going to fit on the site. Something will have to give. What will that be? Who will exercise the <br />discretion to make that decision? Will the City be able to simply deny development permits <br />because the project as approved can't be done consistent with the new storm water standards? <br />TIA Requirement in EC 9.8650: The City suggests that the Type II TIA standards will <br />apply to this proposal in the future. EC 9.8650 to EC 9.8680 requires study of traffic impacts of <br />development applications in certain situations. If that study shows certain levels of impact, then <br />the code anticipates implementing solutions in connection with approval of the project. <br />The purpose of Traffic Impact Analysis is stated in EC 9.8650, which says in part: <br />"The purpose of Traffic Impact Analysis Review is to ensure that developments <br />which will generate a significant amount of traffic, cause an increase in traffic that <br />will contribute to traffic problems in the area, or result in levels of service of the <br />roadway system in the vicinity of the development that do not meet adopted level <br />of service standards provide the facilities necessary to accommodate the traffic <br />impact of the proposed development." <br />The triggers for doing a Traffic Impact Analysis are stated in EC 9.8670. The most likely trigger <br />that would apply to this development proposal appears in EC 9.8670(1), which says: <br />"(1) The development will generate 100 or more vehicle trips during any peak <br />hour as determined by using the most recent edition of the Institute of <br />Transportation Engineer's Trip Generation. In developments involving a land <br />division, the peak hour trips shall be calculated based on the likely development <br />that will occur on all lots resulting from the land division." <br />The approval criteria for the results of a study are stated in EC 9.8680. The most relevant <br />standard for this project is in EC 9.8680(1), which says: <br />"(1) Traffic control devices and public or private improvements as necessary to <br />achieve the purposes listed in this section will be implemented. These <br />improvements may include, but are not limited to, street and intersection <br />improvements, sidewalks, bike lanes, traffic control signs and signals, parking <br />regulation, driveway location, and street lighting." <br />The TIA code standards above call for discretionary judgments about what is needed or desirable <br />in terms of transportation improvements. See the standard in EC 9.8680(1) quoted above and <br />compare it with the "Purpose" statements for TIAs in EC 9.8650. <br />APPLICANT'S FINAL ARGUMENT - Page 6 <br />Cathedral Park (CU 02-4) Record July 2016 <br />