HomeMy WebLinkAbout2021-01-04; Traffic and Mobility Commission; ; Fiscal Year 2020-21 Growth Management Plan Monitoring Report –Item 4
Meeting Date: Jan. 4, 2021
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 (Second Review)
Recommended Action
Receive a presentation and provide input on the approach for the Fiscal Year 2020-21 Growth
Management Plan Monitoring Report Circulation Section.
Background
This presentation provides an overview of the approach to the circulation section of the Fiscal
Year 2020-21 Growth Management Plan (GMP) Monitoring Report and is a follow-up from when
this item was first heard by the Traffic and Mobility Commission at their meeting on November
2, 2020. The original staff report for item is provided in Exhibit 1 and a summary of the
commission’s feedback regarding the approach which is provided in Exhibit 2.
Additions to the GMP Monitoring Approach
The following section provides a summary of the additional and/or revised tasks which were
discussed by the Traffic and Mobility at the November meeting. These elements will be
incorporated into a task order with a consultant to prepare the Multimodal Level of Service
(MMLOS) analysis report for the FY 2020-21 GMP report.
Vehicle Traffic Data Collection Locations
Staff has provided a list of 79 locations identified for data collection as part of the vehicle LOS
analysis (see Exhibit 3). In addition to the vehicle LOS analysis count locations, new counts will
be conducted as part of the MMLOS analysis for pedestrian, bicycle, and transit modes. The
specific locations of these counts will be determined after the update of the MMLOS
methodology and is anticipated to include the following roadway typologies: Identity Streets,
Village Streets, Coastal Streets, School Streets, Arterial Connectors, Neighborhood Connectors,
Employment/Transit Connectors, and streets within ½ mile of a transit center.
Traffic Recount Rules
The commission requested that clear guidelines be provided to determine when recounts are
conducted. Typically, recounts are conducted due to equipment failures or when significant
inconsistencies with historical count data are observed. For the FY2020-21 report, staff is
proposing to conduct recounts only in the event of equipment failures due to the probable
impacts of the COVID-19 pandemic on citywide travel patterns. The COVID-19 pandemic has
significantly altered vehicular use due to changes in commute behavior and travel patterns, in
particular during peak hours. Consequently, any comparison to historical traffic data may be
irrelevant as vehicle traffic volumes are not likely to return to their pre-pandemic levels.
Industrial Street Monitoring
As previously discussed, staff intends to limit the analysis of industrial streets to the high-volume
locations. In the November 2nd staff report staff indicated 11 industrial streets for analysis
however after further review and per direction from the Traffic and Mobility Commission the list
of industrial streets has been updated to include 13 locations.
Intersection Operations Analysis
In addition to roadway facility LOS analysis, intersection LOS will be evaluated along deficient
roadway facilities to identify other potential operational improvements. Potential improvements
to intersection operations will include signal timing adjustments, reconfiguration of vehicle travel
lanes, signal coordination along arterial corridors, and bicycle facility enhancements. The specific
intersections analyzed will be identified after the roadway facility LOS is conducted and the
intersection turning movement counts will likely be conducted in September 2021. Locations will
be considered at all signalized intersections within a deficient facility receiving a deficient LOS E
or F. Evaluation of unsignalized intersections will be considered on a case-by-case basis if there
is a potential for change in traffic control such as a roundabout or modifications to vehicle lane
geometry that could improve operations.
Transit MMLOS Analysis
Transit MMLOS has been previously excluded from GMP Monitoring Analysis because the current
methodology for Transit MMLOS would result in all facilities meeting the MMLOS D transit
standard. The Transit MMLOS considers the existence of the citywide Transportation Demand
Management (TDM) ordinance sufficient to provide adequate scoring to meet the criteria for the
MMLOS D standard. Staff is currently reevaluating the MMLOS methodology in coordination
with the Traffic and Mobility Commission and will include the analysis of Transit MMLOS based
on the updated methodology.
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 nine months to complete.
Exhibits
1. Traffic and Mobility Commission Staff Report, Nov. 2, 2020
2. Traffic and Mobility Commission Meeting Minutes, Nov. 2, 2020
3. Revised list of vehicle count locations
4. Commissioner Linke comments, Nov 2, 2020
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.
Exhibit 1
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
Exhibit 1
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.
Exhibit 1
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
Page 1 of 5 Public Works
Transportation 1635 Faraday Avenue Carlsbad, CA 92008 760-434-2730 t
Council Chambers
1200 Carlsbad Village Drive
Carlsbad, CA 92008
Monday, Nov. 2, 2020, 3:00 p.m.
CALL TO ORDER: Chair Gocan called the Meeting to order at 3:04 p.m.
