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Trammell Crow Draft EIR Community Comments

Updated: Jul 15, 2020

Have you submitted comments for the Trammell Crow Draft Environmental Impact Report (EIR)? If you would like to share the comments you submitted to City of Morgan Hill in this compilation, please forward by email to: Are you still contemplating what to write in your letter to the City? Another grass roots organization, Californians Advocating Responsible Rail Design (CARRD) has written a helpful guide on How to Write EIR Comments that is easy to understand and relevant to our public input as well.

Would you like to learn more about the Trammell Crow Draft EIR and how to submit your comments to the City? Check out our Trammell Crow Draft EIR Summary and Commentary in MHRGC Articles.


Letters from our Community


The EIR for the proposed Trammell Crow project estimates that there will be 248 truck trips to the site in a 24 hour period. This is the basis of the entire EIR and its findings and seems to be far from the worst case scenario that we were promised months ago and is most likely optimistic on the low side. Why do I say that, because the 248 number is only 2 truck turns per dock per 24 hour day. Not likely for a distribution center. Industry studies indicate that 53 foot semis can be loaded in 10-12 minutes with state-of-the-art automation equipment. Worst case would look more like 2-3 turns per hour or 7,000 to 10,600 truck trips per day which is a long way from 248! According to the EIR, even at the 248 volume, the traffic impact on 10 segments of Highway 101 are significant and unavoidable in AM & PM commute hours with no remediation available…amazing! This fact in itself should be more enough for the City to reject the project application outright, yet this is obviously not the case. If that isn’t bad enough, the traffic impact of the Shoe Palace project which has 56 dock doors has not been comprehended whatsoever in this analysis or any other analysis that I have heard of. The EIR traffic study is grossly incomplete and is doing the citizens of Morgan Hill a huge disservice because we will have to live with the traffic and air quality disaster forever that will result if this project is approved and built. People going north in the morning won’t be able to get to work or get home at night without facing debilitating gridlock worse than we have now. 101 would be rendered useless and our small town quality of life destroyed. Questions: 1. How is a daily truck trip defined? Is a truck going in and out considered 1 or 2 trips? 2. How will the number of actual truck trips to the site be measured to ensure the forecasted numbers are not exceeded? Will Trammell Crow be required to install technology to measure and regularly report the number of daily truck trips? 3. If the number of truck & total vehicle trips exceeds the numbers stated in the EIR, what is the required action to be taken by the City & Trammell Crow? Also will on site air quality be monitored over time to ensure toxic and greenhouse gas emissions do not exceed federal, state and county standards, particularly if truck trips are higher than projections? 4. Does the City have a process & the budget dollars to enforce these truck trip numbers? 5. Why is there no cumulative traffic analysis in this EIR of the combined Trammel Crow and Shoe Palace projects that provides a clear picture of the real traffic impact? Those are my comments and questions this evening. Thank you. - JW -


As a resident of Morgan Hill (13 years), I have serious reservations regarding the proposed Trammel Crow project for a number of reasons. 1. The traffic projections used for the number of anticipated daily truck trips seem incredibly low given the number of loading docks and, if an automated facility (most likely given the height of the buildings) there will be no doubt, many more trips than the projected 248 per day. 2. Having been intimately involved with the Hale Extension (formerly the Santa Teresa Extension before the City's consultants "rebranded the project) 10 years plus ago I am well aware of the City's interesting propensity to inflate the daily traffic trips when it suits their purpose to justify a project. Bottom line when you want to build, relocate a road, the trips can be manipulated to justify the project, but when you don't want to build one- then the trips magically decrease. My understanding is that the 500,000 SF Shoe Palace project (w/ 42 docks) is only going to generate 8 trips per day per the City's website: 'The Shoe Palace expansion project is a 503,400 square foot Office, warehouse, and distribution facility on a 38.06-acre site. A lot line adjustment was completed to expand the project site and reduce the size of the lot where the existing Shoe Palace headquarters exists today. According to Shoe Palace, the new facility is expected to employ approximately 100 additional employees, for a total of 300 employees and would increase truck deliveries from five to eight per day."  How is it that a project that is twice as large is going to generate 31x as many trips? It seems like it should be 16 per day or so. Does anyone really believe that the Shoe Palace is only going to generate 8 trips a day (your website says 8 per day, not per hour or minute).  3. What are the operating hours for this projected facility- 24-7?  How is the noise not going to negatively impact the lives of the seniors living at the adjacent Westmont facility? 4. I saw nothing in the EIR addressing the combined traffic impact of the Anderson Dam project. How many trucks will be off hauling daily from this site as well? Are they all going to be using Cochrane Ave? 24-7? Valley Water says that imported materials will be moved on Bailey Ave, but curiously, says nothing about the exported materials  What about the impacts to the neighborhoods?

