Olympia engineer Ed Wiltsie submitted this letter to the Mayor of Yelm, Yelm City Council, Yelm Planning Commssion, & Yelm Planning officials for the Yelm’s Public Hearing of the Comprehensive Plan Update scheduled for October 24th. He granted permission to share his letter with the Yelm Community Blog in this exclusive report:
SUBJECT: Yelm Comprehensive Plan Update September 2006 – Traffic
Mayor, Council, Planning Commission & Mr Grant Beck:
Over the past two years I have commented in writing and verbally numerous times on the fact that the pending Y3 Loop should not be used as justification for the approval of further large development within Yelm. I did not comment separately during the September 2006 Planning Commission Review of the Comprehensive Plan this year, but added my comments to Mr. Kleins letter to provide a single input.
It is my understanding the staff response to this comment was the same as that given in past years, which has been that the Y3 Loop is not being used to justify development.
This statement is in error and this issue needs to be clarified because there is apparently a gross misinterpretation of the concessions that have been allowed in the Comprehensive Plan since 1992.
First, the purpose of the Comprehensive Plan is to provide long range planning, direction for future development and is the basis for the development of future ordinances. The purpose of Traffic Ordinances and traffic studies is to maintain Public Health & Safety and the efficient flow of traffic in support of local commerce. Similarly, City Staff, the Planning Commission and the Mayor and Council are responsible for developing and applying the Comprehensive Plan and subsequent ordinances to provide healthy, safe and effective public environments, facilities and utilities, in this case specifically roads and intersections.
To this end Levels of Service (LOS) for traffic performance have been defined with levels ranging from A to F. In general roadways and intersections are designed to operate at Levels of Service A, B or C. When Levels of Service D and E develop, it is typical that the planning process is engaged to develop and implement actions that remediate the less than desirable conditions. Level of Service F is reserved for conditions that are in a state of failure, meaning that they are UNSAFE and require immediate revision. Typically, when LOS F exists, new development is not permitted until the necessary remedial actions have been taken or it is required that the remediation measures be undertaken as part of the development and prior to occupancy of the facilities.
According to the Yelm Comprehensive Transportation Plan, Yelm Avenue has numerous locations that are designated as Level of Service D or E and one or two intersections that function at Level of Service F. These areas have had substandard Levels of Service since 1992 when the first plan was developed. As part of the Comprehensive Plan 13 improvement alternatives have been identified. The Y3 Loop has been selected as the primary alternative for remediation of the substandard traffic conditions within the Yelm Commercial Core since 1992.
Having selected a primary course of action, language was added to the Comprehensive Plan to temporarily justify moderate continued development during the period required for the implementation of the Y3 Loop mitigation effort:
In the urban core LOS F (failure) is recognized as an acceptable level of service where mitigation to create traffic diversions, bypasses, alternate routes and mode of transportation are authorized and being planned, funded and implemented (Page 12, Transportation Comprehensive Plan)
Hence, the City and all developers involved in new development since 1992 have used the above concession to justify the development. The concession is based on the funding and implementation of the Y3 Loop. As such, the staff response to this item was incorrect.
Second, it is noted that technically, any development approved within Yelm without the Y3 Loop being funded and implemented, worsens already unsafe conditions and is contrary to the purpose of the Citys Comprehensive Transportation Plan, Traffic Ordinances, Planning Commission and Mayor & Council.
Third, it has been 15 years since this concession was made and the original language in the Transportation Plan was adopted. It will be at least another 10 years before the Y3 Loop is open to traffic.
Up until recently, development within Yelm has proceeded at a reasonable rate with modest worsening of the traffic conditions and the execution of modest alternate mitigation, such as continuing streets and limited Yelm Avenue roadway and intersection improvements.
The recent approval of a nearly 200,000 sf WalMart Shopping Center and the 1200 homes in the Tahoma Terra Subdivision constitutes a MAJOR DEPARTURE FROM THE INTENT OF THE TEMPORARY CONCESSIONS granted within the Comprehensive Transportation Plan and will result in grossly accelerated worsening of the published UNSAFE Traffic Conditions.
As there is no designated Level of Service below LOS F, the worsening of traffic conditions have no lower threshold and can only be measured through increased numbers of accidents, injuries and deaths.
At this juncture in the Comprehensive Plan Revision process, there are several questions that City Staff, the Mayor & Council and the Planning Commission must ask themselves:
Is THE INTENT OF THE TEMPORARY CONCESSIONS granted within the Comprehensive Transportation Plan being interpreted as was originally intended?
Is the interpretation being applied at present preserving Public Health and Safety in the Yelm Commercial Core for individuals traveling along the Yelm Avenue?
How far can the LOS F condition (without a lower threshold) be pushed before the application of the concession will be unreasonable and unjustified?
How long can a LOS F be allowed to exist on the Major Thoroughfare of the City of Yelm with temporary concessions before the supporting mitigation measure (Y3 Loop) is in place?
At this time, I believe that the Comprehensive Plan Concessions are being used inappropriately in support of massive development projects that were not the intent of the jurisdictional bodies that justified the incorporation of the concessions into Comprehensive Plan. As such, the concessions no longer provide sufficient rationale for the continuation and worsening of LOS F/UNSAFE Traffic Conditions along the Yelm Commercial Core.
It is on this basis and in an effort to preserve some modicum of Public Traffic Health and Safety, and efficient traffic flow along the Yelm Commercial Core Corridor that Mr. Klein and I have raised this issue for the past two years.
I therefore request that the Mayor & Council, the Planning Commission and City Staff reconsider its recent response to the request that the Y3 Loop not be used to justify further large development along the Yelm Commercial Core and that this language be incorporated into this Comprehensive Plan Revision.
Edward A. Wiltsie, PE
Photo courtesy of Beyond the Ordinary.net