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HomeMy WebLinkAboutResolution 4424, adopting the Transportation Impact Fee Study1 Commission Memorandum REPORT TO: Honorable Mayor and City Commission FROM: Chris Saunders Steve Worthington SUBJECT: Commission Resolution 4424 adopting the update to the Transportation impact fee study to establish methodology, and document required information to conform to statute, and determine the generalized average cost per unit of service. MEETING DATE: January 28, 2013 AGENDA ITEM TYPE: Action RECOMMENDATION: Adopt Commission Resolution 4424 adopting the updated transportation impact fee study [also known as a service area report] as presented. SUGGESTED MOTION: Having received and considered the updated study for transportation impact fees, the recommendation from the impact fee advisory committee, and having heard and considered public comment I move to approve Commission Resolution 4424 adopting the October 24, 2012 draft of the Transportation Impact Fee Study, excluding the implementation recommendation of how to calculate intersection capacity share of costs described in paragraph three on page 15; and setting an effective date to coordinate with the effective date of Ordinance 1853. Alternative Motion: Having received and considered the updated study for transportation impact fees, the recommendation from the impact fee advisory committee, and having heard and considered public comment I move to approve Commission Resolution 4424 adopting the October 24, 2012 draft of the Transportation Impact Fee Study, excluding the implementation recommendation of how to calculate intersection capacity share of costs described in paragraph three on page 15, and setting the percentage of the fee to be collected at [Commission must determine this figure] percent; and setting an effective date to coordinate with the effective date of Ordinance 1853. BACKGROUND: The City has approximately 255 miles of roadways of different types within its boundaries. These streets are a mix of local, state, and federal roadways. These streets provide service to over 169,000 vehicle trips per day as well as many thousand pedestrian and bicyclists. A mix of local, state, and federal funding provides for maintenance and operations to serve existing users, and also funding to expand the system to serve future users. Local funding for operations and maintenance comes primarily from the semi-annual assessment on real property. In FY2013 this is expected to create $2,986,000 of revenue. This includes funding for daily operations such as wages and supplies and also some funding for the repair and 221 2 replacement of existing streets. The City also received $659,500 in revenue sharing from the fuel taxes collected by the state and federal governments. Like the local assessment these funds are primarily used for maintenance. The City also receives “urban funds” a special restricted use funding to maintain and expand certain defined streets. Capital goods are generally defined as having a service life in excess of 10 years and are physical items such as pipes, treatment and collection buildings, and vehicles. Capital expansion of the street system is achieved by combined funding sources such as impact fees, development project related installations of local streets and portions of the major street network, urban funds, and applicable grants which occur infrequently. All these funding sources must work together to provide the reliable and adequate service needed for a healthy community. Overall, in FY2013 the City expects to expend in excess of $8,896,000 to maintain and expand the street system in addition to funds expended directly by the State and Federal government of roadways they maintain. Coordination of these various efforts is provided through the long range facility plan and the annual capital improvement programming system as well as the operational oversight of the staff and Commission. The City also plays a major role in the Transportation Coordinating Committee; a multi-agency interlocal agreement between the City, County, State, Federal governments, MSU, and transportation advisory groups. The TCC helps prepare long range transportation plans, coordinates between member activities, and works to obtain maximum effectiveness and efficiency in the transportation system and related expenditures. This memo is focused on one element of the overall funding structure for the transportation system, impact fees. Bozeman initially adopted impact fees in 1996. Most recently the fee studies were updated in 2007. The present fee study began in 2011. Impact fees have helped the City provide needed services during high, moderate, and slow growth periods. The memo is structured in sections identified by letter. Each section addresses an individual topic. The majority of the sections are focused on the content of the new fee study, the presentation of information that occurred on October 8th and December 10th and related questions. Section C identifies questions and issues that will be addressed with implementation. Many of these items interrelate to other issues, programs, and standards. These interrelationships are often complex and on-going. These items do not all need to be finally resolved prior to acceptance and adoption of the fee study. After the October 8th meeting of the Commission, the Institute of Transportation Engineers released a new edition of the Trip Generation Manual (ITE manual). The ITE manual is the collection of transportation research which forms the basis for expected numbers of vehicle trips