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Home My WebLink About04-21-21 Public Comment - K. Wilson - Whole FoodsFrom:Mary Bomar To:Sarah Rosenberg; Agenda Cc:Kim Wilson Subject:Whole Foods, Application 20412 Date:Wednesday, April 21, 2021 10:09:26 AM Attachments:Rosenberg 4-21-21.pdf CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Good morning, Please find attached a letter of today’s date from Kim Wilson. A hard copy will follow in today’s mail. Thank you. Mary BomarLegal Assistant Morrison, Sherwood, Wilson & Deola, PLLP401 North Last Chance Gulch P.O. Box 557Helena, Montana 59624 Phone: 406-442-3261Fax: 406-443-7294 Mary@mswdlaw.com This e-mail message is PRIVILEGED AND CONFIDENTIAL communication and is transmitted for the sole and exclusive use of the named addressee(s). Thiscommunication may not be copied or disseminated except as directed by the named addressee(s). If you receive this communication and you are not a named addressee,please notify us immediately. In such an event, you may not retain a copy of this communication, or any part thereof, and may not retain, preserve, divulge or use in anyway whatsoever any of the information contained or transmitted herein. Morrison Sherwood Wilson Deola pup MS WD Robert Farris-Olsen Andree Larose Scott Peterson Anne E, Sherwood John M. Morrison Frederick F. Sherwood David K. W. Wilson, Jr. Linda M. Deola Brian J. Miller Attorneys at Law 401 North Last Chance Gulch P.O. Box 557, Helena, Montana 59624-0557 www.mswdlaw.com (406) 442-3261 (406) 443-7294 FAXkwLlson@mswdlaw.com April 21, 2021 Ms. Sarah Rosenberg City of Bo2eman Dept, of Community Develop. P. O . B o x 1 2 3 0 Bozeman, MT 59771 srosenberglfdbozeman.net agenda(5ibozcman.net Whole Foods, Application 20412Re; Dear AIs. Rosenberg: Irepresent Bozeman Matters, agroup of citizens who love their community and who want to see it thrive, but are increasingly concerned with the unchecked growth of Bozeman and Gallatin County. They have asked me to submit these comments on the Whole Foods application on their behalf, ptu'suant to the Notice of Site Plan Application giving members of the public until April 22"*^' to comment. Attached hereto are memos in support of our comments from Greenlight Flngineering, concerning trafﬁc and transportation issues; and HydroSolutions, concerning water quality and related issues. The Bozeman Development Code contains detailed application requirements. Section 38.230.100 (6)(a) speciﬁcally requires conformance with the transportation facilities and design provisions of Section 38.400, including provisions addressing the impact of the proposal on existing and anticipated trafﬁc and parking, pedesttian and vehicular ingress, egress and circulation and adequate connection and integration of transportation systems with adjacent developments and the general community. As Mr. Nys’ report demonstrates, the trafﬁc impact study (TIS) submitted by the developer’s consultant contains numerous errors and omissions and fails to meet all the requirements of Section 38.400 of the Code. Idirect you to Mr. Nys’ report for details, but his Executive Summary highlights the following issues: 1 ●At least two intersections fail to meet City of Bozeman Municipal Code (“BMC”) level of sendee standards with no mitigation proposed, in violation of City requirements. ●The trip generation presented in the TIS is not based upon industry standard and signiﬁcantly underestimates the trips generated by the project. ●Several intersections required for analysis were omitted from the TIS. ●The existing trafﬁc signal timing was not used in the analysis of the Main Street/College intersection, ensuring that the TIS's analysis of that intersection and queuing into the roundabout is not reliable. ●SimTrafﬁc was used to determine intersection queuing, but there is no evidence that any microsimulation caKbration was performed. ●The queuing analysis illustrates that queues from the Main Street/College Street intersection will spill into the proposed roundabout. ●The TIS has not utilized the current version of the Highway Capacity Manual as required by the BMC. ●The trafﬁc study is based on an inappropriate build-out year and fails to provide an analysis year based upon 15 years after the construction of required mitigation. ●No analysis was performed for the period of highest trip generation, the holiday season. This is important when considering the operations of the proposed roundabout. If queues extend into the roundabout and the roundabout can't circulate, then trafﬁc may spill back onto Main Street. These appear to be serious shortcomings which should be addressed by the developer and the City prior to the project being given ﬁnal approval. Turning to water management issues. Section 38.230.100 (7) requires conformance (a) compatibility to and sensitivity to the immediate environment of the site... with: and subparagraph (8) requires conformance with environmental objectives of articles 4-6 including (a) enhancement of natural environment (e.g., through low impact development stormwater features...) The attached report by HydroSolutions details several questions and concerns about the stormwater management plan proposed by the developer, as well as the general water management within the project. These issues should likewise be addressed prior to ﬁnal plan approval. Finally, Iwould note that several members of the Development Review Board raised concerns about the location proposed for handicapped parldng across amajor through street from the storefront. The City should consider taking additional steps to alleviate these concerns. 