Advanced Mobility Group | 3003 Oak Rd. Suite 100, Walnut Creek, Ca. 94597 | www.amobility.com
May 3, 2023
San Rafael City Council
City of San Rafael
1400 Fifth Avenue,
San Rafael, CA 94901
Subject: Rebuttal to Appeal of The City of San Rafael Planning Department’s Approval of 1515 4th Street Apartments Project No. (s): PLAN22-039 and ED22-016 Dear San Rafael City Council,
The AMG team was made aware of an appeal to the approval for the mixed-use development at 1515 4th Street. The appeal raised concerns regarding our Local Traffic Analysis (LTA) and we would like to address these below.
AMG properly assessed public health, safety, and traffic safety impacts of the proposed development. The LTA only analyzed the intersections with immediate access to the project site for various reasons.
On September 9, 2022, prior to commencing analysis, City staff outlined the City’s requirements in accordance with San Rafael’s Transportation Analysis Guidelines. This scope identified the intersections providing immediate access to the project site (4th Street/ Shaver Street & 4th Street E Street) as the intersections required for analysis.
During analysis, our team referenced The City of San Rafael’s Transportation Analysis (TA) Guidelines. These guidelines affirm that Tier 2B projects within the Downtown San Rafael Area only need to prepare a Local Traffic Analysis that focuses on assessing project driveways, and 2- 4 intersections providing immediate access to the project site. The AMG team also referenced San Rafael’s Downtown Precise Plan and considers that this plan wholly exhibits the existing conditions in the area. Another reason the team only considered the intersections adjacent to the project site was to create a conservative analysis. If other intersections or roadways had been considered, the number of trips would have been distributed to other roadways minimizing the traffic impact at the study intersections.
AMG also properly assessed the public safety issues on the proposed project’s driveways. The sidewalks adjacent to the project driveways will be separated by an 18-inch planting strip acting as a buffer between pedestrians and the project driveways providing additional safety for pedestrians. This planting strip “buffer” was mentioned under the Roadway Assessment section of our LTA.
Advanced Mobility Group | 3003 Oak Rd. Suite 100, Walnut Creek, Ca. 94597 | www.amobility.com
In addition, a flashing light will be installed at
each driveway to alert pedestrians of any
vehicles exiting the driveway, providing
additional safety. Exhibit 1 shows a similar
flashing light system installed in another San
Rafael project.
In addition to our study, to respond better to
the appeal we did an additional queuing
analysis at the project driveways to ensure
that there was sufficient storage for queuing
at both driveways. At both driveways, a Gate
System will be recessed from the edge of the
driveway, to enhance pedestrian safety on the sidewalk. Exhibit 2 below shows the gate at the driveway entrance for another project in San Rafael.
The garage access gate takes approximately 5-
10 seconds to open and serve a car. Using
Poisson’s Distribution Model, and the trip
generation for the project, the arrival rate at
the driveway is expected to be 0.25 veh/min
and the service rate is 6 veh/min (assuming 10
seconds to serve). Based on the expected
arrival and service rates, the average number
of vehicles in the queue is calculated to be
0.002 vehicles, meaning that the queue length
at the driveways is never expected to be more
than one car. The project driveways have
enough storage to accommodate a car without conflicting with pedestrian activities on the sidewalk.
Our Team properly assessed the roadway conditions on Shaver Street. The proposed development will remove on-street parking fronting the project site on Shaver Street which will increase the roadway width on Shaver Street to 22 feet, which will improve safety and traffic operations on Shaver Street.
The AMG team was also made aware of the peer reviewed traffic analysis by PHA Traffic Consultants. We have prepared a separate response to that peer reviewed traffic analysis.
Exhibit 2: Gate at the Driveway Entrance
Exhibit 1: Flashing Light System
Advanced Mobility Group | 3003 Oak Rd. Suite 100, Walnut Creek, Ca. 94597 | www.amobility.com
After re-reviewing our traffic analysis, we have reconfirmed the proposed project is safe for pedestrians, neighbors, motorists, and residents. The Project also complies with all City Codes, Design Standards, and Industry Safety Guidelines.