created by new development. The City is committed to using the most up to date available information in its impact fee program. Therefore, the consultant prepared a new draft of the transportation study dated October 24, 2012 which uses the data from the newly published edition in the fee calculations. The effect of the change may be determined by comparing figure 14 from the October 24 and the September 23rd studies. Financially there is a small, as little as 1.2%, increase in the calculated cost of service. There is also a change in uses where the metric for elementary and secondary schools changed from a cost per student to a cost per 1,000 square feet of building area. This memo presents the October 24, 2012 draft for potential action. The City Commission previously considered this item on October 8th and December 10th, 2012 The sections are: A. Responses to questions from December 10th 222 3 B. Process to complete actions C. Issues for Future Discussion and Implementation Sections: A. Question from December 10, 2012: 1) Restaurant/Retail category consolidation: The fee calculated must be applied to a demand calculation which can be applied to specific proposed construction. Staff and the advisory committee discussed with the consultant the possibility of revising how the schedule of fees is developed. Several changes to current practice are proposed in the draft study. One question remains and is described below. The current schedule of fees uses a variety of demand measures depending on the characteristics of the use. It has more than 35 different categories. This can be beneficial in supporting the proportionality of the fee to a specific site. However, over time as a building is reused additional fees may become due as the uses in place change from one category to another. There are also some categories that are infrequently used. The consultants proposed to consolidate the number of non-residential categories. A less detailed set of categories simplifies the day to day administration of the program and is advantageous to some users. It also reduces the likelihood of additional fees being due with reuse of an existing building. This corresponds with the Commission’s direction to be more business friendly and encourage rehabilitation/reuse of existing structures. Fees are paid for the building lifetime use as a given category. The Commission accepted the recommendation and the new fee study uses a much consolidated list of non-residential uses. A more general category provides a more consistent measure on average although there will be some outliers where the structure remains a single use over its entire service life. Page 22 of the transportation impact fee study presents the proposed list of use categories. The current list of categories is attached to this memo. Examples of these changes are included with the fee examples. The question of whether or not to combine the retail and restaurant categories was raised at the October 8th Commission meeting. The consultant provided a written response to that question. An additional question was raised at the December 10th meeting. A second response was provided and is attached. 2) Payment timing: This issue was addressed the cover memo for Ordinance 1853. 3) Effects of Changes to the Percentage Collected: The transportation impact fee is the one impact fee which is not presently collected at the full calculated cost of service. No recommendation is made in the fee study on this issue. Ordinance 1853 considered earlier in the January 28th meeting included a text change to move any reduced percentage from the ordinance to the adopting resolution. The Commission may choose to adopt any percentage up to the calculated cost of service. In order to collect less than the full cost of service the Commission should include a percentage with the text of Resolution 4424. Some suggested motion language is provided above. If the Commission does not specify a percentage and simply adopts the study the full cost of service will be collected. 223 4 Need for alternate transportation funding: When adopting the 2008 transportation study the City Commission decided to collect the fee at 60% of the calculated cost of service. Therefore, the City is required to find other funds to make up the 40% difference in order to maintain levels of service. Future impact fee payers can’t be required to make up a fee deferred or not collected previously. Over the past four years, the City has collected $4,248,392 in transportation impact fees. This means that the 40% discount resulted in an cumulative need for alternate funding of $2,832,261 over that time frame. It should be noted that this four year period saw a significant slowdown in the pace of new building construction as a result of the national economic slowdown. Had development proceeded at is pace in the prior four years the deficiency would have been much larger. Alternative funding to make up the 40% must be for capacity expansion and not for any maintenance or correction of existing problems. At this point, a single federal earmark used to expand South 19th Avenue has offset the discount. However, at some point this will no longer be the case and additional funds will need to be found if the discount is to continue. On page 23 of the study the consultants estimate cumulative transportation impact fee revenue over the next ten years of approximately $29,000,000 if the fee was adopted at the full calculated cost of service. For each 10% reduction in the fee collected the City would receive on average over the ten year period $290,000 less