HomeMy WebLinkAboutStaff Report 4.B Late Docs 04/06/2009April 2, 2009
Petaluma City Council
The City of Petaluma
11 English Street
Petaluma, CA 94952
RE: East Washington Place: Fiscal and Economic Impact Analysis
Dear Council Members,
Regency has reviewed the Fiscal and Economic Impact Analysis (FEIA) prepared by Bay Area
Economics and finds the report to be consistent, if not conservative in comparison to the 2004
Thomas Retail Leakage Study, the 2007 economic and urban decay study performed for the East
Washington Place EIR, as well as our own market research analysis. As an example to the
conservative nature of the FEIA, Regency estimates total annual sales from the project to be
$140 million versus the $119 million projected in the analysis.
While Regency is satisfied with the overall report we would like to take this opportunity to point
out a few benefits we feel warrant additional attention. Most importantly the total property tax
increment paid by the project is $954,789; however the executive summary only calls out
$472,000. Although the difference $482,789 is not retained by the Redevelopment Agency, the
majority of those funds do go to either the County or City for the benefit of the local community.
Some additional benefits we feel were not clear in the FEIA and worth noting are
• Regency purchased the property in 2004 for $22 million, which was used to build the new
state-of-the-art Kenilworth Junior High School
• During the entitlement process to date Regency has paid over $1,000,000 in real estate
taxes
• To date Regency has invested $134,000 in youth sports for Carter Field
• We conservatively estimate that with a net gain of 593 retail jobs created, those
employees would earn a total of $14.6 million dollars a year. When you factor in the 53
office jobs created the total increases to $16.7 million per year. A significant portion of
these earnings are then reinvested into the local community.
• During the construction phase of East Washington Place those temporary construction
workers (FEIA estimates to be approximately 338) would earn an average of $52,804 per
year. Over an 18 month construction period that equates to $27.8 million paid in wages.
Portions of those wages will be spent locally for food, fuel, and other basic needs.
• The project will provide close proximity shopping alternatives to the community reducing
not only greenhouse gas emissions but also fuel costs to the local consumer
2999 OAK ROAD, SUITE 1000. WALNUT CREEK, CA 94597.925.279.1800.888.797.7348 . FAX: 925.935.5902. REGENCYCENTERS.COM
Again, Regency finds the FEIA report to be a fair assessment and supports the findings of
previous studies. We are eager to begin public hears on the project this coming summer. It is
important to note that for every week that passes the community loses out on approximately
$35,000 of incremental sales and property tax revenue. With the overwhelming benefits outlined
in this report, we hope that the City of Petaluma will make East Washington Place a top priority
so that such benefits may finally come to fruition.
Warm Regards,
f? C! !fir
Bruce Qualls
Regency Centers
Cooper, Claire dltoE)
From: Brown, John
Sent: Thursday, April 02, 2009 3:18 PM
To: Cooper, Claire
Subject: FW: Comment on BAE Fiscal and Economic Impact Analysis for East Washington Place
(Target) Development
Attachments: Comment on BAE FETA 4-2.pdf; Comment on BAE FEIA 4-2.doc
The attached needs to go with the agenda if it hasn't already
From: thomas.w.lester@gmail.com [mailto:thomas.w.lester@gmail.com] On Behalf Of Bill Lester
Sent: Thursday, April 02, 2009 2:38 PM
To: Brown, John; Moore, Mike; martin bennett
Subject: Comment on BAE Fiscal and Economic Impact Analysis for East Washington Place (Target) Development
Dear Mr. John Brown (City Manager) and Mr. Mike Moore (Director of Community Development),
My name is T. William (Bill) Lester, and I am a PhD Candidate at UC Berkeley and an affiliated scholar at the
UC Berkeley Center for Labor Research and Education. I am writing to submit to you a comment on the Fiscal
and Economic Impact Analysis (FEIA) prepared by Bay Area Economics regarding the proposed retail
development at East Washington Place. Please find the comment attached in MS Word format and as a PDF
document. I worked closely with Mr. Martin Bennett of the Sonoma County Living Wage Coalition in
preparing this comment. Ile explained that if I sent this comment to you by 3pm today, it would be included in
the packet prepared for council members for the meeting of April 6th. Please contact me by phone or email, if
you have any questions or concerns, or if you cannot open the attachments.
