Staff Response to Amazon Corners Public Comment

The following information was included with the Planning Director Decision. It is duplicated here for ease of access.

To address key issues raised in public testimony in response to the Traffic Impact Analysis (TIA) and Adjustment Review applications, staff has prepared the following responses. As over 100 letters were received, this is not a comprehensive list of every comment received. However, staff has thoroughly reviewed all submitted testimony and provides a response with the intent of addressing the common themes and primary concerns raised by neighbors overall.

The key issues identified in the testimony are in italics, followed by staff response. It is also noted that staff’s evaluation of the approval criteria for each application further addresses some of the issues highlighted below (and the decision documents constitute the City’s official evaluation of each criteria). On January 10, 2017, the applicant also submitted a response to public comment. Their response letter is included as Exhibit 1 to this attachment.

The proposed building is too tall and it is out of character with the existing neighborhood.

At 62 feet in height, the property building is taller than the church that was previously on the subject property, as well as the single-family homes to the east and south of the property. As such, it represents a change to the neighborhood, and staff understands the concerns raised by neighbors.

As noted in the Planning Director’s decision, the zoning of the subject property is C-2 Community Commercial, which allows buildings up to 120 feet in height. The proposed building falls well under this maximum.

To address neighborhood compatibility, the land use code limits building height where commercial property abuts residential property. For instance, when C-2 zoned property abuts R-1 zoned property, the building on the C-2 property is limited to the maximum allowable height in R-1 (30 feet) within 50 feet of the R-1 zoned property. In this case, proposed building is setback approximately 60 feet from residential properties to the east, and thus is not required to be lower in height.

The property owner is not requesting a special allowance or adjustment for the height of the building, nor is such a request necessary or required. The height of the building is permitted outright based on the zoning of the property.

While not everyone will agree these regulations are adequate to address neighborhood compatibility, City staff are legally obligated to apply the currently adopted regulations and standards. If neighbors believe that the C-2 zone allows development that is too tall, or that the zone does not provide adequate protections for neighborhoods, then a higher level discussion far beyond this project would need to be initiated. Changes to the Eugene Code require City Council initiation, extensive community outreach, public notice and hearings, recommendation from the Planning Commission, and ultimate approval by the City Council.

For background, the Metro Plan diagram, which is a central piece of the City’s long range land use plan, has designated the subject property for commercial use since at least 1982. Consistent with this designation, the subject property, as well as the property to the north (Albertson’s) and properties to the south on East Amazon Drive, are zoned C-2. The subject property has been zoned C-2 since before 1968.

Put differently, the City Council made an intentional decision a long time ago to designate these properties for higher intensity commercial uses, and it is expected that over time the properties will redevelop with new commercial, office and residential uses to serve Eugene’s growing population.

108 apartment units will bring too many people into the neighborhood and they will park on neighborhood streets

Staff recognizes that the proposed mixed-use building is a more intensive as compared to the previous church development, and will result in more people in the neighborhood than this previous use. As noted above, the subject property is zoned C-2, and unlike many of the other zones in the City, the C-2 zone has no maximum residential density. This means that the development standards are the only limiting factor for the number of apartment units that could be built on the subject property. In other words, as long as the development standards are met (height, setbacks, parking, etc.) and a TIA is approved (assuming a TIA is applicable), then there is no hard limit on the number of apartment units that could be built.

While the applicant plans to meet future parking requirements (and on-site parking is therefore not evaluated in the land use decision), staff has provided the following information regarding parking requirements: The land use code requires 1 on-site parking space per dwelling unit; however, a 25% reduction is automatically applied as a right of development. This means that if an applicant were to construct 108 apartments, then 81 on-site spaces would be required. Many retail uses require 1 space per 330 square feet of floor area or 1 space per 660 square feet of floor area. Restaurants and delis require 1 space per 66 square feet of seating area (plus 1 space per 440 square feet of non-seating area).

The purpose of this information is to illustrate that the current developer has potentially limited the size and scale of their proposal in an attempt to limit impacts to the neighborhood, and that the applicant has not requested further reductions to required on-site parking. In this case, the applicant currently proposes more than 150 on-site parking spaces, including an underground parking garage to maximize efficient use of the available space.

