Guest Commentary: Public Comment to the BTSSC – “The ARC SEIR Transportation Impact Analysis is neither adequate nor complete”

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The following written public comment to the Bicycle, Transportation & Street Safety Commission (BTSSC) was delivered by Matt Williams to the Commission members and the City the day before the BTSSC meeting.   The opinions expressed in the public comment are as an individual, and not as a representative of any organization.

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DATE:            April 8, 2020

TO:                  Bicycle, Transportation & Street Safety Commission

FROM:           Matt Williams

SUBJECT:      Aggie Research Campus—Subsequent Environmental Impact Report Traffic and Circulation

 

First, I would like to thank Sherri Metzger, Ash Feeney, and Fehr and Peers for providing the Excel spreadsheet I requested containing the data from the tables from pages 42 through 161 of the SEIR Appendix F, Volume 2 – Transportation Operations Analysis Technical Appendix.

Second, my deep dive analysis of the intersection data in the spreadsheet produced the following substantial concerns.  At the end of this memo, I provide a Recommendation that I would vote for if I were a member of the BTSSC.

(1)  The 23 intersections studied/counted did not include the two most impactful “choke point” intersections

  • The intersection of southbound Mace Boulevard with the I-80 eastbound loop on-ramp was omitted. That uncounted intersection is physically between Intersection 13 and Intersection 14
  • Intersection 14 Mace Boulevard/Chiles Road was reported as a 4-way intersection rather than a 5-way intersection. The fifth “way” of that intersection is the I-80 eastbound slip on-ramp.  Especially during the PM Peak Hour that I-80 slip on-ramp off northbound Mace is the single biggest “choke” point in the existing traffic in the 23-intersection study area.  If Fehr and Peers and the City want to avoid including 5-way intersections, that I-80 slip on ramp should be included as an intersection of its own.

In my personal opinion failure to include the two most impactful intersections in the 23-intersection transportation analysis means that analysis, and the SEIR is not adequate or complete

(2)   The 23 intersections studied/counted do not adequately report the impact of traffic (Vehicle Miles Traveled) on adjacent residential neighborhoods. The following two additional intersections should be added to the analysis, Alhambra Drive/5th Street and Alhambra Drive/Loyola Drive.

(3)  Page 33 of SEIR Appendix F, Volume 1 – Transportation Operations Analysis reports the following, with bolding added by me for emphasis:

Project Trip Generation

Table 3 summarizes the estimated weekday and peak hour trip generation for the ARC project using the MXD+ tool. As shown in this table, the ARC project would generate an estimated 23,888 new external daily vehicle trips, 2,232 new external AM peak hour vehicle trips, and 2,479 new external PM peak hour vehicle trips during a typical weekday. The Mace Triangle would generate an estimated 762 new external daily vehicle trips, 93 new external AM peak hour vehicle trips, and 82 new external PM peak hour vehicle trips during a typical weekday.

The SEIR spreadsheet data provided by the City produces the following vehicle counts for the five intersections that provide ingress and egress to ARC during the AM peak hour:

 

The aggregate total of the Gross Ins and Outs to the ARC Project for those five intersections is 1,913, which is only 87% of the 2,232 new external AM peak hour vehicle trips reported on page 33 SEIR Appendix F, Volume 1 – Transportation Operations Analysis.

There appears to be no apparent reason for that 13% difference between the reported aggregate and the calculated aggregate in the tables.  Absent an explanation for this discrepancy, I believe the SEIR is not adequate or complete

The SEIR spreadsheet data provided by the City produces the following vehicle counts for the five intersections that provide ingress and egress to ARC during the PM peak hour:

The aggregate total of the Gross Ins and Outs to the ARC Project for those five intersections is 2,205, which is only 89% of the 2,479 new external AM peak hour vehicle trips reported on page 33 SEIR Appendix F, Volume 1 – Transportation Operations Analysis.

There appears to be no apparent reason for that 11% difference between the reported aggregate and the calculated aggregate in the tables.  Absent an explanation for this discrepancy, I believe the SEIR is not adequate or complete.

(4)   There are additional data inconsistencies in the intersection data that become visible when one attempts to better understand Vehicle Miles Traveled along the most likely routes that vehicles will used to travel to ARC in the AM peak hour, and travel from ARC in the PM Peak Hour.  The graphic below shows the AM Peak Hour data, as provided to me by City staff in the Excel spreadsheet in the top half of the graphic. The bottom half of the graphic shows the two of the most likely routes to ARC in the AM Peak Hour.