Best Regards,
Advanced Mobility Group (AMG),
Joy Bhattacharya, PE, PTOE
[email protected]
(415) 688-0024
Advanced Mobility Group | 3003 Oak Rd. Suite 100, Walnut Creek, Ca. 94597 | www.amobility.com
May 4, 2023
San Rafael City Council
City of San Rafael
1400 Fifth Avenue,
San Rafael, CA 94901
Subject: Rebuttal to Peer Review Response by PHA Transportation Consultants on Local Transportation Analysis (LTA) prepared for 1515 4th Street Dear San Rafael City Council,
The AMG team was made aware that a peer review of our Local Transportation Analysis (LTA) for the mixed-use development at 1515 4th Street was submitted to you as part of an appeal.
The peer review by PHA Transportation Consultants raised concerns regarding our LTA. We will address each concern (italicized text) in the format compiled in the peer review.
Project Descriptions
The project description lacks details on the type of apartments, site traffic access, driveways locations, garage access, and the land uses in the vicinity of the project site. These details are needed for people to visualize the magnitude of the project and how well the project fits in the area.
AMG thoroughly described the project throughout the entire LTA. We followed the scope of work and the requirements for the LTA provided by City Staff. Details on apartment types and land use types surrounding the vicinity of the project are not within our scope of work, per the email and the San Rafael Transportation Analysis (TA) guidelines. Our team went above and beyond describing site traffic access, driveway locations, and garage access in LTA. Please refer to the descriptions in the Site Access and Roadway Assessment sections in our LTA, and Appendix A includes the project site plan where the driveway locations are shown. -LTA adequately describes apartment type, site traffic access, driveway locations, garage access, and surrounding land uses.
Project Trip/Traffic Generation Analysis
The report shows the daily apartment trip generation rate as 2.93 per dwelling unit (ITE land use code 221, “Trip Generation Manual 11th Edition”). This appears Low. The trip rate from the previous “Trip Generation Manual 10th Edition” for the same mid-rise apartment is 5.44 trips per day per dwelling unit. At 2.93 trips per unit per day, the residential portion of the project will generate 475 daily trips, while at 5.44 trips per unit per day, it will generate 881 daily trips. This Advanced Mobility Group | 3003 Oak Rd. Suite 100, Walnut Creek, Ca. 94597 | www.amobility.com
discrepancy means the traffic report may have significantly underestimated the traffic impact of the project.
After re-reviewing our Trip Generation Analysis, we have validated our results. Per San Rafael’s TA guidelines, a Transportation Analysis should use the latest edition of the “Trip Generation Manual” for Trip Generation Analysis. AMG followed these guidelines and used the latest edition of the manual that uses studies that are more pertinent to the project. Also, the value provided in the peer review seems to be an unreliable comparison. Looking at the 10th Edition Trip Generation Manual, we found that the average trip rate for a Multi-family Housing development with four to ten floors of living space in a dense multi-use urban location is 2.59.
This value is actually lower than the 2.93 average trip rate used in our analysis. -Traffic Impact was analyzed adequately in accordance with City TA Guidelines and Latest ITE Code.
The project site is developed and currently occupied by commercial uses. How much more traffic the proposed project will generate compared to the previous use? Are there credits (reductions) taken for the previous use of the site in the traffic analysis? As indicated on Table 4 of the LTA report, no credits were taken for previous commercial use at the project site. If credits had been incorporated, the net new total trips would have been lower. AMG decided to conduct a conservative analysis without taking any credits for the previous use.
-No Credits were taken for the previous use of site in the LTA.
Study Intersection Traffic LOS Analysis
With 162 apartments plus 9,000 square feet of ground floor retail/commercial use, site related traffic will likely access the site from various directions via 4th Street, 3rd Street, Second Street, Shaver Street, and E Street. The traffic report evaluates traffic operations (LOS) on only two intersections along 4th Street near the project site. This is inadequate and will be unable to fully capture the project trips and the traffic impact of the project on the other surrounding intersections.
AMG’s Level of Service Analysis at the study intersections fully captured the traffic impact of the development. The scope sent by City Staff identified the intersections providing immediate access to the project site (4th Street/ Shaver Street & 4th Street E Street) as the intersections required for analysis. The City of San Rafael’s TA Guidelines sustain that Tier 2B projects within the Downtown San Rafael Area will only need to prepare a Local Traffic Analysis that focuses on assessing project driveways, and 2-4 intersections providing immediate access to the project site.