While some may believe that the City’s code does not require sufficient on-site parking, the City Council has made deliberate policy choices to require less on-site parking for developments. The City’s policies promote bus transit, bike/pedestrian facilities, and walkable neighborhoods – promoting the construction of expansive surface parking lots is not consistent with this vision.

The City’s existing supply of commercial and residential land, including redevelopment on infill sites like the subject property, is also an important component of our long-range planning efforts as part of “Envision Eugene,” and Council’s policy direction as part of that process not to expand the City’s Urban Growth Boundary (UGB) to accommodate commercial and residential development over the next 20-year planning period. This means that Eugene needs to accommodate growth inside our current UGB, and multi-family apartment projects are a key component to this.

A detailed rendering of the project should be provided.

Based on the application requirements at EC 9.8025 for Adjustment Review, the applicant was not required to submit a detailed 3D rendering of the proposed development (the applicant did submit elevation drawings which was sufficient for staff’s evaluation). So, unless the code is revised to explicitly require 3D renderings for adjustment review applications, staff does not have the ability to require them. That said, we agree that 3D renderings could help people to better visualize a project, and in the future staff can encourage applicants to provide this type of information when it seems appropriate.

Since underground parking might not be viable, there should be a determination by a qualified professional that below-grade underground parking is viable.

The proposed development has been designed by a licensed architect who is professionally qualified to determine the feasibility of underground parking. Regardless, the viability of an underground parking area will be further assessed at the building permit stage; if for some reason the underground parking is not viable, the applicant will need to find another parking solution that complies with the Eugene Code. Also, since the applicant is not requesting an adjustment related to the underground parking area, this issue does not relate to the applicable approval criteria.

The proposed site plan does not clearly show the proposed building projections into the setback area beyond the building footprint. The site plan should be modified to show the amount of all building projections beyond the footprint. This could be accomplished with a colored dashed line, or similar indication.

Building projections (i.e. where the building overhangs exist) are shown as a dashed line on the applicant’s site plan. That said, staff agrees that this could have been labeled more clearly on the plans. We appreciate when community members point out issues like this so we can refine the way we review plans, and then ultimately ensure that land use applications are as easily understandable as possible. This also highlights the importance of providing staff contact information on the public notice – our staff are always happy to talk to neighbors if they are unsure of something or have a question about a detail on the applicant’s site plans.

No through movement connecting E. 32nd to Hilyard should be permitted.

The applicant has requested an adjustment to allow through movement; detailed discussion regarding this request is included in the adjustment review decision document.

Traffic Impacts

Potential traffic impacts from the proposed development have been noted as major concerns in the public testimony. As such, before specific comments regarding traffic are addressed, Planning and Public Works staff want to first provide a general overview of the purpose, limitations, and goals of traffic impact analyses.

The stated purpose of a traffic impact analysis 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.

Traffic impact analyses are not intended to analyze every intersection and every street within a mile of a development site, but only those that receive a potentially impactful amount of traffic from the proposed development (50 or more peak hour trips from the development). If all streets and intersections had to be studied, regardless of the development’s traffic impacts, traffic impact analyses would be extremely expensive and time consuming to the point that they would be infeasible for any single developer. This is why different thresholds for analysis have been adopted – these thresholds strive to strike a balance between meaningful analysis and feasibility.

As part of a traffic impact analysis, there are limitations on the mitigations that can be imposed on a single developer because new traffic from one development, especially along a more major street like Hilyard, will only be a small fraction of the existing traffic. In other words, it would not be fair to require a developer to pay for major street upgrades (i.e. street widening, traffic signals, etc.) when their development is increasing traffic on an adjacent street by only 2%.

The intersection of 30th and Hilyard receives traffic from thousands of Eugene homes and businesses, and a single developer was not required to pay for the traffic lights that currently exist at the intersection (at least not directly). Instead, the City imposes System Development Charges (SDCs) on new development, which requires developers to pay fees through the permit process that are ultimately deposited into a series of funds maintained by the City. The amount of SDCs a developer pays correlates with the level of development; for example, the SDC costs to construct 100 apartments is much higher than the SDC costs to build one single-family home. The SDC funds are then used to improve roads, maintain parks, and build other necessary infrastructure to support the community. Even where a traffic impact analysis finds that mitigation is not warranted, a developer will still be paying (indirectly) for future street improvements across the City.

