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HomeMy WebLinkAbout2020-11-02; Traffic and Mobility Commission; ; Fiscal Year 2020-21 Growth Management Plan Monitoring Report – Circulation Section ApproachItem 4 Meeting Date: Nov. 2, 2020 To: Traffic and Mobility Commission Staff Contact: Nathan Schmidt, Transportation Planning and Mobility Manager Nathan.schmidt@carlsbadca.gov, 760-637-7183 Subject: Fiscal Year 2020-21 Growth Management Plan Monitoring Report – Circulation Section Approach Recommended Action Receive a presentation and provide input on the approach for the Fiscal Year 2020-21 Growth Management Plan Monitoring Report Circulation Section. Executive Summary This presentation is intended to provide an overview of the proposed approach for the FY 2020- 21 Growth Management Plan (GMP) Monitoring Report Circulation Section and to receive feedback from the Traffic and Mobility Commission prior to executing a task order with a consultant to prepare the Multimodal Level of Service (MMLOS) analysis report. Background Annual traffic monitoring as part of the GMP Monitoring Report is necessary to evaluate changes in traffic volumes, travel patterns, and multimodal roadway operating conditions from previous years. The report also helps identify negative and positive traffic impacts due to recent development and roadway improvement projects, identify facilities that are reaching capacity, help determine recommended measures to address congested conditions. GMP Monitoring Approach Study Street Facilities for Vehicle LOS All street typologies subject to automobile level of service (LOS) monitoring will be evaluated as part of the FY2020-21 GMP Monitoring Report and will include: arterial streets, arterial connector streets, and industrial streets. The FY2019-20 GMP Monitoring Report analyzed 45 industrial streets for the first time, including cul-de-sacs. Based on the initial analysis of the FY 2019-20 results, staff recommends limiting the analysis to 13 of the highest volume industrial streets. Vehicle Traffic Data Collection / Monitoring Locations The FY2019-20 GMP Monitoring Report analyzed 107 locations for vehicular level of service. For the FY 2020-21 Report, staff is proposing an initial list of 79 locations including the following four roadways that have not been analyzed in the past. Table 1: Added Vehicular LOS Analysis Locations for FY2020-21 Monitoring Roadway Extents Typology Comment Cannon Rd Carlsbad Blvd to Avenida Encinas Arterial Poinsettia Ln Cassia Rd to El Camino Real Arterial New roadway opened 12/2020 Rancho Santa Fe Rd Olivenhain Rd to Calle Acervo Local Functions as Arterial Olivenhain Rd Rancho Santa Fe Rd to 1,100 feet west of Rancho Santa Fe Rd Arterial New traffic counts will be collected at each location for a 72-hour period for three consecutive weekdays, Tuesday through Thursday in April/May 2021. The new traffic volumes will be reviewed through a year-to-year comparison to verify the accuracy of the count data and recounts will be conducted if any counts are determined to be invalid. Recounts may be required due to reasons such as equipment failure or due to a non-typical occurrence such as a construction detours or emergency incidents. Since these traffic counts are intended to capture school traffic, recounts may occur in May or after September of 2021, depending on when the notice of the recount is issued to the consultant. A formal quality assurance/quality control procedure will be provided by the consultant and reviewed by staff in advance of the collection of traffic data. It should be noted that when a previous year’s monitoring report has determined that a facility was operating at LOS D, then all segments within the facility will be monitored in the next annual GMP Monitoring Report. Because of this requirement the initial list of locations provided in Exhibit 1 for the FY2020-21 are subject to change based on the findings of the prior year’s analysis. Vehicle Level of Service Analysis Vehicle level-of-service (LOS) will be determined at the “facility” level using the most current version of the Highway Capacity Manual (HCM) as required by the City of Carlsbad General Plan Update. Vehicle LOS will be calculated using the Carlsbad Roadway Capacity Tables Report to determine LOS for each street facility based on the highest peak hour directional volume from the three-day traffic counts. The roadway service volumes are determined using ARTPLAN software using calculations outlined in the HCM and is used nationally as a planning tool for roadway corridor level of service analysis. Prior to conducting the LOS analysis, the consultant will review the latest version of the Carlsbad Roadway Capacity tables to verify any changes to roadway lane configurations and update the capacity tables as needed. In addition, a comparison of the current year’s roadway LOS will be made with the previous year’s roadway LOS, to assess changes in the roadway conditions. Identification of Deficient Street Facilities for Vehicle LOS Based on the vehicle LOS analysis described above, street facilities determined to not meet the vehicle LOS performance standard of LOS D or better will be identified as deficient. The report will include an analysis of possible projects that could mitigate the deficiencies or improve traffic operations. Staff will also evaluate the list of previously exempt street facilities to determine if such exemptions are still warranted as required by General Plan Mobility Element Policy 3-P.9,. Multimodal Level of Service Analysis As recommended by the Traffic and Mobility Commission at their meeting on October 5, 2020, city staff will work with an ad-hoc planning group to update and revise the city’s MMLOS Tool and associated methodology. Once the methodology has been finalized staff will review the street typologies to determine the specific locations for new vehicle traffic counts and if additional field data is required to meet the needs of the revised MMLOS methodology. Street typologies evaluated as part of the MMLOS analysis of the pedestrian and bicycle travel modes will include: Identify Streets, Village Streets, Arterial Connector Streets, Neighborhood Connector Streets, Coastal Streets, School Streets, Employment/Transit Connector Streets, and streets that are within a half-mile of a transit center. The level of evaluation of Local/Neighborhood streets as part of the FY2020-21 report will be addressed by the ad-hoc planning group. Staff does not anticipate evaluating the transit mode as part of the FY2020-21 GMP Monitoring Report. Transit MMLOS has not previously been analyzed as it is no longer needed to be monitored because the city passed the citywide Transportation Demand Management (TDM) ordinance which ensures that all facilities meet the minimum MMLOS D standard for transit. The level of evaluation of Transit MMLOS as part of the FY2020-21 report will be addressed by the ad-hoc planning group. MMLOS analysis will be conducted using the revised MMLOS methodology for all street facilities within the applicable street typologies as outlined above. Based on this analysis segments that have deficient MMLOS scores (MMLOS E or F) for bicycle and pedestrian modes will be identified. Mitigation Recommendations After completion of the Vehicle LOS and MMLOS analysis for pedestrians and bicyclists, the City will work with the consultant to identify potential mitigations for the deficient street facilities. Mitigations for vehicle LOS will be evaluated for all newly identified deficient street facilities. These