ROLL CALL: Present: Gocan, Hunter, Penseyres, Fowler, Linke
Absent: Perez and Wanamaker
PLEDGE OF ALLEGIANCE: Commissioner Hunter led the Pledge of Allegiance
APPROVAL OF MINUTES:
This meeting was conducted virtually via Zoom due to the stay-at-home order for COVID-19.
ACTION:
Motion by Commissioner Hunter seconded by Commissioner Linke, to approve the minutes for the Oct.
5, 2020 meeting as presented.
Motion carried: 4/0/2/1 (Absent: Perez and Wanamaker; Abstained: Gocan)
PUBLIC COMMENTS ON ITEMS NOT LISTED ON THE AGENDA: None
CONSENT CALENDAR:
This item was pulled for discussion by Commissioner Penseyres
1.EL CAMINO REAL WIDENING BETWEEN POINSETIA LANE AND CAMINO VIDA ROBLE – Support staff’s
recommendation to the City Council to implement the El Camino Real Roadway Improvements from
Poinsettia Lane to Camino Vida Roble, Capital Improvement Program (CIP) Project No. 6072 (Project)
providing operational improvements consistent with the city’s General Plan Mobility Element. (Staff
Contact: Bandon Miles and Hossein Ajideh, Public Works).
DISCUSSION:
Commissioner Penseyres requested to pull this item from the consent calendar to address Traffic
Control Plan (TCP) for bicyclist during construction and to ask staff to consider reasonable alternative for
bicycle commuters.
Associate Engineer Miles referenced the TCP and showed that the construction area impacts the third
northbound through lane, curb and gutter and sidewalk. Since there is not adequate space to
accommodate a bicycle lane, the bicycle lane was removed. The outermost through lane was widened
to 14 feet and SHARE THE ROAD signs were specified as well as reducing the posted speed limit through
the construction zone by 10 mph. If necessary, a bike lane detour could be considered using Poinsettia
Lane/Alicante Road/Town Garden Road. Once a contractor is brought on board, staff could investigate
to determine if there is extra room to provide a delineated bike lane through the construction zone.
Exhibit 2
Page 2 of 5 Public Works
Transportation 1635 Faraday Avenue Carlsbad, CA 92008 760-434-2730 t
Transportation Director Frank inquired if Commissioner Penseyres had any input to provide staff that
would make the TCP better for bicyclist.
Commissioner Penseyres answered that he will be glad to discuss with staff potential bike lanes
strategies.
ACTION:
Motion by Commissioner Penseyres, seconded by Commissioner Linke, to approve Consent Calendar
Item 1 - El Camino Real Road Improvements between Poinsettia Lane and Vida Roble with the addition
of a separate meeting of Commissioner Penseyres with staff to discuss options for the Traffic Control
Plan to address bicyclists. The results of the separate meeting will be reported to T&MC through the City
Traffic Engineer Report.
Motion carried: 5/0/2 (Absent: Perez and Wanamaker)
DEPARTMENTAL REPORTS:
2. POLICE MONTHLY REPORT – CANCELLED
3. APPROACH FOR PRELIMINARY ENGINEERING ASSESSMENT FOR COLLEGE BOULEVARD REACH A,
CAPITAL IMPROVEMENT PROGRAM PROJECT No. 3636 – (Staff Contact: Tom Frank and Hossein
Ajideh, Public Works)
Staff’s Recommendation: Receive a presentation and provide input
Engineering Manager Ajideh presented the report and reviewed a PowerPoint presentation (on file in
the Office of the City Clerk).
PUBLIC COMMENT ON DEPARTAMENTAL REPORTS ITEM THREE ON THE AGENDA:
Public comments submitted via email prior to the Traffic & Mobility Commission meeting and read
into the record:
Brian Phillips, submitted historical information and a request on the Marron Rancho that was the first
permanent ranch home built in north county during the time that the Native Americans existing in this
area were primarily nomadic hunters, gathers, and fishers. This Marron land grant structure still remains
intact today at its original location within/adjacent to project limits and may be classified as the oldest
and most important structure standing in Carlsbad today.
The Rancho was owned by Senior Marron and stretched from present day Oceanside to present day La
Costa, easterly to present day Vista/San Marcos. Later in its history the Rancho, owned by Senior
Marron, was managed by Mr Kelly, and in subsequent generations following the passing of Senior
Marron, deeded to the eight surviving offspring of Mr Kelly's brother.
Preliminary engineering scope should include the facts of the original land grant plat and the building of
the Marron homestead within/adjacent to the College Reach A project limits, said RFQ scope to
include the stated public historical objective to preserve the homestead from any/all deleterious
actions capable of undermining/negatively impacting the environment and integrity of the homestead
site and structure, and the RFQ scope to include the further stated public policy objective to identify
measures within the project scope that will preserve and enhance the Marron homestead structure in its
location within and/or adjacent to the CIP 3636 project limits.