2 Thank you for the opportunity to comment on this proposal. .Sincerely, David K. W. Wilson, Jr. cc: clients. 3 HydroSolutions’ MEMORANDUM Date:April 12, 2021 David (Kim) Wilson, Attorney, Morrison, Sherwood, Wilson &Deola, PLLP, on behalf of Bozeman Matters. To: David Donohue, HydroSolutions IncFrom: Review of Gallatin Valley Mall, LLC ApplicationSubject: 1.0 Introduction HydroSolutions Inc (HydroSolutions) completed alimited review of selected reports and supplemental documents associated with the Gallatin Valley Mall LLC (GVM) Whole Foods Market Application, Bozeman, Montana regarding water, wastewater, and the adequacy of the environmental information. Ifocused my review on aspects of water quality, water quantity, stormwater management, grading, drainage, landscaping and snow management. Ireviewed selected plan sheets, details related to environmental issues, selected email correspondence, and proposed mitigation outlined in the documents. While in general, the documents reviewed contained much of the required information to meet City of Bozeman requirements, Idid identify questions regarding some analyses used in the application and provided questions where Ibelieve more explanation for the information used in the analysis is needed. Comments are organized into General Comments (Section 2.0) and Speciﬁc Comments (Section 3.0) with comments referencing speciﬁc application documents reviewed as part of the comment. 2.0 General Comments General Comment 1: Given the extensive degree of development in Bozeman, is there capacity in the City’s storm water system to accommodate stormwater runoff from this new development? Iam aware that during construction of senior housing development just to the north of GVM and behind Target, the developer was told that they could not direct water pumped seasonally from aseries of dewatering wells directly into the stormwater system because the system was near full capacity. Has the stormwater capacity issue been resolved so that GVM development water can be accommodated, as proposed? General Comment 2: All drainage area calculations used in the Stormwater design plans should be reviewed and veriﬁed by City engineers during review of the application. HELENA: 406.443.6169 |303 Clarke S1. |Helena, MT 596011 BILLINGS: 406.655.9555 |1500 Poly Dr. Suite 103 |Billings MT, 59102 www.hydrosi.com Gallatin Valley Mall -Whole Foods Application Review 3.0 Speciﬁc Comments Letter outlining development review application, prepared by Grossman Development Group, LLC (GDG) dated November 19, 2020 Comment: The existing stormwater catch basins and detention pond are inundated with groundwater. Any new development on GVM property should be contingent on bringing the entire stormwater management system on GVM property, including the existing stormwater catch basins and detention pond, up to current City of Bozeman stormwater management standards. 1) Letter outlining development review application, responses to the City’s concept review comments (dated July 28, 2020) prepared by Grossman Development Group, LLC (GDG) dated November 20, 2020 Comment: As noted under Engineering Comments, Number 3, paragraph 3, the “proposed development must satisfy the City stormwater requirements for both water quality and quantity”. GVM may wish to consider the use of agutter ﬁltration system to remove potential contaminants before they enter the watenways. Additionally, in the response, GVM states that the “proposed site plan includes agrading and drainage plan that accounts for stormwater quality and quantity.” GVM needs to further explain how the proposed development will not have anegative impact on the ineffective stormwater management system currently in operation on the rest of the mall property. 