The first route starts at Intersection 1 at East Covell Boulevard/Pole Line Road and proceeds east along Covell Boulevard, around the Mace Curve, and then south on Mace to ARC, and then further on Mace down to Intersection 17 at Mace Boulevard/El Macero Drive.  The + or – column shows the difference between the through vehicles reported at each respective intersection and the through vehicle count calculated as one proceeds from Pole Line through the route.  Note that between Manzanita Lane (Intersection 4) and Wright Boulevard (Intersection 5) a discrepancy of 150 unaccounted-for vehicles appears to the through vehicle count. Then between Wright Boulevard and Monarch Lane a 195-vehicle discrepancy appears.

 

Similar discrepancies appear between Intersections  21 and 9, 9 and 11, 11 and 13, and 13 and 14.

There are always going to be small discrepancies due to timing differences, but the magnitude of the noted discrepancies are well beyond simple timing differences.  It is worth noting that the 209 vehicle discrepancy between Intersection 13 (Mace Boulevard/I-80 WB Ramps) and Intersection 14 (Mace Boulevard/Chiles Road) is most likely attributable to the omission from the collected data of the intersection of southbound Mace Boulevard and the I-80 eastbound loop on-ramp.

Also shown in the graphic are similar discrepancies that appear in the route from the I-80 eastbound off ramp (Intersection 15) through Intersections 14, 13, 11, 9, and 22 .  The very high discrepancy numbers between Intersection 14 (Mace Boulevard/Chiles Road) and 13 (Mace Boulevard/I-80 WB Ramps) are probably attributable to the omission from the collected data of the intersection of that I-80 slip on-ramp off northbound Mace, which is the single biggest “choke” point in the existing traffic in the 23-intersection study area.

Absent an explanation for these discrepancies and similar discrepancies in the PM Peak Hour data, I believe the SEIR is not adequate or complete.

Recommendation

Because of all the above examples where the SEIR Appendix F – Transportation Impact Analysis is neither adequate nor complete, I recommend that the Bicycle, Transportation & Street Safety Commission (BTSSC) approve the following resolution addressed to both the Planning Commission and the City Council.

  • That the BTSSC does not consider the Aggie Research Campus Draft Subsequent Environmental Impact Report to be either complete or accurate. 
  • That the BTSSC will not consider the Aggie Research Campus Draft Subsequent Environmental Impact Report to be complete or accurate until the substantial discrepancies and omissions identified in Appendix F – Transportation Impact Analysis are remedied.
  • That the BTSSC  recommends that neither the Planning Commission nor the City Council certify any Aggie Research Campus Environmental Impact Report until the Transportation Impact Analysis is both complete and accurate.

Thank You

Thank you to all the BTSSC members for your consideration of this detailed and holistic analysis of the SEIR Transportation Impact Analysis.

I am available to review the detailed spreadsheet with its 14 different scenarios with any individual (or non-quorum group of) BTSSC member.


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About The Author

Matt Williams has been a resident of Davis/El Macero since 1998. Matt is a member of the City's Utilities Commission, as well as a former Chair of the Finance and Budget Commission (FBC), former member of the Downtown Plan Advisory Committee (DPAC), former member of the Broadband Advisory Task Force (BATF), as well as Treasurer of Davis Community Network (DCN). He is a past Treasurer of the Senior Citizens of Davis, and past member of the Finance Committee of the Davis Art Center, the Editorial Board of the Davis Vanguard, Yolo County's South Davis General Plan Citizens Advisory Committee, the Davis School District's 7-11 Committee for Nugget Fields, the Yolo County Health Council and the City of Davis Water Advisory Committee and Natural Resources Commission. His undergraduate degree is from Cornell University and his MBA is from the Wharton School of the University of Pennsylvania. He spent over 30 years planning, developing, delivering and leading bottom-line focused strategies in the management of healthcare practice, healthcare finance, and healthcare technology, as well municipal finance.

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11 thoughts on “Guest Commentary: Public Comment to the BTSSC – “The ARC SEIR Transportation Impact Analysis is neither adequate nor complete””

  1. Doby Fleeman

    Much of this email appears to be addressing the cumulative failure of the City, County and CalTrans to adequately plan for and construct the necessary arterial infrastructure (I-80) improvements to support the continued growth of the University, City of Davis, neighboring cities and counties, together with decade over decade growth in commuter traffic between the Capitol and Bay Area.