revenue per year. There are several different methods which could be used to make up this difference. A single mil of general property tax is valued at approximately $83,000. An annual levy of 7.7 mils would meet the annual average need for alternative funding over the past four years. An annual levy of 14 mils would be needed to cover the future shortfall if the 40% discount were to be continued and needed to be made up. This approach spreads the cost to the general tax payers. On occasion the City may receive grants for transportation. The City received an appropriation (earmark) of $5,000,000 from the federal government. These funds were used to expand South 19th Avenue from 3 lanes to five lanes thereby increasing system capacity. Earmarks are unpredictable in their frequency and amount. Given the federal budget debates the likelihood of further earmarks seems to be declining. Should such a grant be received the Commission could make a change in the future. The City could use SIDs to pay for portions of work along roadway corridors. Such special districts would require the City to demonstrate a particular benefit to those within the district from the additional charges. Depending on the type of road and nature of the improvements this can be a difficult standard to satisfy. An SID must be designed and approved on a case by case basis for each project. The SID formation process is largely directed by detailed state statutes. SIDs appear to work best as partner funding for local project costs to match impact fees. State law authorizes the County to establish a local gas tax of up to two cents per gallon. Establishment and distribution of such funding would require an interlocal agreement and countywide voter approval. This seems an unlikely option at this time. One possible option is to create an alternative funding source. The City of Billings has established an assessment program which they use to construct arterial and collector streets. The structure is very similar to the program that Bozeman uses for street maintenance. These funds could be used for target fee reductions to specific industries or could be used to provide a regular source of capacity expanding funding. In the second circumstance, the amount of 224 5 funds needed to offset the present 40% reduction in the fees collected would be approximately $710,000 per year. This figure is based on an annual average of the impact fee collections for the past four years. To raise this amount of revenue would be equivalent to 25% of the current street maintenance assessment for FY2013. No change to the impact fee ordinance or study would be required for this approach. Creation of such a program and any new charges would likely be coordinated with the annual budget process which typically occurs in April-June. The City can also issue bonds to construct street improvements. The most recent transportation bond was approved in 1995 and will be paid off in the next couple of years. Bonds also are general fund liabilities paid by the community as a whole. The present impact fee study shows an offsetting credit for the contributions which new fee payers will make to paying off the bond. In lieu of a new bond the City could ask the voters to continue the same number of mils as used to pay the present bond as an ongoing contribution to transportation development. This would provide savings in interest and bonds costs and enable more improvements to be completed for the same expenditures. 4) Targeted Incentives: This issue was addressed with the cover memo for Ordinance 1853. 5) North Park property contributions: The question of offsetting impact fees with land contributions was raised at the December 10th meeting. The City could consider contributing some or all of the value of property to encourage development at North Park. This is an issue better addressed in the larger question of economic development and targeted incentives. Such a contribution does not impact the amount of impact fee calculated or charged. 6) Ordinance 1853: This ordinance was considered earlier in the evening. Several changes were under consideration including both policy and cleanup of the text related to the policy. For further discussion please see that portion of the agenda packet. 7) Intersections: The manner and amount of funding intersection improvements has generated community discussion. The subject is briefly addressed on page 15 of the study in the third paragraph. A determination of what is new work and what may be a maintenance item will vary by intersection and the proposed work. Each intersection must be evaluated individually for its existing conditions and how a proposed project may alter those conditions. As a basic standard, impact fees may not be spent on maintenance. In Section 4 of the study those intersections which do not meet the established functional standard are identified. These intersections will certainly require funding other than impact fees to correct that functional deficiency. Impact fees may be paired for capacity expanding costs beyond deficiency correction. As development proceeds, the City will continue to receive and perform traffic studies which may identify other limitations. The City acts preemptively to prevent failure of function from occurring. The City agrees that impact fees may only fund capacity expanding costs and may not correct deficiencies. An average cost approach as suggested by TischlerBise on page 15 applies the cost of improvements to all users of the intersection. As stated in the study, this approach presupposes that the intersection is