1 1 Response to Lora Petso's letter The response by Guttermouth


									1/ Response to Lora Petso’s letter:

The response to each comment is provided in the same order it was provided in the letter:

a. General concern about the policy changes in the Plan

   Overall, the updated Transportation Plan does not reflect a shift in the City’s transportation
   policy direction. Staff worked with the Transportation Committee to update the
   transportation policies, over the course of four committee meetings. In general, the
   Committee’s review and update of the policies sought to (1) tighten the language so that it is
   more specific, and also grammatically consistent; (2) remove redundancies; (3) reflect
   programs or initiatives that the City has implemented since the last Plan update in 2002; and
   (4) remove policies that are actually development standards, and are more appropriately
   placed in the City’s development regulations, as codified in Edmonds Community
   Development Code (ECDC) Title 9 (Streets and Sidewalks) and Title 18 (Public Works

   For the fourth category listed above, it has been determined by staff that some of the
   standards reflected in the 2002 Plan are not covered in ECDC, and that it will not be feasible
   to amend the ECDC prior to adoption of the Comprehensive Plan amendments. In this case,
   the policies that cover these areas have been put back into the Transportation Plan as a stop-
   gap measure; but staff will move these standards into the ECDC as part of a comprehensive
   review and update of the code.

   In addition to the revisions listed above, the goals, objectives and policies were renumbered
   so that they could be more easily cited (e.g. under the 2002 Plan, numbering of goals,
   objectives, and policies restarted at “1” under each policy section, so there were numerous
   policies with the same policy number. For the 2009 update, policies were renumbered
   consecutively from section to section, so that each policy now has its own unique number).

   Responses to specific policy concerns that have been raised are addressed in section (f)

b. General concern about procedures for adopting Comprehensive Plan

   Procedures set forth by staff for adopting the Transportation Plan are consistent with the
   requirements of the Washington State Growth Management Act (GMA). The Transportation
   Plan serves as the transportation element of the City Comprehensive Plan. The GMA allows
   cities to adopt amendments to their comprehensive plans once per year. Thus, the updated
   Transportation Plan will be adopted toward the end of this year, at the same time as any other
   2009 amendments to the Comprehensive Plan. Staff is requesting that the Council approve
   (but not adopt) the Transportation Plan at this time, with intent to adopt as part of the overall
   annual Comprehensive Plan updates. This is mainly because work on the Transportation
   Plan, which began last year, is ahead of the other proposed amendments. Staff thought it
   would ease the process for the community and Council to review the Transportation Plan

   earlier (because it is ready for review, and includes a lot of information), and then be able to
   focus on the other proposed amendments later.

   However, if it is shown that anything in the other proposed Comprehensive Plan amendments
   would affect the recommendations in the Transportation Plan, there will be time to make any
   needed adjustments to the Transportation Plan prior to adoption.

   Regarding change to level of service (LOS) standards, one reduction is reflected in the 2009
   update, which is a change in the standard for SR 524 from LOS D to LOS E. This is a result
   of feedback provided on July 2nd, 2009 by WSDOT after their review of the Public Review
   Draft of the Transportation Plan. The additional public hearing (scheduled for September 1)
   was requested by staff to allow sufficient public review of this change. Additional
   information about LOS standards is provided below.

c. Concern about use of REET revenue to fund transportation projects

   The Transportation Plan does not recommend any changes in the use of Real Estate Excise
   Tax (REET) funds for transportation; but revenue projections do reflect REET as a source of
   funding as it is reflected in current City policy. Under current City policy, the first $750,000
   of REET revenue collected each year is dedicated to parks, and additional revenue collected
   beyond that level goes to transportation. This has resulted in a wide variance in REET funds
   that have gone to transportation over the years, from a considerable amount in real estate
   ‘boom’ years, to little or no funding in other years. The revenue projections in the 2009
   update reflect a conservative level of future REET funding for transportation, based upon
   typical levels that have been generated across the past 10 years or so.

d. Concern about establishment of a business license fee to fund transportation projects

   The business license fee is not identified as a specific source of funding in the Final
   Transportation Plan. It is mentioned as one of the options that are ‘out there’ but it is not an
   option that the staff recommends pursuing at this time. In early drafts of the 2009 update,
   calculation was provided to show what the order of magnitude could be for this type of fee.
   However, the calculation was dropped from the final recommended Plan since it is not part of
   staff’s recommended revenue source. It is still mentioned in the Plan as a theoretical revenue
   source that is an option for the City to pursue in the future (along with other potential sources
   such as Local Improvement Districts, joint agency funding, and additional grant funding).