From the Valley Water website:  (Public Impacts) What public impacts are expected during construction? The project will require a lot of heavy equipment and will generate associated traffic in multiple shifts to complete the seismic retrofit of Anderson Dam. Residents living near Anderson Dam should anticipate disturbances due to traffic, lighting, noise and dust. More specific impacts will be defined in the Environmental Impact Report and will be minimized as much as practical. The water district will work with the City of Morgan Hill, the County's Department of Parks & Recreation and local residents to develop a program to minimize these construction impacts. All imported materials necessary for the reconstruction of Anderson Dam will be stockpiled at a site off of Burnett Avenue. Trucks hauling these imported materials will exit Highway 101 at Bailey Avenue and use a frontage road to access Burnett Avenue. Imported materials will not be transported to the dam site via Cochrane Road.   5. How will these 2 combined projects impact the already strangled traffic on the 101-Coyote Valley corridor?  How much traffic will be displaced to Monterey and Santa Teresa? Where is the study? Why has there not already been a study required? Why aren't these 3 projects, (Shoe Palace, Trammel Crow & Anderson Dam) combined impact taken into account? 6. The damage to our roads- how many $10's of millions of dollars are we short on our road infrastructure due to the City's 15 year plus program of deferred (as in virtually zero) maintenance? Bottom line- we need an independent traffic analysis. 7. The sheer size of this project screams "automated"- which realistically means more efficient, maximizing ROI to both the lessor and lessee. Which means more trips, more noise and probably relatively few jobs for the size of the project and even fewer well paying jobs. How are we the citizens benefiting from this project? 8. This project is way too large and impactful to be dealt with during the Covid situation. Hearings on this project should rightfully be done in a public forum where the Council will have to look it's fellow citizens in the eye. The way that the Shoe Palace project was shepherded and moved through the City planning and approval process was shameful.I will leave the attendant air quality issues to people more knowledgeable on that subject than I than I. Slow this train down and make decisions based on what is best long term for the community as opposed to those of the developers.


- FM -


I have had an opportunity to review the EIR for the Trammel Crow project. I do think that this project will have a significant Negative impact to our city. It appears Trammel Crow will do anything to mitigate impacts, pay more fees, and get this project started.

Once it's built and functioning the city will have no recourse to the major impacts this facility will have on our families, and the city's quality of life we all enjoy. This project should not go forward. Please do not let this project move forward, it will be a mistake, and the increased bad air quality and traffic will choke this city. Sincerely,

- CS -


I’ve been a very happy resident of Morgan Hill since 1991 and, until last year, I’ve greatly appreciated how our lovely little city has evolved over the past 29 years. I attended the May 2019 Community Meeting during the EIR scoping period for this project and we were told the Environmental Impact Report would address our concerns because environmental studies would be based on “worst case analysis”. Fast forward to May 2020 when we actually SEE the draft EIR and my thoughts are with the other speakers on this: assumptions used for this “worst case analysis” including 248 truck trips per day for 124 loading docks, are far from realistic if this becomes a fully functioning distribution center. Nevertheless, there are ALREADY SIGNIFICANT and UNAVOIDABLE IMPACTS related to AIR QUALITY outlined in this report. And recently I’ve learned that Trammell Crow is prepared to mitigate these air quality issues most likely by purchasing “carbon offset credits”. Does that mean their potential distribution center and trucking activities are allowed to contaminate our Morgan Hill air space as long as they pay the regulatory agencies to offset that pollution?

Morgan Hill City Planning Division, on their webpage states they "perform a variety of services intended to protect, maintain, and develop an attractive, safe, and healthy environment." How is this protecting the healthy environment for our Live Oak kids? Or for our future students of the new Borello school? Or for the thousands of residents living in that area of the city? We need to reject this proposal and ask Trammell Crow for something that is a better fit and healthier solution for our community.