allowed to fail before improvements are being undertaken. A marginal cost approach as used by the City previously applies the cost of improvements to the new/future users of an intersection. As an example: an intersection presently serves 5,000 vehicles per day, post improvements will serve 10,000 vehicles per 225 6 day, and the work will cost $500,000 and will only add new hardware and turning lanes making no changes or repairs to existing components. An average cost approach would charge each of the 10,000 vehicles both new and old $50. A marginal cost approach would charge each of the additional 5,000 vehicles $100. This issue is also related to the manner in which level of service is measured. Intersection level of service is measured by delay; corridor level of service is measured by number of vehicles passing through in addition to delay. The transportation plan describes these measures in Section 2.2.4 and identifies locations where known problems exist and future problems are likely. Ordinance 1853 included a proposed definition of maintenance to help address this issue. The question of intersection analysis, although mentioned in the study which focuses on demand and cost, is an implementation issue. Therefore, the wording of the adopting resolution specifically notes that the recommendation of how to evaluate the growth capacity of individual intersections is not adopted. The issues identified will be considered with each specific project to improve an intersection so that impact fees are spent appropriately to their purpose and limitations.. B. Process: The City conducted a request for qualifications followed by a request for proposal process to select a consultant to assist the City in updating the four fees. A contract with the selected consultant, TischlerBise, was completed on June 29, 2011. Since that time, the consultant has been collecting and reviewing data, preparing analysis and draft reports, and meeting with Staff and the Impact Fee Advisory Committee (IFAC). The IFAC is the body required by statute and formed by local resolution to advise the City Commission relating to impact fees. The IFAC conducted public hearings on August 16th and September 13th to hear input from members of the public on the draft impact fee studies. After conducting the public hearings the IFAC voted on motions to recommend approval of the individual fee studies. The Committee recommended favorably on all four studies having found that the studies were consistent with the requirements of state law regarding impact fees. Minutes of all of the IFAC meetings were provided with earlier packets and are available through the Community Development Department. On October 8th the City Commission received the reports and heard a presentation from TischlerBise regarding the reports. No action on the studies was taken. The meeting was for receiving information, hearing from the public, and formulating questions from the Commission to be answered at a future meeting when all Commissioners are present. The Commission set November 26th for follow up action on the study. This action was moved to December 10th. The Commission passed Ordinance 1843 making structural changes to the impact fee ordinance language which took effect on December 5th. These changes specify that adoption of the new water impact fee study is by resolution. A draft resolution was prepared for Commission action. A resolution of the Commission can be effective immediately. Depending on the action taken by the City Commission on Ordinance 1853 it may be desirable to coordinate the effective date of the ordinance and resolution. This would build in an inherent delay to the effective date of the resolution. Some delay in the effective date of the implementing resolution gives opportunity for 226 7 implementation procedures to be set up and information to be provided to the public. The draft resolution includes an effective date which is coordinated with Ordinance 1853. C. Issues for Future/Additional Discussion related to Transportation. These items are not required to be settled prior to action on Resolution 4424. Notes on action are shown at the end of each segment in italic text. Initial Street Construction Requirements: One of the differences which gave a different cost per lane mile of construction between the 2008 and 2012 studies is when the capacity expanding construction happened. The 2008 study had construction costs resulting from projects where collector and arterial roadways were expanded after initial construction. The 2012 study has projects where the center turn lane was included with initial construction. The difference in timing results in considerably different costs. The new study relies on the costs for the initial construction approach which are quite a bit less costly. This reduces overall capital costs but increases the number of lane miles being maintained. The City currently maintains 235 miles of streets and alleys. The City has adopted an initial minimum construction standard of two travel lanes for all streets. The City could consider modifying this standard to require that three lanes be constructed with the initial street construction to minimize capital costs. These ‘third lane’ projects would be potentially impact fee credit eligible to offset the additional expense of the third lane. This approach would require the City to set aside some funds for this which would lessen funds immediately available for other projects. To change the initial construction requirements would require an ordinance. UNRESOLVED ISSUES: 1) Accept consolidation of retail and restaurant or keep them separate 2) Whether to implement the study at 100% or at some lesser percentage selected by the City Commission. 