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HomeMy WebLinkAboutStaff Open Record MemoA ftM I WPIanning 99 west 10`h Avenue Eugene, Oregon 97401 Phone: S41-682-S377 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 4 Attachment A Pedestrian Crossing - Conceptual Detail A RAMF CONNEU71;'u ~ ~ ' ' ~ u o THIS DRIVEI/VAY STAYS PROPOSED CROSSING HE RRFB, 8' WIDE, CONTINEN MARKINGS, MEDIAN REFUGE ~A ~ . e r' . r ✓ k N 4 u r. .'r O EXISTING LTD STOP HERE CE SS RAMP AND SIDE~'TTK ~ z CONENCTION TO PATH ^r EXISTING STREET LIGHT STREET LIGHT LOCATION TEr ~ - ; EXISTING LTD SHELTER HERE • ~ ~ 'fit I`• p ~ , TI IIS DRIVL\VAY GETS CLOSED