There should be traffic calming measures implemented along Hilyard Street, and a petition was submitted to the City some time ago but nothing has been done. The project should also provide:

  • median refuges for vehicles at 31st Street and Hilyard;
  • bike lanes on 32nd Avenue;
  • median refuge for cars traveling south on 32nd Avenue;
  • mitigation of head-on left turns at 32nd Avenue and Hilyard;
  • a bus stop bump-out on Hilyard in front of Amazon Corners;
  • creation of 8 to 12 foot sidewalks with adequate setbacks.

While many of the mitigations above would provide a benefit to the neighborhood, the City cannot legally impose mitigations that are not justified in an applicant’s traffic study (assuming the City agrees with the technical findings of the study). That said, Planning staff contacted City of Eugene Transportation Planning staff to inquire about potential projects along Hilyard Street. Transportation staff note that the City intends to construct some form of a traffic calming treatment on Hilyard Street (south of the subject property near Tugman Park) as part of a bond funded project for walking and biking improvements in the area. This project will include a public process (i.e. public meetings) and is expected to occur by the end of 2018. For more information related to the City’s traffic calming program, visit:

The City also offers residents more immediate tools to address speeding on neighborhood streets including the Citizen Radar Program and Traffic Enforcement. For more information you can visit the program website ( In the program, neighbors participate in a two-hour training in the use of radar guns and can then check them out to monitor neighborhood traffic speeds. Typically working in pairs, neighbors record the speed of the vehicles (along with the license plate and matching vehicle description). Police then issue a letter to the registered owner of the vehicle for those observed speeding egregiously. We like to hear back from people that have participated in the Citizen Radar Program to share what they learned about speeding. Also, the Eugene Police Department Traffic Enforcement Unit may be reached at 541-682-5157 to report neighborhood speeding problems for enforcement action.

Neighbors have also recommended that a bus stop “bump-out” be constructed adjacent to the subject property. 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 bumpout 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.

Nonetheless, with or without a bump-out at this location, the development site has good access to transit service. The site is adjacent to a bus shelter along Hilyard Street that receives regular bus service, which promotes the use of alternative modes of travel other than automobile.

The neighbors also suggest that 8-10 foot sidewalks be constructed as part of the development project. While staff agrees that in some cases wider sidewalks can improve the pedestrian experience and overall design of a project, Hilyard Street is already built to full urban standards including four travel lanes, a median, street tree landscape strips and sidewalks. East 32nd Avenue also includes sidewalks that meet City standards. Since the City does not require any development to construct public sidewalks wider than 5 feet, and sidewalks of this width already exist adjacent to the subject property, it would not be justified to require the developer to pay for construction of a wider sidewalk. As discussed above in regards to a bus bump-out, there is also no extra space within the right-of-way to build additional street improvements or wider sidewalks.

In regards to bike lanes along East 32nd Avenue, local neighborhood streets do not see enough traffic to warrant bike lanes. There are other more major roads in Eugene that are in need of bike lanes, so the City’s Public Works Department is currently focused on these locations. Also, even if bike lanes were warranted at this location, the entire street would need to be reconfigured because there is not space within the right-of-way to accommodate bike lanes (i.e. the street tree landscape strip would need to be removed which may not be a desirable option).

Finally, the neighbors note that it is difficult to turn left (south) on Hilyard Street from East 32nd Avenue, and therefore a vehicle refuge (i.e. center turn lane) should be placed in the right-of way. In this case, there is an existing landscaped median between the northbound and southbound traffic lanes, and the City rarely supports removal or replacement of medians. Medians add aesthetic value to the street (landscaping, street trees), improve safety (limit left turn conflicts, create narrower visual effect which reduces traffic speeds), and provide pedestrian refuges. Center turn lanes, on the other hand, are most useful where there are frequent driveways on both sides of the street (which is not the case here), and replacing medians would have a negative effect on aesthetic value, safety and traffic operations.

The TIA study area should be expanded to include additional streets and intersections.

The City of Eugene Engineering staff reviewed and concurred with the scope of the traffic study. Thresholds are adopted for establishing the extent of the study are and study area intersections based upon City standards and Institute of Engineers (ITE) best practice. For example, many of the streets and intersections in the area do not meet the threshold for analyses and inclusion in the study area (they will not see a net increase of 50 trips during the peak hour from the development). In other words, even if the City thought additional intersections should be evaluated, we cannot require this analysis because the applicant’s study area was adequate according to City standards and ITE best practice.