mitigation strategies may include improvements to mainline roadway segments, intersection lane configurations and/or signal timings, Transportation Demand Management (TDM) strategies and Transportation Systems Management (TSM). For MMLOS, all deficient facilities will be reviewed for potential improvements to bicycle, pedestrian, and transit facilities that would improve MMLOS to an acceptable MMLOS D or better. Documentation The final FY2020-21 GMP Monitoring Circulation report will combine the results of the vehicle LOS monitoring and the MMLOS monitoring into a single report. The report will clearly identify the level of service methodology used for each travel mode and include figures that will illustrate which facilities have been exempted by the city council and identify MMLOS for each facility by color and a separate map will be provided for each travel mode. The traffic count data, vehicle LOS calculations and MMLOS tool output worksheets for bicycle, pedestrian, and transit modes for each study location will be included in appendix. Necessary Council Action No council action is required for this item. Next Steps After receiving the Traffic and Mobility Commission’s input on the approach to the FY2020-21 GMP Monitoring Report, staff will prepare a detailed scope of work and select a consultant from the city’s current master list of qualified transportation engineering firms. Work on the FY2020- 21 GMP Monitoring Report Circulation section is expected to begin in spring 2021 and will take approximately six to eight months to complete. Exhibits 1. List of vehicle count locations Exhibit 1 List of Vehicle Traffic Count Locations Street Facility General Plan Street Typology 1. El Camino Real - City Limits to Marron Rd Arterial 2. El Camino Real - Marron Rd to Carlsbad Village Dr Arterial 3. El Camino Real - Carlsbad Village Dr to Tamarack Ave Arterial 4. El Camino Real - Tamarack Ave to Cannon Rd Arterial 5. El Camino Real - Cannon Rd to College Blvd Arterial 6. El Camino Real - College Blvd to Palomar Airport Rd Arterial 7. El Camino Real - Palomar Airport Rd to Gateway Rd Arterial 8. El Camino Real - Gateway Rd to Town Garden Rd Arterial 9. El Camino Real - Town Garden Rd to Camino Vida Roble Arterial 10. El Camino Real - Camino Vida Roble to Poinsettia Ln Arterial 11. El Camino Real - Poinsettia Ln to Aviara Pkwy/Alga Rd Arterial 12. El Camino Real - Aviara Pkwy/Alga Rd to La Costa Arterial 13. El Camino Real - La Costa Ave to La Costa Towne Ctr Arterial 14. El Camino Real - La Costa Towne Ctr to Levante St Arterial 15. El Camino Real - Levante St to Calle Barcelona Arterial 16. El Camino Real - Calle Barcelona to Leucadia Blvd Arterial 17. College Blvd - City Limits to Carlsbad Village Dr Arterial 18. College Blvd - Carlsbad Village Dr to Redbluff Pl/Inlet Dr Arterial 19. College Blvd - Redbluff Pl/Inlet Dr to Rift Rd/Richfield Dr. Arterial 20. College Blvd - Rift Rd/Rich Field Dr to Cannon Rd/Bobcat Blvd Arterial 21. College Blvd - El Camino Real to Salk Ave Arterial 22. College Blvd - Salk Ave to Faraday Ave Arterial 23. College Blvd - Faraday Ave to Aston Ave Arterial 24. College Blvd - Aston Pl to Palomar Airport Rd Arterial 25. Aviara Pkwy - Palomar Airport Rd to Laurel Tree Ln Arterial 26. Aviara Pkwy - Laurel Tree Ln to Mariposa Rd/Cobblestone Rd Arterial 27. Aviara Pkwy - Mariposa Rd/Cobblestone Rd to Plum Tree Rd Arterial 28. Aviara Pkwy - Plum Tree Rd to Camino De Las Ondas Arterial 29. Aviara Pkwy - Camino De Las Ondas to Poinsettia Ln Arterial 30. Aviara Pkwly/Alga Rd - Poinsettia Ln to El Camino Real Arterial Connector 31. Aviara Pkwy/Alga Rd - El Camino Real to Corintia St Arterial Connector 32. Aviara Pkwy/Alga Rd - Corintia St to Melrose Dr Arterial Connector 33. Melrose Dr - City Limits to Palomar Airport Road Arterial 34. Melrose Dr - Palomar Airport Road to Poinsettia Ln Arterial 35. Melrose Dr - Poinsettia Ln to Rancho Santa Fe Rd Arterial 36. Rancho Santa Fe Rd - City Limits to Camino Junipero Arterial 37. Rancho Santa Fe Rd - Camino Junipero to La Costa Ave Arterial 38. Rancho Santa Fe Rd - La Costa to Camino De Los Coches Arterial 39. Rancho Santa Fe Rd - Camino De Los Coches to Calle Barcelona Arterial 40. Rancho Santa Fe Rd - Calle Barcelona to Olivenhain Rd Arterial 41. Rancho Santa Fe Rd – Olivenhain Rd to Calle Acervo Arterial 42. Olivenhain Rd - El Camino Real to west of Rancho Santa Fe Rd Arterial 43. Cannon Rd - Carlsbad Blvd to Avenida Encinas Arterial 44. Cannon Rd - Avenida Encinas to Paseo Del Norte Arterial 45. Cannon Rd - Paseo Del Norte to Car Country Dr Arterial 46. Cannon Rd - Car Country Dr to Legoland Dr Arterial Exhibit 1 47. Cannon Rd - Legoland Dr to Grand Pacific Dr Arterial 48. Cannon Rd - Grand Pacific Dr to Faraday Ave Arterial 49. Cannon Rd - Faraday Ave to El Camino Real Arterial 50. Cannon Rd - El Camino Real to College Blvd Arterial 51. Palomar Airport Rd - Carlsbad Blvd to Avenida Encinas Arterial 52. Palomar Airport Rd - Avenida Encinas to Paseo Del Norte Arterial 53. Palomar Airport Rd - Paseo Del Norte to Armada Dr Arterial 54. Palomar Airport Rd - Armada Dr to Aviara Pkwy Arterial 55. Palomar Airport Rd - Aviara Pkwy to Camino Vida Roble Arterial 56. Palomar Airport Rd - Camino Vida Roble to El Camino Real Arterial 57. Palomar Airport Rd - El Camino Real to El Fuerte Arterial 58. Palomar Airport Rd - El Fuerte to Melrose Dr Arterial 59. Palomar Airport Rd - Melrose Dr to City Limits Arterial 60. La Costa Ave - I-5 to Piraeus St Arterial 61. La Costa Ave - Piraeus St to El Camino Real Arterial 62. Carlsbad Village Dr - I-5 to El Camino Real Arterial Connector 63. Carlsbad Village Dr - El Camino Real to College Blvd Arterial Connector 64. Poinsettia Ln - Aviara Pkwy to Cassia Rd Arterial Connector 65. Poinsettia Ln – Cassia Rd. to El Camino Real Arterial Connector 66. Poinsettia Ln - El Camino Real to East of El Fuerte Arterial Connector 67. Legoland Dr - Cannon Rd to Armada Arterial Connector 68. Armada Dr - Legoland Dr to Palomar Airport Rd Arterial Connector 69. Rutherford Rd - Faraday Ave to Priestly Dr Industrial 70. Priestly Dr - Faraday Ave to End Industrial 71. Lionshead Ave. – Melrose Dr. to City Limits Industrial 72. Camino Vida Roble – Palomar Oaks Way to Palomar Airport Rd Industrial 73. Camino Vida Roble – Palomar Airport Rd to El Camino Real Industrial 74. Whiptail Loop W – Faraday Ave. to Whiptail Loop E Industrial 75. Whiptail Loop E – Whiptail Loop W to Faraday Ave. Industrial 76. El Fuerte St. – Faraday Ave. to Palomar Airport Rd. Industrial 77. Loker Ave. W – Palomar Airport Way to El Fuerte St. Industrial 78. Loker Ave. E – El Fuerte St. to Palomar Airport Rd. Industrial 79. Gateway Rd. – El Fuerte St. to Palomar Airport Rd. Industrial Notes: • All locations to include bi-directional, 72-hr traffic counts • Counts to occur in May 2021 from Tuesday to Thursday while school is in session. 