e. Concern about Point Wells

   To clarify, because the Point Wells site is under Snohomish County jurisdiction, it is the
   County that has completed the initial analysis of the site, to support a programmatic EIS on
   the proposed land use change. As discussed during the 8/4/09 City Council meeting, the
   Point Wells analysis was not included in the City’s modeling because the proposed change in
   land use designation at that site has not been adopted by Snohomish County. Reflection of
   adopted land use plans in transportation analysis is consistent with GMA requirements. In

      •   The proposal before the County is a requested change in land use designation, not a
          site proposal. The purpose of the programmatic EIS prepared by the County for the
          Point Wells request was to help inform the County Council’s decision on whether to
          approve or reject the proposed land use designation; and as such, the transportation
          analysis assessed the high end of what could occur under the proposed change in
          designation (which does identify potentially a high level of transportation impacts in
          Edmonds, Woodway, and Shoreline). However, for the purpose of the City’s
          Transportation Plan, which is to identify projects that the City desires to fund over the
          next 16 years, it would be premature and highly speculative to try to ‘guess’ what will
          occur at this site beyond the adopted land use.

      •   If the County approves a change in land use designation at the Point Wells site,
          whatever development is specifically proposed at the site is still subject to the State
          Environmental Policy Act (SEPA) before any development can occur. As part of this
          process, the County’s programmatic EIS indicates that a high level of coordination
          with affected jurisdictions would need to occur – this would include identifying
          impacts and appropriate mitigation for a specific site plan – with the developer
          responsible for mitigating its share of transportation impacts. The City’s current
          Transportation Plan would provide a solid basis to allow such coordination to occur,
          because it shows what the City expects transportation conditions in Edmonds to be
          without a change in land use at Point Wells. The Transportation Plan provides the
          City with a baseline that will allow comparison of additional impacts of development
          at this site, which in turn would clarify the share of mitigation within the City for
          which the developer would be responsible.

   However, we do recognize that the County’s Comprehensive Plan amendment process is
   occurring concurrent to the City’s, and it is possible that a change in land use designation
   could be adopted by the County by the end of this year. In this case, development at the Point
   Wells site cannot occur right away for the reasons stated above, so the City will have time to
   incorporate this change into its next Comprehensive Plan update, which is scheduled for
   2011. This illustrates why comprehensive plans are continuously reviewed and potentially
   updated every year, even though they are long-range planning documents.

f. Concern about specific policy changes

   (1) Cul-de-sac policy
   This policy was not dropped because anyone disagrees with it, but because it is a design
   standard that more appropriately belongs in the City’s development code. This standard
   distance came from the American Institute of Certified Planners (AICP), a nationwide
   institute providing standards for planning practice. Additionally many local jurisdictions are
   currently using 600’ as their standard maximum cul-de-sac length. However, upon review by
   staff from the Development Services Department, it has been determined that this standard is
   not covered in the ECDC, so it has been added back into the Transportation Plan as a stop-
   gap measure, as discussed in section (a) above.

(2) Street right-of-way requirements for new development
The comment references Policy 5.2 in the previous plan, but to clarify, the policy mentioned
is actually Policy 5.1. This policy is also numbered 5.1 in the update. Right-of-way
requirements for new development are specified in the Standards Details, which are codified
in the ECDC. Right-of-way requirements for specific development proposals are not dictated
by the Comprehensive Plan. Thus, the reference to the Transportation Element was removed
for consistency with city procedures and to eliminate confusion.

(3) Sidewalk location policies, and locations of proposed new sidewalks
The previous Policy 1.2 (“Sidewalks should be located in areas where there is sufficient
pedestrian traffic”) and Policy 1.3 (“Sidewalk design should be related to the function and
the anticipated amount of pedestrian traffic”) were replaced with numerous policies
(numbered 6.1 through 6.19) that are consistent with the spirit of the original policies, but
provide much more specific direction.

Sidewalk projects were identified and prioritized through an extensive process that was
conducted by the citizens’ Walkway Committee. The Walkway Committee consisted of 12
members who live in across the different geographical areas of the city, who walk the city
regularly. Table 4-1 in the Transportation Plan summarizes the prioritization criteria that
were established (which are a refinement of the criteria presented in the 2002 Plan). The
criteria place the highest emphasis on safety, connectivity, and level of pedestrian activity.
Appendix D of the Transportation Plan summarizes the scores for each of the projects on the

Proposed sidewalk projects were presented at Open House #2 (on 3/5/09), and again in the
proposed priority order at Open House #3 (on 6/30/09). Some projects were added based
upon feedback received on the Public Review Draft Transportation Plan, prior to Open
House #3.