Advanced Mobility Group | 3003 Oak Rd. Suite 100, Walnut Creek, Ca. 94597 | www.amobility.com
The AMG team also referenced San Rafael’s Downtown Precise Plan and considers that this plan comprehensively shows the traffic impact of all the combined development in the area.
Another reason the team only considered the intersections adjacent to the project site was to create a conservative analysis. If other intersections or roadways had been considered, the number of trips would have been distributed to other roadways minimizing the traffic impact at the study intersections.
-Project Trips and Traffic Impact were adequately captured in the LTA.
Traffic Conditions Study Scenario
The traffic report studies only two traffic scenarios, existing and existing plus the project scenario. This is inadequate and will likely miss the cumulative traffic from other proposed but not yet built or occupied development projects in the area. These approved but not yet built projects will add more traffic to the study area affecting traffic operations when they are complete and occupied.
AMG adequately assessed the traffic impact expected to be created by the development in the future. Per San Rafael’s TA Guidelines, projects that are exempt for VMT Analysis do not need to consider other Cumulative or Baseline Conditions in addition to the Existing and Existing Plus Project (Near-Term Condition) Scenarios. The TA guidelines also state that projects consistent with the General Plan will only be required to complete Existing and Near-Term Conditions. As mentioned above, the Downtown Precise Plan analyses the cumulative conditions surrounding the project area in a comprehensive manner and it has been approved and accepted by the City.
-The Project Traffic was studied adequately per City Scope and City TA Guidelines.
Project Site Access (Driveway Access)
The project site plan shows two site access driveways to be located on Shaver Street while pedestrian access will be on E Street. There is a discussion on the stopping sight distance for vehicles, however, there is no discussion on the sight distance between the exiting vehicle and pedestrians on the sidewalk. The sight distance between exiting vehicles and pedestrians is critical if the access driveways (garage driveways) have solid walls on both sides of the driveway while the sidewalks are narrow. In this situation, motorists exiting the garage driveways may not be able to see pedestrians in time to stop until the front end of the vehicle reaches the middle of the sidewalk, thus creating unsafe conditions for pedestrians.
This is especially crucial for vehicles exiting (emerging) from the underground garage, which will make it even more difficult for motorists and pedestrians to see each other.
AMG properly assessed the proposed project’s driveways. Field Work was conducted in which a safe sight distance was verified. The sidewalks adjacent to the project driveways will be Advanced Mobility Group | 3003 Oak Rd. Suite 100, Walnut Creek, Ca. 94597 | www.amobility.com
separated by an 18-inch planting strip acting as a buffer between pedestrians and the project driveways providing additional safety for pedestrians. This planting strip “buffer” was mentioned under the Roadway Assessment section of our LTA. A flashing light system will be installed at each driveway to alert pedestrians of any vehicles exiting the driveway, providing additional safety.
-Sight lines for exiting vehicles are safe for pedestrians.
As discussed earlier, the site access driveways are links between the project site and the adjacent street network. The report did not identify and discuss the number of entering and exiting lanes for the proposed driveways and traffic controls, signs, and security gates needed; and whether or not the driveway design and traffic entering and exiting the driveways would create conflicts with traffic circulation in Shaver Street.
AMG properly assessed the site access of the project driveways. Each driveway will have a lane in each direction separated by a concrete median. A security gate will be installed at each driveway, which will open with a remote control. The width of each lane will be between 11 – 12 feet, which will provide sufficient room for vehicles to enter. These features are shown in Appendix A of the LTA.
-Project driveway design will not create conflicts with traffic circulation on Shaver St.
Shaver Street is a narrow two-way street with parking on both sides and narrow pedestrian sidewalks. The two proposed project access driveways will likely impact traffic operation, pedestrians, and residential access to and from Shaver Street and Latham Street.
As indicated in the LTA report, AMG acknowledged that Shaver Street is a narrow roadway that is 30 feet wide. Currently, the drive aisle width of Shaver St. is 14 ft. The project is relocating on-street parking fronting the project on Shaver Street to 4th & E street, increasing roadway width to 22 feet, making it safer for vehicles to access Shaver Street. As discussed above, the sidewalk adjacent to the project will have an 18-inch planter buffer to provide additional pedestrian safety.
