One of our community members, Scott, wrote a letter to the city in reference to the traffic survey was submitted by the developer. It should be noted that all surveys (environmental, traffic, etc) have been PAID for by the developer, performed by the developer’s vendors.
Scott’s thoughts and comments are logically sound and need to be seriously taken into consideration. The letter is below. (minimally edited for context)
TO: Lacey Community Development Department
The provided traffic impact analysis fails to support that current road infrastructure is adequate to facilitate this project without unreasonable nuisance and endangerment to the citizens of Lacey.
Unfortunately this analysis is mostly oriented to analyzing the development’s impact on intersections several miles away. It fails to appropriately address a more pertinent, nearby problem: Apartment residents will necessarily need to utilize the intersection of 25th Street and Ruddell Road–an intersection that is already inadequate and unsafe even while handling a small fraction of the future traffic volume that will be generated by this development.
In addition to this conceptual flaw, the report contains substantive errors that further distort what will be the true traffic impact of this development. A few of these errors are summarized below, with further explanation following in this commentary:
- Inaccurately characterizes Hicks Lake Road as a “Major Residential Street”.
- Significantly undercounts the volume of vehicular trips to be generated.
- Misrepresents Crash Volume data, obscuring intersection dangers.
- Assumes usages of adjacent private properties and neighborhood streets that are both inappropriate and certain to be resisted by those affected.
- Ignores the inability of surrounding streets to handle the large volumes of tractor-trailer traffic and concrete transport to be generated during the construction phase.
A traffic impact analysis conducted on more sound conceptual grounding, utilizing data both relevant and appropriately weighted, would have come to this conclusion: The several thousand new daily car trips generated will bottleneck at the intersection of 25th and Ruddell. The inability of this intersection to handle this increased traffic will result in delays, frustration, and an unacceptable number of accidents and injuries.
Major Areas of Concern
Hicks Lake Road
The Drawings label Hicks Lake Road a “Major Residential Road”, but that does not make it one. Visual inspection reveals it to be more akin to a country lane. There is no center line, bicycle lane or striping of any kind. It is mostly uncurbed and in many places shows damage and weathering. Hicks Lake Road is already in a state of advanced deterioration, even before the first of several thousand trucks bearing concrete and other delivered building materials begin to erode its condition.
Traffic Volume to be Generated
There are several misrepresentations in this analysis of the traffic volume to be generated. The first is a straight-forward entry error: Instead of the 178 units proposed in this project, Table 3 on pg.16 uses the figure of 155 units for calculation purposes. Even if one accepts the utilized trip rate of 5.44 trips/per day/per unit, using the correct figure of building units raises the total daily traffic volume from the claimed 843 to 968 trips per day.
The figure of 5.44 trips/per day/per unit is suspect. The analysis states this is a calculated norm as determined by the Institute of Traffic Engineers (ITE) for apartment buildings 3-10 stories in height. For apartment buildings two stories in height, ITE’s recommended figure significantly jumps to 7.32 trips/per day/per unit–an increase of 35%. Why the great difference? Buildings in height of 3-10 stories are generally located in urban cores or areas where residents likely live within walking distance of work, school, retail, and/or can conveniently access frequent mass transit–features that this project lacks in entirety. The driving habits of residents of this project will more closely resemble residents of low-rise suburban apartment buildings than those of persons living in an urban mid-rise building. The ITE recommended trip rate of 7.32 trips/per day/per unit for these buildings is a more appropriate choice.
Another facet that cannot be ignored is the existence of submittal to build just next-door another apartment project with 132 living units. It is unlikely that the City of Lacey would approve one of these projects and then deny the other for reasons of insufficient road infrastructure.There is also the consideration of other adjacent parcels also zoned for high density that could support additional development. In any case, the bare minimum of units to be considered for traffic impact analysis should be the combination of these two projects–310 building units.
