Council Members, and CSC commission members,
It has been brought to my attention that the Complete Streets Commission
("CSC") was not asked to review the Parkline project. Is this true? If so,
why not? Its a stated role of the CSC to ". provide input on major land
use and development projects as it relates to transportation."
According to the 7/21/15 Council Staff Report, ". the Citys Transportation
Demand Management (TDM) Program Guidelines and the Transportation Impact
Analysis (TIA) Guidelines define the process, requirements and standards for
determining a development projects potential impact(s) on the
transportation network"
In my view, it should be routine for CSC to review development projects
specifically in light of these documents, and I ask you to review the
Parkline Project for conformance with these guidelines.
Please be advised that in my own review, using Menlo Parks adopted TIA/TDM
standards, I noticed the following issues and irregularities:
1. There seem to be at least three places in the adopted TIA policy
where the analysis clearly deviated from policy,
a. The effectiveness of the alleged Parkline TDM plan was not verified
according to policy (TIA note 12)
b. Average Daily Traffic ("ADT) volume ("segment") counts on nearby,
sensitive local streets, particularly Ringwood, were not performed. (TIA
Section 7.B)
c. Despite many, clear congestion (LOS) impacts (and possible ADT
segment impacts) no "alternatives" have been evaluated in the event of
non-compliance (TIA section 9).
* These impacts were so clear that the applicant recently took it upon
themselves to proposed a commercial reduction (alternative) to reduce
traffic impacts.
2. There are also issues with the DEIR analysis.
a. The EIR analysis considers the alleged TDM plan measures to be part
of the project, not a project mitigation.
* TIA Section 4.A attachment B makes no mention of including TDM
deductions in project VMT calculations.
* I believe the practice is questionable, in part for reasons below.
b. The alleged TDM plan is not a specific plan, similar to the one
proposed in Table 3. of the 7/21/2015 Staff Report "reference plan"
conducted by Kimley-Horn for 1315 OBrien Drive.(Attached)
* The Kimey-Horn TDM plan distinguishes between "potential" methods
and "proposed" methods; it includes specific methods (Table 3), and it
evaluates the effectiveness of those methods (Attachment B).
* The Parkline "plan" is a promise to make a plan using a set of
strategies that Parkline "could" or "would" take from a menu of potential
methods whose listed effectiveness varies and was never verified in the
Parkline context, in part, because there is no specific TDM plan to verify.
c. Regarding vehicle miles travelled ("VMT"), the Parkline DEIR VMT
finding of "not significant" relies completely upon a TDM trip reduction
number, 28%, that seems unrealistic, unprecedented, and unverified.
* The Kimley-Horn TDM plan reduces trips by 21% and VMT by only 17%.
It notes that a 21% trip reduction is similar to other nearby plans.
* In the Greenheart DEIR, made by the same EIR preparer as Parkline,
TDM is inherently acknowledged to be both "unreliable" and "not guaranteed".
* How can a vague and unreliable element of the project, whose
effectiveness is unverified and cannot be guaranteed, be relied upon to
make a finding of "non-significance"?
Finally, for reference, I reviewed the transportation/TDM methods,
practices, standards and findings made by San Carlos in its Alexandria
Center DEIR.
The Alexandria Center project in San Carlos is a near-perfect comparable for
Parkline.
* It is a commercial "infill" project that abuts El Camino Real on the
east.
* On the west side of ECR is downtown San Carlos.
* San Carlos is a suburban community with a suburban city center and
population of 28,000
* There is a CalTrain station within .5 miles of the project.
* San Carlos has an adopted TDM ordinance. (Menlo Park does not). It
must also comply with C/CAG TDM policies.
* San Carlos uses the same method to verify TDM effectiveness as Menlo
Park.
In terms of rigor, clarity, and honesty the Alexandria Transportation DEIR
seemed superior in every way to that provided by ICF for Parkline.
I hope that the CSC reviews the Parline project, or, if not, then I hope the
CSC performs a post mortem of the Parkline traffic analysis to review and
critique practices undertaken for the Parkline Project in light of Menlo
Parks TIA/TDM policies.
Sincerely,
Paul Collacchi