-Shaver St. will continue to be safe for traffic operation, pedestrians, and residential access to and from Shaver St. & Latham St.
Parking (On-Street and On-Site)
The two proposed access driveways on Shaver Street will result in a loss of on-street parking spaces. Will the project provide parking spaces in the parking garage to compensate for the loss of street parking? The project includes 9,000 square feet of retail space on the ground floor. Are there parking spaces in the parking garage designated for retail use? Or will they be accommodated on the street?
Advanced Mobility Group | 3003 Oak Rd. Suite 100, Walnut Creek, Ca. 94597 | www.amobility.com
As indicated in the LTA report, the on-street parking will be relocated to 4th and E Street resulting in no net loss or gain of on-street parking. Besides assuring no loss of on-street parking, no additional parking analysis was required, since the project will not impact or result in parking gain or loss. In addition, parking analysis was not included in the scope of the project per the email sent by City Staff on September 9, 2022, and is not warranted by the City’s guidelines. Per San Rafael Downtown Precise Plan Section 2.3.040 – the Project has no retail parking requirement.
The report does not discuss the internal circulation, drive aisles and how vehicles will navigate within the parking garage, and whether or not some of the parking spaces will be designated for the ground floor retail use.
AMG properly analyzed internal circulation within the parking garage. No vehicles larger than a single unit car will be allowed in the parking garage. As indicated in the LTA report, entrance and exit of vehicles will be adequate. In addition to the report, AMG prepared turning radii diagrams to show that circulation and entrance within the parking garage is adequate. The diagrams are included as an appendix to this letter.
-Internal circulation in parking garage is adequate. As stated above, Project has no retail parking requirement.
Signals Warrant Study for Stop Control Intersections
The intersection of 4th Street and Shaver Street is controlled by a stop sign at the Shaver Street approach. The report needs to discuss whether or not the intersection needs to be signalized with the addition of the project traffic and also traffic from other approved but not yet built projects in the area.
Per the scope of work outlined in the email from City Staff, a Signal Warrant Study was not needed as part of our LTA. Additionally, the Level of service at the 4th Street & Shaver Street intersection is not affected significantly as shown in Table 5 of the LTA report. This table also shows that average delay increases by less than 2 seconds in Existing Plus Project Condition.
With the proposed project, the intersection continues to operate at levels of service that are within acceptable standards of the city, thus a traffic signal is not warranted. However, in response to the peer review, AMG did verify that this intersection does not meet the warrants for installing a traffic signal.
-No traffic signal is warranted with added Project Trips Study Area Traffic Safety
The proposed project site is bordered by 4th Street, 3rd Street, and 2nd Street further south.
All of these streets are crosstown arterial streets that provide access to and from the Freeway US 101. These streets have on-street and must also must share the road with Advanced Mobility Group | 3003 Oak Rd. Suite 100, Walnut Creek, Ca. 94597 | www.amobility.com
bicyclists. Traffic safety is a major concern.
AMG properly evaluated the traffic safety impacts caused by the proposed development. The San Rafael TA guidelines do not require analysis of streets not providing immediate access to the project for Tier 2B projects in Downtown San Rafael. Additionally, Table 4 shows that the project will only create 60 and 71 new peak hour trips in the AM and PM respectively. This is a low number for an area that already experiences high volumes, so these new trips will not aggravate the existing condition.
-Added Project Trips will not cause additional traffic safety concerns.
Conclusion:
After re-reviewing our traffic analysis and reviewing the peer review comments, we have validated our conclusions in the LTA report that the proposed project does not have any significant impact. We have reconfirmed that the proposed project is safe for pedestrians, neighbors, motorists, and residents. The Project also complies with all City Codes, Design Standards, and Industry Safety Guidelines.