1 Traffic and Mobility Commission, Commissioner Correspondence From: Commissioner Steve Linke Meeting Date: November 2, 2020 Subject: FY 2020-21 GMP Monitoring Report – Circulation Section Approach (Item #4) This correspondence contains many of my comments, suggestions, and questions about the proposed methods for Growth Management Plan (GMP) monitoring of circulation/mobility facilities. It gets very long and technical, so parts of it may be a challenging read. It is not “polished,” but I wanted to get it out by today. FORMAL DOCUMENT FOR RULES I am not sure whether this item is intended only for the FY 2020-21 GMP Monitoring Report. The final methods should be formalized and were originally supposed to be included in an overarching document called the “Mobility Systems Evaluation and Monitoring (MSEM) Manual.” MONITORED STREET FACILITY CHANGES Addition of remaining vehicle-prioritized street facilities to monitoring list I have been pointing out for the last few years that there were many vehicle-prioritized facilities left off the monitoring list, such as Olivenhaid Road; Carlsbad Village Drive; parts of Cannon Road, Poinsettia Lane, and Aviara Parkway/Alga Road; and all of the Industrial Streets. I am pleased that all of these facilities will now be included in the monitoring. Industrial Street monitoring The staff report states that 45 Industrial typology facilities were monitored for the FY 2019-20 GMP Monitoring Report, but that only the 13 highest volume locations are planned for future monitoring. That sounds reasonable to not waste resources monitoring facilities with no chance of deficiency. However, it would be useful to see the results of the 45 facilities and what criteria were used to pare the list down to 13. Also, the new “List of Vehicle Traffic Count Locations” in the staff report only includes 11 Industrial Streets, rather than 13. Non-vehicle-prioritized street facilities on monitoring list A few Local/Neighborhood typology facilities also were added to the list, presumably due to relatively high vehicle volumes: • Rancho Santa Fe Road from Olivenhain Road to Calle Acervo (listed as Arterial typology) • Legoland Drive from Cannon Road to Armada (listed as Arterial Connector typology) • Armada Drive from Legoland Drive to Palomar Airport Road (listed as Arterial Connector typology) 2 I think the correct (Local/Neighborhood) typology for these facilities should be included in the table for now (to avoid confusion), but perhaps the General Plan should be updated to reflect their Arterial status. I also would like to propose some additional facilities for vehicle level of service (LOS) monitoring that have historically been monitored and/or have relatively high volumes. The cost of adding several additional mid-block pneumatic tube counters should be minimal, and I think the data will be valuable, even if the current General Plan does not require meeting a vehicle LOS standard on such facilities. Further, in a March 14, 2017 legal settlement with an environmental group, the city agreed in Paragraph 4.3.7 to “establish a baseline performance metric and monitoring protocols to measure progress toward achieving [transportation mode shifts] assumed in the Climate Action Plan.” Thus, tracking changes in vehicle usage over time, along with transit, pedestrian, and bicycle usage, on these additional streets could help establish mode shifting. Please add the following Employment/Transit Connector typology streets that are already included in the service volume table: • Two facilities on Faraday Avenue from Van Allen Way to Melrose Drive • Two facilities on Poinsettia Lane from Avenida Encinas to Aviara Parkway Please add the following facilities that were monitored annually through 2016: • Six locations along Carlsbad Boulevard (Coastal typology) • Tamarack Avenue (Neighborhood Connector typology) • La Costa Ave from El Camino Real to Rancho Santa Fe Road (Neighborhood Connector typology) Please add other higher-volume facilities: • Poinsettia Lane from east of El Fuerte Street to Melrose Drive (School typology) • Other Neighborhood Connector Streets, such as Avenida Encinas, Paseo Del Norte, Calle Barcelona, etc. (based on Transportation Department experience) DATA COLLECTION Alternative traffic counting methods Counts can also be collected from in-pavement inductive loop detectors and/or video cameras—perhaps at almost no cost. For streets that do not require monitoring, it may still be useful to track that data over time in areas where it is available. And if bicycle traffic can be differentiated, it can be a way to track mode shift. 3 Locations of counters within facility The tube counters probably should be placed in the predicted maximum volume portion of the facility and not too close to intersections or in areas with heavy lane changes. Question: Is there a guideline for placement? Timing of traffic counts All of the traffic counts are planned for the May or September timeframes on Tuesdays through Thursdays (school in-session). That should capture peak usage for nearly all streets. However, some streets may have heavier usage in the Summer and/or on weekends, such as Carlsbad Boulevard (albeit not required for monitoring). Perhaps there are other streets near destinations that are frequented at alternative times. Question: Has that been accounted for? Recount rules There should be clear rules on when and how recounts are done and how alleged “outlier” counts are addressed. There have been shenanigans to manipulate traffic count data to match a pre-conceived idea, which need to be tightly regulated (e.g., see my 10/16/2020 letter to the City Council on the Marja Acres project—Attachment 1). Removal of exemptions from facilities that are not deficient As I have described previously, General Plan Mobility Element Policy 3-P.11 was supposed to say that its list of exempt facilities would not be allowed until: “After the College Boulevard extension and Poinsettia Lane connections are completed…” That language was unethically removed by staff just prior to final adoption by the City Council. Ms. Gomez said at our last meeting that that situation could be investigated. I think this is an appropriate time to do that, because the facilities that are not actually deficient should not be considered exempt, regardless of when/how they were exempted. SERVICE VOLUME UPDATES Prior to analysis of the traffic count data, the service volume table should be updated each year for all facilities that have undergone changes that affect their service volumes—and to add any new facilities. In addition to revisions that reflect changes to lane configurations, as described in the staff report, it is my understanding that several other changes also could affect the reported service volumes as calculated by the ARTPLAN software, including: • Speed limit • Median type • Traffic signal spacing, type, timing, and phasing • Parking • Turn lane storage length 4 Also, it is my understanding that default values may be used for several other technical ARTPLAN inputs for many (or all) of the facilities, and that better results could be achieved if these inputs are customized to reflect the unique character of a facility. Those include: • Turning movement percentages • Arrival type • % heavy vehicles • Peak Hour Factor (PHF) • K factor • D factor Question: Are custom or default values used now, and what are the rules and plans to update them, if any? Questions: Turning movement percentages may have a substantial effect on the service volumes. How can those be determined without intersection counts? Could data from loop detectors and/or video be used to estimate turning movements for this purpose? MORE DETAILED ANALYSIS TRIGGERED WHEN FACILITY APPROACHING DEFICIENCY Segment-level analysis The staff report describes an approach in which street facilities that reach LOS D should undergo more detailed LOS analysis of the individual street segments, because some of them may actually be worse than LOS D. This is a very good approach that is consistent with guidance provided by traffic engineers in past monitoring studies and an 11/7/2019 Technical Memorandum prepared by STC Traffic entitled “Facility Level of Service Approach for Growth Management Program – Technical Review” (Attachment 