Sample Letter - Flawed Traffic Impact Analyses #2

Public Comment Letters Opposing the Project are Due: Monday, July 29th by 5:00 pm!

Here is another Sample / Form Letter for folks to copy / paste / submit to Kyle Smith, Nevada County Senior Planner:Kyle.Smith@nevadacountyca.gov;

You can copy & paste these email addresses for Kyle Smith, the five Nevada County Planning Commissioners, and five Board of Supervisors so they can hear your concerns.

Kyle.Smith@nevadacountyca.govdanny.milman@co.nevada.ca.uslaura.duncan@co.nevada.ca.usTerence.McAteer@co.nevada.ca.usMike.Mastrodonato@co.nevada.ca.usjo.garst@co.nevada.ca.usJo@jogarstdesign.comheidi.hall@nevadacountyca.goved.scofield@nevadacountyca.gov;lisa.swarthout@nevadacountyca.govsue.hoek@nevadacountyca.govHardy.Bullock@nevadacountyca.gov

Traffic Impacts Report – Flawed by outdated data, insufficient turn lane analysis, inadequate sight distance mitigation, questionable level of service (LOS) analysis, and insufficient consideration of broader impacts on traffic, safety, and the environment.

This sample letter can be adapted and personalized to express your concerns about the traffic Impacts created by the proposed Alpenglow Sawmill and Glu-Lam factory. It highlights key reasons why the project’s real traffic impacts will be much greater than evaluated by the applicant and the County.

[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]

[Date]

Nevada County Planning Department

Attn: Kyle Smith, Senior Planner
950 Maidu Avenue, Suite 170

Nevada City, CA 95959

Subject: Opposition to the Traffic Impact Analysis for the Alpenglow Sawmill and Glu-Lam Factory Project

Dear Members of the Nevada County Planning Commission,

I am writing to express my opposition to the proposed Alpenglow Sawmill and Glu-Lam Factory project based on significant concerns regarding the Traffic Impact Analysis (TIA) prepared by LSC Transportation Consultants, Inc. for the project application. Upon reviewing the TIA, I have identified several flaws and inconsistencies that raise serious doubts about the adequacy of the analysis and the resultant mitigations proposed.

1. Outdated Traffic Volume Data

The TIA utilized traffic volumes from the 2019 Hobart Mills Limited Traffic Analysis rather than conducting new counts for 2022. This approach fails to reflect current traffic conditions, particularly in light of potential changes in traffic patterns due to the COVID-19 pandemic. Relying on outdated data does not provide an accurate representation of the existing traffic scenario and its capacity to accommodate additional load.

2. Insufficient Turn Lane Warrant Analysis

The conclusion that new turn lanes are not warranted is based on the NCHRP Report 457. However, this analysis does not fully account for peak seasonal variations or future traffic growth. The high volume of trucks and the potential seasonal increase in traffic during peak summer months could necessitate dedicated turn lanes to ensure safety and efficient traffic flow on SR 89.

3. Inadequate Sight Distance Mitigation

The report suggests that sight distance issues can be mitigated by relocating a speed limit sign and trimming vegetation. This is a temporary solution and does not guarantee long-term safety. Vegetation regrowth and other unforeseen factors could continue to pose a risk at the intersection of SR 89 and Klondike Flat Road.

4. Questionable Level of Service (LOS) Analysis

The LOS analysis indicates that the intersection will operate at LOS A/B with the project. This assessment may not consider the cumulative impact of this and other nearby developments on traffic conditions. The analysis should include a more comprehensive review of potential cumulative impacts to ensure that the LOS does not degrade over time.

5. Vehicle Miles Traveled (VMT) Assumptions

The TIA concludes that the project will result in a net reduction in VMT by providing a local sawmill. However, this conclusion is based on assumptions that may not fully account for regional traffic patterns or the potential for induced demand. A more thorough analysis is needed to accurately assess the project's impact on VMT.

6. Impact on Bicycle Safety

The report's assessment that the project will not negatively impact planned bicycle facilities along SR 89 is insufficient. The presence of heavy trucks on SR 89 poses a significant risk to cyclists, and the analysis does not adequately address the potential safety concerns for non-motorized road users.

Conclusion

Given these significant concerns, I strongly urge the Nevada County Planning Department to require a more thorough and updated Traffic Impact Analysis. Additionally, the scope and potential impacts of the proposed Alpenglow Sawmill and Glu-Lam Factory project should trigger the need for a comprehensive Environmental Impact Report (EIR) rather than a Mitigated Negative Declaration. The EIR process will ensure that all potential impacts are adequately addressed and that appropriate mitigations are implemented.

Thank you for considering my comments. I trust that the Planning Department will take the necessary steps to ensure the safety and well-being of our community.

Sincerely,

[Your Name]