The scope of the study also includes all streets and intersections that provide direct access to or from the development. The development site accesses Hilyard Street and East 32nd Avenue, and therefore the scope of work includes East 32nd and Hilyard and the intersection of Hilyard and East 32nd . All direct site access is taken at these points, which is why they are included in the analysis. The study also included the intersections of Hilyard and East 31st , and Hilyard and Amazon Parkway/East 30th . In summary, the scope of the study is consistent with the approved scope of work and does not need to be expanded.

Additional areas should be included in the study because traffic is already congested. New travel demand generated by the proposed development will seek out and utilize all available alternative routes, including neighborhood streets. In addition, existing travel demand will be displaced and forced to seek alternative routes to avoid the increased congestion. Both site-generated traffic and displaced traffic should be evaluated.

The traffic study does account for displaced traffic and site-generated traffic. The traffic study identified appropriate levels of service, before and after the proposed development for the study area intersections. The traffic counts performed also captured the background volumes and patterns of the existing street system and all users on it, and therefore any alternate routes and displaced traffic patterns are included in the background counts and no-build scenario analyses. Site generated trips are assigned to the system based upon the patterns and volumes from the traffic counts; the end result is an analyses that identifies how the expected trips generated by the site will use the systems based on the observed patterns of driver behavior.

The traffic study demonstrated the ability for the site-generated traffic to access the arterial and collector street system and move south and west. The traffic study also counted vehicles on East 32nd Avenue and their turning movements onto Hilyard Street – the dominant movement is vehicles turning right (north) on Hilyard.

That said, it is common (and reasonable) that neighbors predict traffic behaviors based upon their personal experience; however, there are transportation planning aspects such as the “gravity principal” that have to be considered too. The “gravity principle” finds that the easiest access to regional transportation systems and commercial/employment centers draw the most demand for vehicle use from residential development. The predicted use of Hilyard Street is consistent with that principle and the study information provided (and the development is not expected to have a significant impact on Alder Street as a result). Further, the applicant is not required to mitigate cut-through traffic with off-site improvements in this case because the levels of cut-through that might be generated from this single development is minimal according to the applicant’s TIA and review by the City’s Public Works staff with traffic engineering expertise.

While staff understands cut-through traffic on streets like Alder is highly undesirable, some cut-through traffic will always occur in any neighborhood. The City will continue to improve streets and intersections throughout Eugene to minimize cut-through traffic as much as possible. Also, if there are issues with speeding in a neighborhood, neighbors can request traffic calming measures such as speed bumps (see discussion above regarding the City’s traffic calming program). For example, there is an existing mitigation on Alder Street that prevents vehicles from traveling south (it allows bike and pedestrian access only); if traffic calming becomes warranted in the future, the traffic calming program could study the issue to see if additional mitigation measures are warranted along Alder Street.

The different traffic scenarios highlighted by neighbors also provide a look into an infinite number of transportation options and challenges for the neighborhood. While staff agrees every neighborhood has their own traffic issues, many of the streets discussed are not within the study area or required to be analyzed in the traffic study. This is one of the limitations of traffic impact analysis that cannot be avoided unless industry standards and the Eugene Code are revised to require wider study areas and more extensive scopes of work.

Because of schools in the area there should be morning traffic counts, specifically between 7:30 and 9:30 AM.

The study included trip generation1 in the AM peak hour within the study area; however, AM peak hour trips for the study analyses period are substantially lower than the PM peak hour for the study analyses period. In effect, the proposed project does not generate enough trips during the AM peak hour of the analyses period to warrant off-site Level of Service or operational analyses. The net 50 peak hour trip threshold also applies to the AM peak hour, but there are no study intersections that will receive 50 or more peak hour trips during the analyses period. Based on the reasoning above, AM peak hour analyses was not required and was therefore not included in the approved scope of work.

Impacts to schools are typically analyzed when the study area abuts a school site (especially when the study area abuts the entrance to a school site). In any case, the rush hour of other uses in the area is not justification for requiring a development to analyze the impacts because developments are only required to analyze and mitigate the impacts they create. Nearby schools are all existing and developed uses outside the approved study areas, and therefore no analyses is required based upon existing impacts from other uses in the area.