2). However, there are a number of complications that should be addressed. Many of the street facilities jump from LOS C to LOS F (at least one even jumps from LOS B to LOS F), because intersection capacities have been reached on those facilities (see the “##” symbols in the service volume table). Therefore, the trigger for detailed segment analysis should be the highest grade level before deficiency/failure, rather than just simply LOS D. In addition, there are some streets that default to LOS D no matter the traffic count due to tight signal spacing (see the “**” symbols in the service volume table)—for example, Aviara Parkway and the already-exempted portions of Melrose Drive and Cannon Road at the freeways. In fact, the already-exempted portions of Palomar Airport Road and El Camino Real at the freeways default to LOS E. To avoid unnecessary additional counts, would it make sense to define the trigger for individual segment counts as being a traffic count that puts the facility at its highest grade level before deficiency, but the count has to be a certain percentage of (e.g., at least 85%), or a certain number of vehicles (e.g., 100) within, the deficiency threshold for that grade? 5 For example, northbound El Camino Real from Camino Vida Roble to Palomar Airport Road is LOS C through 1,330 vehicles per hour (vph) and LOS D from 1,331 to 2,510 vph, so it becomes deficient at 2,511 vph. During FY 2018-19 monitoring, the peak was 1,598 vph. Although that is LOS D, it is significantly lower than the 2,510 vph “failure point”—63.7% of that number. So, perhaps it would be unnecessary to do detailed analysis at this point, but that may make sense of it reaches 2,134 (85% level). In contrast, southbound College Boulevard from the City Limits to Carlsbad Village Drive is LOS C through 930 vph and LOS D from 931 to 1,680 vph, so it becomes deficient at 1,681 vph. And its peak was 1,674, which was extremely close to the failure point—99.6% of that number. That would definitely warrant the more detailed segment analysis. As another example, northbound El Camino Real between La Costa Avenue and Aviara Parkway-Alga Road jumps from LOS C to LOS F at 2,581 vph, and its peak was 2,356 vph. So, even though it can never get an LOS D grade, it was at 91.3% of its highest grade before deficiency, which would warrant the more detailed segment analysis. If this more limited trigger of detailed segment analysis is used, I think it should happen in the same monitoring year as the full facility count. For example, if May facility-level traffic counts generate values that trigger segment-level analysis (e.g., 85%), then the segment-level analysis should occur later in May or in September. The above strategy should be incorporated into the “Evaluating Facility Level of Service (LOS)” flow chart for both GMP monitoring and TIA documents, which was included in the attached STC memo and the last GMP Monitoring Report. The above strategy also should be applied retroactively to all deficient street facilities, including those that have been exempted, to the extent that it has not already been done. Intersection analysis As I have detailed previously, staff removed intersection LOS analysis from the TIA Guidelines, which are used for monitoring and development applications. However, the GMP, CFIP, and General Plan Mobility Element all describe intersection analysis, so I feel that the removal was improper. I also feel that it is not good policy, because intersection analysis can help identify potential improvements (e.g., turn lane improvements, signal timing changes, etc.). Further, the GMP Year 2018 Traffic Conditions Report states: The service volumes are used for LOS reports and to identify potentially congested roadway segments and isolated intersections that need further analysis. The HCM defines the service volume LOS method as a planning level analysis that provides a means of quickly assessing one or more urban street facilities to determine which facilities need to be more carefully evaluated (with operational analysis) to ameliorate existing or pending problems. In practice this is typically applied to longer arterial corridors rather than individual segments. The LOS reported 6 for the arterial may be better than individual segments or intersections. When LOS D is reported for an arterial further LOS analysis should be conducted for specific segments and/or isolated intersections. Accordingly, I think the detailed segment analyses should be accompanied by intersection analyses. Due to the higher cost of intersection counts, only doing them on facilities that are approaching or in deficiency is a smart approach that does not waste resources. In addition, perhaps once the intersection analyses are done to help identify useful capacity, TSM, and/or TDM projects, they would not need to be repeated in future years, unless there are material changes that warrant it. MULTIMODAL LEVEL OF SERVICE (MMLOS) Confusing statement in staff report It is unclear why, in the staff report, it is stated that specific locations for new vehicle traffic counts will be determined after the MMLOS Tool/methodology has been finalized, since that tool is presumably specific to pedestrian and bicycle LOS. Disappointing inclusion of “pre-existing deficiency” claim in final FY 2018-19 GMP Monitoring Report At our last commission meeting, I strongly opposed language in the staff report that made the false claim that the inclusion of MMLOS in the 2015 General Plan update was never intended to be used for monitoring independent of new development. To my extreme disappointment, that inaccurate revisionist interpretation was actually inserted directly into the final GMP Monitoring Report for acceptance by the City Council—after our review: In 2015, when the City Council amended its circulation performance standard to include consideration of non-vehicular modes of transportation, the City did not intend to apply the standard retroactively, i.e., in the absence of new development. Rather, the intent was to require implementation “concurrent” with new development, as contemplated under CMC Section 21.90.045. The City did not intend to initiate a City-wide public works project to fix existing non-vehicular deficiencies or to halt all development until every pedestrian path and bike facility met the City’s new MMLOS standards. Similar approaches were utilized for the City’s other CFIP performance standards. For example, the City’s 1986 CFIP explained, “The preceding map highlights those areas of the city which will be required to comply with the open space performance standard. The other areas of the city are already developed.” (See also Friends of H Street v. City of Sacramento (1993) 20 Cal.App.4th 152 [statutory requirements addressed future growth and did not require local governments to bring existing neighborhoods and streets into compliance with general plan.]) Had I known this language was going to be in the actual report, I would have pushed back a lot harder, because this would essentially absolve the city from having to maintain the minimum service standards for pedestrians, bicyclists, and transit—and only when new developments go in would the developer have to meet the minimum standard. 