Institute of Transportation Engineer's Trip Generation. In <br />developments involving a land division, the peak hour trips shall be <br />calculated based on the likely development that will occur on all lots <br />resulting from the land division. <br />(2) The increased traffic resulting from the development will <br />contribute to traffic problems in the area based on current accident <br />rates, traffic volumes or speeds that warrant action under the city's <br />traffic calming program, and identified locations where pedestrian <br />and/or bicyclist safety is a concern by the city that is documented. <br />(3) The city has performed or reviewed traffic engineering analyses <br />that indicate approval of the development will result in levels of <br />service of the roadway system in the vicinity of the development that <br />do not meet adopted level of service standards. <br />Under EC 9.8670(2), an analysis is required if the development "will contribute to <br />traffic problems in the area" and "where pedestrian and/or bicyclist safety is <br />a concern..." We believe there are traffic problems in the area, as well as <br />pedestrian and bicyclist safety concerns. These are described in our prior <br />comments of January 6, 2017, which are included herein by reference. <br />However, we also recognize that the City has not fully and adequately studied <br />and characterized traffic conditions in this area. A recent request to the City by <br />Fodor & Associates for traffic counts in the area revealed that the City has very <br />little basic traffic data in this area. Not only does the City lack recent traffic counts <br />in the area, there is little data upon which to base any historic trends. The City's <br />lack of traffic data and pedestrian and biking studies should not be the basis for <br />allowing new development to create traffic and safety problems. Instead, the City <br />should take advantage of this opportunity to collect any needed traffic <br />information in order to make an informed assessment of the area. <br />We believe the burden of proof regarding compliance with EC 9.8670(2) rests <br />with the Applicant and the City Traffic Engineer. We therefore request that the <br />applicant document that these issues do not exist and that the criteria do <br />not apply. We also request that the City Traffic Engineer provide <br />independent, professional verification that these conditions do not and will <br />not exist in this area. This response should involve the collection of all traffic <br />studies done in the area, of pedestrian and bicycling studies done in the area, <br />and of actual recent traffic counts in the area. <br />We also request a written statement from the City Traffic Engineer <br />Fodor & Associates - Page 3 <br />