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WPIanning
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Eugene, Oregon 97401
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Fax: S41-682-5572
www.eugene-or.gov/planning
Memorandum
Date: March 8, 2017
To: Fred Wilson, Eugene Hearings Official
From: Erik Berg-Johansen, Associate Planner, City of Eugene Planning Division
Scott Gillespie, Development Review Manager, Public Works Engineering
Subject: Amazon Corner TIA Appeal (TIA 16-7) - Open Record Staff Memo
Background
Before the public hearing on March 1, 2017, both the applicant and appellant submitted new
evidence and testimony regarding the subject appeal case; these materials were provided to
the Hearings Official (HO) before the hearing. At the public hearing the applicant and appellant
gave oral presentations regarding the merit of the applicant's Traffic Impact Analysis (TIA).
Other members of the public also testified at the hearing to state their position on the project
and to provide comments and testimony.
Staff appreciated the number of residents who took time out of their evening to attend the
public hearing. Hearing different perspectives from our community members is extremely
informative and is a key part of the public process. Important concerns were brought up at the
hearing, and the intent of this memo is for staff to provide a response to some of these issues.
The Meaning of "Accommodate"
The Hearings Official requested that staff clarify the meaning of "accommodate" where it exists
in the Purpose Statement for Traffic Impact Analysis applications (See EC 9.8650):
The purpose of Traffic Impact Analysis Review is to ensure that developments which will
generate a significant amount of traffic, cause an increase in traffic that will contribute to
traffic problems in the area, or result in levels of service of the roadway system in the vicinity
of the development that do not meet adopted level of service standards provide the facilities
necessary to accommodate the traffic impact of the proposed development.
At the hearing, staff explained that Level of Service (LOS), or traffic "mobility" 1, is an objective
measure of traffic accommodation. If a street is operating at LOS A, it's safe to say that it is
1 LOS is a performance measure for mobility. Mobility is the relative ability of citizens to travel regionally.
accommodating vehicle traffic. If a street is operating at LOS F, it would hard to argue that the
street is successfully accommodating traffic. The City of Eugene has adopted LOS D as an
acceptable level of traffic - therefore, staff believes that this adopted level of mobility is a good
measure of traffic accommodation in context of the TIA purpose statement. If a street or
intersection in Eugene is operating at LOS A, B, C or D, staff believes the facility is successfully
accommodating traffic impacts.
Further, the transportation system abutting and serving the subject development site is
complete for all modes of transportation, and the applicant has demonstrated that the system's
capacity can safely accommodate traffic to and from the site, and can also accommodate
regional mobility. As discussed above, the applicant also demonstrated that mobility (the
approved traffic performance standard) will not be degraded below the adopted minimum of
LOS D.
An analysis of "traffic accommodation" also requires examination of the transportation facilities
already in place. City streets are designed to adopted standards, and these standards ensure
that streets create a safe and efficient transportation system to accommodate all users. This
includes the capacity to serve and accommodate proposed land uses that are consistent with
the existing zoning (in this case C-2 zoning). East 31St Avenue and East 32nd Avenue are local
streets that were designed and built in conformance with City standards. Hilyard Street was
also designed to City urban arterial standards with the exception of bike lanes (however the
Amazon bike path is located directly across Hilyard Street, and the Alder Street bike route is
located directly to the east). Based on these facts, the existing streets serving the site are
already designed to accommodate vehicle traffic in this urban area.
Pedestrian Crossing
As part of the Planning Director's approval of the TIA application, a condition of approval was
included that will require the developer to construct a new pedestrian crossing across Hilyard
Street. The condition is as follows:
• The applicant shall construct an enhanced mid-block pedestrian crossing on Hilyard Street
between the intersections of East 31st and East 32nd Avenues. The enhanced crossing
shall include a Rectangular Rapid Flash Beacon (RRFB), median refuge, striping, signage,
street lighting, access ramps and sidewalk to create a direct and continuous connection 8
feet in width from the existing Amazon Path to the existing sidewalk fronting the
development site. Improvements shall be in conformance with City of Eugene Privately
Engineered Public Improvement (PEPI) standards, to be provided prior to the issuance of
any occupancy permit for the proposed development.
Public Works staff confirm that the pedestrian crossing would be constructed just north of the
sheltered bus stop that exists adjacent to the subject property (see staff's conceptual detail
included as Attachment A to this memo). The appellant states concerns regarding the location
of a future pedestrian crossing, and believes that the crossing might not function properly.
