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John Palmer
Scott Valley HOA comments on the Richardson Terrace project proposal
The following letter by the president of the Scott Valley Homeowners Association has been sent to the Mill Valley Planning Commission to comment on the upcoming hearing on November 17, 2022 on the proposed Richardson Terrace mixed-use development at 575 E. Blithedale Avenue.
Dear City Manager, Planning Director, and Members of the Planning Commission,
I am a 52-year resident of Mill Valley, and for 28 of those years, I have lived in Scott Valley, where traffic on Blithedale is a fact of daily life. I am currently the President of the Scott Valley HOA, with almost 200 homes in our constituency, and am writing this letter in that capacity with the unanimous support of its Board.
I was very active in the last iteration of Friends of Kite Hill, an ad-hoc alliance of 9 of the HOAs and neighborhood associations in the immediate vicinity of Richardson Terrace. This is the first of two letters I am sending regarding that project, this one specifically to refute some of the findings in the traffic report from WTrans.
Friends of Kite Hill, under my direction, commissioned a traffic report in 2012 from Pang Ho, who does traffic studies for many Bay Area cities (See attachment, below). When the current proposal for Richardson Terrace was set for a hearing, I re-contacted Mr. Ho, and commissioned an update (attached here), again for the benefit of our alliance, and for the benefit of the Planning Commission and anyone who may doubt, as I do, the conclusions of the WTrans Report. In addition to his report, I have attached his CV and other credentials.
Just for starters, the WTrans report based all of its findings and conclusions on traffic counts that were done in 2021, while many COVID restrictions were still in place. Obviously, with schools now in full session, youth sports activities in full swing, stores re-opened, and people returning to work in offices at least a good part of the time, there’s a lot more traffic in late 2022 than in 2021.
This fact alone should disqualify the WTrans report because as noted, all of its conclusions were based on objectively outdated data.
The comments by Dalene Whitlock of WTrans, dated 11/4, in the recently posted Staff Report addressing this issue, as raised in the letter from Mr. Kennedy, are defensive, not at all instructive, and simply ignore the obvious – that there is a lot more traffic today than a year ago. She states:
“The traffic data used for the study was obtained during a time that would reflect typical current traffic volumes. Regardless of what factors have changed traffic patterns over time, using counts obtained on a typical day is a standard approach to traffic analyses.”
In other words, her response to basing conclusions on objectively outdated information is simply to pronounce, without evidence, that traffic today is basically the same as it was a year ago when many COVID restrictions were still in place, or if it isn’t, that such increases don’t matter, even though the report’s conclusions were derived from them; she then concludes that the WTrans method, relying on outdated data and then defending its use, reflects a “standard approach.”
This response reflects faulty logic, to put it mildly. A new traffic count is needed, and all conclusions derived from the old counts should be re-examined.
I have excerpted some of the findings from Pang Ho’s report for your convenience. Numbers 1-8 below are direct quotes from Mr. Ho’s letter, then my comments resume.
- Our review indicated that the proposed site access driveways are problematic and are likely to interrupt traffic operations on East Blithedale Avenue and create unsafe traffic conditions
- The proposed access driveways on East Blithedale Avenue are problematic, particularly the eastern one. While it has adequate stopping sight distance it is too close to another driveway located less than 100 feet to the east. Additionally, there is another curb cut and a pedestrian path about 50 feet east of the proposed east driveway. All these access points could present potential conflicts and interruptions to the westbound traffic
- Motorists making a left turn out from the project site driveway will likely experience even bigger problems as they must cross traffic streams from both the east and west directions and will experience even longer delays
- While the report indicates the proposed driveways will satisfy city design standards in terms of the widths of the driveway and drive aisle, there is no mention of the driveway turn radius. Without a wider turn radius, a truck will need to slow down significantly as they enter the site and will block westbound traffic, and would likely create rear-end collisions during peak commute hours when traffic volumes are high.
- The traffic study indicated the site will be able to accommodate garbage trucks and fire trucks; please indicate/clarify whether or not these trucks would be able to turn around within the site without having to back out to East Blithedale Avenue. (This is another disqualifying deficiency)
- The vehicle queuing analysis (Transportation Impact Study page 16, ) shows that many of the turn lanes at the study intersections, particularly the East Blithedale and Camino Alto intersection, had long vehicle queues that are exceeding the storage lane capacities. This will result in vehicle queues spillover to other traffic lanes blocking traffic in both east and westbound directions. These problems need to be addressed. Because of these queuing problems, the intersection LOS analyses discussed in the Transportation Operations Study may have been unrealistically better than the actual field operations
- The intersection LOS analyses (Transportation Operations Report page 11-15) indicated that the East Blithedale Avenue/Mesa Avenue-Hilarita Avenue intersection currently operates at LOS F at one of the approaches, which is considered an unacceptable condition according to the Mill Valley City standard. The approach LOS will continue to operate at LOS F after adding the proposed 575 East Blithedale Project traffic but with even longer delays. The report, however, provides no discussion on how to address the LOS F condition.
- The traffic reports need to evaluate the two access driveways' operations and safety. They are critical as they connect the existing street system and the proposed project.
In reading the WTrans report and studying the site plan, I note there is no turnaround inside the property itself. This is extremely problematic for delivery and emergency vehicles in particular. Frankly, I don’t understand how the MV Fire Dept. signed off on this plan, and I don’t understand how large trucks are going to get out of the property once it’s filled with cars, people, bikes, and other delivery vehicles. Will they have to back out onto Blithedale?
How will that work, in practice?
At the very least, the Richardson proposal should be continued while all these deficiencies are fully re-considered, and until a new, accurate traffic count can be completed. Ideally, the project should be redesigned to provide the kind of housing the city really needs, to conform to the current Housing Element of the General Plan, which the project presently does not, and to reduce its impacts on traffic, the environment, and the aesthetic elements of its very poor design.