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Home My WebLink About01-03-25 Public Comment - N. ten Broek - Traffic Study The Guthrie application (#24493)From:Noah ten Broek To:Bozeman Public Comment Subject:[EXTERNAL]Traffic Study The Guthrie application (#24493) Date:Tuesday, December 31, 2024 3:08:00 PM Attachments:Guthrie TIS Review Greenlight 7-5-24 (1).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. Dear City, Please find applicable and relevant traffic studies attached to this email. Best regards, Noah ten Broek July 5, 2024 Bozeman City Commission 121 N Rouse Ave Bozeman, MT 59715 RE: Application 23354 - The Guthrie Transportation Impacts Commissioners: Greenlight Engineering has been asked to evaluate the transportation related impacts of the proposed “The Guthrie” development in Bozeman, Montana. We have reviewed the November 2023 “The Guthrie Traffic Impact Study” (“TIS”), the January 26, 2024 TIS addendum (“TIS addendum” and the April 29, 2024 TIS addendum #2 (“TIS addendum #2”). It is clear that the application is not compliant with City of Bozeman requirements. 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. There is no evidence that the unmitigated failing intersections will operate safety. Critical intersections required for analysis were omitted from the TIS and TIS addendum. Intersections Fail to Meet City Mobility Standard and No Mitigation is Provided BMC Section 38.400.060(B)(4) requires: “All arterial and collector streets and intersections with arterial and collector streets must operate at a minimum level of service "C" unless specifically exempted by this section. The city determines level of service (LOS) values by using the methods defined by the most recent edition of the Highway Capacity Manual. The review authority may approve a development only if the LOS requirements are met in the design year, which must be a minimum of 15 years following the development application review or construction of mitigation measures if mitigation measures are required to maintain LOS. Intersections must have a minimum acceptable LOS of "C" for the intersection as a whole. a.Exception: If an intersection within the area required to be studied by section 38.220.060.A.12 does not meet LOS "C" and the intersection has been fully constructed to its maximum lane and turning movement capacity, then an LOS of less than "C" is acceptable b.Exception: The review authority may grant a waiver from an LOS of less than "C" at a specific intersection if the review authority determines: (1)Granting a waiver for the intersection would not be contrary to public 13554 Rogers Road ● Lake Oswego, OR 97035 www.greenlightengineering.com ● 503.317.4559 health and safety and is in the public interest; (2)Improvements to the intersection to raise the overall level of service to a "C" or better are currently scheduled for commencement of construction within three years as shown on the most recently adopted Transportation Capital Improvement Plan; (3)All rights-of-way necessary for the required intersection improvements have been obtained by the city or by the Montana Department of Transportation; and (4)The commission has approved a financing plan for the intersection improvements. The TIS reports: “The Future (2038) capacity calculation results were very similar to the Existing Conditions (2023) results, with all intersections and approaches projected to continue to operate at LOS C or better during both peak hours with the exception of the intersections of West Villard Street and West Beall Street with North 7th Avenue, which are expected to operate at LOS D of (sic) worse on the minor legs during both peak hours.” Figure 6 of the TIS and TIS addendum clearly illustrate that the intersections of N 7 th Avenue/W Villard Street and N 7th Avenue/W Beall Street are both projected to operate at LOS F, two letter grades below the existing operations of LOS D. The TIS discusses possible mitigation to these failing conditions, but does not provide any traffic analysis that supports possible mitigation and argues against providing any mitigation. Without mitigation, the application clearly fails to comply with the BMC that requires all intersections to operate at LOS C or better. Therefore, the application must be denied. The TIS states: “The intersections of North 7th Avenue/West Villard Street and North 7th Avenue/West Beall Street are anticipated to operate at substandard LOS on the east and west legs during the AM and PM peak hours. The additional (sic) of a dedicated left-turn lane on West Villard Street and right and left-turn lanes on West Beall Street are not expected to result in a significant capacity improvement. The installation of a two-way left-turn lane (TWLTL) on North 7th Avenue would have a larger improvement in delay by permitting two-staged left-turns from the minor legs. This would require major reconstruction to North 7th Avenue and is not an easily feasible solution. It is