Mr. Fred Wilson <br />March 17, 2017 <br />Page 7 <br />The Hearing Official should find that the Director did not error in setting the scope of work for <br />the TIA to include what was requested of the applicant, and to except the balance of the potential <br />information requirements that were deemed unnecessary or irrelevant to inform the results of the <br />analysis. <br />4. The TIA report was adequate to the task, and the Director's approval should be <br />affirmed. <br />We recommend to the Hearing Official, the Staff Report for the hearing, and the supplemental <br />staff reports at the seven and 14 day periods. These reports address the major issues in good <br />fashion. We note that the Staff has not addressed our arguments in points 1 and 2 above. That is <br />understandable, as to do so would mean that the staff would be questioning the applicability of <br />their own code language, which on the face of things would seem to apply. The applicant <br />believes, however, that the points in 1 and 2 above are really threshold legal issues that should be <br />in a first and second step, before getting to challenges to the adequacy of the TIA report. <br />Here we address, in summary fashion, a handful of the more contentious issues that arose in the <br />hearing and post-hearing periods. Each of these issues is addressed in detail in the applicant's <br />documents listed above. <br />(a) The appellant asserts that the TIA did not sufficiently address intersections beyond <br />those that are contiguous to the site, that provide direct access to the site, and that are impacted <br />by an additional 50 trips or more. The evidence in the record clearly demonstrates compliance in <br />this regard. Two driveways provide the only direct access to/from the site to/from the adjacent <br />streets; the intersection of 32nd & Hilyard is the only contiguous intersection; and only the <br />intersections at 31" and Hilyard and 30°i & Hilyard are impacted by 50 trips or more. Analysis <br />of all has been included in TIA. Broadening the study to analyze additional intersections in the <br />wider neighborhood is not required, and it would not change the conclusions of the analysis. <br />(b) The appellant has repeatedly claimed that an AM peak hour analysis has not been <br />done. Actually, the Applicant has done this twice, using different approaches to the trip <br />generation for the commercial retail space. See Sandow Engineering Letter to Scott Gillespie, <br />December 26, 2017, and Sandow Engineering Response to Transportation Issues, March 8, 2017. <br />(c) Lastly, the Appellant has alleged that the parking issue was not fully addressed. This <br />has been addressed in detail in the Sandow Engineering's Response to Additional Testimony, <br />March 15, 2017. <br />