regarding the applicability of EC 9.8670(3). Please keep in mind that our prior <br />comments have requested an expanded study area to include more nearby <br />intersections and neighborhood streets than have been evaluated in the <br />Applicant's original TIA. This larger study area should be the basis for applying EC <br />9.8670(2) and (3). The specific code language states that it must include the <br />roadway system "in the vicinity of the development." <br />Trip Generation Estimate Too Low <br />The Applicant uses a "specialty retail center" designation to model trip generation <br />from the 14,000 square feet of retail space. This designation is Land Use #826 in <br />the ITE Trip Generation Manual and it appears to be the lowest trip generation <br />category of all the possible commercial uses that could locate in the proposed <br />development. Many other possible commercial uses would generate considerably <br />more trips. We believe the assumption that all commercial space will conform to <br />the low trip generation rate of the "specialty retail" designation is unrealistic. <br />Other possible commercial/retail uses could generate two to ten times more <br />trips. These include: <br />• Fast food restaurant <br />• Convenience market <br />• Coffee/donut shop/bakery <br />• Cafe/quality restaurant <br />• Office/professional services <br />All of the above uses also generate AM peak trips that will coincide with the <br />existing morning rush hour. Unless the Applicant proposes to ban all the <br />above uses and forbid all commercial tenants from operating or receiving <br />deliveries before 9am, a more-realistic mix of commercial/retail land use <br />designations should be assumed for the purpose of accurately estimating <br />trip generation. All AM commercial trips should be assumed to coincide <br />with the existing AM peak. <br />Evidence of Bicycle Safety Concerns in Area <br />The photo below in Figure 1 is submitted as documented evidence of the bicycle <br />and pedestrian safety concerns referred to in EC 9.8670(2). The bike crossing of <br />Hilyard Street was witnessed during a brief site visit on December 31, 2016. This <br />photo looks westward and shows the southwest corner of the subject property <br />Fodor & Associates - Page 4 <br />