3) If less than 100% cost of service is to be collected how does the City Commission what alternative funding source should be pursued to make up the difference. ALTERNATIVES: 1. Adopt the transportation impact fee study as recommended by staff. 2. Delay adoption to a future time. 3. Adopt the transportation impact fee study with directed changes after having made findings to demonstrate why the changes are needed. 4. Adopt the transportation impact fee study with direction on the unresolved issues. FISCAL EFFECTS: The adoption of the Resolution adopting the proposed studies directly impact the amounts the City will collect in Impact Fee revenues in the coming years. Page 23 of the study provides an estimated revenue of approximately $29,000,000 over ten years given the growth evaluation in Appendix A. Expenditures of the fees will enable continued new construction which contributes on-going revenues and which will incur on-going expenses for provided services. See section A.3 for discussion on impact of percentage collected and alternative funding. Attachments: Commission Resolution 4424 Transportation Impact Fee Study dated 10/24/2012 Memo from TischlerBise re: recommended categories 227 8 List of current transportation categories Report compiled on: 1/17/2013 228 Resolution 4424 Page 1 of 5 COMMISSION RESOLUTION NO. 4424 A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF BOZEMAN, MONTANA, ADOPTING THE TRANSPORTATION IMPACT FEE STUDY PER ARTICLE 2.06, BMC. WHEREAS, the City of Bozeman is committed to addressing the community’s expressed needs and desires for services; and WHEREAS, the City of Bozeman is committed to meeting those desires and demands for services in a fiscally responsible manner; and WHEREAS, the City of Bozeman is committed to meeting those desires and demands for services in a manner which recognizes the fiscal and legal interests of all of the system users now and in the future and not a limited subset of users; and WHEREAS, the City of Bozeman has developed and adopted a transportation facility plan which examined current and future needs and provides a lawful, logical, balanced, operationally sound, and cost effective basis upon which to maintain and develop the City’s transportation system; and WHEREAS, the City Commission has chosen to utilize impact fees as one element of an integrated approach to fund and provide transportation services; and WHEREAS, Sections 7-6-1601 through 7-6-1604, MCA provide specific authority and guidance regarding the documentation necessary to establish an impact fee and procedures to adopt and administer an impact fee; and 229 Resolution 4424 Page 2 of 5 WHEREAS, the City contracted with TischlerBise, Inc. to provide professional services in development of an updated transportation impact fee study (the “Fee Study”); WHEREAS, TischlerBise, Inc. reviewed the existing demand and needs for transportation facilities, the existing facilities available to meet that demand, and the method of financing the existing systems and needed new facilities; and, WHEREAS, TischlerBise, Inc. also reviewed the contribution made or to be made in the future in cash or by taxes, fees, or assessments by property owners towards the capital costs of transportation facilities; and, WHEREAS, TischlerBise, Inc. reviewed and relied upon the City of Bozeman’s level of service (LOS) standards and facility cost assumptions as established by recently constructed projects in recommending transportation impact fees; and, WHEREAS, TischlerBise, Inc. has prepared a transportation impact fee study dated October 24, 2012 including the assumptions, population and residential and non-residential development projections, capital infrastructure and impact fee calculations, which study has been submitted to and reviewed by City staff and Impact Fee Advisory Committee and City Commission; and, WHEREAS, in addition to the Fee Study, TischlerBise, Inc. and the City have prepared, updated, and relied upon other documentation, as required by Section 7-6-1602 MCA, in developing the transportation facilities impact fees adopted pursuant to this Resolution including but not limited to the following which has been summarized in the required service area report: (1) Greater Bozeman Area Transportation Plan Update; (2) Chapter 38, Unified Development Code; BMC; 230 Resolution 4424 Page 3 of 5 (3) City of Bozeman Design and Specifications Manual; (4) Street Impact Fee Capital Improvement Program; (5) Adopted Capital Improvements Program for General Fund, Street Maintenance Fund, and Street Impact Fee Fund; (6) the City Budget; and (7) Specified bid tabulations; and WHEREAS, the City develops its transportation facility plans, and its capital improvements program in a manner open to the public and accepts and responds to public comment and input; and WHEREAS, the City and TischlerBise Inc. developed the transportation impact fee study in a manner open to the public and accepted and responded to comment and input; and WHEREAS, the City of Bozeman Impact Fee Advisory Committee considered and made a recommendation to the City Commission on the Fee Study; and WHEREAS, the Impact Fee Advisory Committee conducted public hearings on the subject of the transportation impact fee study on August 16, 2012 and September 13, 2012, and the City Commission conducted a public hearing on October 8, 2012, and a public meeting on December 10, 2012; and WHEREAS, public comment was received