Thank you very much for the opportunity to participate in this dialogue
Sincerely,
T. William Lester
PhD Candidate
Department of City and Regional Planning
University of California, Berkeley
and
UC Berkeley Center for Labor Research and Education
blesterRberkelev.edu
(310)562-8392
Comment on BAE's Fiscal and Economic Impact Analysis for Proposed East
Washington Place Shopping Center in Petaluma, CA
April 2nd, 2009
Prepared by:
T. William Lester, PhD Candidate]
Department of City and Regional Planning, UC Berkeley
UC Berkeley Center for Labor Research and Education
The Sonoma Living Wage Coalition asked the UC Berkeley Center for Labor
Research and Education to review the Fiscal and Economic Impact Analysis (FEIA)
prepared by Bay Area Economics in regards to a proposed shopping center at East
Washington Place in Petaluma, CA. The Petaluma City Council passed an ordinance
requiring an assessment of the impact of large scale retail development projects on the
community. The goal of such community impact reports (CIRs) is to assess whether a
proposed development with negatively or positively impact the economic and fiscal
health of the communities workers, taxpayers, and citizens. A key component of a CIR is
to measure the impact of development on existing standards and norms in the local labor
market. While new developments may increase the quantity of jobs in the labor markets,
they may also affect job quality for existing residents seeking jobs and incumbent
workers in similar industries. Such job quality standards include wage levels, the
proportion of frill -time work available, as well as the likelihood of receiving employer
provided medical benefits.
This written comment points out several Tactual and analytic errors in BAE's FEIA
report, which collectively raise substantive doubt as to its basis for making an overall
favorable recommendation for the proposed project. This comment makes five specific
points concerning the FEIA report:
1) The reported share of workers in retail who work part-time for non-
economic reasons is understated;
3) The wage rates assnnnec( for specific retail industries are too high;
3) The report over-estimates the income of tips on worker's incomes;
4) The report provides insufficient tient information on the number workers
offered health coverage by Target;
5) The repot does not mention the role of retailing, and big -box retailing
in particular, in lowering standards in local labor markets.
It is our recommendation that the council should consider these points before making its
final recommendation or ask that BAE address these comments in their FEIA report. As
the proposed development includes a big -box retailer (Target), it is essential to fully
understand and estimate the impact of such developments in light of recent scholarship
that suggests that highlights the negative impact of this particular form of retailing on the
Contact: blester@berlceley.edu
labor market. Since much of the literature on the impact of Big -Box retail is focused on
Target's leading competitor, Wal-Mart, it is particularly important that the developer
and/or Target itself, provide specific details on wage levels, average turnover rates, and a
richer description of its employee benefit program in order to construct a more accurate
FEIA. The Council should consider asking developers and/or anchor tenants for these
specific details in future community impact reports.
1. Part-time work for non -economic reasons
On page 45 of the FEIA, BAE states that only 13 percent of retail and wholesale workers
nationwide were working part-time for economic reasons, as opposed to making the
choice to work part-time while in school or caring for other household members. The
citation for this figure lists the data source as table published on the web from the Bureau
of Labor Statistics (BLS) derived Current Population Survey data. However, when I
rechecked this figure it should actually read 18.1 % for 2008, or 944,000 out of 5.2
million part-time workers in the combined wholesale and retail sectors.'- The report then
implies that since the figure is small, one should not be that concerned about the fact that
Target plans to use approximately two-thirds part-time workers. Recent data from the
Department of Labor also show that involuntary part-time work has risen sharply during
the current recession.3
However, we can gauge a more accurate picture of the share of part-time workers
working part-time for economic reasons if we male this calculation from the more
detailed microdata available from the Current Population Survey (CPS). Table 1 lists the
share reason for working part-time for workers in California working in a set of retail
industries that better approximates the type of establishments included in the
Development.
Table 1. California Part-time Workers in Selected Retail Industries by Reason for
Working Part-time, 2008.
Department stores and general merchandise
Related retail sectors'
Reason for working part-time
Economic Non -Economic %economic
30,810 67,061 31.5%
68,813 235,551 22.6%
Total 99,623 302,612 24.8%
Source: Current Population Survey, 2008. Ahcrodata accessed through IPUAIS.og. Authors calculations.
Bureau of Labor Statistics, Characteristics of the Employed (CPS Tables) Table. 21. "Persons at work in
nonagricultural industries by class of worker and usual full- or part-time status"
ftp://ftp.bls.gov/pub/special.requests/If/aat2l.txt
VS. Bureau of Labor Statistics (2008) 'Involuntary part-time wort: on the rise" Issues in Labor Stotietics
Summary 08-08 / December 2008.
J Related retail sectors include the following industries: Furniture and home furnishings stores; Radio, TV,
and computer stores; Building material and supplies dealers; Hardware stores; Grocery stores; Pharmacies
and drug stores; Health and personal care, except drug stores; Clothing and accessories, except shoe stores;
Shoe stores; Jewelry, luggage, and leather goods stores; Sporting goods, camera, and hobby and toy stores;
Music stores; Book stores and news dealers; Office supplies and stationary stores; Miscellaneous retail
stores.
As indicated above, this figure is considerably larger than the national rate quoted in the
BAE report. When we focus specifically on the department stores and general
merchandise sectors this figure is even higher, 31.5%.
These higher figures are consistent with recent academic research that highlights the
growth of part-time work throughout the service sector and the fact that many workers
are forced to take multiple part-time jobs to boost their incomes. According to the
Economic Policy Institute, nonstandard workers—a group that includes part-time workers
as well as temp -workers, independent contractors, and day laborers—made up over 30%
of the workforce in 2005. They find that these workers "in general are not only often paid
less but they are less likely to receive benefits from their employers and more likely to be
uninsured. ,5
2. Wage levels
On pages 47 and 48 of the FEIA, BAE presents an analysis of the expected wage levels
associated with the projected 331 part-time and 390 full-time positions directly linked to
the East Washington Place development. This is a critical step in the analysis as it makes
a comparison between the wages offered at the project to the official living wage rate of
$13.64 for the City of Petaluma.