    I’m no expert on traffic analysis, but key impingements you identify in this email appear directly related to absorption rates on I-80.   Given the multiple agencies responsible for addressing these regional needs, it seems unreasonable to hold hostage a desirable, long-identified development prospect because of our previous failure to make such investments.   Given the extended duration for full build-out, one would hope the necessary additional investments – both in high-speed rail as well as I-80 improvements – will have been completed well in advance.

    If anything, maybe the projects approval would light a fire under the City to accelerate progress both of these important long term initiatives – high speed rail and aterial widening.

    1. Matt Williams Post author

      Doby said . . . “I’m no expert on traffic analysis, but key impingements you identify in this email appear directly related to absorption rates on I-80.”

      That is my take as well Doby.  Which makes the omission by Fehr and Peers of the two eastbound I-80 on-ramp intersections from their traffic counts all the more puzzling.  With that said, I too am no expert.  However, the data itself talks, and being an expert is not one of the prerequisites to listening.

      Doby further said . . . “Much of this email appears to be addressing the cumulative failure of the City, County and CalTrans to adequately plan for and construct . . .”

      In my opinion this statement is by far and away the most important on in Doby’s comment.  Our most conspicuous failing is the lack of regional planning.  It will come as no surprise to anyone who has read my past comments here in the Vanguard that I would add UC Davis to Doby’s list.  UCD is the largest creator of impacts, both positive and negative, in the Yolo/Davis region.  I would also add Valley Clean Energy to Doby’s list.  The strictly compartmentalized method of planning that we have used for decades is an obstacle in today’s economy (pre-COVID-19), and will be even more of an obstacle as we emerge from the COVID-19 crisis and examine the wreckage it has wrought.

      Doby also said . . . “it seems unreasonable to hold hostage a desirable, long-identified development prospect because of our previous failure to make such investments.”

      I can hear Bill Marshall groaning when he read that part of Doby’s comment.  The reason Bill would groan, is that an EIR is a disclosure document, not a decision document.  A decision process can hold something hostage, but a disclosure process can not.  My comments to the BTSSC made observations on the completeness and adequacy of the disclosure specifically within the ARC SEIR.  I refrained from making any subjective statements about the project decision.

      I don’t think anyone can disagree with my belief that the omission of traffic counts for the two I-80 eastbound on-ramps was a failure in both the completeness and the accuracy of the disclosure.  The good news is that it is a 100% fixable failure.  Conducting a new count that includes those two intersections (making 25 intersections total) will address that completeness and adequacy issue.

      If Fehr and Peers is going to complete a recount of the intersections, including the Alhambra – Fifth Stree and Alhambra – Loyola intersections (making 27 intersections total) is very easy to do, and doing so will help illuminate the incremental traffic impact on those close-by residential neighborhoods.  In my opinion, that simply amounts to good disclosure.

      Points 3 and 4 of my comment to BTSSC may be easy for staff and Fehr and Peers to address.  The data is what the data is, and it is the data that they provided me.  Understanding what the data is saying, and why the data discrepancies exist is again a disclosure issue.

      Back when I grew up in Philadelphia, one of the local radio stations WDAS had a disc jockey named Butterball who hosted a Friday night dance party every Friday night at rotating locations.  The slogan Butterball very frequently shouted out over the airwaves was, “Choice, not Chance, at a Butterball Dance!!!”  I’m going to pirate Butterball’s slogan and say “Doby, it’s Disclosure, not Hostage Taking, at an EIR dance.”

      My personal opinion is that any hostage taking will have to wait until after the ARC SEIR is certified by City Council as adequate and complete.

       

       

      1. Mark West

        Matt W. “Our most conspicuous failing is the lack of regional planning.”

        So, why is it that we don’t have regional planning? Is it perhaps because the current system is what was defined by the State? Does the City even have the option of taking a regional approach here? The project proposal was submitted to the City for development as part of the City of Davis, not as part of some nonexistent regional authority.

        The same basic question applies to your concerns about the EIR and the supporting studies. Is the answer to your complaints of missing analyses simply that they are not required? I expect that the consultants understand the requirements better than any of us here.

        1. Matt Williams Post author

          I really, really like the questions that Mark poses in his first paragraph.  I’m going to leave it to Doby Fleeman to weigh in with thoughts on those questions.  He is better qualified to answer those questions than I am.