2) Comment: As noted under Engineering Comments, Number 4, the City requested complete information regarding the pipe crossing from south to north through the subject property which conveys offsite drainage and irrigation. It is not clear if this part of the proposed plan has been approved by the City, or if aseparate plan set including plan and proﬁle views have been submitted. The City should provide access to this information so that the full details can be reviewed by the public. Comment: As noted under Engineering Comments, Number 5, correspondence between Brian Heston and GVM regarding cash-in-lieu (CIL) of water rights has been ongoing. The City should provide the ﬁnal information regarding GVM water use, CIL agreement, and the volume of water used for both irrigation and in¬ store use. Comment: As noted under Engineering Comments, Number 6, the City will analyze and determine if sewer capacity is available to accommodate the project. Has the City made this determination and what is the decision? Gallatin Valley Mall Re-Development, Site Plan Application, November 20, 2020 Comment: Section D. Subsection g.. Snow Storage. Details on how snow accumulation will be managed, where it will be stockpiled, and how will road contaminants (oil, grease, solids) be prevented from moving into surface water drainages should be provided and reviewed. The existing stormwater catch basins and detention pond are inundated with groundwater. In the winter, will there be capacity for snow melt to be retained in the catch basins and detention ponds containing ice until spring thaw? The City should require that the applicant provide data and calculations demonstrating how the developer arrived at this conclusion, or provide a reference to information already submitted, reviewed, and approved by the City. 3) Comment: Section H, Landscaping. The text states that an irrigation well will be installed near the southeast corner of the Whole Foods building. However, Landscape Plans L101 and L104 show the irrigation well located in the southeast corner of the South Parking lot. The proposed irrigation well location and GVM plans for well 2021.04.12 IPage 2^^HydroSolutions Gallatin Valley Mall -Whole Foods Application Review installation should be reviewed. If more than one well is proposed, explain how exempt well separation requirements will be met, or how appropriate water rights will be obtained. Comment: Section J. Water Rights. Climate information for the Whole Foods locations used in the water usage comparisons found in Table 1, including comparisons of evaporation, monthly precipitation, and other factors between those locations and Bozeman used in reaching GVM’s conclusion should be provided. This water use analysis is sensitive to climatic variations and should be carefully considered when making CIL water rights agreements in light of changing precipitation amounts and the potential for signiﬁcant drought conditions. Gallatin Valley Mall Re-Development, Stormwater Management Design Report, Prepared by C&H Engineering, November 18, 2020 Comment: Existing Site and Stormwater Section. Given that the existing stormwater catch basins and detention pond are inundated with groundwater and not functioning as originally designed, what, if any, new impacts are expected to the existing stormwater system from this new development? 4) Comment: Groundwater Considerations Section. Groundwater elevations were measured in September 2020. The month of September is typically aperiod where we see shallow groundwater elevations dropping. In general, high groundwater is typically found during the late spring -early summer months in the Gallatin Valley alluvium. It is risky to assume that high water levels will only be approximately 1foot above the measured September groundwater level and use that assumed elevation to design the stormwater system. To avoid underestimating and assuming key input elements of the stormwater design, ﬁeld data should be collected during late spring and early summer, and areview of nearby seasonal groundwater elevation data should be completed. Signiﬁcant groundwater data have been collected from monitoring wells located at nearby contaminant sites, such as the Bozeman Solvent Site, underground storage tank (LIST) sites, car dealerships, etc., and should be reviewed as part of assessing the magnitude and timing of groundwater ﬂuctuations. This new data should then be used in completing the stormwater management plan. Comment: Retention Pond Design. As stated in the text, the retention ponds are less than 2.5 feet deep overall. Given the uncertainty regarding the extent of groundwater ﬂuctuation and high groundwater elevations, these ponds may become inundated with shallow groundwater. How will this condition affect the seasonal performance and efﬁcacy of the stormwater management system and what mitigations will be available to remedy this condition? Comment: Inﬁltration Chamber Design. The text states that falling head tests are planned in the near future to verify inﬁltration rates, which are key to an effective Stormtech inﬁltration system. Has the inﬁltration tests been completed, and if so, reported data and analysis should be provided for review. 