The figure for Traffic Volume to be Generated is more accurately calculated as 310 BU x 7.32, or 2,269 additional daily vehicle trips. Adding in delivery and other service vehicles rounds the estimate to 2,500 additional daily vehicle trips that will need to be accommodated.
Crash Volume Data
The analysis compiles and transcribes great amounts of data but fails to effectively assess the likelihood for increased numbers of injury accidents resulting from the new development. Unless the residents of this new project are intended to fan out through adjacent neighborhoods (this subject will be addressed below), the only arterial access is to utilize 25th Street and then turn onto Ruddell Avenue.
In Section 3.5, “Existing Crash History”, this traffic impact analysis obscures the danger of this intersection by inserting irrelevant data of six other intersections that have no common characteristics to 25th & Ruddell. All of the other intersections shown in Table 1 on pg. 14 feature stop-lights or a traffic circle, and the traffic volume of the two intersecting streets is somewhat equal to each other. None of these conditions apply at 25th & Ruddell where more than 90% of the “Total Daily Entering Traffic” will just be whizzing by on Ruddell–vehicles traveling unimpeded in a straight line that will almost never become engaged in an accident.
For an intersection between a relatively low volume Connecter Route and a high-volume Arterial, it is turning movements that initiate accidents and should be the data point of interest–NOT the total number of vehicles who only flow through an intersection. But Table 1 includes the pass-through traffic at 25th & Ruddell to deceptively inflate the denominator used to calculate the fraction of “Crashes per Vehicles Entering”, and then suggests there is some relevance of this fraction when compared to other totally dissimilar intersections. There is no relevance here, and the boldfaced numbers in Table 1 reveal nothing about the risks for drivers on 25th turning onto Ruddell.
The only intersection listed with some relevance to 25th & Ruddell is the intersection of 22nd & Ruddell. They are similar in that both are low volume Connector Routes feeding into a busy Arterial. They differ in that the intersection at 22nd is controlled by a traffic light and here southbound Ruddell traffic has a left turn lane here; at 25th there is no stop light nor a southbound left turn lane. Refer to Table 4 on Page 10 of this analysis, “Existing 2020 PM Peak Hour Traffic Volume”. During the time-period studied, the stop-light controlled intersection at 22nd & Ruddell produced 315 turning movements; during the same time period there were 95 turning movements at 25th & Ruddell. Despite the intersection at 22nd having a higher volume by some 330%, Table 1 on Page14 reveals it is the intersection at 25th that produces more accidents and more injury-accidents.
This comes as no surprise to those of us who daily use these intersections. When one is attempting to turn onto Ruddell from 25th, the fencing and trees of the apartment complex there obscure the view of the northbound Ruddell traffic, creating a “blind corner”. Even now the situation here makes for an unpleasant adventure; a vehicle turning left there faces difficulties in finding a slot between the northbound and southbound Ruddell traffic. And the person attempting to turn right can’t see the northbound Ruddell traffic at all if there’s another 25th Avenue car trying to turn left that is blocking their view. Imagine how impatient drivers will feel if they’ve been the 10th car backed up in line along 25th Avenue while trying to get to work in the morning, possibly provoking aggressive decisions to pull out onto Ruddell.
The southbound Ruddell traffic has no left-turn lane for accessing 25th Avenue. The proposed new development will increase by a factor of 200-400% the number of vehicles desiring to turn from southbound Ruddell onto 25th, likely at times to create a backlog of non-moving vehicles. These stopped vehicles will be subject to becoming involved in rear end collisions from fast moving south bound Ruddell traffic.
This traffic impact analysis fails to accurately represent the hazardous status of the intersection at 25th & Ruddell–a condition that will be made exponentially worse by new development.
