Impact of this project on our neighborhood's traffic

View the slide presentation to the Planning Commission here...
1.    Good morning, Ladies and Gentlemen.

2.    Let me get right to some of the problems associated with the density of the project with regard to the number of ADTs generated by the commercial and office traffic.  The project site is zoned 60% Neighborhood Commercial and 40% Community Commercial but it appears as though the entire site is being built as Community-serving commercial and office space with a token amount of residential.  An 8000 square foot supermarket is slated for ground floor tenancy. The applicant’s Traffic Study shows the majority of the traffic generated by this project coming from outside the Kensington neighborhood.  Yet the residential streets were not included in the Traffic Study.

3.    It is not speculative to suggest that traffic exiting the parking garage at the rear will exit the alley and, faced with no barrier, choose to turn in the direction of the residential neighborhood and utilize the surrounding streets as a shortcut to go around the traffic signals in order to exit Kensington more quickly.  Yet these streets, one block north and south of Adams Avenue, were not included in the Traffic Study.  Nothing in the MND addresses this impact.

4.    We were told by the Ken-Tal Transportation and Safety Sub-Committee the traffic study would cover the area along Adams Avenue from 15 to Aldine Drive, one block north and south of Adams.  Mr. Jansen promised the same area would be studied, although the raw data shows that it was collected in January, and he should have known by May when he made that promise that it did not include Kensington Drive north or south of Adams, Edgeware Road south of Adams, or Biona, Vista, Van Dyke, Alder or Madison at all.  We have provided the Agendas and meeting minutes for the Ken-Tal Planning Committee for the past year and wish them entered into the record.

5.    Before we go much farther, we must state for the record that we have found numerous, significant errors in the Traffic Study that render the conclusions, as well as any mitigation based on this study, worthless. We begin with what appears to be this minor mischaracterization of the 77 square feet of snack racks and cold drink cases at the gas station cashier counter as a ‘650 square foot 24 hour convenience store’, which gave the project 12 times the ADT credits it is entitled to.

6.    Utilizing the same City Traffic Impact Study Manual referenced by the Traffic Study, we noted that the pass-by reductions for the bank and supermarket are excessive in that they exceed 10%.  Logically, you can agree with the manual that, “It would be unreasonable to assume that more than one out of ten drivers would divert to a site on a daily basis” especially given that Kensington is a cul-de-sac neighborhood on the road to nowhere.  Please note that there were only five multi-family units on-site, not the seven the study used to derive its credits.

7.    We took the liberty, again using the same manuals referenced by the Traffic Study, to correct the erroneous data and recalculate the Cumulative Trip Rates and Peak Hour Rates.  The result is a Cumulative Trip Rate of 2,023 ADTs vice the 1,413 ADTS calculated from the study data, and an evening Peak Hour Rate of 213 ADTs vice 161. We would be happy to enter our data into the record.  

8.    Further calculation arrives at 21 ADTs northbound at the I-15 ramp during a Peak evening hour, which exceeds the 20 ADTS the study used as reasoning for not analyzing freeway on-ramps.

9.    Because the project traffic will generate 213 additional ADTs during the peak evening hours, it meets the criteria of the Congestion Management Program for a “large project”.

10. Under the Congestion Management Program, an Enhanced CEQA Review Process must be followed, traffic impact studies conducted and mitigation provided for new large project impacts.

11. Therefore, a CMP Traffic Analysis should be performed and SANDAG comments received before the normal CEQA review can proceed.  This project, with 213 peak hour ADTs, requires a CMP Traffic Analysis.

12. As the Traffic Study forms the basis for much of the Initial Study and the mitigation of the impacts of the traffic generated by this project, it would appear to be of the utmost importance to request that a new, comprehensive study be performed.

13. But we are not done with the subject of traffic.  We refer you to the City of San Diego Street Design Manual.  While the Mid-City Communities Plan designates Adams Avenue as a “3-lane collector”, the correct term, according to the manual, is “Two Lane Collector With Two Way Left Turn Lane”.

14. Three things catch the eye here.  First, this designation applies to a street with a curb-to-curb width of 54 feet.  Secondly, at 13,000 ADT you have a Level of Service of D, which is an acceptable level of service for CEQA review. Third, design speed is 35 MPH. I will tell you now that Adams Avenue in Kensington is posted for 25 MPH.

15. Unfortunately, east of the I-15 bridge, Adams Avenue is only 47.5 feet wide, not quite meeting the width required to be designated a “Two Lane Collector With Two Way Left Turn Lane”.

16. The Traffic Study, flawed as it is, concludes that with mitigation consisting of restriping and a traffic light, the traffic impacts of this project can be mitigated, and that “Adams Avenue is considered built to its ultimate roadway classification  between I-15 and Marlborough Drive”.  We don’t understand the basis for this statement in that restriping does not widen Adams Avenue by six and a half feet.  We also note that in Table 16, even with mitigation, the ADTs result in a Level of Service that would indicate a significant impact that is unmitigated under CEQA guidelines.

17. The “Fair Argument” rule applies here, and whether the inadequacy of the Traffic Study is used to support it, or the improper classification of the roadway, in any case, the impact of the traffic generated by this project cannot be mitigated by what is proposed in the MND.

18. We’d like to make a few more points for the record.  The failure to study the freeway ramps is likely to have an impact after a traffic signal is installed at Adams and Kensington Drive because there is already a queue forming on this segment of roadway at peak hours.

19. Restriping a street which is too narrow for the intended classification will not improve traffic flow if oversized vehicles straddle the centerlines.

20. Aldine Drive was not included in the study and would be used by inter-community traffic coming from Talmadge and the College area.

21. If MTS and San Diego Fire and Rescue have not been given a solid traffic study on which to base a review and comment, we can expect fallout after the project is built when parking is removed from Adams Avenue to remove obstacles that prevent emergency vehicles from responding to calls on time, or that cause buses to lose time of their routes.

22. The Initial Study Checklist does not seem to have taken Public Service response times into account.

23. At best the analyst’s assessment is that the project might have an impact on transportation, and no impact on parking.  Again, without a sound study on which to form an opinion, this Initial Study and Environmental Assessment, as well as the Mitigated Negative Declaration, are just paper.

24. We ask today that base your decision on this matter on the Fair Argument standard under CEQA in order to fully assess the impact of this project on our community’s assets.   We would also like to request that any subsequent mitigation include mechanisms for limiting the amount of traffic that this project can generate to ensure retail and office tenants are of a nature that is compatible with Neighborhood Serving Commercial, and as a means of ensuring that no further mitigation will be required as a result of this development. We also ask that you Do Not Certify Mitigated Negative Declaration Number 105244, and that you deny the Planned Development Permit Number 360181 and Vesting Tentative Map Number 360180.