BUT, if decision makers believe it’s easier and more financially beneficial to move forward, despite these significant and unavoidable impacts, this is what I need to ask: If City of Morgan Hill is having financial struggles today, how are we going to balance the books if we end up having a steady stream of lawsuits filed by residents endangered by this project? I’m not making this up… just ask the City of San Bernardino, Fresno, and other cities facing litigation today due to the high rate of cancer and other detrimental health effects of distribution centers in those cities. Thank you - LN -


My questions and concerns relate to the process and criteria the Morgan Hill Development Department used to select David J. Powers and Associates to complete the Environmental Impact Report for the proposed Trammel Crow Development.

Ideally the organization that completes the Environmental Impact Analysis and Report for this project would be non-partisan and focus on adhering to the California Environmental Quality Act, which according to the California Public Resources Code: “CEQA is California's broadest environmental law”.

David J. Powers and Associates is the same company that completed the Initial Study and Mitigated Negative Declaration for the 503,400 square foot Shoe Palace expansion.

The traffic analysis for The Shoe Palace Expansion assumed an increase of 5 to 8 truck trips per day. From the Shoe Palace Initial Study: “The new facility would employ 100 additional employees, for a total of 300 employees and would increase truck deliveries from five to eight per day.” An increase of 5 to 8 truck trips per day when the dock count from the Shoe Palace site goes from 4 to 56 seems grossly negligent.

The Morgan Hill Development Department received a letter about the Shoe Palace expansion Initial Study from a law firm representing the Laborers International Union of North America dated November 19, 2018 that stated: “With the assistance of expert traffic engineer Daniel Smith. Jr., P.E., and environmental consulting firm SWAPE, we identified a number of significant omissions and flaws in the IS/MD’s analysis of likely traffic, air quality, and greenhouse gas (“GHG”) impacts. In addition, the IS/MND’s discussion of wildlife impacts is inadequate as a matter of law.” The letter from the law firm goes on to identify a number of issues with the Initial Study and MND of the Shoe Palace Expansion completed by David J. Powers and Associates.

According to the California Department of Fish and Wildlife The purpose of CEQA is to:

  • Disclose to the public the significant environmental effects of a proposed discretionary project, through the preparation of an Initial Study (IS), Negative Declaration (ND), or Environmental Impact Report (EIR)

  • Prevent or minimize damage to the environment through development of project alternatives, mitigation measures, and mitigation monitoring.

  • Disclose to the public the agency decision making process utilized to approve discretionary projects through findings and statements of overriding consideration.

  • Enhance participation in the environmental review process through scoping meetings, public notice, public review, hearings, and the judicial process.

  • Improve interagency coordination through early consultations, scoping meetings, notices of preparation, and State Clearinghouse review.

However, in a communication to MH Development department (obtained via public records request) in July of 2018 David J. Powers and Associates wrote: “Hi, attached please find our revised scope of work, the schedule has been reduced by nine weeks from initial version, primarily by simplifying the traffic analysis and shortening the internal review times. The cost came down as well, reflecting the simpler traffic analysis. Other options to reduce the schedule include selecting a 20-day public review for the MND, rather than the 30-days City has been opting to provide. We investigated the possibility of preparing an Addendum (which would avoid the need altogether for a public review period) and should discuss that option by phone. If there is a good time for a short call this week, let us know.”

I want the Morgan Hill Development Department to explain the criteria used to select David J. Powers and associates to complete the Trammel Crow development analysis, especially in light of concerns raised about their work on the Shoe Palace expansion.

I have already contacted the California Department of Transportation with concerns about the City of Morgan Hill’s adherence to CEQA related to the Shoe Palace Expansion Initial Study and Mitigated Negative Declaration. I received a direct reply from Mr. Tony Tavares, Cal Trans Director for the nine bay area counties stating: “I’ve asked my Environmental and Planning team to review this issue.”

I have also written a detailed letter to Xavier Becerra, California Attorney, with copies of the Shoe Palace Initial Study and Mitigated Negative Declaration and the exhibits that I’ve noted, expressing with my concerns with Morgan Hill’s adherence to CEQA. - MJ -


We are against granting a change in zoning for the Trammell Crow project, which is falsely labeled a "Technology Park." This "Technology Park" is, in fact, a Distribution Center, and was labeled as such by a Trammell Crow representative at the Planning Commission meeting in December, 2019.