The report presents data from the California Employment Development Department
(EDD) that indicates that the median wage rate for Sales and Related Occupations is
$14.00 per hour. While the authors of the BAE report are careful not to claim that all
workers at Target and other retail establishments will necessarily earn the median wage,
they make the implicit claim that, since this rate is above the official living wage rate for
the City of Petaluma ($13.64 without medical benefits in 2008), the project will not
reduce average retail wages in the labor market.
The evidence from public data sources strongly suggests that this analysis is incorrect.
First, the quoted wage rate for "Sales and Related Occupations" is not the correct
comparison
t!ioint, as it is an aggregate figure that includes unrelated, higher paid
occupations . Second, given recent scholarship on the high rate of turnover, orjob-
churning, in the retail sector (particularly at big -box establishments), it is likely that the
wage rate for workers at Target are likely to be closer to the 25"' percentile (entry-level)
rather than the median.
In Table 2, we present a more detailed, disaggregated analysis of wage levels for most
common retail occupations in establishments within the project itself. Specifically, we
use the 2006 Industry Staffing Patterns report for California (published by the EDD) to
s Mishel, Lawrence, Jared Bernstein, and Sylvia AIlegreto, The State of ll'orking America 2006/2007.
Economic Policy Institute, Ithaca, NY: ILR Press, an Imprint of Cornell University, Table 4.7, page 241.
5 Insurance Sales Agents; Securities, Commodities, and Financial Services Sales Agents; Travel Agents;
Real Estate Brokers; Real Estate Sales Agents; Sales Engineers. All of these occupations pay a mean wage
above S30/hour. Source: California Employment Development Department (EDD), OES Employment and
Wages by Occupation, 2008 Ql.
find out what the most common occupations are for each retail industry. We then list the
most recent occupational wage data available from the EDD for the Santa -Rosa -Petaluma
MSA. For the Department Stores and Other General Merchandise industries -the sector
which includes Target -the vast majority of workers (87%) are concentrated in only
three occupations Retail Salespersons, Stock Clerics and Order Fillers, and Cashiers.
However, these occupations have median wage rates ($9.91-$11.60) well below $14.00
and below the prevailing living wage in Petaluma.
Table 2. Top Occupations within Retail Industries in 2006 and 2008 Wage Rates
Rank Occupation Title
Department Stores and Other General Merchandise
1 Retail Salespersons
2 Stock Clerks and Order Fillers
3 Cashiers
4 Managers of Retail Sales Workers
5 Mgrs of Office and Admin. Supt Workers
All other occupations
Weighted Average Wage
Other Retail Industries?
1 Retail Salespersons
2 Cashiers
3 Managers or Retail Sales Workers
4 Stock Clerks and Order Fillers
5 Packers and Packagers, Hand
All other occupations
California Wage Rales for Santa
Employment, 2006' Rosa -Petaluma MSA,
CA, 20082
Share of
Industry
Emp. Emp. 25th Median 75th
84,600
38%
$9.03
$11.60
$15.57
54,500
24%
$9.11
$11.60
$15.33
47,300
21%
$8.56
$9.91
$13.12
13,100
6%
$15.41
$18.67
$23.65
7,300
3%
$18.35
$2226
$2822
15,700
7%
$9.52
$14.00
$21.94
$9.67 $11.18 $16.33
322,300
30%
$9.03
$11.60
$15.57
252,700
24%
$8.56
$9.91
$13.12
88,100
80".
$15.41
518.67
$23.65
70,900
7°/o
$9.11
$11.60
$15.33
40,100
4%
$8.42
$9.08
$10.25
325,500
309'0
$9.52
$14.00
$21.94
Weighted Average Wage 59.85 $11.77 577.85
Sources: California Employment Development Department (EDD). 1) 1006 Staffing Patterns by Indust)
and Occupation; 1) OES Employment and Wages by Occupation, First quarter, 1008.
For the additional retail industries that will include potential tenants in the remainder of
the development, the top five occupations are slightly different, but are still dominated by
the occupations paying the lowest wage levels. For each of these two industry
7 Industries included: Florists (453100; Shoe Stores (448300); Used Merchandise Stores (453300),
Jewelry, Luggage & Leather Goods Stores (448300); Beer, Wine, and Liquor Stores (445300); Book,
Periodical, and A-lusic Stores (451300); Other Miscellaneous Store Retailers (453900); Sporting
GoodslMusical Inst ianent Stores (451100); Specialty Food Stores (445200); Clothing Stores (448100)
Gasoline Stations (447000); Lawn & Garden Equipment/Supplies Scores (444'00); Office Supply,
Stationery & Gift Stores (453100); Home Furnishings Stores (441100), Health and Personal Care Stores
(446000);Budding Material aid Supplies Dealers (444100);Farnitare Stores (442100); Electronics and
Appliance Stores (443000.); Grocer)+Stores (445100).