2021.04.12 IPage 3 HydroSolutions GREENLIGHT ENGINEERING April 10, 2021 David K.W. Wilson, Jr. 401 North Last Chance Gulch P.O. Box 557 Helena, Montana 59624 RE: Gallatin Valley Mall Redevelopment Transportation Impacts Mr. Wilson, You have asked us, on behalf of your client, Bozeman Matters, to evaluate the transportation related impacts of the proposed Gallatin Valley Mall redevelopment in Bozeman, Montana. We have reviewed the November 2020 "Gallatin Valley Mall Pad Redevelopment Trafﬁc Impact Study" ("TIS") prepared by Abelin Trafﬁc Services. There are several signiﬁcant errors and omissions in the TIS that make it unreliable and not compliant with City of Bozeman and/or industry standards. Executive Summary At least two intersections fail to meet City of Bozeman Municipal Code ("BMC") level of service standards with no mitigation proposed, clearly in violation of City requirements. The trip generation presented in the TIS is not based upon industry standard and signiﬁcantly underestimates the trips generated by the project. Several intersections required for analysis were omitted from the TIS. The existing trafﬁc signal timing was not used in the analysis of the Main Street/College intersection, ensuring that the TIS's analysis of that intersection and queuing into the roundabout is not reliable. SimTrafﬁc was used to determine intersection queuing, but there is no evidence that any microsimulation calibration was performed. The queuing analysis illustrates that queues from the Main Street/Coliege Street intersection will spill into the proposed roundabout. The TIS has not utilized the current version of the Highway Capacity Manual as required by the BMC. The trafﬁc study is based on an inappropriate build-out year and fails to provide an analysis year based upon 15 years after the construction of required mitigation. No analysis was performed for the period of highest trip generation, the holiday season. This is important when considering the operations of the proposed roundabout. If queues extend into the roundabout and the roundabout can't circulate, then trafﬁc may spill back onto Main Street. 13554 Rogers Road ●Lake Oswego, OR 97035 w w w. g r e e n l i g h t e n g i n e e r i n g . c o m ● 5 0 3 . 3 1 7 . 4 5 5 9 Intersections Fail to Meet City Mobility Standard and No Mitigation is Provided Bozeman Municipal Code Section 38.400.060(B)(4) requires: "All arterial and collector streets and intersections with arterial and collector streets shall operate at aminimum level of service "C" unless speciﬁcally exempted by this subsection. Level of service (LOS) values shall be determined by using the methods deﬁned by the most recent edition of the Highway Capacity Manual. Adevelopment shall be approved only if the LOS requirements are met in the design year, which shall be aminimum of 15 years following the development application review or construction of mitigation measures if mitigation measures are required to maintain LOS. Intersections shall have aminimum acceptable LOS of "C" for the intersection as awhole..." According to Table 2, 4and 6of the TIS, the intersection of Main Street/West approach will operate at LOS F. The TIS inexplicably offers no mitigation to this situation, in clear violation of the BMC. According to Table 6of the TIS, the intersection of Main Street/College Street will operate at LOS D. The TIS states "The results of this analysis suggest that future trafﬁc volume growth in this area may cause the intersection of Main Street and College Street to fall to LOS Dduring the PM peak hours...This issue could be correct [sic] with modiﬁed signal timing if needed." As required by the BMC, the intersection must be mitigated. The TIS provides no analysis of this "modiﬁed signal timing" so there is no way to know if this mitigation is feasible or not. The City of Bozeman has no jurisdiction over the signal timing of the failing intersection. While modiﬁed signal timing may be an acceptable solution, this modiﬁed signal timing has not been evaluated. There is no evidence that MDT would agree to signal timing changes as mitigation or that signal timing changes are feasible. We obtained the existing signal timing data from MDT. It is important to note that the intersection of Main Street/College Street operates in coordination with other trafﬁc signals along the Main Street corridor. Signal timing changes may necessitate changes to other intersections along the Main Street corridor that have not been studied as part of the TIS. The TIS is Based on Trio Generation That Does Not Comply with Industry Standard Table 3of the TIS reports the estimated trip generation of the proposed development. The table reports that the the proposed development will generate 43 trips in the weekday AM peak hour, 175 trips in the weekday midday peak hour and 175 trips in the weekday PM peak hour. None of these trip generation estimates are in compliance with industry standard. The ITE Trip Generation Manual presents trip generation data based upon average trip rates and ﬁtted curve rates. The ITE Trip Generation Handbook provides criteria for the practitioner to use of the average rate versus the ﬁtted curve rate. All of the trip generation estimates provided in the TIS are inappropriately based upon the average trip rates rather than the ﬁtted curve rates. 