HomeMy WebLinkAboutAgenda Bill 1.A-Late16 04/25/2011'Prom: Katy Schardt [kbty@kbtYschardt.corn]
Se.nt*. Monday,,April 25,.,2011 3:21 PM
To - 'City' ty Clbrk
Subject: 'Deer Creek Village
Attachments: Abrams Assoc Ltr Village DEIR 04251 l.pdf
Enclosed please find a letter from Abrams Associates with comments regarding the Deer
Creek Village DEIR.
Thanks,
Katy Schardt
Katy Schardt
Compass Commercial
3262 Penryn Road, Suite 200
Loomis, CA 95650
(916) 660-9,623
katy(cD-katyschardt.com
Abrams .Associates
TRAFFIC °ENCINEERINC, INC.
April 22, 2011
To: Derek Farmer
Community Development Department
City of Petaluma
11 English Street
Petaluma, CA 94952
Re: Comments on Deer Creek
Final Environmental Impact Report (FEIR)
Abrams Associates have reviewed the Final Environmental Impact Report (FEIR) prepared for
the Deer Creek Village Project. Abrams Associates represents Syers Properties, owner of the
Plaza North Shopping Center in Petaluma. This letter is being transmitted on behalf of Syers
Properties.
Summary. This FEIR is inconsistent with CEQA regulations and should not be approved. The.
Planning Commission should not recommend certification to .the City Council. The FEIR is
incomplete, is sorely lacking in detail, and is not adequate to properly evaluate the impacts of the
Deer Creek Village Project. The traffic and transportation section of the D.EIR should be
updated and re- circulated before this EIR is approved by the City Council.
Rainier Interchange. It;s, acknowledged' by all parties 'involved. that there that there is no
funding for the Rainier Interchange, and that there is no schedule as to when it would be
completed. However the cumulative traffic forecasts: assume that the Rainier Interchange with
101 will be in place. The result is that the EIR ignores some significant transportation impacts.
There is no analysis of any future scenario where the Deer Creek Village Project will have been
completed, and the Rainier interchange is not built. There is no doubt that such a scenario would
show very significant (LOS "F ") impacts on McDowell Boulevard and East Washington Street.
As a result, there are no mitigation measures shown forihis scenario, and no mitigations have
been required of the project applicant.
Need for an Additional Scenario. The study of any scenario where the Rainier interchange is
not built is a major shortcoming of the analysis. The FEIR have a plan that would mitigate
these traffic problems. If not, a condition should,be included that.the East Washington
Development not be permitted to proceed until the construction of the Rainier Interchange
project is underway.
The summary of transportation impacts and mitigation measures is incomplete. The DEIR does
not address the LOS deficiencies that °will exist without the completion of the Rainier
Interchange. These deficiencies will be on East, Washington Street at intersections at N.
McDowell ( #1), at the Hwy 101 ramps (17 and #18), on North McDowell ( #17, #18, and #19),
1660 Olympic Boulevard, Suite 210 • Walnut Creek, Ck94$96 • 925.94'5.020.1 • Fax: 925.945.7966
Page 2 of 2 — Deer Creek Village DEIR
and on Old Redwood Hwy (#2 # 3, and #4). Each of these locations will exceed the City LOS
standards for one or more of the traffic scenarios. All of these traffic impacts have been ignored.
The traffic forecasts for the cumulative scenarios are clearly in error when compared to the
baseline data. There are many examples of this throughout the,analysis, and there is no
explanation of how the future forecasts are less than - the existing volumes. What modeling
methodology has been, used? What changes in traffic flow have been assumed when conducting
this analysis? Does this forecast assume the Rainier. interchange? Do the traffic forecasts
assume reductions in traffic due to future intermodaf projects (rail, express bus, etc.)? All of
these questions need to `be in order to complete the DEIR.
There are many other roadway. changes and improvements assumed to: be in place at the time that
the project would be. completed. This is.a serious error. The roadway projects that involve
Highway .101,.E, Washington Street and Lakeville Highway should not be assumed to have been
implemented. A suitable explanation of the status and - funding :sources needs to be provided.
Without these roadway improvement projects, there would be serious Level of Service violations
at least seven (7) of the study intersections. A scenario should be tested that does not assume
these roadway changes have been implemented:
Given the technical problems with the trip assignments and capacity calculations, it is impossible
to comment on the impacts and mitigation measures at,specific locations. There are many other
comments on traffic and transportation that need to be addressed once the above questions have
been answered.
Sincerely yours,
Charlie Abrams, Calif CE #32500, Calif TE #1417
Principal, Abrams Associates