and considered; and WHEREAS, the City Commission reviewed and discussed the Fee Study and accepts and agrees with the portions of the content of the Fee Study which documents costs and expected demand per service unit and sets a fee schedule and recognizes that updates and modifications will be made to the fee schedule in the future in accord with the annual cost adjustment requirements of Chapter 2, Article 6, Division 9 BMC; and 231 Resolution 4424 Page 4 of 5 WHEREAS, the City Commission found that all required elements necessary for compliance with standards for development of an impact fee have been satisfied. NOW, THEREFORE, BE IT RESOLVED by the City Commission of the City of Bozeman, Montana, that 1. The October 24, 2012 draft of the Transportation Impact Fee Study Update, as contained in Exhibit "A", attached hereto and by this reference made a part hereof, is hereby adopted; except the recommendation of how to calculate intersection capacity share of costs described in paragraph three on page 15. 2. As of the effective date of this resolution, any person who seeks to obtain any of the forms of development listed 2.06.1640, BMC must pay a Transportation Impact Fee pursuant to the schedule included in Exhibit A of this Resolution. 3. The percentage of the fee collected shall be _______ percent of the amount calculated. Effective Date. PASSED AND APPROVED by the City Commission of the City of Bozeman, Montana, at a regular session thereof held on the _____ day of ________, 2013. This resolution shall be in full force and effect on the same day as Ordinance 1853 which is the _____ day of ________, 2013. ___________________________________ SEAN A. BECKER Mayor ATTEST: ________________________________________ STACY ULMEN, CMC City Clerk 232 Resolution 4424 Page 5 of 5 APPROVED AS TO FORM: ___________________________________ GREG SULLIVAN City Attorney 233 234 235 236 237 238 239 240 241 242 243 244 245 246 247 248 249 250 251 252 253 254 255 256 257 258 259 260 261 262 263 264 265 266 267 268 269 270 271 272 273 274 275 276 277 278 279 MEMORANDUM TO: Chris Saunders, AICP City of Bozeman, MT FROM: Dwayne Pierce Guthrie, PhD, AICP DATE: December 14, 2012 SUBJECT: Trip Generation Rates for Commercial Development The text below from Trip Generation (Institute of Transportation Engineers 9th Edition 2012) supports the TischlerBise recommendation to use ITE 820 Shopping Center as a reasonable proxy for all commercial development. “A shopping center is an integrated group of commercial establishments. Shopping centers, including neighborhood, community, regional, and super regional centers, were surveyed for this land use. Some of these centers contained non-merchandising facilities, such as office buildings, movie theaters, restaurants, post offices, banks, and health clubs. Many shopping centers, in addition to the integrated unit of shops in one building or enclosed around a mall, include out parcels (peripheral buildings or pads located on the perimeter of the center adjacent to the streets and major access points). These buildings are typically drive-in banks, retail stores, restaurants, or small offices. Although the data herein do not indicate which of the centers studied include peripheral buildings, it can be assumed that some of the data show their effect.” The shopping center trip generation rates are based on 302 studies with an r-squared value of 0.79. The latter is a goodness of fit indicator between the individual studies and the regression curve. R-square values range from 0 to 1, with higher values indicating the independent variable (floor area) provides a better prediction of the dependent variable (average weekday vehicle trip ends). If the r-squared value is less than 0.50, ITE does not publish the value because factors other than floor area provide a better prediction of trip rates. Bozeman City Commissioners asked about the possibility of maintaining separate categories for restaurants. In the current fee schedule, Bozeman has fees for Quality Restaurant (ITE 931) and Fast Food with Drive Through (ITE 934). The trip rates are based on 15 and 21 studies, respectively, with no published r-squared value. Based solely on difference in trip generation rates, the impact fee for a quality restaurant would be 2.1 times higher, per thousand square feet, than the proposed fee for general commercial. Similarly, an impact fee for a fast food restaurant with drive through would be 11.6 times higher, per thousand square feet, than the proposed fee for general commercial. 280 Bozeman City Commissioners also wanted to know if the average rate for shopping centers overestimates trip generation for stand-alone retail development. The table below compares trip rates to the recommended shopping center category (ITE 820) shown with yellow shading. The table is sorted in ascending order by trip rate, with an average rate of 53.41 derived for standalone retail development. This average excludes four development types with very high trip rates (i.e. restaurants, drive-in banks, and convenience stores, listed at the bottom of the table). Bozeman’s current street impact fee schedule includes the development types shown with gray shading. To provide a more comprehensive evaluation, TischlerBise added all ITE retail land uses that had at least ten studies or a published r-squared value (i.e. greater than 0.50). As confirmed by this analysis, it is the professional opinion of TischlerBise that ITE 820 Shopping Center provides a reasonable proxy for the trip generation characteristics of all commercial development. 281 282 283