It is also important to note that even if AM analysis was completed, the nearby intersections are most congested during the PM peak hour (this is the case for most streets and intersections 1 Expected trip generation accounts for new traffic from the proposed development, and it establishes which intersections are studied. Traffic counts, on the other hand, establish “background” traffic that informs what is happening on the surrounding street system without the development. Expected trip generation is added to background traffic to predict traffic impacts (both figures are also used to determine level of service). all around the City). Since the applicant analyzed the PM peak hour (i.e. the “worst-case” scenario), and is mitigating impacts accordingly, there would likely be no realistic benefit to analyzing the AM peak hour even if it was required. In other words, it is highly unlikely that additional traffic mitigations would be warranted if the AM analysis was completed.

The restriping mitigation proposed at E. 31st Avenue and Hilyard Street is inadequate.

This comment is thoroughly addressed beginning on page 6 of the TIA evaluation.

Traffic queuing will cause problems as the Amazon Bike Path crossing will potentially be blocked and pedestrian and bike safety could be impacted.

The traffic analyses includes a queuing and blocking report for the study intersection of Hilyard Street and East 31st Avenue, and it shows that the eastbound average queue and 95th percentile ques are not expected to block the bike path crossing. Regardless, it is illegal to block a pedestrian crossing so if this becomes a problem it is solely an enforcement issue.

This intersection also needs a traffic refuge (median) so that vehicles turning north onto Hilyard from E. 31st can safely cross one side of Hilyard without having to wait for both sides to be available for crossing. A pedestrian refuge is also needed here for the same reason.

There is currently a raised landscape median on Hilyard at East 31st Avenue and northbound left-turn pockets to East 31st Avenue. Despite the fact that the City (and likely many residents) would not support replacement of landscaped medians with center turn lanes, taking refuge in the intersection blocks northbound left turns and further degrades operations and safety. The intersection is also a point of speed and horizontal lane transition to the northbound left turn pocket for Amazon Parkway; taking refuge in the intersection increases the crash risk. Because of these issues, it is industry practice to limit or restrict access and unorthodox operations at roadway transitions. A sanctioned two-stage crossing at an intersections is unconventional, prohibited under Oregon law, and likely dangerous. Other potential mitigations related to East 31st Avenue are further discussed in detail beginning on page 6 of the TIA evaluation. Regarding pedestrian access, a condition of approval was imposed through the TIA decision to require a pedestrian crossing near East 32nd Avenue.

No mitigation is proposed at E. 32nd and Hilyard where vehicles making a left turn from E. 32nd onto Hilyard southbound are already having great difficulty. The TIA indicates that 17 additional southbound left turns from E. 32nd would be added to the existing level, for a total of 58 turns during the PM peak. Is this even possible? A median refuge on Hilyard at E 32nd would greatly facilitate this movement and should be evaluated as a mitigation option.

The traffic analysis studied the intersection of Hilyard Street and East 32nd Avenue, and followed all industry standards and best practices. As a result of the study, the applicant’s engineer found that minimum level of service standards were met with the addition of the proposed development (and therefore no mitigation is required).

Traffic impact analyses are not required to determine the maximum number of turns or the theoretical capacity of any particular turning movement, lane group or approach. The analyses indicated that 17 additional southbound left turns will not degrade the level of service below adopted minimum standards. The TIA (specifically the Highway Capacity Manual level of service analyses) does consider all turning movement conflicts (i.e. conflict between left turns), and the report did not identify any significant queuing that would affect left and right turns. The dedicated left turn lane on Hilyard at East 32nd Avenue must be maintained, but the analyses did not predict queuing that warranted elongation. And as noted previously, a vehicular median refuge at an intersection will have a negative effect on operations and safety, and a two-stage turn at an intersection is prohibited by law. The analyses did not identify a refuge as a mitigation, and the City of Eugene would not support a refuge in this case even if proposed by an applicant.

The baseline traffic data is inadequate and it is impossible to determine the source of the data for existing traffic. Actual, recent traffic counts using physical traffic counters should be collected for all study intersections.

Traffic counts were provided by the engineering consultant for all study intersections, which are located in Appendix D of the traffic study (no theoretical model data or historic counts were used). According to Public Works staff, the counts are factual, accurate and meet all industry standards, and were taken during the appropriate study periods as approved in the scope of work. Also, the industry standard and Eugene’s standards allow traffic counts to be performed within 2 years of preparing the analyses – the consultant performed the counts 2 months before the analyses which is well within the acceptable time frame.