All potential projects were evaluated very thoroughly by the Walkway Committee members.
Regarding the priority of specific projects, N. Meadowdale Beach Road is one of the only
remaining collectors in the City without sidewalks. This addition would create a pedestrian
connection between 76th Avenue W (sidewalk currently under construction) and Olympic
View Drive (sidewalk recently added during Phase 1 of OVD project). Pine Street is also
included in the Walkway Plan and was ranked lower than the previous project because of
lower vehicle speeds and stop-controlled intersections. Olympic Avenue has an existing
walkway with rolled curb on the east side of this street. This stretch has high pedestrian
volume with access to Yost Park and Edmonds Elementary School to go along with high
vehicular activity. Additionally a roadway classification upgrade (from local to collector) is
recommended for Olympic Avenue.

(4) Sidewalk construction policies
Similar to the cul-de-sac policy, the sidewalk construction policies were initially dropped
from the Draft Transportation Plan because they are development requirements that more
appropriately belong in the City’s development code. However, upon review by staff from
the Development Services Department in June 2009, it was determined that these

requirements are not covered in the ECDC, so they were added back into the Transportation
Plan as a stop-gap measure, as discussed in section (a) above. These are included as Policy
7.1 through 7.4 in the updated Transportation Plan.

(5) Goal to establish level of service standards
The goal to “Establish appropriate levels of service for transportation facilities to adequately
serve existing and future developments” was removed because the LOS standards are
actually established under Policy 15.3, so it was considered redundant.

(6) LOS Policies

Transit policy:
The 2002 policy indicated that a maximum distance of ¼ mile access to transit is “desirable”,
but that ½ mile is “acceptable”. Since the City does not control where transit is provided, the
purpose of transit policies in the Transportation Plan is mainly to communicate the City’s
priorities to the agencies that provide transit service – for local bus service, this is
Community Transit. It was determined by the Transportation Committee that presenting
“desirable” verses “acceptable” distances to transit did not provide very strong direction
regarding the City’s priorities on access to transit – so the policy was revised to state only
that “A desirable maximum distance is ¼ mile.” (Policy 9.2 in the updated Plan).

LOS standards for roads:
The following information was provided at the August 4 City Council Meeting

City Local Streets
The purpose of the City’s concurrency standards is to maintain mobility on city streets, in
line with current levels of development. Since the primary function of local streets is to
provide access, and not serve a high level of mobility, the project team determined that it is
not appropriate to define a concurrency standard for local streets. In addition to concurrency
objectives being counter to the function of local streets, it is simply not practical for the City
to monitor LOS on all local streets (which make up about 76% of the streets in the City) for
the purpose of concurrency. For these two reasons, the LOS B standard that was defined for
local streets in the 2002 Plan was dropped. However, even though a standard was defined in
the 2002 Plan, no concurrency locations in that plan consisted of the intersection of two local
streets –so this decision does not affect the analyses or conclusions of either version of the

Please note, also, that the addition of the Traffic Calming Program in the 2009 update does
address the potential for operational issues on local streets in a way that correctly lines up
with their purpose, and thus is much more effective than concurrency for monitoring and
addressing traffic operations on local streets. If local streets are experiencing traffic volumes
that are too high or speeds that are too fast, this program lays out the steps that the City will
take to address those issues. We feel that application of a Traffic Calming Program is
superior to concurrency in addressing traffic issues on local streets.

The concurrency standard of LOS C for collectors and LOS D for arterials is the same in the
2009 update as it was for the 2002 Plan.

State Highways
Any state highway not designated as Highway Statewide Significance (HSS) is automatically
considered as a Highway Regional Significance (HRS). Local jurisdictions may choose to
include them in their concurrency program. In Edmonds, SR 524 and SR 99 north of SR 104
are HRS. In the 2002 Plan, SR 524 was held to the City’s arterial standard of LOS D – and
no standard was applied to SR 99. In 2005, PSRC developed LOS standards for HRS
facilities, in collaboration with local jurisdictions within the region. As they were emerging,
the HRS standards were often treated as suggestions, with many local jurisdictions
maintaining their locally adopted standards on these facilities. However, in its review of the
June 2009 draft, WSDOT directed the City that the PSRC standards must be applied to HRS
facilities. Thus, the 2009 update applies the PSRC standard of LOS E to these facilities.

(7) TIP policy section dropped
The TIP section was dropped from the policies because the requirements are dictated by state
law, and the policy section was just a repeat of those requirements. In addition, the
2010-2015 TIP is included in the Implementation section of Chapter 6. However, to clarify
how the annual TIP process ties to the overall Transportation Plan, this information, which
was removed from the policies, will be added into the Implementation Section of Chapter 6.

