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HomeMy WebLinkAbout09. SEPA2022-038 Comments COP (Signed) 11-14-22 � 1..��.yrj ���0 Community Development Department � PO Box 293,525 N 3�d Ave, Pasco,WA 99301 P:509.545.3441/F-509.545.3499 November 14, 2022 Attention: Elizabeth Smith, Planner J-U-B Engineers, Inc. 3611 S. Sintel Canyon Way Kennewick, Washington 99337 Subject: Draft Environmental Impact Statement for the proposed City of Pasco Comprehensive Plan Amendment—Jubilee Foundation/New Heritage; CPA2002-003 &SEPA2022-038 The City of Pasco appreciates the opportunity to review and submit comments on the proposed 2022 Comprehensive Plan Future Land Use Amendment on the on the Jubilee Foundation/New Heritage proposal. The following comments and questions have been prepared by City of Pasco staff to be addressed and/or considered for incorporation in the environmental report. Sewer 1. The DEIS only references the City's 2014 Capital Sewer Plan (CSP). The review of sewer impacts from the proposed Land Use Amendment should be updated based on the 2021 CSP Addendum to see possible differences in capacity for this area. 2. The Maitland LS should have capacity, but the gravity main downstream of the proposed Land Use Amendment has some sections expected to exceed 80% capacity in the coming years, which could be problematic with the proposed change in land use, likely causing significantly more flow to be conveyed through this portion of the collection system. Water 1. The DEIS appears to rely on future storage in Zone 2. The most recent Capital Improvement Plan shows this storage reservoir not being completed until 2026, provided funding support can be obtained prior to the start of the project.This raises the concern that the proposed Land Use Amendment won't be able to be accommodated until the Zone 2 water reservoir is constructed. 2. Given the proposed Land Use Amendment location is in Zone 2, it essentially receives the majority of its water directly from the East Side BPS, which is already starting to get stressed (at least during the heavy processing months). Residential developments may have a bigger impact on peak flows in the morning and evening than an industrial user might have. 3. The City encourages the applicant to contact RH2 Engineering to ensure the appropriate evaluation and potential impacts ofthe proposed amendment are known based on the most recent data for water and sewer utilities. Transportation 1. Page 62, Road 40 East is incorrectly referred to as East 40th Avenue. Same issue on Page 3 in Appendix 3. Page 2 in Appendix 3, similar issue where Road 40 East is referred to as East 40th Street. 2. Page 63 states 1,315 PM peak hour external trips are generated by Alternative 1, but Table 20 and Table 3-1 shows 1,334 external trips. 3. The analysis should consider the added traffic from the industrial park Tarragon Pasco-111 to the east on Road 40 East, and additionally the new connection between Road 40 East and Heritage Boulevard.The new connection to Road 40 East may impact the 4%inbound and 3%outbound traffic to US-12 east of A Street.Consider expanding the scope of this analysis to include the intersections of Road 40 East & Sacajawea Park Road and US-12 & Sacajawea Park Road/Tank Farm Road. 4. Page 63 mentions acceptable LOS but the acceptable levels of service are not defined in the document. What are the acceptable LOS thresholds, which intersection types to they apply to (AWSC,TWSC, Signal, etc.), and whose standards are applied to each intersection (City of Pasco, Washington State Department of Transportation, etc.)? 5. The report covers PM peak hour analysis. Please confirm why AM analysis was not performed for any portion of the study area, including WSDOT facilities. 6. Level of service calculations, analysis methodologies, traffic volumes, and supporting documentation should be included as technical appendices. 7. Page 65 refers to Alternative 2 as Medium Density Alternative, but in other parts of the report (such as Page 7 in Appendix 3, or Table 3-1) it is referred to as Medium Intensity, or Mixed Use. Use a consistent name for each alternative. 8. Page 65 states 1,140 external trips are generated by Alternative 2, but Table 20 and Table 3-1 shows 1,138 external trips. Additionally, this page states 56% of trips are inbound but Table 3-1 shows 58% inbound when calculated. 