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RMM REMY 3 MOOSE I MANLEY LL. James G. Moose jmoose@rmmenvirolaw.com January 28,2013 Board of Supervisors Board Chambers, 6ui Floor 44 N. San Joaquin Street, Stockton CA, 95202 Re: Love's Travel Stops, State Route 12 East of Thornton Road, Lodi,CA Dear Supervisors: Our firm represents the Applicant for the Love's Travel Stops Project ("the Project"), which would be located east of Thornton Road, north of State Route 12 (SR 12) in unincorporated northwestern San Joaquin County. The Project is scheduled to come before your Board for formal consideration on February 12, 2013. In this letter and its attached exhibits, we respectfully offer analysis and substantial evidence in support of approval of the Project and in opposition to approval of any of the Project alternatives outlined in the environmental impact report ("EIR") prepared for the Project. These alternatives consist of the following: "No Project Alternative" (Alternative 1); "Reduced Project Size" (Alternative 2); "Alternative Use — Combination Gasoline Station" (Alternative 3); and "Alternative Use — Retail with Fast-Food Restaurant" (Alternative 4). The information being conveyed herein supports the formal rejection of these alternatives as being "infeasible"within the meaning of that legal term of art, and also supports approval of the Project due to the economic and social benefits it will bring to the County. Information relating to the second possible Board action is responsive to one of the grounds on which Pilot Flying J, Inc. ("Pilot") has appealed the Planning Commission's approval of the Project on December 20, 2012. Pilot has urged that the Commission's "Statement of Overriding Considerations" is not supported by substantial evidence. This letter and its attachments render that contention moot by including quantified expert economic evidence of the clear economic and fiscal benefits of the Project. In compliance with the California Environmental Quality Act (Pub. Resources Code, § 21000 et seq.) (CEQA), the Draft and Final EIRs for the Project include the requisite"reasonable range of alternatives" (Cal. Code Regs., tit. 14, div. 6, ch. 3 (CEQA Guidelines), § 15126.6, subd. (a).) The No Project Alternative assumes that the Project is not approved and that development of the proposed truck stop would not occur. Under Alternative 2, the truck stop would be developed at half the size of the proposed Project. Specifically,the alternative proposes a truck stop with 12 available fuel-dispensing pumps and reduced square footage for the 455 Capitol Mall,Suite 210 Sacramento CA 95814 1 Phone:(916)443-2745 1 Far.(916)443-9017 1 www.rmmenviroiaw.com