7 This is similar to the Vehicle Miles Traveled (VMT) Analysis Guidelines situation, in which the commission reviewed them, but then a material change (the entire commercial VMT map was modified) was made just prior to their being presented to the City Council. Transit LOS It is also not acceptable to exclude transit LOS from monitoring based on the passage of the citywide TDM ordinance, as claimed in the staff report. That ordinance does little or nothing to improve transit conditions in Carlsbad, and, frankly its inclusion in the transit LOS point system at 60 point to ensure LOS D citywide was an unprincipled act that needs to be reversed immediately. It would be more accurate to say that the current transit LOS is grade “E” or “F” for most of the City of Carlsbad, given the miniscule number of people who use it. In addition, developers can point to that MMLOS Tool nonsense as an excuse not to mitigate their traffic impacts with transit improvements. I provided the example of the Marja Acres development at the last meeting. That project will add 2,300+ new vehicle trips to the already-deficient El Camino Real corridor, and it relies heavily on subsidized transit passes to mitigate its traffic impact. However, the only transit enhancement they are providing under the MMLOS Tool is a bench and trash can at one bus stop that currently averages three boardings per day. Attachment 1: 10/16/2020 Linke letter to City Council regarding Marja Acres review process Attachment 2: 11/7/2019 STC Traffic Technical Memorandum 1 October 16, 2020 Re: Marja Acres project (Letter 1 of 2): Development application review problems Honorable Mayor and Councilmembers (Cc: Planning Commission): I am not opposed to the Marja Acres project, but there have been major issues during the application review process that I want to highlight in this letter. Carlsbad’s Growth Management Plan (GMP), General Plan, and Transportation Impact Analysis (TIA) Guidelines, in conjunction with sound professional engineering judgement, are supposed to provide a logical process to generate accurate data that ensures developers pay their fair shares for the impacts of their projects in a manner that is transparent to the public. However, I believe many of the review actions described below are inconsistent with the spirit and letter of the governing documents and/or demonstrate poor engineering judgement and poor public policy. This could frustrate Carlsbad residents and burden taxpayers when traffic worsens due to insufficient proactive mitigation. And I feel this is a general problem with the review process that needs to be addressed for the sake of other current and future development applications. I also think it would be useful to have an audit conducted on the review process to assess its fairness and compliance with the governing rules, and to identify improvements that can be made. I want to note that much of the information below is based on communications between staff, the developer, the developer’s traffic consultant, and others, which I obtained through a public records request. In a second letter, I plan to describe some specific issues with the current Marja Acres environmental impact report (EIR) and associated documentation that I think should be addressed before approving that specific project. SUMMARY • Although the TIA Guidelines were published in April 2018 in response to a settlement agreement, staff told the developer on multiple occasions during the process that implementation of the guidelines was being delayed pending modifications. • Despite the complexity of the Marja Acres traffic studies, and despite the fact that several different studies were conducted between April 2018 and present, no TIA Scoping Agreement was ever executed, as required by the TIA Guidelines. Such agreements provide transparency and accountability by establishing upfront the methods to be used, but they are seemingly never executed for any projects. • Staff has made many different (often self-contradictory) interpretations of whether and how the TIA Guidelines should be applied, depending on convenience and/or benefit. In some cases, they 2 have claimed they do not have to follow them at all. In another case, they have claimed that they have to follow at least one provision to the letter. In many cases, there are creative interpretations that do not seem to match the original intent. • Staff shared with the developer that the TIA Guidelines, or selected provisions therein, do not have to be followed, because they have never been brought to the City Council for approval. • The traffic study in the original 4/15/2019 draft environmental impact report (DEIR) contained a fatal flaw that masked the fact that the project would cause a level of service (LOS) failure on El Camino Real, which I pointed out in comments. • Rather than addressing the LOS problem, staff and the developer collected, and planned to include in a revised EIR, new “supplemental” traffic counts collected in 6/2019 on El Camino Real that were lower than the last two counts (11/2018 and 5/2019), in order to demonstrate no impact under the GMP. In addition, in violation of the General Plan and TIA Guidelines, they planned a switch to using the flawed old Carlsbad segment vehicle LOS method that produces all “A” grades to demonstrate no impacts under the California Environmental Quality Act (CEQA). • A subsequent set of traffic counts collected in 9/2019 showed deficiencies on El Camino Real, squashing these plans. Again, rather than addressing the LOS problem, they then switched to an entirely new approach—vehicle miles traveled (VMT)—that allowed them to avoid LOS under CEQA altogether. This, even though VMT methods had not been developed, and the application was deemed complete long before the VMT rule change would go into effect. • Staff provided early access to draft VMT methods as they were being developed, and a recirculated DEIR with VMT analysis was completed and distributed for public review on 6/5/2020—well before the VMT Analysis Guidelines were finalized or the VMT switchover became effective on 7/1/2020. • In spite of the switch to VMT for CEQA purposes, the GMP still requires LOS analysis for vehicles and transit in the project area as part of a local mobility analysis (LMA). However, for the transit portion of the LMA, the only mitigation is a bench and trash can at one bus stop—and a bike rack and repair area in the project. • And for the vehicle portion of the LMA, there were new shenanigans. The LMA was withheld until about 24 hours before the Planning Commission hearing, and there was a last-minute manipulation of the trip generation portion, which artificially reduced the projected net new traffic of the development from over 2,300 average daily trips (ADT) to just 901 ADT. That is a ridiculously low number that could cost the city around $100,000 in lost traffic impact fees. • The ADT reduction arose from a change in the way existing traffic was subtracted from the total generated by the proeject. The 2,300+ ADT number was based on subtracting actual traffic going to the existing businesses as determined by traffic counts at the driveways, while the 901 ADT number was based on subtracting artificial traffic calculated with an estimator tool. • Staff made the trip generation method change despite emails that challenged it, pointing out that the “existing [businesses] are old and underperforming,” that the driveway counts were very recent, and that using the driveway count data “is a better approach.” • Staff then falsely claimed to the Planning Commission that they were required to make the trip generation method change based on the TIA Guidelines. 