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.