This proposed change in zoning will adversely affect the quality of life of our citizens. An unacceptable increase in traffic, noise and air quality is not what we want as citizens of Morgan Hill.

It is respectfully requested that the Trammell Crow request for rezoning of this project be denied. Thank you.

- CT&ET -


I write to comment on the Draft EIR for the Morgan Hill Technology Center Mixed Use Project submitted in May 2020. There are several alarming issues in this draft that are either not fully contemplated or are merely glossed over with no real analysis or mitigation solutions.

Proposed Purpose: The alleged purpose of this project is a mix of uses including industrial, commercial, and residential. 1.04 million square feet for industrial use; 50,000 square feet for commercial and 319 residential units. Based on these allotments, it is clearly primarily an industrial/warehouse park. The sheer size of this project indicates that the true intention is to allow for a distribution center such as Amazon or other fulfillment center to set up business here. In fact, several community leaders have indicated that if that happened, it would be a boon for Morgan Hill and allow for new jobs (indicating to me at least, this was a discussion initially to persuade Morgan Hill this was a good idea). The developer, recently, has insisted that Morgan Hill is too far away to make this project attractive as a distribution center, however, another distribution center-the Shoe Palace- has built such a facility which would be across the freeway from this project. The proposed purpose of the project is a sham and a lie to the community as it clearly is contemplated as an industrial/warehouse distribution center. I am embarrassed that the City Counsel has fallen for such a ruse in the first place.

Truck trips: The EIR contemplates such a low number of anticipated truck trips that it boggles the mind. Simple math coupled with the large scope of the industrial project raise concerns that there are some un-truths being presented, or “alternative facts” to achieve the developer’s end. There simply has been no analysis of the cumulative effect of this project with the Shoe Palace catastrophic fulfillment center across the road. Even if one believed the projections in the EIR, those coupled with the Shoe Palace truck trips would be devastating to the community, its roads and access to neighborhoods, schools and homes. The EIR thus, is incomplete or inaccurate on this analysis.

The impact on the local freeways is listed as a Significant and Unavoidable Impact. This is not acceptable. As one who lives here and must occasionally drive on the 101, it is currently the worst traffic then this area has seen in years. Without alternative routes, adding a significant amount of trucks to the already horrible situation would make actually doing business and living in Morgan Hill prohibitive. Such a project should not be allowed unless and until there is some ability to mitigate- such as dedicated freeway lanes to trucks, alternative routes, etc. which all must be contemplated with the DOT. The EIR instead focuses on unrealistic peak hours and lower trips than will actually take place. The EIR must re-consider with CURRENT traffic studies, its projections and offer mitigation proposals. Anderson Lake Project: The EIR does not contemplate how this project will work with the Anderson Dam retrofit project which will greatly increase truck traffic, road closures, and delays. The EIR is flawed and missing this critical analysis. As stated above, the increase in traffic is one of the most glaring issues that is not sufficiently analyzed in the EIR.

Pollution monitoring after project: The EIR fails to provide any information or analysis on how it will mitigate air quality and other pollution concerns once the foot-print is carved out by the developer. Much is written about watering down roads, preventing idling diesel engines, etc. during construction. However, when the project is done, and the roll-up doors are ready for business, how will Morgan Hill be protected then? There is no assurance that any environmental concerns that are contemplated during the project, will have methods in place to reduce emissions, pollution and irritants, after the building is complete. The EIR fails to address this point.

Jobs: One of the stated goals of the project is to add jobs to Morgan Hill. However, the EIR does not have any evidence to support that the various use/projects would in fact add jobs. The word “job” is used in the EIR draft 12 times; each time in the context of a “hope” or goal of the project. With warehouse automation it is unclear whether the warehouse option would add ANY jobs. Further, the EIR assumes Morgan Hill residents would not have to commute [thus adding to the traffic unavoidable impact] to this location.

Alternative Projects: The EIR sets forth no project, no project-existing general plan/zoning alternative, reduced intensity Alternative and Warehouse alternatives. By the analysis presented, No Project and Reduced alternative Project avoid or reduce the significant impacts identified in the EIR. However, with traffic/transportation being one of the major significant impacts of this project, I would recommend No Project until current statistics are actually analyzed and greater efforts to mitigate damage are proposed.