2 The 3'‘‘ edition of the ITE Trip Generation Handbook instructs apractitioner to use the ﬁtted curve rate when "A ﬁtted curve equation is provided and the data plot has at least 20 data points." In the case of the weekday AM peak hour and weekday PM peak hour, aﬁtted curve equation is provided and has more than 20 data points. As such, the ﬁtted curve rate should be used. As Table 1illustrates, the TIS substantially underestimates the trip generation of the proposed development. Table 1. Shopping CenterTrip Generation of Fitted Curve vs. Average Trip Rates Size (ksf)Trip Rate Methodoiogy A M P e a k H o u r E n t e r E x i t P M P e a k H o u r To t a l E n t e r E x i tTota 159Fitted Curve Trip Generation 45.8 175 108 67 305 146 Average Rate Trip Generation (Used in T[^43 26 84 9145.8 17 175 Difference in Trips 132 82 50 130 62 68 ^Trip Generation Manual, 10"' Edition The TIS underestimates the trip generation of the development by 132 trips in the weekday AM peak hour and by 130 trips in the weekday PM peak hour. There is acompletely different issue associated with the weekday midday trip generation. The midday trip generation presented in the TIS is based upon ITE Trip Generation Manual data for the weekday PM peak hour. The use of this PM data to estimate midday trips is not supported by evidence or by the industry standard methodology of the ITE Trip Generation Manual or Trip Generation Handbook. The Trip Generation Handbook would direct the practitioner to collect trip generation data at three to ﬁve similar sites during the weekday midday peak hour in order to develop atrip generation rate for the weekday midday peak hour. Lastly, the TIS states that "Projected pass-by trips were calculated using the information from the ITE Trip Generation Manual for shopping centers #820 (44%)." The Trip Generation Manual provides no pass-by trip information, but that information is found in the Trip Generation Handbook. However, this manual does not provide that a44% pass-by trip rate should be used for shopping centers. The ITE Trip Generation Manual provides apass-by trip rate of 34% for use during the weekday PM peak hour only. Applying a44% pass-by trip rate to any time period is inappropriate. The TIS incorrectly estimates pass-by trips. The Study Area Does Not Meet City Requirements The BMC requires astudy area that includes "All arterial-arterial, collector-collector and arterial- collector intersections within one-half mile of the site, or as required by the city engineer during the pre-application review, concept plan review, or informal project review." The TIS notes that "Based on the City of Bozeman Subdivision Regulations, the developers must study all effected intersections within %mile of aproposed development." The TIS evaluates no offsite intersections ignoring the requirement to study applicable intersections within %mile of the site. Instead, the TIS studies only two of the three site driveway intersections. Figure 1below illustrates the intersections within 'A mile of the site. 3 After review of Figure 2.5 of the Bozeman Transportation Master Plan, it is clear that the BMC requires the analysis of at the least the following additional intersections: ●Main Street/Fowler Avenue ●Fowler Avenue/Babcock Street ●Fowler Avenue/Garﬁeld Street ●College Street/23"‘* Avenue Figure 1: Intersections within one-half mile of the site As noted above, the TIS substantially undercounts the trip generation of the proposed development. Even with appropriately accounting for trip generation, the exclusion of nearby intersections from analysis deﬁes logic. Additionally, the study area is required to include "All major drive accesses that intersect collector or arterial streets or roads." The easternmost access to the is excluded from the TIS. 4 strangely, even though the development will generate 3,535 daily trips, 175 weekday AM peak hour trips, 305 weekday PM peak hour trips, and 334 Saturday peak hour trips, no intersections were analyzed other than two of the site access points. 7/5 is Not Based on Existing Signal Timing As mentioned previously, we obtained the existing signal timing at the Main Street/College Street intersection from MDT as we would when performing any trafﬁc impact analysis. It is abundantly clear that the existing trafﬁc signal timing was not utilized in the TIS and there was not an attempt to accurately replicate trafﬁc signal timing parameters. It is common practice to base atrafﬁc analysis on existing trafﬁc signal timing. By not utilizing the existing trafﬁc signal timing, it ensures that the results of the TIS do not reﬂect real world conditions and should not be relied upon. None of the operational analysis at the Main Street/College Street intersection should be accepted. TIS Relies on Microsimulation Model Without Calibrating The TIS relies on amicrosimulation model, SimTrafﬁc, to determine intersection queuing. There is no evidence that any calibration was performed as is necessary in order to provide areliable analysis. The TIS makes no reference to calibration of their microsimulation model. In fact, there is evidence that calibration was not performed as it is clear that not even the existing signal timing was utilized in the analysis. The Federal Highway Administration (FHWA) document Trafﬁc Analysis Toolbox Volume III: Guidelines for