3 DETAILS April 2018 TIA Guidelines and failure to execute TIA Scoping Agreements On March 14, 2017, the City of Carlsbad executed a settlement agreement with an environmental group that required—within one year—an update of Carlsbad’s TIA Guidelines to bring them into compliance with the level of service (LOS) and transportation demand management (TDM) provisions in the 2015 General Plan Update.1 In April 2018, the TIA Guidelines update was published in satisfaction of that agreement.2 On December 24, 2018, the application for the proposed Marja Acres project was deemed complete, and on April 15, 2019, a draft environmental impact report (DEIR) with a traffic study was distributed for public review.3 The TIA Guidelines require that TIA Scoping Agreements be executed between the city and developers for such traffic studies, which define the methods and requirements of the study.4 However, no TIA Scoping Agreement had been executed. Later in 2019, there was a major shift in the traffic study approach to a completely different set of methods, but, again no TIA Scoping Agreement was executed, despite the complexity of this project. I have requested the TIA Scoping Agreements for several other larger, ongoing development projects in Carlsbad, but no responsive documents have been provided, indicating that staff does not do them. In addition to being a violation of the TIA Guidelines, that approach is ripe for shenanigans and is poor public policy. The troubling, years-long progression of the traffic studies done for the Marja Acres project is an unfortunate example of this broken system, as I will now detail. Selective enforcement of TIA Guidelines and associated rules and methods Despite the fact that the new rules/guidelines should have been developed and in effect concurrent with adoption of the General Plan Update in 2015, and despite the fact that the city spent a year updating the TIA Guidelines after the settlement agreement was executed, city staff informed the Marja Acres developer (the applicant) on multiple occasions through at least September 2018 that implementation of the TIA Guidelines was being further delayed pending more modifications.5 For the Marja Acres application (and others), staff has had many different (often self-contradictory) interpretations of whether and how the TIA Guidelines should be applied, depending on the context. For 1 Carlsbad City Council Resolution No. 2017-044 (North County Advocates Settlement Agreement, 3/14/2017): http://edocs.carlsbadca.gov/HPRMWebDrawer/RecordHTML/467762 2 Carlsbad TIA Guidelines (April 2018): https://cityadmin.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=22758 3 State of California Clearinghouse CEQAnet Web Portal entry for the original (April 2019) Marja Acres DEIR: https://ceqanet.opr.ca.gov/2018041022/2 4 One of the main objectives of the TIA Guidelines is to create a framework for creation of Scoping Agreements. In particular, see Section 3 and the Scoping Agreement template in the appendix. 5 E.g., 6/21/2018 and 9/24/2018 emails between city staff, the developer, and their traffic consultant. 4 example, when I have asked about the lack of execution of formal TIA Scoping Agreements, staff has cited a section of the TIA guidelines that describes the use of phone calls and emails as a substitute,6 but those are only a substitute for an in-person meeting to guide the creation of a TIA Scoping Agreement— not a substitute for the agreement itself. Then, in their response to my public comment on the Marja Acres DEIR, staff argued that the TIA Guidelines did not have to be followed at all, because they were not in effect when the project TIA was submitted.7 It should be noted here that the TIA Guidelines went into effect in April 2018, the traffic counts included in the first published Marja Acres TIA (April 15, 2019 DEIR) were not collected until November 2018, and the entire TIA approach was completely revised again in late 2019, so this is a ridiculous argument. Staff also shared with the Marja Acres developer that it can be argued that the TIA Guidelines, or selected provisions of the guidelines do not have to be followed, because the City Council has never formally approved them.8 I have heard this “theory” elsewhere, as well. It should be noted, ironically, that staff has chosen never to bring the guidelines to council for approval, likely to allow them to selectively enforce them and make changes at will. Hopefully, that will change with the recent priority to have the Traffic and Mobility Commission (T&MC) conduct an external review and have council approve them. And now, in complete contradiction to the above arguments, staff is arguing that they have to follow the TIA Guidelines—at least for one alleged provision that allows them to artificially make a huge reduction in the amount of traffic generated by the Marja Acres project. This is also a flawed argument, as detailed below, but this all demonstrates the extreme inconsistency and bias in the process.9 Meanwhile, staff has been tinkering for several years with other methods and tools, such as the multimodal level of service (MMLOS) tools, which are supposed to define the service requirements for pedestrian, bicycle, and transit modes of travel. The clear intent of the tinkering is not to improve conditions for those modes of travel, but rather to avoid having to report performance failures by the city or developers. Transportation Department staff recently committed to having the T&MC participate in a review of the MMLOS tools, and hopefully a better strategy can be agreed upon going forward. Fatally flawed traffic study in the original April 15, 2019 Marja Acres DEIR The Marja Acres project is adjacent to a portion of El Camino on which vehicle traffic is much heavier in one direction, depending on the time of day (nearly an 80%/20% split). And, due to the center median, all traffic going in and out of the project must occur in the southbound (actually eastbound in that 6 E.g., 7/10/2020 email from staff to me 7 See the response to comment IND-R1.12 in the Marja Acres final EIR 8 E.g., see the draft of the applicant’s traffic consultant’s responses to my public comments in an 8/5/2019 email to staff 9 Staff testimony at the 9/16/2020 Planning Commission public hearing on Marja Acres 5 specific area) direction. To accurately reflect congestion, the TIA Guidelines require separate assessment of traffic in each direction. In November 2018, consistent with the TIA Guidelines, the applicant’s traffic consultant collected separate traffic counts in each direction on El Camino Real between Tamarack Avenue and Cannon Road. However, when they prepared their TIA, they effectively combined the traffic volumes in both directions and assumed a ~50%/50% split (bidirectional assessment), leading to the incorrect conclusion that the project would not have a significant impact on congestion.10 In a pair of May 2019 public comments on the DEIR, I detailed this fatal flaw in the traffic study and provided evidence that the project actually would cause southbound El Camino Real to become deficient under the Growth Management Plan (GMP) by causing it to transition from LOS D to E/F.11 In emails I obtained recently through a public records request, I discovered that there was an acknowledgment at the time that the bidirectional assessment method was, indeed, flawed.12 A draft response to my comment from the applicant’s traffic consultant dated August 5, 2019 included the following statement: …[T]he TIA erroneously used the City’s published ‘bidirectional capacity’ from Table 2 of the Roadway Capacity Tables Report (Capacity Report), instead of the ‘directional capacity’ from Table 1 of that same report.13 This TIA was produced by