As a member of this community, my family moved here to have peace and beauty in our lives. This project is the antithesis of that. - PR -


I'm in favor of all developments that are designed with concern for Morgan Hill's environment and quality of life and projects that will support local businesses and create high paying jobs.

My questions on the EIR are as follows:

a) EIR for this project does not include a single "Feasible Alternative". How did the consultants prepare their alternatives impact and mitigation analysis without such plan from the developer? EIR consultants do not have the resources to generate their own alternative plan. Does that mean they imagined an alternative plan to produce very detailed numbers for each category of impacts?

b) Without any viable alternative plan, I feel all the analysis summarized in Tables 7.6-5, 6 and 7.7-1 is pure speculation.

c) 248 daily diesel truck traffic count for the desired project based on 124 docks seems to be highly underestimated.

I urge the City to do the following to bring some credibility to this EIR prior to any certification:

1) require the developer to submit an Alternative Plan or Plans based on the current GP and Zoning.

2) EIR consultants are paid by the developer, so they are expected to manipulate every number in the favor of the project. In light of Shoe Palace debacle and for this highly controversial project, City might be able to gain some support with the community if they were to retain an independent traffic consultant at taxpayers’ expense. Emphasis with that consultant should be to project fair and impartial traffic counts, especially the diesel truck counts. Traffic projections should be based on historic data from the warehouse/distribution center industry and not based on the facility operations and use statements made by the developer.

I thank you in advance for considering my comments.

- MS -


Our small town has historically suffered from congestion, air quality and noise from flow though regional traffic on freeway US101. In buildout scenario, traffic consultant for the Trammel Crow EIR has projected 248 diesel truck trips per day from their warehouse operations. No one in the community is aligned with that projection just as this same consultant had failed to sell their analysis for the Shoe Palace project.

Even with that highly controversial and suspicious truck count, EIR has concluded that transport impact to the freeway and the Cochrane Road interchange is “Significant Unavoidable Impact”.

The freeway backs up in both directions north and south seven days a week. Cochrane Road crossing has been the historic choke point. State and regional transportation authorities have no funds or near term plans to create additional capacity along this route through our community.

I’m asking the City to do the following for the welfare of our beautiful town:

a) EIR must incorporate Shoe Palace and Target Shopping Plaza expansions in a buildout scenario. Shoe Palace truck traffic counts must be re-established based on 56 docks using ‘distribution center’ industry standards for truck traffic. Anderson Dam reconstruction project should also be included in the study for short term impacts.

b) Deny General Plan and Zoning change for a 124 dock distribution center proposal without any mitigation offered for the “Significant Impact” to already impacted US101 and Cochrane Road interchange.

- RB -


In the letter we received from City of Morgan Hill dated May 15, 2020 announcing the public review for the Trammel Crow Morgan Hill Ventures (Morgan Hill Technology Park) Draft EIR, it states the following: Pursuant to CEQA Guidelines Section 15087(c)(6), the subject site is not listed on any of the lists of sites compiled under Section 65962.5 of the Government Code concerning hazardous waste or hazardous waste disposal. This stated caveat was surprising because, as residents of nearby Mission Ranch Neighborhood, we are aware of the large amount of hazardous demolition debris that was transported back in 2006 to the site that is now owned by Trammell Crow. In 2006, this was vacant property next to DePaul Health Center. We all watched curiously as dump trucks containing big chunks of concrete material from the former Flying Lady Restaurant and parking lot was brought in and dumped at the site. At the time, we had no idea this demolition debris was known to contain asbestos, an extremely hazardous material, and probably should not have been transported in open dump trucks. We learned this a few years later. After the dumping was complete, a layer of dirt was placed on top of the dump site and this land became part of the “Tree Farm” which is how it remained for over a decade until this parcel was purchased by Trammell Crow. Many of us reading through the Draft EIR have discussed the details we found and we want to ensure proper handling of this contaminated section of land during future construction. These are the questions raised:

1. How is 65,000 to 70,000 cubic yards of DEMOLITION DEBRIS, ranging from 5-9 feet in depth, now identified as “Naturally Occurring Asbestos”, or SERPENTINE FILL? How is this not a hazardous waste disposal? We did find that Serpentine Rock is defined as a meta-igneous rock that often contains white streaks of chrysotile running through it, which are a type of naturally occurring asbestos. Asbestos is linked to an array of health conditions such as mesothelioma and other cancers.