Best Regards,
Advanced Mobility Group (AMG),
Joy Bhattacharya, PE, PTOE
[email protected]
(415) 688-0024
Advanced Mobility Group | 3003 Oak Rd. Suite 100, Walnut Creek, Ca. 94597 | www.amobility.com
APPENDIX
The following Sheets contain the Turning Radius Diagrams for the mixed-use development project at 1515 4th Street in San Rafael. These diagrams show the path movement a vehicle may make to safely navigate the project driveways. The diagram shows the path of the centerline turning radius, and its boundaries depict the path taken by the front overhang of the vehicle and the path of the inner wheel.
Sheet 1 shows the turning radius movements of a passenger vehicle entering the project driveways by making a left turn.
Sheet 2 shows the turning radius movements of a passenger vehicle entering the project driveways by making a right turn.
Sheet 3 shows the turning radius movements of a passenger vehicle exiting the project driveways by making a left turn. The driveway sight triangle is also depicted in this sheet per San Rafael Municipal Code Guidelines.
Sheet 4 shows the turning radius movements of a passenger vehicle exiting the project driveways by making a right turn. The driveway sight triangle is also depicted in this sheet per San Rafael Municipal Code Guidelines.
From: Gloria Potter
Sent: Thursday, May 4, 2023 4:41 PM
To: Distrib- City Clerk <[email protected]> Subject: I want to add my name to the list of protestors RE: THE OVERSIZED AND
MISPLACED APARTMENT
BUILDING PLANNED FOR 1515
4TH ST. IN SAN RAFAEL.
A building of that pr
opposed height does not
belong in this area; especially
when there is ground
elsewhere available. At the
most that location should not
have such a high rise structure
with a density which is
overpowering and adding so
much more traffic. San Rafael,
especially its West End is
obviously not prepared for this.
Aside from all the technical
objections it is a monstrosity; a
prison-like design that in my
opinion offends the city of San
Rafael.
Gloria Potter
San Rafael, Ca 94901
From: Irene Langlamet
Sent: Friday, May 5, 2023 9:47 AM
To: Jeff Ballantine <[email protected]> Subject: Re: 1515 4th St. - Proposed Development
Good Morning Jeff,
I would like for you to submit the following comments to the City Council at the May 8, 2023 meeting, please.
The proposal for a 7 - 8 story Mixed-Use building at the 1515 4th St location is certainly out of place for this community! Put it somewhere else! I have no problem with an apartment building there as long as it is not taller than 3 stories.
What happened to the Downtown Master Plan that was all the rage several years ago? Was it thrown out the window?
What is the plan for the abandoned buildings on 4th Street where the Woolsworth store used to be. (ie 1009 4th St.). Are you going to allow an 8 story Mixed-Use building there. Will you let it go higher? Is San Rafael going to become a "Baby San Francisco"? I hope not!
1515 4th Street location with Shaver Street being sooooooo narrow will make it impossible for traffic to move cohesively in either direction. The "New World Order" developer wants to put the ingress and egress onto Shaver St only - why? Wouldn't it be better to have ingress and egress avenues on E St as well, which is wider and can accommodate a third lane to turn. Is it all about "money"? Make as much as you can and move on!
Parking in the neighborhood of Shaver, Latham, Hayes and F Sts is already a parking nightmare as everyone and his neighbor takes advantage of "free parking" in front of our houses - some stay for weeks! The streets are narrow and more and more traffic speeds through Latham St to get away from the stopped traffic on 4th, 3r and 2nd Streets. There are children living in the neighborhood and they frequently play on the street after school.... are they safe? Anybody care?
I would like to urge you to vote "NO" on this project or at least lower the stories to 3. Do you have the power to make changes to this proposal? If not, why do the residents of San Rafael need a "Design Review Board" and a Planning Commission Board or a City Council" for that matter? The residents have spoken at the previous Board meetings to no avail - the project was "rubber stamped"! Sad.
Grant "permit parking" on Shaver (if there is any room for it), Latham St, Hayes St, and F St "free of charge" to residents. Last time we looked into permit parking in the area you all wanted to charge each permit $85.00 - obscene!
Thank you for considering my comments even though I already have a feeling that it will be rubber stamped again! I identify as a taxpayer without representation.
Sincerely,
Irene Langlamet
resident
From: Jenny Kerr
Sent: Friday, May 5, 2023 11:00 AM
To: Distrib- City Clerk <[email protected]> Subject: 1515 4th St.
