Another Terrible Traffic Study: C’Mon Man!

Both the original Transportation Engineering NorthWest (TENW) Traffic Study for First Light #3026416 at 2000-3rd Ave. and its Update of 1/3/19 (posted 1/16/19) are incomplete and misleading. The foundation of the study’s projection of future traffic volumes (and cumulative impact) is completely invalid having excluded the project’s closest tower neighbors, as we’ve described below:

 #3025502 at 2033-4th Ave.  Located 60 ft away on the same alley: 23-story hotel and apts with no loading berth and no parking.

 #3023678 at 1927-3rd Ave.  Located cross-corner on Third Ave at Virginia:  38-story mixed-residential 340 apts, 159 pkg stalls and 2-25-ft loading berths, one blocked by a column, the other with an inaccessible turn radius.

 #3026266 at 2025-5th Ave. Located 1 blk away sharing Virginia and Lenora St. egress: 44-story, 480 apts, 315 pkg stalls, an undefined loading space that blocks waste and recycling storage.

 #3028017 at 2005-5th Ave.  Located 1 blk away sharing Virginia and Lenora St. egress:  44-story, 440 apts. 292 pkg stalls, 2 loading berths, one dually labeled for trash and recycling.  Turn radius inadequate to the 16’ alley (project incorporates landmarks, no setback required).

 #3023025 at 1915-3rd Ave. Located ½ block away on Third Ave. sharing Virginia St. egress: currently 14-story hotel/apts with no loading berth (waiver requested).  Property recently sold to Bergman Luggage bldg. owners. Plan for that block could grow exponentially. 

Beside these major omissions, TENW’s 1/3/19 Responses to the City’s Correction Transportation Notice #1 and #2 are incomplete and contain assumptions not supported by data.  Following are our comments on each TENW Correction response:

 TENW’s Response to Correction Comment #1:  Parking Supply and Demand.

 Our Comment: Parking demand appears to be greater than the amount of parking provided (441 stalls). The Update’s Attachment B shows owner demand at 395 parking stalls but only 334 are dedicated to residential use. Twenty-five “flex” stalls can be used for residential or commercial. Using all flex stalls for residential provides 359 residential spaces--shorting residential demand by 36 stalls.  It also leaves just 82 spaces for restaurant/office/retail use where the daytime peak demand is 103 spaces with an average of 92 spaces required from 8 a.m. to 6 pm.  

 The study questionably assumes an average of 239 residents will commute by car or otherwise move their vehicles from the garage daily between 8 a.m. to 6 pm. What supports that assumption?  The assumption is contradicted by TENW’s answer to Correction Comment #5 that says “Consistent with other residential projects in the area, it is assumed that any residential trips within the downtown core would be made by non-vehicular mode of travel.”   

 Parking demand will likely exceed availability for tower residents and 600 office/restaurant/retail tenants as well as the project’s neighbors who relied on the previous 65-car surface lot.  TENW needs to answer the correction notice question: “How/where will this excess demand for parking will be accommodated and how will this affect overall parking conditions in the downtown core?”

 TENW’s Response to Correction Comment #2:  Displaced Parking Impacts

 Our Comment: The project is fortunate to have one small remaining surface parking lot on the block to serve its five project neighbors, none of which have parking and will rely on this lot or the alley to accommodate service trucks for deliveries, moving and repairs.  

 The project will also need that small lot. Like most of Seattle’s parking garages, First Light’s garage ceiling height won’t accept common trucks and vans used for repairs, remodels and maintenance.  

 The occupancy estimate for the former surface parking lot appears low. Losing 65 open air spaces will be a blow to surrounding older buildings on that block and beyond. Speaking from personal experience, residents of older buildings with no parking are regularly told by vendors who won’t come downtown it’s because they can’t find parking that will accommodate their trucks. 

 TENW’s Response to Correction Comment #3:  Detail Loading Operations/Alley Impacts.

 Our Comment:  TENW doesn’t answer questions on the frequency and type of commercial deliveries and residential move-ins/outs.  It doesn’t identify the substantial impacts on the adjacent street/alley network.  It inaccurately claims the project has three loading berths when it only has two.  The alley width and berth configuration are not accessible to trucks.  The 25’ berths are smaller than required by code and won’t fit most trucks. The proposed solution of micro-scheduling moving and deliveries is unenforceable and based on being able to predict all traffic conditions.  A schedule is also useless if not coordinated with activities at neighboring buildings.

 At the Oct. 16, 2018 Rec Meeting, Escala presented a detailed study of the issues with the project’s functional design for waste facilities and loading (pp. 3, 8, 11). Public comment that night moved the project architect to say he would like to work toward a better functional design. The developer’s attorney sitting nearby quickly discouraged that offer.

Here’s a link to our October 15, 2018 post on First Light:

 The report illustrates the loading issues that need to be addressed. It is especially critical because a hotel tower (#3025502) is proposed just 60’ away on the same alley.  

 In addition to the Oct. 16 Rec Meeting package, Escala has found data to better estimate the demands of residential towers for package deliveries and move in/outs.  This project will have even greater demands because of its significant office/restaurant/retail space. 

 --Package Deliveries.  A 2017 Hofstra University Study every apartment/condo unit generates 1.5 e-commerce parcel deliveries a week with volume expected to grow 15% annually.  For upper end dwellings, that ratio is likely higher. Using the minimum ratio this project can expect 689 residential parcel deliveries a week or up to 137 a day since most package deliveries occur Mon-Fri. This estimate is residential only and separate from the demands for the tower’s office, restaurant and commercial deliveries and truck visits for maintenance and repair.  

 --Residential Moves. Condo turnover is less than apartments, however First Light is being heavily marketed to overseas investors, has a high rental cap, and is likely to have a high average of units as rentals. Attached is a moving frequency estimate by The Tilghman Group for two mixed-use apartment towers near the project. Even by cutting that moving rate by half, the regular number of moving trucks unable to access or fit First Light’s loading berths will upend neighborhood deliveries by blocking the project’s one-lane alley.


TENW’s Response to Correction Comment #4  Future Non-Motorized Facilities.

No Comment

 TENW’s Response to Correction Comment #5  Project Trip Distribution-Residential.

 Question:  What data is TENW referring to when it states, “Consistent with other residential projects in the area, it is assumed that any residential trips within the downtown core would be made by non-vehicular mode of travel.” 

 Prepared by Megan Kruse

On behalf of Escala


Both SDOT and SDCI need to hold the First Light Applicant accountable for getting the Traffic Study done right and making the design truly functional before allowing it to proceed. If you agree, send your comments to SDCI Director, Nathan Torgelson, , and tell him C’Mon Man, this cannot stand!!