Adjacent Neighborhoods & Properties
The 100-page traffic impact analysis only allots 3 short paragraphs, Section 6.3.3, to the problematic intersection at 25th & Ruddell–an intersection that will need to be utilized by almost all of 2,500 daily vehicular trips generated by new development. In that section 6.3.3 the analysis acknowledges there are problems here, and reveals their strategy for working around those problems. The following italicized wording is transcribed directly from the analysis:
The project traffic wishing to travel south on Ruddell Road SE have multiple alternatives to 25th Avenue SE. Project trips can reach Ruddell Road using 30th Avenue by traveling through Forest Grove Apartments. These project trips also have several neighborhood roads that provide access from 25th Avenue SE to 22nd Avenue SE, which then provides a signalized approach to make a WB left-turn onto Ruddell Road SE. These alternate routes seem sufficient, such that no improvement is warranted at this intersection.
The traffic impact analysis makes no mention of any agreement between Schneider Homes and Forest Grove Apartments to allow the new residents to drive through the Forest Grove Apartments parking areas in order to access Ruddell. The likely conclusion is there is no such agreement. Almost certainly the advent of several hundred cars daily traversing through their parking lot will prompt Forest Grove Apartments to close access from Hicks Lake Road. A closing such as this was recently enacted by the adjacent Surrey Lane Apartments.
Similarly, neither do the “neighborhood roads” mentioned provide an acceptable alternative. The analysis is referring to the streets Maxine, Shirley, Angela, Larch, and Sycamore. These streets were not intended or designed to be Connector Routes–they are quiet neighborhood streets lined with occupied residences. Families living here employ a great deal of on-street parking, which often restricts effective passage to only one lane. Many of the houses on these streets are lived in by children, often playing in the street or walking to the adjacent Lacey Elementary School.
The influx of hundreds of new vehicle trips daily through these streets, many of them ignoring speed limits, will significantly degrade the quality of life and present dangers for those living there. This will prompt a very predictable result: Persons living on these streets will exercise their rights to have installed speed bumps and other traffic calming/reduction devices so as to effectively prevent the apartment residents from using these streets for access to 22nd Street. Whether it’s dealt with in advance, or after a great deal of nuisance, angst, and possible injuries, the result will be the same: Almost all of the 2,500 daily vehicle trips generated by new development will necessarily flow through the intersection of 25th & Ruddell.
The analysis included no evidence of consideration to gauge the ability of the current road infrastructure to safely accommodate the construction traffic to be generated. Upwards of one-thousand trips into and out of the site by semi-tractor trailers will be required: Five acres of forest to be logged and cleared, importing and exporting of dirt and gravel, concrete, lumber, drywall, roofing etc.–these will all involve large trucks and equipment.
Besides the physical inability of Hicks Lake Road to hold up to this type of traffic, there is the question of how these vehicles will access the site. Unless it is deemed acceptable for concrete transporters and tractor-trailers to be snaking through the neighborhood streets described above, all of these will need to utilize the intersection of 25th & Ruddell. The difficulties of ordinary cars to navigate this intersection will be compounded by the size and turning radii of large trucks, with the potential to cause traffic back-up and delays.
Since a car traveling west on 25th hoping to turn onto southbound Ruddell has very limited sightlines of the northbound Ruddell traffic; they will inch up as far as possible so as to be able to see whether they can safely enter the intersection. When simultaneously a northbound concrete transporter approaches the intersection attempting to access the building site, it will be unable to make that turn due to insufficient space to execute the turn. Unable to move, that truck will then further block the car driver’s vision and concentrate other northbound traffic into the only lane remaining passable–making it even more difficult for the car to find an accessible slot to enter between the northbound and southbound Ruddell traffic. Like the truck, the car now becomes stuck-in-place. This is only one version of standoffs certain to be repeated endlessly during the construction phase.
Likewise, there will be problems for site access by a tractor-trailer southbound on Ruddell trying to turn onto 25th, again facing insufficient space to execute the turn if a car is present. Additionally, there are the challenges tractor-trailers will face after leaving the construction site when attempting to pull out onto Ruddell Road. There is plenty that could go wrong here.