9. Page 66 states that the Comprehensive Plan does not specify industrial land uses for the site. As mentioned elsewhere in the report, the site is zoned I-2 Medium Industrial. This zoning designation has a defined set of acceptable land uses. Revise this sentence to clarify the zoning for the site and the associated restriction for industrial land uses that are allowed. 10. Page 66 states 1,235 PM peak hour trips are generated by Alternative 3, but Table 20 and Table 3-1 shows 1,237 external trips. 11. Is a v/c of 1.0 the threshold for mitigation?Or 0.70? It is not clear what the target v/c is for roadway segments, if they differ per functional classification, and whose standards are being used (City of Pasco? BFCOG?WSDOT?). 12. Mitigation measures in section 6.9.3 are specific to certain intersections, please (ist or tabulate the intersections and roadway segments that require mitigation for each alternative. 13. Table 21 should also show the segment mitigation improvement as it is included in Table 3-3 on page 9 of Appendix 3. 14. On Figure 8 (and relateci figures, including those at the end of Appendix 3), please include a note for the segment mitigation where US-12 ramp improvements are needed per Table 3-3. 15. Appendix 3 page 2 states that traffic volumes for the 2018 year were collected by BFCOG. Are these segment volumes or intersection turning movement counts? Include the volumes in an appendix or plot them on a figure for review. 16. Appendix 3 page 2 states that capacities from the regional model were used for each roadway. What are the capacities for roadways? Do they depend on functional classification, speed limits, presence of TWLTL, or other factors? A table or general description of this information is needed. 17. Appendix 3 page 2 states that an adjustment factor is applied to the capacity of intersections.What are these factors and how are they calculated?What was the base assumed capacity of each type of intersection? 18. Appendix 3 page 3 states that the same methodology for planning level analysis was used as the Transportation Element of the Comprehensive Plan. What is this methodology? More detail is needed. 19. Does the BFCOG travel demand model contain population and employment forecasts for 2038 (per Comprehensive Plan) or 2040?The report seems to suggest 2040 is the forecast year. Do all cities in the BFCOG area contain updated 2040 population and employment forecasts? 20. The title for Table 3-1 should specify that the values shown are for the PM peak hour only. Additionally, specify the alternative numbers (1, 2, 3)for the column headers. 21. The trips for the preferred alternative on Table 3-1 are not summed correctly. 867+660-213=1,314 not 1,334. Similar issue with Alternative 2. 22. The trip distribution methodology described on page 5 of Appendix 3 states that a cordon line around the study area was used to measure existing volumes across the cordon during the PM peak hour. This estimate may skew the distribution towards regional travel patterns which may not be the same between each alternative, as was mentioned in the report on page 6 of Appendix 3 where the No Action alternative is stated to have primarily employment trips rather than residential or services in the other two alternatives.A select-zone analysis would provide much better accuracy for each alternative's trip distribution and can be unique to each alternative (although Alternative 1 and 2 likely are similar enough to assume the same trip distribution). 23. Appendix 3 page 8 states that more detailed analysis will be performed with a development proposal. Is this referring to the Traffic Impact Analysis, or does this refer to something else? 24. Trip generation was performed using ITE's Trip Generation Manual 10th Edition. This edition was deprecated in September of 2021 with the release of the 11th Edition, pfease update the trip generation accordingly. 25. An internal trip reduction was applied to all 3 alternatives. How was this reduction calculated, using what methodology and assumptions? Show supporting docum�ntation and detail the methodology. 26. Do the Comprehensive Plan v/c ratios at the end of Appendix 3 show v/c results for 2038 or 2040?There is no year in the figure title. 27. A more readable method to show v/c impacts would be to show the change in v/c between the Comprehensive Plan and each of the 3 alternatives, highlighting changes that exceed the target v/c. Consider adding this to the report. Thank you for the opportunity to provide comments. If you have any questions, please contact our office. Sincerely, ( Rick White, Director City of Pasco, Community and Economic Development @pasco-wa.�ov � (509) 545-3441