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Impact Analysis General Comments for Albina Fuel Site Redevelopment 1/9/01 The Traffic Impact Analysis was based on a number of questionable assumptions. Because of these flawed assumptions, it is impossible to reach any valid conclusions concerning the adequacy of the transportation systems. 1) Fails to analyze impacts to traffic safety The study fails to address possible impacts of proposal on traffic safety. The study states that none of the intersections within the study area are unsafe, but fails to investigate the impacts to public safety of additional vehicles and pedestrians the proposal is likely to generate. Nor does it consider the impact of traffic redirected to other arterials (see item #3 below). 2) Assumes no increase in ambient traffic The study assumes ambient traffic in the vicinity of the Albina property will not increase for the next 20 years. While City, state, and regional policies dictate a reduction in per capita vehicle miles traveled, it is imprudent to assume that future increases in the City's population will not result in an increase in traffic. 3) Analysis redirects trips The study assumes that a significant number of motorist already using Broadway will choose alternate arterial routes; that is, they will chose to redirect their commutes based on increased congestion on Broadway. The number of redirected trips (e.g. 830) is roughly equivalent to the number of additional trips generated by the proposed development (e.g. 875). The study fails to describe specifically the regional impacts of the reroute. To which "parallel arterials" were trips rerouted? 4) Study area is incorrectly defined It is unlikely that the study area defined in the report includes all roadways and intersections that might be affected by the proposal (particularly those alternate arterial routes mentioned in item #2 above). Shouldn't all areas affected by the proposal be included in the study area? This would include all road segments and intersections to which traffic is rerouted. 5) Ignores potential cut-through traffic The study assumes that additional traffic congestion created by the proposed development would not produce neighborhood cut-through traffic, that is, motorist will not choose to cut-through neighborhoods in response to increased congestion at intersections on Broadway. This assumption is particularly suspect since the congestion caused by the proposal is expected to result in the redirection of 830 trips to other arterials. 6) Inconsistent approach to land development and transportation The applicant asks that the property be rezoned to an EX zone. The EX zone proposed for the property is intended for redevelopment of sites located in the central downtown area. The approach used by the applicant to mitigate traffic impact focuses on improvements for personal vehicles and fails to address more appropriate transportation alternatives. The site development concept described by the applicant suggests a dense urban pattern of development, whereas the approach to transportation improvements is likely to create a suburban and auto-oriented pattern of development.
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