Dear City Clerk,
I live in Gerstle Park a few blocks from where this housing project is planned. I moved here seven years ago from San Francisco and was instrumental in creating San Rafael PorchFest, for which I booked all the music talent for two years.
I have previously expressed my shock and outrage concerning this charmless, ill-conceived and outsized real estate project that will forever mar the West End in innumerable ways, not least in regards to traffic congestion, but also the health and safety of nearby residents.
The previous study, which was clearly skewed in the developers’ favor, has been proven to be woefully inaccurate by an independent traffic study.
I urge you to do what is right for your constituents in putting the brakes to this project until proper, nonbiased studies can be considered.
Sincerely,
Jennifer Kerr
San Rafael, CA 94901
From: Lou Langlamet Jr
Sent: Friday, May 5, 2023 9:28 AM
To: Distrib- City Clerk <[email protected]> Subject: 1515 4th Street project
Please read this letter as I will be out of town. I have lived in the neighborhood for over 75 years. Their was an apartment building were the phone company is now, they had shallow wells and when the phone company built,they used the water and discharged it into the gutter, creating a green slimy mess that people would shovel out. Will this project create the same problem? I once again challenge the traffic report! The surrounding streets are substandard, two vehicles cannot pass, parking is very scarce! Adding 200 + vehicles is ridiculous! With just two holes in the wall on Shaver is a disaster waiting to happen, especially in an emergency ! The developers are engineers should get off their butts and add at least two more on E st. Marin Eyes on E st and 3 rd has a retaining wall that appears to be failing, being braced against trees on 3rd st. Will this project adversely affect ground stability? This project has a lot of problems! They need to be addressed!
Thank You for letting me express my opinion .
Louis A. Langlamet Jr.
-----Original Message-----
From: Tricia Hall
Sent: Thursday, May 4, 2023 6:08 PM
To: Distrib- City Clerk <[email protected]> Subject: Proposed Large housing and retail project at 1515 4’th St.
We are opposed to the current proposed housing and retail project for 1515 4’th St, San Rafael! It is out of scale with other buildings on the area, provides insufficient parking for poten�al residents and No parking for poten�al customers of the retail establishments. Addi�onally, Marin Water has made No provisions to store or create addi�onal water for the approximately 300-400 addi�onal Marin residents.
This is also an area with insufficient ability to absorb the resul�ng increase in traffic that this size of a housing complex will create.
There are areas closer to a the freeway which are beter suited to a significant housing project although the lack of increased water remains a significant issue ! Also please note that there already is poli�cal discussion in Sacramento to rescind the 2018 ruling which ini�ated “necessitated” the construc�on of this size of a residen�al project and that ruling must Not be the basis of rubber stamping this or other projects that are too large for the local community! Please listen to the community, consider the legi�mate concerns we and other Marin residents have expressed and DO NOT approve of this project which is simply Too Large for the community and will result in traffic nightmares and other significant community problems! Thank you,
Sincerely,Tricia and Tom Hall
Sent from my iPhone
From: Will Beckman
Sent: Thursday, May 4, 2023 2:38 PM
To: Distrib- City Clerk <[email protected]> Subject: 1515 4th St
The entrance/exit on Shaver - routing all car traffic through Shaver is very dangerous and problematic as most traffic will be circling around the building going west and/or flooding the surrounding quiet streets with traffic. It is especially nonsensical from the city’s perspective when we have a broad underutilized E street on the eastern side of the building. I understand it may not be preferable to have the ingress and egress on E from the developers perspective but it’s much for the city and flow of traffic in general. Parking and traffic around the site is already in a stressed state and the additional traffic will be a problem. Analysis of the traffic patterns may show a limited amount of cars but the reason for limited traffic is that the street is so narrow it already requires passing cars to stop as they pass each other.
Latham and Shaver are also a vital pedestrian and bike route for children going from Sun Valley to Davidson Middle School. Adding hundreds of cars on to Shaver and Latham each morning will endanger children attempting to go down those narrow streets on their bikes.
San Rafael should demand a redesign with the garage entrance/exit on E Street and make this development a good example instead of a reviled, mandated eyesore that causes major traffic and parking issues and endangers our children attempting to get to school in the morning. -Will Beckman