likely that when volumes are high on North 7th Avenue during the AM and PM peak hours, vehicles attempting to make a left-turn from the minor legs will reroute to a signalized intersection if excessive delay is experienced. Restrictions to West Villard Street and West Beall Street minor legs could also be considered in the future to improve minor leg operations; however, this change would greatly impact the connectivity of the neighborhoods. Minor leg volumes at both deficient intersections are low and would not warrant the installation of a signal unless a safety concern arises in the future.” While the TIS suggests what shouldn't be done at these intersections, the TIS and TIS addendum fail to provide any traffic analysis evaluating any potential mitigation at these failing intersections, so it is unclear how the intersections would operate with the mitigation discussed. 2 There are also likely many other mitigation options not discussed that could be explored that were not apparently evaluated. The TIS notes that a TWLTL would have a larger improvement on delay than alternative solutions, but neither the TIS nor TIS addendum actually provide traffic capacity analysis of this alternative. The TIS notes that such mitigation would be expensive, yet that is not a criteria for an exception. The BMC states that an exception to the LOS requirement may be granted “If an intersection within the area required to be studied by section 38.220.060.A.12 does not meet LOS "C" and the intersection has been fully constructed to its maximum lane and turning movement capacity, then an LOS of less than "C" is acceptable.” However, this is not the case. It is clear based on the TIS that a TWLTL would likely be expensive, but the expense of an improvement doesn't absolve the applicant of complying with city approval criteria. There is no evidence that other exceptions have been evaluated or granted. BMC 38.220.060.A.11.g.2.d requires that “The report must include the following information...For two-way stop controlled intersections, analysis of whether the intersection would satisfy signalization warrants if the two-way stop control was removed.” As discussed above, at least two of the two-way stop controlled intersections in the study area fail to meet the City of Bozeman's LOS standard, yet even the failing intersections were not analyzed for traffic signals as clearly required by the BMC. The TIS notes that “Minor leg volumes at both deficient intersections are low and would not warrant the installation of a signal unless a safety concern arises in the future.” However, the TIS and TIS addendum fail to provide any evidence that traffic signal warrants were analyzed. It is also important to note that not all of the Manual on Uniform Traffic Control Devices traffic signal warrants are dependent on the volume of the minor street. The TIS speculates that “It is likely that when volumes are high on North 7th Avenue during the AM and PM peak hours, vehicles attempting to make a left-turn from the minor legs will reroute to a signalized intersection if excessive delay is experienced.” There is no evidence that drivers will reroute as suggested in the TIS. Rerouting to different intersections creates additional delay for drivers and many drivers will not be aware of the delay at the intersection until such time they observe the delay at the intersections. Use of other intersections also creates additional delay at those intersections that has not been evaluated. If this rerouting is likely to occur, then the TIS or TIS addendum should have provided analysis of those impacts and illustrated that all study intersections operate acceptably rather than relying on speculation without evidence. The TIS notes that “Restrictions to West Villard Street and West Beall Street minor legs could also be considered in the future to improve minor leg operations; however, this change would greatly impact the connectivity of the neighborhoods.” The intersections clearly fail, so it is unclear why improvements to the intersection “be considered in the future to improve minor leg operations” when the BMC clearly requires 3 improvements in order for the application to be approved. Additionally, if this mitigation is feasible and recommended, the TIS or TIS addendum should have analyzed the impacts as possible mitigation if this application is to be approved. The applicant notes that these restrictions would impact the connectivity of the neighborhoods, but don't analyze those impacts. Safety of Future Failing Intersections Not Analyzed or Considered BMC 38.220.060.A.11.h requires a TIS to “...Indicate the levels of service (before and after development) of existing and proposed streets and roads, including appropriate intersections, to safely handle any increased traffic. Describe any anticipated increased maintenance that will be necessary due to increased traffic and who will pay the cost of maintenance.” The application clearly illustrates significant deterioration of the N 7th Avenue/W Villard Street and N 7th Avenue/W Beall Street intersections with no proposed mitigation. If the City of Bozeman finds that mitigation is not required at these intersections, the applicant should illustrate that the intersections can “...safely handle any increased traffic” given the significant unmitigated capacity deterioration illustrated in the TIS and TIS addendum. The Study Area Does Not Meet City Requirements BMC 38.220.060.A.11.g.2.c.ii requires a study area that includes “A.M. and P.M. capacity analysis with an A.M. and P.M. peak-hour capacity analysis provided for...