4
groupings—Department Stores/General Merchandise and Other Retail Industries—we
present a weighted average wage rate, which are both below the prevailing living wage
($12.18 and $12.77 per hour).
While the median wage rate in retail occupations approaches the living wage rate, we
suggest that the median may not be the best figure to use as a comparison for Target,
given the high rate of job turnover associated with big -box retail. Given Target's
statement that two-thirds of its proposed workforce will be part-time workers, the issue of
job turnover and lack of tenure within a given job category is especially problematic and
suggests that larger share of Target workers will be closer to the 25"' percentile ($8.56-
$9.03 per hour). According to a recent study of large companies in the retail industry, the
rate of employee turnover ranged between 40% and 86% overall, and was highest among
part time workers.s
However, the turnover issue is not the only reason to suspect that wages at Target will be
below the wider average for the local labor market. We can use Wal-Mart as a
comparison here. Researchers at the UC Berkeley Center for Labor Research and
Education analyzed detailed payroll data provided by Wal-Mart and found that the
overall wage distribution was 31 % lower than other large retailers in California.9
Overall, this wage analysis argues that the wage figures used by BAE are too high and
that the more realistic analysis suggests that the average wages offered by Target and
other retail firms in the proposed development will be below the prevailing living wage in
Petaluma.
3. Tipped workers only a fraction of restaurant workers
On page 48 of the FETA, BAE states that workers in hood Preparation and Serving -
Related Occupations, while earning a median wage of only $10.47 per hour, make up for
low wages by earning substantial tips. However, the level of tip income for workers in
this broad occupational category varies greatly across specific restaurant occupations.
Typically, the only servers who earn a large share of their income from tips work at full-
service restaurants, while fast-food workers are typically not tipped. In addition, workers
in the "back of the house" as well as managers and hosts do not generally receive tips.
The BAE report does not indicate if the restaurant included (with expected employment
of 21 workers) in the development is a full-service or limited -service establishment.
However according to data from the EDD, waiters and waitresses at fill -service
restaurants make up only 38% of jobs in the full-service restaurant industry, and 19% of
the overall food service industry.10 Furthermore, the amount of tip income that servers
earn is a function of the average menu prices at the restaurant. Thus, the only servers
'Carne, F. and C. Tilly (2008). "America's biggest low-wage industry: Continuity and change in retail jobs"
Institute for Research on Labor and Employment (IRLE) Working Paper Series 2009-004: p. 2.
9 Dube, Arindrajit and labobs, Ken (2004) fliddcn Cast of Wal -Mena Jobs. Res�onse m Wal -Mart's
Statements, LIC Berkeley Center for Labor Research and Education, August 3` , 2004, p. 1.
10 California Employment Development Department (EDD). Industry Staffing Patterns Report, 2006.
who will make the majority of the income from tips are those who work at higher -priced
restaurants. Therefore, the issue of tip income should not divert the Council's attention
from the fact that restaurant jobs offer some of the lowest wages in the labor market, well
below the Petaluma living wage rate.
4. Health Insurance Coverage in Retail
A critical factor in assessing the impact of the proposed development on job quality in the
local labor market and the overall fiscal health of the City and the surrounding
community is the share of workers covered by employer-sponsored health insurance. In
this section we make two arguments. First, we argue that the figures provided about
Target are insufficient to accurately asses the degree to which new employees will
receive health benefits and request that the City require more information to complete the
FEIA. Second, we provide estimates from the Current Population Survey that show that
the share of workers in retail who are offered employer -paid health insurance is below
that of other industries, and that part-time workers are less likely to have such benefits
through their jobs.
On page 48, BAE suggests that "on average Target pays more than 70% of the
employee's health care premium." However, they do not state how many of their workers
receive health care benefits, and what the total hourly threshold is for receiving such
benefits. This is particularly critical given the large share of workers who are part-time.
As reported by the Minneapolis Star -Tribune, Target eliminated health care benefits for
workers who work less than 20 hours a week in 2003.11 Without additional information
from Target regarding the number of workers expected to be employed between 0-20
hours, 20-32 hours, and 32 hours and above, we camtot fully asses the number of workers
who will be covered by employer sponsor health insurance.
Without this detailed information from Target, we can provide an approximation with
publically available survey data from the Current Population Survey. For workers
employed in relevant retail industries' employed in California in either 2007 or 200813,
41 % were included in employer sponsored group health insurance program. For workers
specifically employed in the department stores and other general merchandise sectors,
this figure is 47%.
For retail workers who were included in employer provided insurance programs, only
21% reported that their employers paid the full cost of the premiums. Within department
stores this figure was 26%."' Therefore, although only a minority of workers receive
their health care coverage from their employers the vast majority of those covered
workers share in the cost burden.
