This is what I submitted to the Hearings Officer in written testimony:
February 5, 2003
Land Use Hearings Officer
1900 SW Fourth Avenue, Suite 3100
Portland, OR 97201
RE: LUR 00-00672 CP ZC Albina Fuel
To Whom It May Concern:
I have carefully reviewed the traffic study and have many concerns regarding the lack of analysis in some areas and the assumptions, which form the basis for the study's conclusions.
Square Footage of Proposed Zoning: The high intensity use scenario under the existing zoning assumes 420,000 SF of development (page 3 of study). This assumption is based on an FAR of 2:1. Under the two scenarios for proposed zoning, the square footage is 115,000 SF commercial space plus 300 housing units. Assuming 1000 SF per housing unit, the total square footage is 415,000 SF. Yet the FAR for the RX zone is 4:1. Therefore the study should be assuming 840,000 SF of developed area. That would mean 336,000 SF (20%) of commercial space and 500 housing units. The study should assume a full build out under the proposed zoning scenario.
Community Service Use Within RX: The proposed zoning designation RX permits up to 20% of the square footage to be used for community service use such as schools and recreation centers. This is in addition to the 40% for commercial use. The developer has indicated on multiple occasions, a serious interest in this site by the YMCA. Therefore this possibility should be considered in the traffic study. Traffic generated by such a use is significantly different in intensity from the other commercial uses.
The square footage noted above should be revised to add 168,000 SF of community service space and reduce the housing units accordingly. The traffic study does not show any assumptions for this type of use. It should be included in the analysis.
Traffic Study to East and North: The study analyzes 8 intersections that are to the west and south of the site. There is no analysis of traffic conditions to the east and north. A comprehensive traffic study should extend east, at least to the 37th and Broadway intersection. There is also a major problem with north/south travel in the area to the north of the study site. See additional comments under connectivity.
Lack of Connectivity: The traffic study fails to identify traffic problems due to loss of connectivity. Barricades, left turn prohibitions, one way streets all contribute to traffic congestion because they restrict traffic flow to only a few streets. The following elements restrict connectivity:
* Barricades North of Broadway: Barricades, located on the north side of Broadway at 30th Avenue, Schuyler Street on 28th Avenue and Schuyler Street at 32nd Avenue, prevent cars from traveling north of Broadway or south of Schuyler. The only streets allowing through traffic are 33rd Avenue, to the east, and 27th Avenue to the west. This means all traffic trying to travel between the areas just north of Broadway and the study site must travel via 33rd Avenue or 27th Avenue. See attachment.
* Barricades West of 28th : Similarly, barricades located on the west side of 28th Avenue at Weidler, Halsey, Clackamas and Wasco Streets prevent westbound traffic off of 28th Avenue and eastbound traffic from these streets cannot reach 28th Avenue. This means all traffic trying to travel between the areas just west of 28th Avenue and the study site must travel via Broadway.
* One Way at Weidler: A new traffic barrier has been added in the last month. Weidler has become a one way street between 28th and 30th Avenues. The study also notes that Weidler will eventually become one way from 30th to 32nd Avenue.
See Part 2 for remainder of text.
February 5, 2003
Land Use Hearings Officer
1900 SW Fourth Avenue, Suite 3100
Portland, OR 97201
RE: LUR 00-00672 CP ZC Albina Fuel
To Whom It May Concern:
I have carefully reviewed the traffic study and have many concerns regarding the lack of analysis in some areas and the assumptions, which form the basis for the study's conclusions.
Square Footage of Proposed Zoning: The high intensity use scenario under the existing zoning assumes 420,000 SF of development (page 3 of study). This assumption is based on an FAR of 2:1. Under the two scenarios for proposed zoning, the square footage is 115,000 SF commercial space plus 300 housing units. Assuming 1000 SF per housing unit, the total square footage is 415,000 SF. Yet the FAR for the RX zone is 4:1. Therefore the study should be assuming 840,000 SF of developed area. That would mean 336,000 SF (20%) of commercial space and 500 housing units. The study should assume a full build out under the proposed zoning scenario.
Community Service Use Within RX: The proposed zoning designation RX permits up to 20% of the square footage to be used for community service use such as schools and recreation centers. This is in addition to the 40% for commercial use. The developer has indicated on multiple occasions, a serious interest in this site by the YMCA. Therefore this possibility should be considered in the traffic study. Traffic generated by such a use is significantly different in intensity from the other commercial uses.
The square footage noted above should be revised to add 168,000 SF of community service space and reduce the housing units accordingly. The traffic study does not show any assumptions for this type of use. It should be included in the analysis.
Traffic Study to East and North: The study analyzes 8 intersections that are to the west and south of the site. There is no analysis of traffic conditions to the east and north. A comprehensive traffic study should extend east, at least to the 37th and Broadway intersection. There is also a major problem with north/south travel in the area to the north of the study site. See additional comments under connectivity.
Lack of Connectivity: The traffic study fails to identify traffic problems due to loss of connectivity. Barricades, left turn prohibitions, one way streets all contribute to traffic congestion because they restrict traffic flow to only a few streets. The following elements restrict connectivity:
* Barricades North of Broadway: Barricades, located on the north side of Broadway at 30th Avenue, Schuyler Street on 28th Avenue and Schuyler Street at 32nd Avenue, prevent cars from traveling north of Broadway or south of Schuyler. The only streets allowing through traffic are 33rd Avenue, to the east, and 27th Avenue to the west. This means all traffic trying to travel between the areas just north of Broadway and the study site must travel via 33rd Avenue or 27th Avenue. See attachment.
* Barricades West of 28th : Similarly, barricades located on the west side of 28th Avenue at Weidler, Halsey, Clackamas and Wasco Streets prevent westbound traffic off of 28th Avenue and eastbound traffic from these streets cannot reach 28th Avenue. This means all traffic trying to travel between the areas just west of 28th Avenue and the study site must travel via Broadway.
* One Way at Weidler: A new traffic barrier has been added in the last month. Weidler has become a one way street between 28th and 30th Avenues. The study also notes that Weidler will eventually become one way from 30th to 32nd Avenue.
See Part 2 for remainder of text.
