minimum standards for the TIA established in Administrative Order No. 58- 02- <br />02-F. Section R-9.8650-F(8) lists the minimum transportation system included in <br />the TIA. Section 8.1.2 states that this must include: All streets and intersections <br />that provide direct access to or from the development, regardless of the <br />generated volume of traffic. <br />At a minimum, the study area to be included in the traffic impact analysis <br />should be expanded to include: <br />1. Intersection of E 32nd and Alder Street <br />2. Traffic levels on Alder between E 32nd E 30th <br />3. Intersection of Alder and E 30th <br />4. Intersection of Hilyard and E Amazon/ E 33rd (all directions) <br />5. Traffic levels on E 33rd from Hilyard to Donald (including ADT) <br />6. Intersection of E31st and Ferry Street <br />7. Intersection of E 33rd and Ferry Street <br />These additional areas should be included because traffic in this area is already so <br />congested that the new travel demand generated by the proposed development <br />will seek out and utilize all available alternative routes, including neighborhood <br />streets. In addition, existing travel demand will be displaced and forced to seek <br />alternative routes to avoid the increased congestion. Both site-generated traffic <br />and displaced traffic should be evaluated. <br />We believe the intersection of Hilyard and E Amazon/ E 33rd is already exceeding <br />standards during certain times of day, especially morning rush hour, so this <br />proposed development's impact on this intersection needs to be analyzed <br />closely. As noted later in these comments, overflow traffic onto neighborhood <br />streets will generate safety problems that should be addressed in the TIA. Also, as <br />noted later in these comments, there is a major bike path on Hilyard Street, a <br />main on-street bike route on Alder Street, and a critical connection between the <br />two on E 32nd that should be addressed under pedestrian and bicycle safety <br />issues under EC 9.8670(2). Furthermore this area is designated as a safe route to <br />school for four elementary schools. For all of these reasons, the scope of the <br />TIA must be expanded. <br />The diagram used to show trip distribution is an overly-simplistic diagram that is <br />inaccurate, not to scale, and misleading. A TIA should be required to provide an <br />accurate base map as part of such diagrams. We would like to see bike paths, <br />waterways, on-street bikeways, and safe school routes (i.e., Alder Street) <br />Fodor & Associates - Page 5 <br />