COMMISSION DISCUSSION:
Exhibit 2
Page 3 of 5 Public Works
Transportation 1635 Faraday Avenue Carlsbad, CA 92008 760-434-2730 t
Commissioner Penseyres inquired if it is already decided that the College Boulevard extension will be a
four-lane road or four-lane equivalent and if staff is estimating failure at four-lane what will be done after
the extension of College Boulevard to address failure and build-out?
Transportation Director Frank explained the importance of adapting the roadway to balance the safety
and efficiency needs between all modes of travel, safe routes to schools, and public outreach
recommendations. This holds true for the two-lane option which might include a roundabout. Staff wants
to study it further and listen to the community concerns to make sure that the project will meet the traffic
projections and the community needs.
Transportation Director Frank emphasized that the geotechnical, environmental, structural and the
hydrology items are the high cost items on this project, the travel lane restriping and the landscaping are
relative small and minor cost in comparison and that is the reason for the “equivalent” language added.
Commissioner Penseyres asked if the two-lane option with traffic signals will not work, would a
roundabout make it better?
Transportation Director Frank said at the earlier traffic projections staff was looking at a possible one-lane
roundabout and this is one more reason to discuss and study the options in more detail.
Commissioner Penseyres inquired if the scope of could include consideration for Class I, two-way, off-road
multi-use facility? And if we get some additional right of way when we are buying right away, to provide
a completely off-road facility that would provide cyclists/pedestrians a safe route, a Class I roadway.
Transportation Director Frank answered yes it could be a part of the project and reminded the
commissioners that their feedback is exactly what staff is looking for to put this project forward.
Commissioner Linke suggested that staff take another look at the future traffic projections produced by
zone 15 to determine what is actually needed there. Staff should also look at funding and timing of funding
from the developer and the city and their associated responsibility for the roadway improvements. A
recommendation to include the research of alternative designs in the RFP, including the protection of the
historic Marron homestead.
Commissioner Fowler shared his concern that the finance part for the extension of College Boulevard is
still pending.
Deputy City Manager Gomez answered that the City Council agreed on a preliminary engineering
assessment with an initial 3-million of funding to conduct the study, including project cost estimates, an
analysis of future traffic projections, and a community needs assessment.
Commissioner Wanamaker joined the meeting at 3:57 p.m.
ACTION:
Motion by Commissioner Penseyres, seconded by Commissioner Hunter, for staff to consider including
in the scope of work a Class I –multiuse trail facility on the eastside of College Boulevard from El Camino
Real to Cannon Road.
Motion carried: 6/0/1 (Absent: Perez)
4. FISCAL YEAR 2020-21 GROWTH MANAGEMENT PLAN MONITORING REPORT – CIRCULATION
SECTION APPROACH – (Staff contact: Tom Frank and Nathan Schmidt, Public Works)
Staff’s Recommendation: Receive a presentation and provide input
Transportation Planning and Mobility Manager Schmidt presented the report and reviewed the
PowerPoint presentation (on file in the Office of the City Clerk).
Exhibit 2
Page 4 of 5 Public Works
Transportation 1635 Faraday Avenue Carlsbad, CA 92008 760-434-2730 t
COMMISSION DISCUSSION:
Commissioner Linke presented a PowerPoint presentation and letter in response to the staff report
findings (on file in the Office of the City Clerk).
Commissioner Linke proposed that the intersection operations analysis should not have been removed
from the transportation impact analysis guidelines and GMP monitoring analysis and that the city should
consider conducting an operations study at the intersections that are at the 85% of failure rate, saving our
resources. This would enable staff to proactively determine if an intersection looks like it might fail in the
next year and do the counts in advance of the failure. He proposed more locations to collect traffic counts
along Carlsbad Boulevard/Poinsettia Lane/Tamarack Avenue and Faraday Avenue.
Transportation Planning and Mobility Manager Schmidt shared that the ADT counts for these locations
are available as they were conducted as part of the bicycle and pedestrian mode analysis.
Transportation Director said that he likes all the suggestions presented by Commissioner Linke and that
staff will evaluate the possibility of incorporating it to the scope of work and bring back to the T&MC.
Commissioner Linke showed that including all modes of travel in the Growth Management monitoring
program report will make meaningful improvements.
Transportation Director Frank suggested to bring these items, as well as where to put potential
multimodal counters to see if more activity occurs after improvements, to the ad-hoc committee.
Commissioner Linke suggested that the city should harmonize the two paths for (1) the GMP monitoring
program and (2) private developers traffic impact analysis.
CITY TRAFFIC ENGINEER REPORT:
City Traffic Engineer Comments: Attachment A
City Traffic Engineer Kim mentioned that the City is in the process of developing a scope of work for the
Local Roadway Safety Program grant. The program includes an analysis of traffic collision data on a regular
basis to proactively implement safety features on our roadway. The study will be going before the
commission to include their input.