professional traffic engineers contracted by the applicant and was presumably reviewed by city traffic engineering staff, but it was included in the DEIR despite the fatal flaw. I was not sure whether this was a purposeful mistake to avoid having to show a significant traffic impact, or just a serious error. Based on the email exchanges I have now seen, I will give the benefit of the doubt and conclude it was just an error. That said, the above acknowledgment of the error was never made public, and the series of events it triggered (described below) are very troubling—with no more benefit of the doubt to be provided. Plan to change the conclusions of the traffic study with questionable new traffic counts Instead of having the applicant acknowledge that its project would cause El Camino Real to become deficient, staff worked with the applicant to collect new traffic counts to replace the counts that 10 April 15, 2019 Marja Acres DEIR 11 Available as letters IND-21 and IND-49 in the final EIR: https://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=45676 12 E.g., 5/28/2019 and 5/29/2019 emails from city staff to the applicant’s traffic consultant 13 Marja Acres Draft Responses to Comments on March 26, 2019 Transportation Impact Analysis (TIA), LLG, Engineers, August 5, 2019 6 resulted in the deficiency.14 They collected what they called “supplemental” traffic counts on El Camino Real between Tamarack Avenue and Cannon Road in June 2019, which were lower than the ones they had originally collected in November 2018, and they were low enough that they could suggest the project would not cause the deficiency on southbound El Camino Real. Staff directed the applicant’s traffic consultant to use the new traffic counts and call the November 2018 counts an “anomaly.” They also devised a new scheme (not described in the TIA Guidelines) to average various combinations of multiple counts along the El Camino Real corridor.15 Staff’s directives were reinforced through multiple rounds of editing and staff review of draft responses to my comments throughout July and August of 2019, with the intent of incorporating the new data into a revised EIR.16 Notably, though, the city had collected other traffic counts in that area of El Camino Real in May 2019— just a month before the June 2019 “supplemental” counts—as part of the annual traffic monitoring program. Those May 2019 counts were even higher than the November 2018 counts, but those were not taken into consideration or planned for inclusion in the revised EIR. Eventually, additional counts done in September 2019 were similarly high to the November 2018 and May 2019 counts, demonstrating that the June 2019 “supplemental” counts were the “anomaly.” The whole strategy of doing “supplemental” traffic counts and cherry-picking the lowest ones with some sort of averaging scheme to get a desired result is very troubling. It represents poor engineering judgement and poor public policy. Plan to use the misleading old Carlsbad street segment LOS methods for CEQA purposes It is equally troubling that staff emails also reveal that, after the fatal flaw was demonstrated in the DEIR traffic study, they also directed the applicant to change to the old invalid Carlsbad street segment LOS method to assess the traffic impacts of the project for CEQA purposes.17 As I have described previously, staff concocted and used the old invalid vehicle LOS method from 1989 through about 2018. It vastly under-reported congestion, returning LOS “A” grades for virtually every street facility in Carlsbad, no matter how congested they were. True to form, in the draft data tables produced in the July/August 2019 timeframe for Marja Acres, the use of that method resulted in every street facility passing with LOS “A” grades, even though the valid methods were returning LOS “D” and “F” grades for the same facilities using the same traffic counts. 14 E.g., 6/12/2019 email from the applicant to city staff and the applicant’s traffic consultant 15 Marja Acres Draft Responses to Comments on March 26, 2019 Transportation Impact Analysis (TIA), LLG, Engineers, August 5, 2019 16 E.g., 8/15/2019, 8/19/2019, 8/20/2019, 8/21/2019, 8/22/2019 emails between city staff, the applicant, and the applicant’s traffic consultant, including attached drafts of responses to my comments and guidance from staff 17 Marja Acres Draft Responses to Comments on March 26, 2019 Transportation Impact Analysis (TIA), LLG, Engineers, August 5, 2019 7 The use of the old Carlsbad method was supposed to end with the 2015 General Plan Update, which requires use of a valid method based on the Highway Capacity Manual (HCM). Also, the TIA Guidelines clearly state that the HCM-based methods described therein are to be used for CEQA analyses.18 Despite that, staff’s directive was reinforced through multiple rounds of editing and staff review of draft data tables and draft responses to my comments throughout July and August of 2019, with the intent of incorporating the results into a revised EIR.19The attempted resurrection of the flawed old Carlsbad method for the Marja Acres project represents poor engineering judgement and poor public policy. New September 2019 traffic counts On September 16-20, 2019, the city collected yet another series of traffic counts on El Camino Real between Tamarack Avenue and Cannon Road, ostensibly for the annual traffic monitoring program. However, they were unusual in that the counts spanned a five-day period (rather than the usual two or three days), and they were collected at three different locations within the segment. So, they were clearly done with the Marja Acres project in mind. In any event, those counts confirmed the reliability of the November 2018 and May 2019 counts (and the unreliability of the supplemental June 2019 counts), and indicated deficiency of southbound El Camino Real. A subsequent series of meetings between staff, the applicant, and the applicant’s contractors in late September 2019 led to the abandonment of the scheme to use the June 2019 traffic counts and the old Carlsbad LOS method for CEQA purposes. However, many man-hours over multiple months were spent on those endeavors before they were abandoned. Premature switch to vehicle miles traveled (VMT) approach for CEQA purposes So, there was again an opportunity to do the vehicle LOS study in the correct way and agree to provide full mitigation through street projects and/or TSM and TDM initiatives. Instead, a new approach was agreed upon—to entirely avoid doing vehicle LOS analysis for CEQA by prematurely switching to a VMT- based approach for the Marja Acres project. That decision was made long before Carlsbad had any guidelines on how to conduct VMT analysis, let alone the July 1, 2020 effective date of the rule change. And this huge change in the study approach was made again without a formal TIA Scoping Agreement, as required by the TIA Guidelines. I do not yet have full transparency on this phase of the project, because staff did not provide any communications in response to my public records request in the six- month period between September 30, 2019 and April 1, 2020.20 18 First section of the TIA Guidelines: “The Transportation Impact Analysis Guidelines provide a detailed description of the methodology to be followed in identifying project impacts for applicable transportation facilities in compliance with applicable federal, state and local requirements (e.g., CEQA, GMP and the 2015 General Plan Mobility Element).” 