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The ARC SEIR Transportation Impact Analysis is neither adequate nor complete

The following was sent to the Bicycling, Transportation, and Street Safety Commission (BTSSC) and the City as written comment by Matt Williams on April 8, the day before the BTSSC meeting.   The opinions expressed in the public comment are as an individual, and not as a representative of any organization.

First, I would like to thank Sherri Metzger, Ash Feeney, and Fehr and Peers for providing the Excel spreadsheet I requested containing the data from the tables from pages 42 through 161 of the SEIR Appendix F, Volume 2 – Transportation Operations Analysis Technical Appendix.

Second, my deep dive analysis of the intersection data in the spreadsheet produced the following substantial concerns.  At the end of this memo, I provide a Recommendation that I would vote for if I were a member of the BTSSC.

  1. The 23 intersections studied/counted did not include the two most impactful “choke point” intersections
    • The intersection of southbound Mace Boulevard with the I-80 eastbound loop on-ramp was omitted. That uncounted intersection is physically between Intersection 13 and Intersection 14
    • Intersection 14 Mace Boulevard/Chiles Road was reported as a 4-way intersection rather than a 5-way intersection. The fifth “way” of that intersection is the I-80 eastbound slip on-ramp.  Especially during the PM Peak Hour that I-80 slip on-ramp off northbound Mace is the single biggest “choke” point in the existing traffic in the 23-intersection study area.  If Fehr and Peers and the City want to avoid including 5-way intersections, that I-80 slip on ramp should be included as an intersection of its own.

In my personal opinion failure to include the two most impactful intersections in the 23-intersection transportation analysis means that analysis, and the SEIR is not adequate or complete 

  1. The 23 intersections studied/counted do not adequately report the impact of traffic (Vehicle Miles Traveled) on adjacent residential neighborhoods. The following two additional intersections should be added to the analysis, Alhambra Drive/5th Street and Alhambra Drive/Loyola Drive.
  2. Page 33 of SEIR Appendix F, Volume 1 – Transportation Operations Analysis reports the following, with bolding added by me for emphasis:

Project Trip Generation

Table 3 summarizes the estimated weekday and peak hour trip generation for the ARC project using the MXD+ tool. As shown in this table, the ARC project would generate an estimated 23,888 new external daily vehicle trips, 2,232 new external AM peak hour vehicle trips, and 2,479 new external PM peak hour vehicle trips during a typical weekday. The Mace Triangle would generate an estimated 762 new external daily vehicle trips, 93 new external AM peak hour vehicle trips, and 82 new external PM peak hour vehicle trips during a typical weekday.

Vehicle-counts-1
The SEIR spreadsheet data provided by the City produces the following vehicle counts for the five (5) intersections that provide ingress and egress to ARC during the AM peak hour:

The aggregate total of the Gross Ins and Outs to the ARC Project for those five (5) intersections is 1,913, which is only 87% of the 2,232 new external AM peak hour vehicle trips reported on page 33 SEIR Appendix F, Volume 1 – Transportation Operations Analysis. 

There appears to be no apparent reason for that 13% difference between the reported aggregate and the calculated aggregate in the tables.  Absent an explanation for this discrepancy, I believe the SEIR is not adequate or complete

The SEIR spreadsheet data provided by the City produces the following vehicle counts for the five (5) intersections that provide ingress and egress to ARC during the PM peak hour:

Vehicle-counts-2

The aggregate total of the Gross Ins and Outs to the ARC Project for those five (5) intersections is 2,205, which is only 89% of the 2,479 new external PM peak hour vehicle trips reported on page 33 SEIR Appendix F, Volume 1 – Transportation Operations Analysis. 

There appears to be no apparent reason for that 11% difference between the reported aggregate and the calculated aggregate in the tables.  Absent an explanation for this discrepancy, I believe the SEIR is not adequate or complete.

  1. There are additional data inconsistencies in the intersection data that become visible when one attempts to better understand Vehicle Miles Traveled along the most likely routes that vehicles will used to travel to ARC in the AM peak hour, and travel from ARC in the PM Peak Hour.  The graphic below shows the AM Peak Hour data, as provided to me by City staff in the Excel spreadsheet in the top half of the graphic.  The bottom half of the graphic shows the two of the most likely routes to ARC in the AM Peak Hour.  The first route starts at Intersection 1 at East Covell Boulevard/Pole Line Road and proceeds east along Covell Boulevard, around the Mace Curve, and then south on Mace to ARC, and then further on Mace down to Intersection 17 at Mace Boulevard/El Macero Drive.  The + or – column shows the difference between the through vehicles reported at each respective intersection and the through vehicle count calculated as one proceeds from Pole Line through the route.  Note that between Manzanita Lane (Intersection 4) and Wright Boulevard (Intersection 5) a discrepancy of 150 unaccounted-for vehicles appears to the through vehicle count. Then between Wright Boulevard and Monarch Lane a 195-vehicle discrepancy appears.

Data-inconsistencies

Similar discrepancies appear between Intersections  21 and 9, 9 and 11, 11 and 13, and 13 and 14.  There are always going to be small discrepancies due to timing differences, but the magnitude of the noted discrepancies are well beyond simple timing differences.  It is worth noting that the 209 vehicle discrepancy between Intersection 13 (Mace Boulevard/I-80 WB Ramps) and Intersection 14 (Mace Boulevard/Chiles Road) is largely attributable to the omission of the intersection of southbound Mace Boulevard with the I-80 eastbound loop on-ramp from the collected data.

As shown in the graphic Similar discrepancies appear in the route from the I-80 eastbound off ramp (Intersection 15) through intersections 14, 13, 11, 9, and 22 .  The very high discrepancy numbers between Intersection 14 (Mace Boulevard/Chiles Road) and 13 (Mace Boulevard/I-80 WB Ramps) are largely attributable to the omission from the collected data of the intersection of that I-80 slip on-ramp off northbound Mace, which is the single biggest “choke” point in the existing traffic in the 23-intersection study area.

Absent an explanation for these discrepancies and similar discrepancies in the PM Peak Hour data, I believe the SEIR is not adequate or complete.

Recommendation

Because of all the above examples where the SEIR Appendix F – Transportation Impact Analysis is neither adequate nor complete, I recommend that the Bicycle, Transportation & Street Safety Commission (BTSSC) approve the following resolution addressed to both the Planning Commission and the City Council.

That the BTSSC does not consider the Aggie Research Campus Draft Subsequent Environmental Impact Report to be either complete or accurate. 

That the BTSSC will not consider the Aggie Research Campus Draft Subsequent Environmental Impact Report to be complete or accurate until the substantial discrepancies and omissions identified in Appendix F – Transportation Impact Analysis are remedied.

That the BTSSC  recommends that neither the Planning Commission nor the City Council certify any Aggie Research Campus Environmental Impact Report until the Transportation Impact Analysis is both complete and accurate.

 

Thank You

Thank you to all the BTSSC members for your consideration of this detailed and holistic analysis of the SEIR Transportation Impact Analysis. 

I am available to review the detailed spreadsheet with its 14 different scenarios with any individual (or non-quorum group of) BTSSC member.

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