Transportation Planning and Mobility Manager Schmidt reminded the commissioners that the Sustainable
Mobility Plan document will be released to the public on Nov. 4, and public feedback survey will be posted
to the city website.
Transportation Planning and Mobility Manager Schmidt updated the commission on the MMLOS ad-hoc
committee that will hold their first meeting sometime in November.
TRAFFIC AND MOBILITY COMMISSION COMMENTS:
Commissioner Wanamaker expressed his concerns about the line of sight distance around the curves and
plant overgrowth along Jefferson Street between Marron Road and Las Flores Drive very unsafe situation
cutting down the view plan and site plan for motorists sharing the road with bikes and with no shoulders.
City Traffic Engineer Kim acknowledges receiving the information and staff will return with a plan of
action.
Transportation Director Frank encouraged the commission to send over their recommendations for
roadway safety at any time in the meetings, by email, in the Carlsbad Connects app.
Transportation Director Frank will provide a link to the T&MC for the new Carlsbad Connects app.
Exhibit 2
Page 5 of 5 Public Works
Transportation 1635 Faraday Avenue Carlsbad, CA 92008 760-434-2730 t
ADJOURNMENT:
Chair Gocan adjourned the Traffic and Mobility Commission Meeting on Nov. 2, 2020, at 5:17 p.m.
___________________________ Eliane Paiva, Minutes Clerk
Exhibit 2
Exhibit 3
Revised 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. Melrose Dr - City Limits to Palomar Airport Road Arterial
31. Melrose Dr - Palomar Airport Road to Poinsettia Ln Arterial
32. Melrose Dr - Poinsettia Ln to Rancho Santa Fe Rd Arterial
33. Rancho Santa Fe Rd - City Limits to Camino Junipero Arterial
34. Rancho Santa Fe Rd - Camino Junipero to La Costa Ave Arterial
35. Rancho Santa Fe Rd - La Costa to Camino De Los Coches Arterial
36. Rancho Santa Fe Rd - Camino De Los Coches to Calle Barcelona Arterial
37. Rancho Santa Fe Rd - Calle Barcelona to Olivenhain Rd Arterial
38. Rancho Santa Fe Rd – Olivenhain Rd to Calle Acervo Arterial
39. Olivenhain Rd - El Camino Real to west of Rancho Santa Fe Rd Arterial
40. Cannon Rd - Carlsbad Blvd to Avenida Encinas Arterial
41. Cannon Rd - Avenida Encinas to Paseo Del Norte Arterial
42. Cannon Rd - Paseo Del Norte to Car Country Dr Arterial
43. Cannon Rd - Car Country Dr to Legoland Dr Arterial
44. Cannon Rd - Legoland Dr to Grand Pacific Dr Arterial
45. Cannon Rd - Grand Pacific Dr to Faraday Ave Arterial
46. Cannon Rd - Faraday Ave to El Camino Real Arterial
Exhibit 3
47. Cannon Rd - El Camino Real to College Blvd Arterial
48. Palomar Airport Rd - Carlsbad Blvd to Avenida Encinas Arterial
49. Palomar Airport Rd - Avenida Encinas to Paseo Del Norte Arterial
50. Palomar Airport Rd - Paseo Del Norte to Armada Dr Arterial
51. Palomar Airport Rd - Armada Dr to Aviara Pkwy Arterial
52. Palomar Airport Rd - Aviara Pkwy to Camino Vida Roble Arterial
53. Palomar Airport Rd - Camino Vida Roble to El Camino Real Arterial
54. Palomar Airport Rd - El Camino Real to El Fuerte Arterial
55. Palomar Airport Rd - El Fuerte to Melrose Dr Arterial
56. Palomar Airport Rd - Melrose Dr to City Limits Arterial
57. La Costa Ave - I-5 to Piraeus St Arterial
58. La Costa Ave - Piraeus St to El Camino Real Arterial
59. Aviara Pkwly/Alga Rd - Poinsettia Ln to El Camino Real Arterial Connector
60. Aviara Pkwy/Alga Rd - El Camino Real to Corintia St Arterial Connector
61. Aviara Pkwy/Alga Rd - Corintia St to Melrose Dr Arterial Connector
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 Industrial
68. Armada Dr - Legoland Dr to Palomar Airport Rd Industrial
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)
Exhibit 4
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.
Exhibit 4
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
Exhibit 4
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?
Exhibit 4
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
Exhibit 4
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.
Exhibit 4
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
Exhibit 4
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
Exhibit 4
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.
Exhibit 4
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.
Exhibit 4
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
Exhibit 4
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
Exhibit 4
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
Exhibit 4
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.
Exhibit 4
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
Exhibit 4
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.
Exhibit 4
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
Exhibit 4
Exhibit 4
Exhibit 4
Exhibit 4
Exhibit 4