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.” Per Figure 2.5 of the Bozeman Transportation Master Plan, there are many intersections that meet the criteria to include as part of the traffic impact study, but were excluded from the TIS and TIS addendum without any explanation. Some intersections near the site that were excluded include the N 7th Avenue/Durston Road/W Peach Street and N 7th Avenue/W Mendenhall Street. Traffic Calming Analysis Lacks Evidence The TIS addendum #2 states: “Local street evaluation of impacts were requested based on existing and proposed future daily volumes of the Guthrie Development. As noted in The Guthrie TIS, November 2023, traffic data was collected on Thursday, November 2, 2023...Daily traffic volumes are estimated in 2038 to be 710 –1050 daily vehicles on 5th Avenue, 830 – 1150 daily vehicles on Villard Street, and 690 – 860 daily vehicles on Beall Street...When local streets experience greater than 1000 ADT, traffic calming measures should be considered to regulate vehicle traffic speeds and to ensure pedestrian safety. The Federal Highway Administration (FHWA) Traffic Calming ePrimer provides a toolbox of traffic calming measures to consider based on roadway characteristics, desired outcomes, and sustainability. These traffic calming measures should be reviewed for the appropriate application based on several factors including speed limits, traffic volumes, emergency routes, transit, maintenance, grade, etc. Based on the local characteristics and the challenge of both reducing vehicle speeds and providing safe pedestrian 4 facilities, a traffic circle should be considered at the 5th Avenue and Villard Street intersection based on the FHWA toolbox.” The TIS addendum #2 insinuates that whether a street has a traffic volume over 1,000 vehicles per day is the major determining factor in determining the need for traffic calming and that if a street has a traffic volume under 1,000 ADT, traffic calming measures should not be considered. Rather, the FHWA ePrimer notes that “For example, a jurisdiction could have a minimum daily traffic volume (e.g., 1,000 vehicles per day; 100 vehicles during peak hour in one direction) before consideration is given to implementing traffic calming.” The ePrimer provides an example of a possible threshold, but does not suggest or dictate this threshold. Instead, FHWA's ePrimer notes that as part of a traffic calming evaluation: “The data to be compiled throughout the affected area include some or all of the following: •“Roadway functional classification – such as local residential street, collector street with predominantly residential uses, and arterial road with commercial •Speed – posted speed, average speed and 85th percentile speed in each direction •Vehicle volume – daily and with directional splits for peak hours •Graphical representation of all traffic control devices in affected area, including signs, markings, and signals •Description of physical characteristics of roadways in affected area, including width, pavement condition, sidewalks, crosswalks, bicycle facilities, curb and gutter versus shoulder •Adjacent arterial streets – are mobility or safety problems on an arterial street contributing to the perceived local street problem or issue? •Crash data – recent by type •Parking – location and use •Pedestrian activity – volume and origin-destination patterns •Bicyclist activity – volume and origin-destination patterns •Designated emergency response routes •Transit routes and bus stops •Locations of schools, parks, senior housing, medical services, and other unique trip generators” Notably, the TIS, TIS addendum and TIS addendum #2 don't provide any evidence of the traffic counts or traffic speeds collected in reviewing the need for traffic calming in the neighborhood. 5 Conclusion It is clear that the application fails to meet City of Bozeman requirements. The TIS and TIS addendum establish that intersections will not meet the city LOS standard, yet no mitigation is proposed. The TIS and TIS addendum fail to provide evidence that the unmitigated failing intersections will operate safely. The study area of the TIS and TIS addendum are not compliant with city requirements. Should you have any questions, feel free to contact me at 503-317-4559. Sincerely, Rick Nys, P.E. Principal Traffic Engineer 6