Il Cited in "Target Cuts Part -Timers' Benefits" Business and Legal Reports (BLl?)
(http://compensation.blr.com/doc_print.c fm? id=150998)
1' This analysis uses the same industry definitions as described in Table I above.
We roll together two CPS survey years to increase sample size.
US Bureau of Labor Statistics, Current Population Survey, 2007-2008; Authors calculations.
6
To analyze the likelihood that part-time workers within retail and general merchandise
firms will be offered health insurance benefits, we must look at national level data, as the
CPS sample sizes are too small for this cross -tabulation. Among part-time workers in
related retail sectors, only 15% were included in the employer sponsor, while only 19%
of general merchandise part-timers were included.
Therefore, given the relatively low rate of health insurance coverage for retail workers in
general, and part-time workers in particular, the proposed development may have a
potentially negative fiscal impact on the City of Petaluma, Sonoma County and the State
of California, as uninsured workers will be forced rely on local public hospitals and
clinics for services.
Research by labor economists at UC Berkeley supports this point. A 2004 study by
Arindrajit Dube and Ken Jacobs finds that a significant portion of workers at Wal-Mart—
Target's closest competitor—were paid such low wages that they were eligible for and
utilized MediCal and other publicly funded safety net programs. This resulted in a cost
of $32 million in health related expenses by local and state governments in California and
another $54 million in other public costs. 15 Current health policy research indicates that
the State of California and its counties collectively spend $2 billion annually to cover the
costs of uncompensated care. 16
5. The link between big -box retail and the proliferation of low-wage work
While developments such as the proposed East Washington Place project bring the
promise of jobs and sales tax revenues—a prospect that may be especially appealing
during a down economy—it is critical that public officials examine the long-term impact
of such development on the local community and the local labor market. In requiring a
FEIA report for new, large-scale developments, the City of Petaluma not only recognizes
the importance of such analysis, but also recognizes that the process itself presents an
opportunity to make wider changes in the economic landscape.
Over the past two decades, there has been a significant increase in income inequality in
California, the Bay Area and the North Bay. 17 This is largely due to the proliferation of
low-wage work and the decline of middle-income, family -sustaining job opportunities.
The retail and food service industries are the largest employer of low-wage workers and
are projected to grow rapidly in the region.
Dube, Arindrajit and Ken Jacobs (2004) "Hidden Cost of Wal-Mart Jobs: Use of Safety Net Programs by
Wal-Mart Workers in California" UC Berkley Labor Center.
ie New American Foundation (2006) "A Premium Price: The I-lidden Costs All Californians Pay in Our
Fragmented Health Care System."
n A number of recent reports have documented the increase in inequality and its lint: to low-wagejobs. See
California Budget Project: d Generation of Widening hrequality (2007), (htm://www.cbo.ore/oublicalions
/Dub workwaeesinchtmh; The Rising Tide Left Some Boats Behind: Boom, Bust, and BeYond in the Scor
Francisco Bay Area (2005) (litto://www.cbD.ore/publications/pub workwaeesinc.hmtll; New Economy,
Working Solutions Nari Rhee and Dan Acland. The Limits ofProsperiq'_ Growth Inequality and Poverty
in the North Bay (2005). (http:/hwww.neweconomynorthbay.org/news_reports.php)
For example, "the top three occupations with the most job openings are Retail
Salespersons, Cashiers, and Waiters and Waitresses". As noted in above these
occupations pay very low wages, tyFically between $8.50-$11.50 per hour and require
only short-term on-the-job training. s
However the fact that these industries are growing and pay low -wages is not inevitable.
Rather research shows that recent restructuring and low -road business strategies have led
to the destruction of higher wage retail jobs and the creation of jobs of very low quality.
One recent paper found a direct causal link between the entry of one big -box retail firm—
Wal-Mart—on retail workers earnings. Dube, Lester and Eidlin (2007) find that for each
new store opening in a county, retail workers see their earnings decline by 0.5 to 0.9%.19
Since Wal -Mart's competitive strategy is offering lower prices, they are able to draw
market share from existing retailers in local communities. To the extent that their lower
prices are derived from paying lower wages and existing retailers are displaced, this
results in an overall degradation of wage standards in local labor markets that can now be
measured at aggregate levels.
This research suggests that, even though the retail sector will continue to grow,
communities do have some degree of discretion with regard to enforcing and upholding
labor standards. The choice is between welcoming companies that compete through a
low -road strategy that drives down wages or attracting those that choose an alternative
strategy that treats workers fairly and competes based on quality and improved consumer
choice.
Ultimately, the information provided by Target and the developer, as reflected in BAE's
report, is insufficient for policy makers to consider this choice filly. Without better data
from Target, it is impossible to do a thorough analysis. Lacking such data, there is no
choice but to rely on general data sources or studies focused on Wal-Mart. These sources
raise significant doubts about the overall impact of the project on the local economy.