2
City staff took the pedestrian crossing requirement very seriously, and the location of the
crossing was an important consideration. Before the Planning Director issued the TIA decision,
the City of Eugene Traffic Engineer (Matt Rodrigues) reviewed and approved the location of the
crossing and the other specifics outlined in the condition of approval. As such, Public Works
staff believe that the pedestrian crossing will function safely and effectively (especially
considering that further evaluation of the precise location will occur through a future PEPI
permit to ensure safety and functionality is maximized). Since crossing Hilyard Street is
currently inconvenient and treacherous, staff believes that a pedestrian crossing at this location
will create an overall positive impact for the entire neighborhood.
Exceptions to the TIA Administrative Rule Requirements
The appellant asserts that the applicant did not provide all of the TIA report requirements listed
in the TIA Administrative Rule. This is true, however the rule states:
"As part of a Type 11 or 111 review, the City Planning Director, or designee, may grant an
exception to any or all of the content requirements of R-9.8650-F when both of the follow
are met:
1. A development will generate less than 100 trips in any peak hour.
2. The applicant has demonstrated that submittal of the item(s) listed in R-9.8650-F is
not necessary in order to show compliance with the approval criteria of R-9.8650-C.
The applicant's traffic engineer, Kelly Sandow, submitted a letter on February 28, 2017 to
formally request content exceptions that were informally requested through the initial scope of
work. Public Works staff have reviewed this letter and concur with the reasoning for each
exception. Therefore, staff confirms the requested content exceptions are valid and consistent
with the approved scope of work.
Staff would also like to reiterate that the City approved the applicant's scope of work before
the TIA application was submitted. By accepting the scope of work and ultimately approving the
TIA application, the City Planning Director provided an "exception" to the content requirements
by default. That said, staff understands the appellant's concerns and agrees that these content
exceptions should be better documented. Based on this feedback, the City will require more
official documentation of exceptions for future TIA applications.
Level of Service for Hilvard/30th Turning Movement
In a letter dated February 28, 2017, the appellant's traffic engineer (Mike Weishar) stated that
"...the left turn at Hilyard is LOS=F." As discussed at the public hearing, LOS F does not meet the
City's mobility standard of LOS D. However, staff notes that based on the City's standards, the
LOS for intersections is not based on one turning movement (in this case a left turn). Instead,
the overall LOS for the intersection takes into account all the different movements at the
intersection. While staff understands this left turn can be difficult during rush hour, the
applicant's engineer has demonstrated that the intersection as a whole operates above the
City's mobility standard.
Direct Access
The appellant asserts that two additional intersections need to be studied because they provide
"direct access" to the subject property. These intersections are East 32nd Avenue and Alder
Street (located east of the subject property), and East 33rd Avenue and Hilyard Street/East
Amazon Drive (located south of the subject property).
According to Public Works staff, "direct access" is interpreted as site driveways and access
aisles or roadways that provide access to the development site. In certain cases, a street or
intersection does not need to directly abut a subject property to provide "direct access." An
example of this includes commercial shopping centers with shared access agreements where
individual structures are located on individual parcels or lease pads; the development
generating the traffic impacts may not abut any adjacent roadway but those shared access
points provide direct access and warrant evaluation. Another example is a large isolated
development at the end of a dead end road; the intersection where the dead end road begins
would warrant evaluation regardless of the traffic volume generated.
In this case the subject development is proposed on a C-2 property that is adjacent to two
developed City streets - there are no unique circumstances like those discussed in the above
examples. In other words, the intersection of East 32nd and Alder Street, and the intersection of
East 33rd and Hilyard Street, do not provide "direct access" to the subject property. Instead, the
50-trip threshold for warranting off-site level of service performance analyses would be most
appropriate in this case to determine whether or not these intersections should be analyzed.
Because the 50-trip threshold was not exceeded for these intersections, they were purposely
excluded from the study area.
Bus Bump-Out
The appellant asserts that a LTD bus bump-out should be installed on Hilyard Street to serve the
existing bus stop adjacent to the subject property. This issue was addressed in Attachment A of
the Planning Director's decision:
Bump-outs allow City buses to pull off the travel lane to drop off or pick up passengers.
While bump-outs can provide traffic operation benefits on certain streets, a bump-out is not
currently feasible at this location. The first issue is that the Hilyard Street right-of-way is not
wide enough to accommodate a bus bump-out (the right-of-way is already consumed by
four travel lanes, sidewalks, and a center median). The second issue is that LTD would need
to support the request and also be involved with the planning and construction process.
From experience, Public Works staff note that LTD generally support bump-outs only when
they are absolutely necessary for safety or operational reasons because they degrade bus
operations (once a bus pulls off the road it is common for people not to yield and let them
back on). In other words, bump-outs are not preferred by the transit provider, so they are
only installed on higher classification roadways (i.e. major arterials) where there are higher
speed limits, a higher frequency of stops, and potential safety issues.
Attachment A: Pedestrian Crossing - Conceptual Detail
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Attachment A
Pedestrian Crossing - Conceptual Detail
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