We see that a “video analysis” was used for the Hilyard and 30th intersection. Is this a completely objective, verifiable, and accurate basis for characterizing this intersection? If so, we would like the actual video and original traffic counts to be entered into the record as part of the TIA so that we may independently verify its accuracy.

Video analysis is a completely objective, verifiable and accurate basis for preparing intersection counts. In fact, video is the preferred method for collecting traffic data, especially for large or complicated intersections. The reason is that video can allow traffic to be counted at a slower rate under controlled conditions, and can even be reviewed multiple times for accuracy. Manual counters, on the other hand, are live and subject to site conditions and human error. Finally, it is not a City or industry standard to provide the video and therefore the City did not require the applicant to provide it.

Minimum standards for the TIA are established in Administrative Order No. 58- 02- 02-F. Section R-9.8650-F(4.1) requires actual traffic counts on an hourly and daily basis for all streets and intersections in the study area. No daily figures are provided in the TIA and we see no evidence that actual traffic counts have been collected. Section R-9.8650-F(5) requires traffic counts for morning peak periods as well as evening peaks.

Administrative Order No. 58- 02- 02-F. Section R-9.8650-F(4.1) does not require actual traffic counts. Administrative Order No. 58- 02- 02-F. Section R-9.8650-F(4.1) requires “Daily and hourly traffic counts that verify traffic growth and peak hour times for the year prior to the application on each street within the study area that carries traffic to or from the proposed development.” Subsection 4 states “The information is available from the City, other impacted jurisdictions, or may be obtained in the field.” The City of Eugene’s peak hour time correspond the require AM and PM peak hour of the adjacent street.

All operational performance standards are based upon peak hour turning movement volumes during the analyses periods identified in the scope of work. The City of Eugene has no Average Daily Trip (ADT) performance based measures or standards for the built transportation system. This renders an Average Daily Trip (ADT) count an irrelevant and cost prohibitive exercise. Industry standard for conversion of the peak hour count is 10% of the ADT.

Traffic counts are provided for peak traffic analyses hours on the study intersections identified in the approved scope of work. The proposed development produced counts for the PM peak hour of the adjacent street as identified in the approved scope of work. The approved scope of work did not include off-site traffic counts for the other peak hours identified in 58-02-02-F R9.8650 F(5). The other peak hours identified in 58-02-02-F R9.8650 F(5) are not warranted as they do not produce enough trips (50 minimum) to warrant Level of Service Analyses per City of Eugene standards.

The diagram used to show trip distribution is an overly-simplistic diagram that is inaccurate, not to scale, and misleading. We would like to see bike paths, waterways, on-street bikeways, and safe school routes (i.e., Alder Street) clearly indicated and labeled with accurate spatial representations.

The diagram presented to show trip distribution is accurate and is not required to be to scale. The diagram’s only purpose is to show the direction and volumes of vehicle trips distributed to the roadway network, and the applicant’s diagram achieves this. The diagram also clearly illustrates the assignment of vehicles to the points of distribution and the limits of the study area. In short, the diagrams provided are consistent with industry practice and effectively show trip distribution and assignment. Further, bike paths, pedestrian links, and transit links are discussed in the traffic study (and are not required to be shown on the trip distribution diagrams), and there are no on-street bike lanes in the study area. Safe routes to schools are not required to be presented or discussed in the study, and waterways are not required to be presented or discussed in the study unless specifically used as part of the primary transportation system (i.e. a ferry).

The predicted trip generation is too low. The applicant uses a “specialty retail center” designation but there are many other possible commercial uses that would generate more trips.

The following description of specialty retail is provided in the ITE Handbook: “Specialty retail centers are generally small strip shopping centers that contain a variety of retails shops and specialize in quality apparel, hard goods and services, such as real estate offices, dance studios, florists and small restaurants.“ Based on the definition, Planning and Public Works Engineering staff finds this is a realistic and appropriate use for the commercial portion of the project. The use category considers likely uses such as restaurants and retail shops. Uses like a fast food restaurant would not be realistic as there is no place on the site for a drive-through. Another use that generates a high number of trips is a convenience store; it is unlikely that a convenience store would be proposed here based on the site’s layout and proximity to a grocery store (Albertson’s) and an existing convenience store (Dairy Mart). Future uses will need to comply with the TIA approval.