" California Employment Development Department, Labor Market Information Division, 3006-2016
Sonoma Counly Projection Highlights. (httn://Nvwsv.calmis.ca.eov/file/indDroi/satrS hiehliehts.ndf )
19 Dube, Arindrajit, T. William Lester, and Barry Eidlin (2007) "Firm Entry and Wages: Impact of Wal -
Mari Growth on Earnings Throughout the Retail Sector" Institute for Research on Labor and Employment
(IRLE) Working Paper No. 126-05, August 6, 2007.
8
5TEGEMA11 & A559CIATE5
LAND USE PLANNING e EIJVIRONMENTAL ANALYSIS
April 2, 2009
RE: Comments upon the East Washington Project FEIA
Summary
As the first FETA prepared in Petaluma, it is reasonable to expect that there would be a settling in
process of how to address the various requirement of the new City policy. The present volatility
of the economy also makes it hard to provide a confident and substantiated prediction of the
economic consequences of approving the new shopping center. But there are various flaws and
omissions that have nothing to do with the present circumstances. The study ignores specific
methodologies required by the City FEIR policy. The study presents a morass of data, and then
often draws conclusions without citation or reference to the provided data. The study provides
projections that use a sample period that almost entirely ignores the present economic collapse,
which has enormous implications upon the 5 -year time frame of analysis. Anecdotal discussions
of vacancy rates downtown avoid the reality of an accelerating decline, which have serious
implications for the creation of large new chain retail capacity. The discussion of potential City
revenue gains ignores the accompanying loss of revenue from existing businesses due to transfer
of in -town purchases to the new Center, in addition to the touted capture of existing leakage.
No one reasonably expected that the first FEIR effort (essentially a "beta" test) would be
perfect, but the report contains enough structural and analytic flaws as to make it almost useless
for the intended purpose of accurately understanding the positive and negative economic
implications of project approval in the sample period of five years following completion.
The study is compromised by the worst economic downturn in generations
In the Introduction, the FETA notes that BAE is preparing not only the FEIA for the East
Washington Place project (EWP), but also preparing the economic impact/blighting portion of
the EWP Environmental Impact Report (FEIA pg.l). Since "blighting" is in large part a function
of vacancy rates, that portion of the analysis is critical. That in turn is driven by the potential for
internal competition within the City resulting in a simple transfer of sales, rather than recapture.
The Introduction than notes that the study relies upon "the most recently available information at
the time of analysis (December 2008) and follows by stating "use of the most recent information
represents a reasonable effort to establish baseline conditions.
But it is not clear that the most recent information was obtained, nor that it was applied to reflect
the critical last 12 months. In the discussion of household income trends (critical to determining
the available purchasing power to distribute between merchants), the FEIA assesses household
income for Petaluma, the "Trade Area", and Sonoma County. Yet the "data" provided that
,07 623.1925e. Fax 707.823.6661
1430 HIGH SCHOOL ROAD e SEBAsroPOL, CA 95472
underlies all the subsequent spending power analysis relies upon the year 2000 and the year
2008. From this, BAE then identifies an "Average Annual Change from the period of 2000 to
2008. This is a painfully weak projection; it is simply a line between two points. But it gets
worse. The footnote to Table 5 then says that "estimates for 2008, 20001 ] (sic), and 2016 based
on interpolation of ABAG 5 -year interval data" (FEIA page 7). But no ABAG original data is
provided, the Table appears to have taken the year 2000 data as a single sample point, and
somehow created a projection from that. Any projection has to be based upon at least two sample
points, which do not exist in Table 5.
The Table 4 that predicts household growth similarly takes one sample point (2000) and then
magically creates projection into the future. The footnote on this Table shows the shakiness of
the assumptions even more by noting that the data for 2008 is "interpolated from ABAG data for
5 -year intervals assuming a constant annual compound rate".
The result is that one of the key inputs to the FEIA, that being project growth in households
combined with projected growth in household income, all seem to hang on the single date set for
the year 2000. This is hopelessly inadequate, particularly given the growth in income and the
economy eight years ago is night and day compared with the present circumstance. As such, the
underlying income to be distributed and spent may be significantly oversstated, which in turn
means the relative impact of adding a major new competitive merchant fighting for a smaller
cash pool may have significantly larger adverse impacts upon the local businesses.
The discussion of employment rates is also misleading and not reflective of current data.
The third leg of the "demographic and economic overviews" does at least provide annualized
data from the year 2000, and the employment data is described as a reflection of buying power.
The FEIA says that the trend for the period 2000 to 2007 shows steady growth in employment,
with peak unemployment of 5.5 percent in 2003 (FEIA page 8). The accompanying Figure 2
shows a comforting employment trend, with a minor spike in 2003 mentioned above. But the
narrative adds that unemployment in November of 2008 had risen to 5.9 percent in Petaluma and
6.5 percent in the County, and then says "recent trends indicate that the number of unemployed
in Sonoma County is likely to continue increasing in the near term". (FEIA page 8).
An immediate question is why was the 2008 unemployment data omitted from the Petaluma and
Sonoma County graphs? Had they been included, the magnitude of the economic shift would
have been very apparent, and amply demonstrated the fallacy of primarily relying on a trend line
projection based upon one of the stronger economic growth cycles in many years.
