Furthermore, the minimum standards for the TIA are established in <br />Administrative Order No. 58- 02- 02-F and require analysis of AM peak traffic. <br />R-9.8650-F(5) Peak Traffic Hours. The TIA shall include peak hour traffic <br />counts for all streets within the study area at the time of application. <br />...Traffic counts shall be provided for. <br />5. 1 The weekday a.m. peak-traffic period <br />Therefore, any applicant that has met the 100 trip threshold in any peak <br />period is required to include AM peak traffic in the analysis. <br />The project is estimated by the Applicant to generate 157 AM peak trips. The <br />commercial component of the proposal will generate 96 of the AM peak trips. <br />However, the Applicant claims that these trips will not coincide with the AM peak <br />of existing traffic, and therefore there will be zero AM peak trip contribution from <br />the commercial/retail space of the proposed development during the 7am to <br />9am timeframe. Where are the facts to support this claim? <br />The Applicant has not defined what the AM peak period is for either the project- <br />generated trips or the existing trips. Actual traffic counts for a full day are needed <br />to determine the proper AM peak period to use. <br />We believe that, with a realistic mix of commercial uses (see following section: <br />Trip Generation Estimate Too Low), the proposal will generate in excess of 100 AM <br />peak period trips. However, as indicated above, the 100 trips do not need to be <br />generated in the AM peak for the study to be required to include full analysis of <br />the AM peak period. <br />The threshold of 100 peak-hour trips is not the only criteria triggering the need <br />for traffic impact analysis. There are three criteria in EC 9.8670 that should be <br />applied to this application. <br />9.8670 Applicability. Traffic Impact Analysis Review is required when one <br />of the conditions in subsections (1) - (4) of this section exist unless the <br />development is within an area (a) shown on Map 9.8670 Downtown Traffic <br />Impact Analysis Exempt Area, or (b) subject to a prior approved Traffic <br />Impact Analysis and is consistent with the impacts analyzed. <br />(1) The development will generate 100 or more vehicle trips during <br />any peak hour as determined by using the most recent edition of the <br />Fodor & Associates - Page 2 <br />