context of closely spaced roundabouts and traffic signals, has not been perFormed. The future Cumulative condition freeway interchange improvements, shown in the October 30, 2017 Project Study Report are very conceptual in nature when considering the cumulative impact of the Casino Project. Additionally, these same conceptual improvements are presented in the River Crossing Marketplace Specific Plan associated with approval of the Costco project. The conceptual improvements (along with the development of the Casino Project)were presented with the River Crossing project approval but were considered speculative. Said conceptual improvements will require significant vetting with additional traffic analysis and preliminary designs to determine viability. A funding mechanism for the Diverging Diamond Interchange and second roundabout is not in place. Pursuant to Anderson First Coalition vs. Citv of Anderson (June 30, 2005), the environmental document should not count on "...speculative traffic mitigation measures..."that are not reasonably funded/programmed. Put another way, the court case indicates that an approving agency should not assume a future road improvement will be in place unless the assertion can be supported by actual funding mechanisms and plans. With the very significant traffic impacts anticipated from the Casino Project, mitigation measures that require the construction of the improvements, as opposed to simply a "fair-share" payment, are required. The details of reimbursements and cost sharing can be deferred beyond the approval of the environmental document, but the fact that the mitigation improvements need to be constructed cannot be overlooked. Addressing the above items, and conducting full environmental review and preliminary engineering, will inform the final roadway and interchange improvements that will be needed to mitigate the project impacts. This Technical Memorandum is provided under our agreement with City of Redding.It is provided to foster discussion in relation to technical matters associated with the Casino Project and should not be relied upon for other purposes. 12639045 10