More importantly, it shows that the optimistic projections for household growth, job growth,
household income, and unemployment are all skewed by the exclusion of the current economic
chasm. The resulting overestimations will then color and inflate the available retail dollars
during the required 5 -year period for the FEIA. All the resulting assumptions as to market share
and business impacts are therefore extremely optimistic and of questionable reliability.
East Washington Place FEIA commen6 20090401
The discussion of the "trade" area does not meet the FETA policy requirement.
The FEIA policy notes under "FEIA Contents" that the FEIA must assess the "project primary
and significant secondary market sectors'. But the FEIA only addresses "market sectors' at the
level of each business proposed for the new shopping center. It is normal practice to take a "big
box" store and break it down into its own product sectors that compete with other businesses in
that sector. Target stores do contain a significant food sales area, yet the FEIA only looks at the
shopping center impacts on food stores by assessing the impacts of the proposed specialty food
store. The FEIA says "no supermarkets can be assumed to be at risk of closure due to the
possibility of a small specialty food store in East Washington place." (FEIA page 37). There is
no discussion of the combined square footage of the stand-alone food store combined with the
area of the Target devoted to food sales, which can be considerable.
5 There is no discussion of the short-term nature of any retail sales "recapture" given the
continuing competition between cities for this revenue source.
This is a fundamental flaw in the approach taken by BAE. The FEIA makes repeated reference
to the "leakage" that is occurring in the general merchandise category, to be taken back by this
Project. In a recognition that cumulative economic impacts of new retail projects can have a
compounding effect, the FEIA includes the Deer Creel: Village project (FEIA page 40) with the
comment that the two projects have different retail mixes and different geographic markets.
What is missing from the entire analysis is the repeating cycle of cities raiding each other for
sales tax revenue. The data on Rohnert Park makes it very clear that a substantial portion of the
general merchandise sales leakage from Petaluma has ended up in Rohnert Park. Can there be
any doubt that Rohnert Park will not sit passively by and lose that revenue source to their own
municipal coffers? While it might be called "speculative" to try to anticipate how surrounding
cities will reply in turn, it is possible to look at cumulative impacts in the context of significant
shopping centers under review in the identified trade area. BAE has already opened the door to
such consideration with the inclusion of the Deer Creek project, yet does not consider whether
similar project are underway that would undercut the financial assumptions and predictions of
this FEIA.
6 The FEIA contains graphs and text statements that rely on unsourced information, or that
are misleading.
In the discussion of sales tax leakage from "general merchandise stores', the FEIA notes that
Petaluma has a "relative weakness as a retail destination" and shows this on Figure 5 (FEIA page
14). That graph shows an ominous upward curb for Rohnert Park taxable sales in that market
sector. Bit that graph represents total sales, not sales per capita. The FEIA has already indicated
that the key measure of leakage is a function of relative sales per capita by market sector. The
more appropriate and useful graph would have used that measure, as done elsewhere in the
Last Washington Place FEIA comments 20080401
FETA. Another example is the claim that "while currently the economy is in recession and
extremely unsettled, the Bay Area continues to see high housing demand". (FEIA page 9). No
source is cited, no indication of what type of housing, and no quantified data as to what
constitutes "high demand". Is this new construction or merely turnover of existing housing stock
through foreclosures and short sales? Which is the case presents a very different picture. More
to the point, the FEIA is supposed to be a document that assembles confirmable data and facts,
goes through an analytical process based upon those facts and data, and reaches conclusions. A
unsupported or documented assertion has no place in this document, particularly for the purposes
of trying to counter the pessimistic image left by the clearly documented economic contraction as
reflected in jobless rates and business decline.
One more example is the discussion of the K -Mart store in the Petaluma Plaza North shopping
center. The FEIA first notes that the K -Mart is the store most directly competitive with the
proposed Target store. In a apparent effort to create a positive picture, the FEIA states "this K -
Mart appeared busier and better -maintained than many other northern California Knarts visited
by BAE in the course of research for other retail impact studies in the last few years"(FEIA page
24). This anecdotal information has no value to the FEIA, although it may have some bearing on
any urban blighting analysis of the corollary EIR.
7 The discussion of Downtown vacancies is confusing and does not address current
circumstances. The FEIA states that as of 2004, there was approximately 362,000 square feet of
retail in the downtown area, but makes no effort at inventorying the current vacancy rate in the
area. It does note that the 18,000 square foot Carrithers building is vacant, which by itself
represents a 5% vacancy rate for downtown (which is identified by BAE as the target for a
stabilized vacancy rate. Since there are a number of other vacancies in downtown, it seems clear
that the vacancy rate may be quite a bit higher than five percent.
The FEIA also notes that the Theatre District project has added 86,000 square feet of retail space,
and that a substantial portion remains vacant.