(8) Disagreement with project priorities

Walkway project priorities – please see response (f.3) above.

Roadway project priorities – Table 3-17 summarizes the prioritization criteria that were
developed for roadway projects. The criteria place the strongest weight on safety and
compliance with concurrency, with additional weight given for projects with high grant
eligibility, high magnitude of improvement (e.g. improve a greater number of traffic
movements), and/or provide multimodal improvements.

With regard to the extension of 228th Street SW in Ballinger, it was added in the updated
Plan after being ranked as the #1 project in the SR 99 Study conducted by the City in 2006.
This project received the highest safety score and also ranks high because of grant eligibility
with the regional magnitude of the project. It would help reduce the intersection delay to
many intersections east of SR 99 along both SR 104 and 220th Street SW. It also adds
pedestrian connection and provides a safe direct access for Edmonds residents to the
Mountlake Terrace Transit Center from SR 99.

(9) Omission of inter-jurisdictional efforts on SR 99 and Point Wells development
This section specifies the inter-jurisdictional coordination needed by the City to implement
the projects and recommendations presented in the Transportation Plan. For the reasons
stated earlier, it is premature to incorporate potential future development at Point Wells into
transportation recommendations or into the implementation plan.

   10) Road resurfacing projects
   The resurfacing of road projects is explained in more detail on pages 3-52 and 3-53. The
   selection of projects depends on the review of pavement survey conducted every 2 years as
   part of the WSDOT Pavement Condition Survey. All principal arterials, minor arterials, and
   collectors are assigned a Pavement Condition Index (PCI) from 0 to 100 based on the quality
   of the pavement. Additionally, Public Works will respond each time a citizen concern is
   received regarding pavement defects on a local street. The complaint will be assessed and
   prioritized with regard to public safety. Those issues that are capable of resolve using city
   forces are dealt with. Those that are too large are added to future overlay considerations. The
   utility projects are also taken into account, whether a water, sewer, or storm project is
   programmed in the near future. The final selection of projects is based on the proximity of
   those different projects. The budget shortfall has limited the number of overlay projects over
   the last couple of years. During the next overlay program, all roadway segments will be
   considered based on pavement condition and proximity to the utility projects.

   11) Future planned development included in model
   The summary in Table 1-1 originally included projected development in the unincorporated
   Esperance area that is surrounded by the incorporated City. The table has been corrected so
   that it only includes projected development (residential and non-residential) within the city
   limits, which does match up to the land use element of the Comprehensive Plan.

2/ Response to Roger Hertrich’s comments:

a. Questions the use of concurrency to classify streets, anticipating streets with a higher
   level of service classification would receive the most money

   The GMA requires that cities and counties each adopt a concurrency management system,
   but leaves it to the local jurisdictions to determine what their concurrency requirements will
   be. In the City’s adopted program, concurrency is not used to classify streets, but the street
   functional classification does determine its concurrency requirements (defined in Policy 15.3
   in the updated Plan). Under the city’s concurrency system, higher classified streets actually
   have a lower standard than lower classified streets. However, it is often true that
   improvements to higher classified streets are more costly than improvements to lower
   classified streets. This is in part why the concurrency requirements are often lower on higher
   classified streets. The other part of the reason is that drivers tend to accept higher levels of
   congestion on higher classified streets.

b. Questions the high level improvement that is projected with a traffic signal installed at
   various locations

   For the stop-controlled intersection of 196th and 88th, the existing LOS is:
              - northbound: LOS C
              - southbound: LOS F

   LOS F is projected in both directions by 2015.

   In developing transportation improvements to address identified deficiencies, it is the goal to
   identify the least expensive level of improvement needed to address the problem, while still
   meeting overall mobility objectives. Since installation of a traffic signal is “all or nothing”
   (as compared to a widening, which is typically proposed only in the direction of traffic
   movements that are experiencing problems), it can end up adding more capacity than is
   needed to meet concurrency, which is the expected case at 196th and 88th, and also at
   Caspers and 9th. In each of these cases, no lower level of project improvement that would
   allow all traffic movements (such as adding lanes in certain directions) was identified that
   would solve the identified concurrency deficiency.

   However, at 196th and 88th, an alternate project that allows right-turn only out of 88th has
   been identified in the Plan as another option that would allow the intersection to meet
   concurrency requirements. While this solution does restrict the mobility of some movements
   by prohibiting northbound and southbound left turns / through movements, it is expected to
   address the LOS deficiency with less additional capacity.

c. Concerns about proposed future signal at Main and 9th

   The intersections of both Main and Walnut with 9th Avenue are operating at LOS E under
   existing conditions, and are projected to operate at LOS F by 2015. Similar to the discussion
   above, it is not the goal of concurrency to improve to anything higher than LOS D, but
   installation of a traffic signal would add capacity to both intersections beyond that required to
   meet concurrency.