          Regarding Mark’s second paragraph.  None of the four concerns I formally submitted in my memo are about missing analyses.  Concern #1 and Concern #2 both have to do with missing data collection.  It is hard to analyze data that isn’t collected.   Concern #3 isn’t about a missing analysis.  It is a concern about the Fehr and Peers-provided end result in their own analysis that does not tie to their own source data.  When the checking account balance your bank provides you does not balance to the sum of the detail transactions, does that concern you?

          Bottom-line, really good questions Mark. Keep them coming

    2. Alan Miller

      DF, I imagine you mean an improved Capitol Corridor.  High-speed rail is not slated to ever pass through Davis.  Improvements to the Capitol Corridor such as electrification, separation of freight traffic, increased frequencies and higher top speeds, are in and of themselves decades in the future — the agreement with the railroad is maxed-out on frequencies.  A few more frequencies are possible with improvements by the state, but even that is years in the future.  An improved schedule is possible in a nearer future.  When people will feel comfortable traveling by train again — an open question.

    3. Richard McCann

      Doby

      That’s a possibility, but we may need to ensure a guarantee from someone, be it the City or the developer, that pursuing a solution is the top priority rather than just exacerbating the problem further than just hoping that this action inspires action from someone else. WE are the City, so WE should ask that our civil servants act to solve this problem. This isn’t going to be solved by aliens from another planet.

    1. Matt Williams Post author

      No David, explicitly I did not; however, I was very clear in my request(s) for the Excel file to Sherri Metzger and Ash Feeney what I was going to do with the data.  They made no effort to contact me.  They simply sent the Excel files.

      Then the notice of the scheduling of the BTSSC meeting came up so suddenly that I barely had enough time to complete the “bare metal” analysis and get it to staff, the traffic engineers and the BTSC members with at least 24 hours to review the memo and the tables it contains.  I ended the memo with the following statement, ”
      “I am available to review the detailed spreadsheet with its 14 different scenarios with any individual (or non-quorum group of) BTSSC member.”  To date, no one other than Todd Edelman has taken me up on that offer, no BTSSC member other than Todd, no staff member and no traffic engineer.  So you may want to ask the traffic engineers the same question.

      With that said, my past experience with contacting City consultants has been (almost) universally consistent.  Their answer to a direct contact request from a member of the public is “The City is my customer/client.  I can’t talk to you without their permission.”

      With all the above said, I do know the limits of my knowledge, experience, training, and I have absolutely no hesitation in reaching out to experts in whatever field is on the table.  And in this case I reached out multiple times to a professional engineer with extensive experience in both public agencies and traffic engineering.

      He/she gave me feedback on all four of my concerns.  His/her thoughts on my concerns #3 and #4 was that I was applying fiscal balancing criteria to traffic data,and that the industry standard for “data balancing” within the traffic engineering industry does not rise to the standard of the accounting industry.

      With his/her thoughts in mind, I found myself guided by the great sage Michael Jordan, who was the first person I heard say “Never up, Never in.”  Although for our younger readers, that advice could come from Steph Curry.  So I left it to the traffic engineers and staff to explain why the identified discrepancies are okay based on Traffic Engineering Industry Standards.

      His/her thoughts on my concern #1 was that there was no understandable reason for the two omissions.

      His/her thoughts on my concern #2 was that it fell into the “nice to have with 20/20 hindsight.”  He/she agreed that it would be very easy to add those two intersections in any effort that adds the concern #1 intersections.

      Bottom-line, i did talk to traffic engineers, just not “the” traffic engineers.

       

       

      1. David Greenwald

        Matt – in my view, you should have had a conversation with either them prior to sending the letter. That way you could have seen what the city’s thoughts were and figure out if you were missing something. Neither Sherri nor Ash at this point are going to be proactive, but they will be responsive. The risk of doing it this way, is it simply gets disregarded which it was whereas if you had sat down with them (by phone these days), you would have had a better chance to see if you really did catch an error or shortfall in the process.

        1. Matt Williams Post author

          I respect your view David, and since the same analysis is going to the Planning Commission as part of their 4/22 meeting, I will reach out to Sherri and share your advice.  If the City chooses to disregard your advice, as well as my reiterated willingness to hear anything Fehr and Peers and/or staff have to say about my observations, then that is a pretty clear message.  I will CC you on the e-mail I send to Sherri.

          Thank you for sharing your observation.  We will see where it takes us.

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