2. Considering samples of the “fill” were found to contain up to 3.5% asbestos, is Trammell Crow prepared to allow for construction activities to be regulated by California Air Resources Board and Bay Area Air Quality Management District (BAAQMD)? From what we have learned, these naturally occurring fibrous minerals found in serpentine, if disturbed by construction, grading and other surface activities, will result in these asbestos fibers becoming airborne and a danger to construction workers and any nearby residents.

3. Based on the proposed mitigation measures to reduce potential impacts, will the Master Plan for the project show the necessary detail of this contaminated area that is designated for onsite burial to encapsulate the asbestos material beneath “permanent site improvements or at depths not to be encountered by future construction activities”?

4. How can this buried and encapsulated area of asbestos material that is adjacent to US 101 not have a negative impact on the Coyote Canal that also runs along the freeway?

Thank you for allowing us to provide this input,

- MR -


Hello, My family moved to Morgan Hill in 2017 to get a fresh start. Here's a little back story on us. We are a family of 4 with 2 boys, ages 10 and 7. Our 7 year old was born with kidney failure and required a transplant at 18 months old. He will forever have a compromised immune system due to his daily anti-rejection medication required to sustain his kidney. In 2016 he was diagnosed with Non-Hodgkin's Lymphoma and had to undergo extensive chemotherapy. Just as he was finishing his treatments, I was diagnosed with thyroid and lymphoma cancer, requiring the removal of my thyroid and 119 lymph nodes. Because of this, my immune system is no longer what it once was, as well. We chose Morgan Hill as our fresh start destination immediately following my surgery. We wanted to get out of San Jose and all the pollution and traffic and join a community where there was plenty of open space, responsibly managed growth, less congestion, was more family oriented and a great place for our kids to grow up. Until now, it has been a wonderful experience. I've attended most of the Trammell Crow project discussions and have stayed fully engaged since this project was exposed to the community. Knowing what this will bring with the air pollution alone is sobering. Add to that the noise pollution, impact to our roads and significantly higher traffic on already over congested roads/freeways, and the picture becomes downright depressing. Morgan Hill is not a truck stop. Nor should it become the South Bay distribution hub. This wonderful community has the potential to become, as many have touted, the next Los Gatos or Saratoga. By building distribution centers, that will not bring high quality, high paying jobs as Trammell Crow has tried to sell this ‘Tech Park' on, that Los Gatos / Saratoga potential will be all but gone. If this were truly going to be a ‘Tech Park', there would absolutely be no need for the proposed buildings with hundreds of docks. Call a spade a spade instead of trying to continue defending the lies in their proposal. The EIR calls out numerous health and infrastructure issues and yet it certainly feels like these are being ignored. Trammell Crow is in business to make $$. When they are done damaging our community it won't make any difference to them, as they will have moved on to building out the next distribution center in the next city willing to overlook their lies and future health concerns. Look up all of their projects, including Livermore, to see what their idea of a ‘Tech Park' is. The traffic study alone was completely flawed, given it was done off of 2017 data. Ironically, we moved to Morgan Hill in March 2017, so I can say without batting an eyelash that my commute to Cupertino between 2017 and now has almost doubled in time. The air quality is being measured at the San Jose plant and doesn't even come close to telling the true story of how bad the pollution will become here. Property values will decline and the city will end up in continuous litigation because of individual and class-action lawsuits due to all of this. Is that what you really want for our city? The Shoe Palace eyesore bait and switch, with next to zero oversight or public awareness/discussion prior to being built (only to now see the building being sold), was maddening enough. Trying to push through another distribution hub on Butterfield is incensing. Add to that Trammell Crow and it becomes abundantly apparent what the city has in mind for our community. To say I don't feel like our voices are being heard is an understatement. If the City Council and Planning Department were truly listening, they would build out our community responsibility, with an emphasis on public safety, while bringing the high quality/high paying jobs to Morgan Hill, ala a true 'Tech Park'. Thank you, - JL -


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