   The project team did evaluate a “non-traffic signal solution” at the intersections of 9th with
   Main and Walnut. Under this solution, parking would be removed along the entire length of
   9th Avenue between the northbound approach of Walnut and the southbound approach of
   Main, and so that this section of 9th would be 4 lanes wide. This would result in two lanes of
   traffic at the northbound and southbound stop-controlled approaches of both intersections.
   While it not common to see two lanes at stop-controlled approaches, it is not unheard of.
   Because it would likely take drivers a little time to adjust to this configuration, staff initially
   opted for the more conventional traffic signal solution. However, this solution will be added
   to the Plan as an alternate improvement to address deficiencies at these two locations.

d. Recommend using safety as the basis for prioritizing projects

   Safety is a strong consideration in prioritizing the City’s projects, as is specified in
   Table 3-17. In fact, three of the top five projects listed in Table 3-18 are identified in the Plan
   primarily as safety projects. However, safety is not the only consideration. The GMA
   requires that jurisdictions identify and fund projects that are needed to maintain their adopted
   concurrency programs (projects must be funded, or have funding identified, within 6 years of
   the year that they are triggered). In many cases, concurrency projects would also improve
   safety conditions at the locations where they are implemented.

e. Question about the traffic concerns / congestion issues to / from Ferry Terminal and
   Sound Transit Station (not referenced in Plan)

   The Edmonds Crossing Multimodal Facility is mentioned in Chapter 5 of the Plan and the
   policy section. This project is still planned as a long-range project (in Washington State Ferry
   plan) and addresses many safety improvements, such as a better separation between all the
   different modes of transportation. Additionally, WSF recently chose the Kingston to
   Edmonds route to participate in the reservation pilot program. The main purpose of this
   program is to reduce ferry queuing with a reservation system. The pre-design study began in
   July and an implementation date could be as early as 2011. If implemented, congestion along
   SR-104 during ferry queuing peak hours would be significantly reduced. Traffic generated by
   the existing ferry terminal was taken into account in the modeling and LOS analysis that was
   completed for the Plan.

3/ Response to Al Rutledge’s comments:

   a) Concerns about SR 99 @ 220th St. SW not being mentioned in plan

   The intersection of SR 99 and 220th is addressed in the plan, and included in the 2016-2025
   Transportation Improvement Plan. The proposed improvements consist of widening the
   westbound right turn lane of 220th and the southbound left turn lane of SR 99. Since this
   intersection is along a Highway of Regional Significance (HRS), the intersection was
   analyzed against a concurrency standard of LOS E and therefore not meeting those by 2025
   with LOS F.

   b) Question about Edmonds Way @ 238th St. SW (during TIP Public Hearing)

   This intersection is also identified in the plan, and included in the 2016-2025 Transportation
   Improvement Plan. The existing LOS is F (see Figure 3-10). Since the intersection is along a
   Highway of Statewide Significance, (HSS), the intersection isn’t subject to concurrency and
   thus no City standard is defined. The improvement consists of installing a traffic signal
   (along with meeting one of the traffic signal warrant per analysis and WSDOT approval) – or
   the City would need to coordinate with WSDOT to determine an alternative solution to the
   operational issues that have been identified.

4/ Response to Council President Wilson’s comment:

- Question about providing additional traffic signal warrant studies at 196th @ 88th

   Staff has evaluated the accidents that have occurred at this location from 2008 (end previous
   study) to the present. The Manual of Uniform Traffic Control Devices (MUTCD) states that a
   traffic signal can be warranted (Warrant 7) at an intersection if: “5 or more reported crashes,
   of types susceptible to correction by a traffic control signal, have occurred within a 12-
   month period”. During that time period, only 4 accidents have been recorded at or near the

   intersection and none are characterized as correctable by the installation of a traffic signal.
   Therefore, the intersection currently doesn’t warrant a traffic signal based on the Crash
   Experience Warrant. Since the existing LOS is F (below PSRC Standards as along SR 524),
   the City will continue to monitor the intersection to explore if any other warrants may be met
   (such as volume warrant). Additionally, an alternative was identified in the Plan by limiting
   northbound and southbound movements to right turn only – analysis indicates that this would
   address the LOS problem without installation of a signal.

If you have any additional questions prior to the upcoming Transportation Plan Public Hearing
(09/01/09), please address them to the City Engineer, Mr. Rob English at:


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