Applying Trafﬁc Microsimulation Modeling Software states that "...without calibration, the analyst has no assurance that the model will correctly predict trafﬁc performance for the project. Calibration is the adjustment of model parameters to improve the model's ability to reproduce local driver behavior and trafﬁc performance characteristics. Calibration is performed on various components of the overall model...The importance of calibration cannot be overemphasized..." In Oregon, the Analysis Procedures Manual states that "Good calibration is...critical for accurate analysis...Although calibration (ﬁne-tuning) may take some time, it is necessary because if the existing conditions is not duplicating observed conditions, then the future conditions or build alternative performance will not be predicted very well." As noted earlier, the existing trafﬁc signal timing was not utilized in the analysis. SimTrafﬁc, a microsimulation software, requires accurate input parameters in order to deliver accurate results. It is clear that given that not even existing trafﬁc signal timing parameters were utilized that the input parameters are of sufﬁcient quality and detail to result in an accurate microsimulation. For this reason, the SimTrafﬁc software should not have been used and the SimTrafﬁc results should not accepted. Queuing from Main Street/Colleae Street Intersection Will Soill Into Proposed Roundabout Regardless of the quality of inputs into the SimTrafﬁc queuing analysis, the TIS illustrates that queues from the Main Street/College Street intersection will spill into the proposed roundabout. 5 The TIS states: "vehicle queues backing up from the trafﬁc signal at Main Street could potentially stop vehicles within the roundabout and impair the roundabout operations. The worst-case scenario under this condition would be if the roundabout became inoperable due to the southbound vehicle queue at Main Street and vehicles could no longer enter the Mall from the Main Street approach, potentially backing trafﬁc into Main Street, which would be extremely undesirable." We agree this situation would be extremely undesirable and should be avoided at all costs. According to the site plan, the construction of the roundabout would reduce available queue storage measured from the Main Street/College Street crosswalk to the roundabout from approximately 175 feet to approximately 155 feet. Table 7of the TIS establishes that southbound queues at the Main Street/College Street intersection will exceed 200 feet and spill into the roundabout. The analysis is based solely on an average weekday AM, midday and PM peak hour. Under those conditions, there is little room for error. At the point where queues extend into the roundabout, movement cannot occur through the roundabout, creating asituation where queues may extend back to Main Street. As established earlier, the analysis of the Main Street/College Street intersection and the queues generated at the intersection are not reliable for several reasons, so the queue analysis should not be accepted. The trip generation presented in the TIS is not based upon industry standard and signiﬁcantly more trafﬁc than analyzed will be generated by the proposed development. The trafﬁc impact study is not based upon the current trafﬁc signal timing at the Main Street/College Street intersection. Lastly, it does not appear that the microsimulation model was calibrated. Consideration should be given to evaluating the peak mall conditions in the context of determining the adequacy of the roundabout solution on-site as this solution may have a detrimental effect on Main Street. Once this development is constructed, there is likely very little MDT or the City of Bozeman can do if queues do extend onto Main Street. No analysis was performed for highest trip generation time period, the holiday season. At aminimum, the Saturday peak hour should be considered, as shopping centers typically generate more trafﬁc during the Saturday peak hour than the weekday PM peak hour. Trafﬁc queuing onto Main Street would be highly undesirable and possibly unsafe. It is likely that the existing internal intersection conﬁguration, which favors trafﬁc entering from Main Street, will not ever queue trafﬁc onto Main Street, while the proposed roundabout could very well create this situation. While the proposed roundabout may improve operations for those within the mall, it may worsen operations for the traveling public. The Analysis is Not Based Upon the Current Version of the Highway Capacity Manual BMC 38.400.060(B)(4) requires the trafﬁc analysis to be based upon the "...most recent edition of the Highway Capacity Manual..." The 6*'’ edition is the current version of the Highway Capacity Manual ("HCM"). It is clear that the trafﬁc analysis is not based upon the 6**’ edition of the HCM. Appendix Cof the TIS very clearly illustrates that at least portions, possibly all, of the analysis are 6 based upon HCM 2010, the previous version of the Highv\/ay Capacity Manual, which was phased out in 2016. TIS is