The implication is that the downtown area is moving toward a higher vacancy rate over 51%,
suggesting that excess space is beginning to exist. Yet the FEIA suggests that the downtown
retail market has its own identity and is somehow immune to competitive pressures. It notes on
page 25 that the downtown does not "have a store directly competitive with Target", but then
notes that smaller stores may still be affected.
Yet the FEIA, in its discussion "estimated impacts" upon downtown (page 39), that the
downtown has some unexplained niche of its own, that its market area is larger than the Target
market area, and closes with the subjective and sweeping statement that " whatever the impact on
particular stores, the existing downtown as a whole will probably be minimally impacted, as it
provides a different shopping experience". The intent of the FEIA process is not to relative to
geographic areas, but to market sectors. The FEIA acknowledges that the downtown contains
many apparel stores, and that there is no particular leakage in the apparel sector, and that the
EWP center will contain secondary apparel stores. But the FEIA then refuses to connect the
East Washington Place FEIA comments 20080401
dots, and assess market sector impacts on smaller downtown apparel stores. Even more
surprising is that there appears to be no assessment of apparel competition with the significant
portion of Kmart that is devoted to apparel. The only market share analysis of Target is limited
to competition with other general merchandise stores, as if Target clothing sales will not, in part,
be at the expense of local apparel stores.
Closing comments
The economy makes this a challenging time to conduct such a study, but that does not excuse
refusing to deal with obvious impacts, with competitive market sectors ignored by the FEIA,
with the core role of demographics, and with the use of uncited sources of information that
cannot be confirmed or clarified.
I hope to send an elaboration on some of these points tomorrow, but wanted to provide this for
the Council packet
Sincerely,
Scot Stegeman
Last Washington Place FFIA commencs'_0080401
From: Paul Francis [petalumaneighbors@yahoo.com]
Sent: Monday, April 06, 2009 2:12 PM
To: Pamela; Teresa Barrett; daveglass@comcast.net; mike4pet@aol.com;
mthealy@sbcglobal.net; david@davidrabbitt.com; tiff@tiffanyrenee.com; - City Clerk
Cc: Brown, John
Subject: To be submitted as agenda item FEIA comments 4-6-2009
Dear Petaluma Mayor, Council, and Staff,
The Petaluma Neighborhood Association is a community organization consisting of residents whose common goals are to
advocate for sustainable development along with economic practices that will enhance the long-term economic vitality of our
city. As the largest group of stakeholders, it is our belief that, the input of Petaluma residents be the final decisive factor in all
future large scale retail development projects.
As most of you know, building development has many direct impacts on a city's ability to maintain economic stability and plan
for future revenue. Therefore, it is of the utmost importance that any future development is carefully scrutinized for its ability to
reinforce specific concepts that will lead our community to a sustainable future for many generations to come.
In addition, building development also has direct and indirect impacts upon a city's social welfare. It is in this reticulum of
neighborhood streets, thoroughfares, walkways, buildings, parks and plazas by which a community can grow, prosper, and
thrive together. These are the places where the individual becomes interdependently linked to his/her community. There is a
direct correlation between how a city is designed and built and the social and economic health of its community. With attention
to and the encouragement of building designs that cultivate social interaction and discourage auto-centric design the prosperity
of the individual, through symbiosis, becomes the collective prosperity of our community as a whole.
It is important that all future development be guided in a direction that promotes and enhances pedestrian and transit oriented
design along with economic and environmental sustainability. That all future retail development adhere to the concepts which
are described in Petaluma's GP2025 and the Central Petaluma Specific Plan that clearly define these principles. Also, that all
future large scale retail development conforms to our community standards first and foremost, and not to, in this case, the
developer's inefficient standards.
The Bay Area Economics, Fiscal and Economic Impact Analysis, for the proposed East Washington Place shopping strip mall
that has been released to you and the public is fundamentally flawed. Not only is it flawed in its process but, also in its biased
approach toward information gathering and application. The process in which BAE has attempted
to analyze any potential impacts was set forth in the form of a "retail leakage
report" and not a proper study of potential economic impacts to the city of Petaluma.
A retail leakage study conducted in such a manner as this, merely represents, rather
blatantly, one particular point of view based on speculation and assumptions.
It is not until the process by which BAE has conducted the FEIA is changed that we
may have a proper non-biased economic analysis presented to us.
My recommendation would be to reject BAE^'s FEIA based on its obvious flaws and commission another consultant to conduct a
fair economic analysis of the EWP project.
Considering the importance of having a fair unbiased process and public involvement, my recommendation would be that a
public oversight committee be assigned to this task of properly scrutinizing the FEIA process along with other issues that may
arise from the large scale project proposed. A small group of residents, consisting of three residents, acting as liaisons between
Regency and Council. A group of residents who have absolutely no ties to the development interests and who stand to receive
no benefits from catering to the approval of said projects. A group of citizens who understand the issues and will place a
sobering perspective on the situation.
Thank you for your thoughtful consideration of my comments and recommendations
Rcspectfully Yours,
Paul Francis
Petaluma Neighborhood Association
cvcvm.netalumanei ¢hborhoodassociation.ore