19 E.g., 8/15/2019, 8/19/2019, 8/20/2019, 8/21/2019, 8/22/2019 emails between city staff, the applicant, and the applicant’s traffic consultant, including attached drafts of responses to my comments and guidance from staff 20I submitted a new public records request to fill the six-month gap, but on 10/15/2020 staff invoked an extension beyond the 10-day response period. 8 The Marja Acres project was given special access to early drafts of the VMT Analysis Guidelines and was conducting its VMT analysis as those guidelines were being developed—before they were made available for review by the public, T&MC, or council. The VMT analysis was allegedly done based on a March 2020 draft of the guidelines, which underwent multiple subsequent revisions. And the Marja Acres recirculated DEIR (RDEIR) that contained the new VMT analysis had a review period that began on June 5, 2020,21 before the VMT rule and guidelines were even adopted by council or took effect on July 1, 2020.22 There was another development doing a traffic study in the same timeframe, and it was more beneficial for them to do LOS analysis rather than VMT. Thus, it is notable that staff stated at the July 15, 2020 public hearing for that development that its application “was deemed complete in October of 2018,” that the switchover to VMT did not take effect until July 1, 2020, and that the city must “apply…the standards that were in place when the application is deemed complete.” Counsel added that this must be done for “fairness and propriety” to the developer. Commissioner Luna also made an impassioned statement that, in fairness to the developer, the rules in place at that time had to be followed, which was subsequently echoed by other commissioners.23 Fair enough, but in the case of Marja Acres, which benefits from VMT analysis, staff hypocritically cited an agency’s ability to decide on a “project-by-project basis” to use the VMT standard,24 regardless of the fact that the LOS standard was in place when the application was deemed complete on December 24, 2018, and regardless of the fact that the VMT Analysis Guidelines had not been finalized, let along gone into effect. Last-minute manipulation of LMA could cost city $100,000 Ultimately, I believe the types and the target levels of the mitigation being proposed to satisfy the CEQA requirement will do little to mitigate the actual traffic impacts in the area. However, in addition to the CEQA/VMT analysis, Carlsbad also still requires mobility analysis under the GMP, General Plan, and TIA Guidelines in the form of an LMA, providing an additional opportunity for mitigation—in the case of Marja Acres, focused on vehicles and transit (based on street typologies). The GMP-based LMA should have been made available for review at the same time as the CEQA-based VMT study in the EIR, because there are overlapping components and intertwined mitigation strategies—and I requested as much. However, the Marja Acres LMA was actively undergoing changes 21 State of California Clearinghouse CEQAnet Web Portal entry for the Marja Acres RDEIR: https://ceqanet.opr.ca.gov/2018041022/3 22 Carlsbad City Council Resolution No. 2020-114 (VMT Analysis Guidelines adoption): http://edocs.carlsbadca.gov/HPRMWebDrawer/RecordHTML/577938 23 7/15/2020 Carlsbad Planning Commission video: (https://carlsbadca.swagit.com/play/07152020-1315) (Item #1) 24 Response to public comment IND-R1.11i in the Marja Acres final EIR: https://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=45676 9 almost right up to the September 16, 2020 Planning Commission public hearing, and I was not provided a copy until about 24 hours in advance of that meeting, so there was little opportunity for reasonable public review. I was hoping that the LMA would provide meaningful additional traffic mitigation. Instead, it largely just cites the VMT-based mitigation plan in the EIR, and then adds a bench and trash can at one bus stop, and a bicycle rack and repair area in the project. Sadly, still more serious shenanigans were done in the LMA in the form of a substantial last-minute reduction in the project’s predicted net average daily vehicle trips (ADT), which will likely reduce the traffic impact fee owed to the city by about $100,000. The final EIR for the Marja Acres project released on 8/26/2020 states (Appendix J, Section 3.2): With redevelopment of the site, the Project is calculated to generate 2,366 net new ADT per the GMP/LMA prepared by LLG in August 2020… In response to my public comment on the EIR (IND-R1.26 in the final EIR), staff stated that “the project would result in 2,334 ADT. And Table 14 in the Planning Commission staff report released 9/10/2020 also refers to a net increase of 2,334 ADT. The small discrepancy in those ADT is yet another traffic study error, and it is important to note that every one of the dozens of previous draft and final traffic studies produced between 2016 and August 2020 had estimated trip generation of well over 2,000 ADT. However, the trip generation method was changed in the days leading up to the 9/16/2020 Planning Commission meeting, which reduced it to just 901 ADT, and an erratum was prepared to “correct the outdated data.” This change was driven by an artificial increase in the number of trips subtracted from the gross ADT based on existing traffic at the project site, which will disappear when the current businesses are demolished. The 2,366 net ADT figure is based on a 700 ADT reduction for the current businesses, which was based on actual traffic counts at the business driveways. However, the last-minute change to 901 net ADT is based on a 2,133 ADT reduction for the current businesses, which was calculated from a SANDAG estimator tool. Email exchanges in late August and early September 2020 about this change in the trip generation method show that there was pushback, in that it was pointed out that the “existing [businesses] are old and underperforming,” that the driveway counts were very recent, and that using the driveway count data “is a better approach.” But staff ignored that sound engineering judgement and directed the last- minute switch to the estimation method that they knew was overestimating current traffic by more than three-fold, thereby reducing net ADT by nearly 1,500 ADT—potentially costing the city around $100,000 in impact fees. 10 During the 9/16/2020 Planning Commission public hearing, staff rejected my claim that this was a shenanigan. They (ironically) claimed that they were bound by the TIA Guidelines to use the SANDAG estimator. But that claim is just more shenanigans. The guidelines do not require the use of the SANDAG estimator. They indicate that the estimator should be “considered” for use, but other alternative approaches are suggested, and it is clear in the guidelines that the city is supposed to work with the developer to come up with the most accurate method. Thus, it was neither necessary nor appropriate to discard the actual traffic count data in favor of an estimate. I encourage you to read the entire Traffic Generation portion (Section 5) of the TIA Guidelines to come to your own conclusions. This represents poor engineering judgement and poor public policy. Last-minute manipulation of trip generation numbers invalidates LMA “Trip generation” is one of the first steps in a traffic study, and all of the subsequent steps rely on its accuracy. Obviously, the artificial reduction from 2,300+ ADT to 901 ADT also artificially reduces all of the traffic projected to be added to the streets, so any impacts on congestion, turn lanes, etc. will be under-estimated. Sincerely, Steve Linke Carlsbad, CA