Based Upon InaDoroDriate Build-Out Year and Underestimates Trafﬁc BMC Section 38.400.060(B)(4) states that "A development shall be approved only if the LOS requirements are met in the design year, which shall be aminimum of 15 years following the development application review or construction of mitigation measures if mitigation measures are required to maintain LOS." As at least two intersections will require mitigation, the TIS must be updated for aperiod of 15 years following the construction of that mitigation. The TIS assumes that the development will be occupied in 2021, but given the current state of the application, occupancy in 2022 is far more likely. Assuming that the development is constructed and mitigation would be implemented in 2022, the BMC requires an analysis based on the year 2037. The TIS reports that "Historic trafﬁc data was obtained from MDT to review the growth trends on Main Street and College Street. Trafﬁc volumes along these road segments has increased 3% annually over the last ten years." It is important to account for the additional trafﬁc growth that is expected to occur. TIS Provides No Evidence of How 2035 Volumes Were Generated The TIS states that "In order to evaluate the 15-year trafﬁc volume projections for this area, [Abelin Trafﬁc Services] reviewed the 2040 trafﬁc volumes from the Bozeman Transportation Master Plan and scaled the anticipated trafﬁc volume growth to likely 2035 conditions using a trafﬁc volume growth rate of 23% for the study intersections." The TIS provides no evidence of the 2040 trafﬁc volumes from the TSP nor provides any information about how a23% growth rate was determined. This calculation cannot be reviewed or replicated. There are Numerous Issues with the Trafﬁc Counts As evidenced by Appendix Aof TIS, atrafﬁc count was conducted at the internal mall intersection where the roundabout is proposed in October of 2020. It does not appear that any adjustments were made to account for decreased trafﬁc associated with the COVID-19 outbreak. As reported in the TIS, trafﬁc volumes collected in 2020 were rejected from use based upon the impact of the COVID-19 outbreak. It seems incredibly likely that the COVID-19 pandemic has reduced trafﬁc within the mall and the count collected in October 2020 is not representative of normal conditions. The trafﬁc impact study fails to rely upon peak hour factors collected in the ﬁeld in performing the trafﬁc operations analysis, but instead relies upon assumed peak hour factors not based on any evidence. Peak hour factors do have an impact on intersection capacity analysis and may affect the LOS of study intersections. 7 The trafﬁc impact study references trafﬁc counts that were collected at the westernmost driveway September 2020. However, the trafﬁc impact study provides no evidence that these trafﬁc counts were performed. Trafﬁc impact studies typically include the raw trafﬁc count sheets, yet none were included. Of the trafﬁc counts that were provided in the TIS, the counts failed to include trucks, buses, pedestrians or bicycles. All of these users of the transportation system can have an effect on the intersection operational analysis and are inputs of the Highway Capacity Manual methodology. The Roundabout Geometries are Poor The roundabout geometries are poor. In his December 29, 2020 memorandum, Karl Johnson with the City of Bozeman asks the applicant to "Provide clariﬁcation of turning movements through the roundabout. Is northbound trafﬁc off of Hufﬁne required to turn east?...It may be advisable to create more deﬂection northbound into the roundabout and limit the southbound exist to 1lane." As evidenced on the November 16, 2020 "Site Plan South," the roundabout has poor geometries with the northbound travel lane oriented not towards the circulatory roadway, but to the median located on the east approach. Synchro May Not Be Ideal Tool for Analyzing Roundabouts There is some evidence that the use of Synchro is not an ideal tool for evaluating roundabouts. Oregon's Analysis Procedures Manual states "Synchro roundabout analysis is also limited. Supplemental analysis of roundabouts either with SIDRA, Vistro or amanual method is necessary to obtain valid results." 8 Conclusion The TIS contains anumber of errors and omissions that result in inconsistency with City of Bozeman requirements or industry standard. The TIS establishes that intersections will not meet the city mobility standard, yet no mitigation is proposed. The TIS relies on trip generation that is not based on industry standard or supported by evidence, and results in an under counting of the trips generated by the proposed development. The analysis is not based upon the existing signal timing and the intersection analysis cannot be relied upon. There is evidence that queues at the Main Street/College Street intersection will queue into the proposed roundabout. Should you have any questions, feel free to contact me at 503-317-4559. Sincerely, Rick Nys, P.E. Principal Trafﬁc Engineer .★'●.● ●● RICHARD M. NYS No. 59700 PE 9