September 19, 2011 Gwen Southerland Chair McMillan Advisory Group 121 Franklin Street, NE, Apt.

K24 Washington, DC 20002 McMillan Sand Filtration Site Development Traffic Impact Study - Review _____________________________________________________________________________________ The McMillan project is a substantial development and as such, the accompanying traffic study should be comprehensive and well documented in its calculations and assumptions. While well written, the report lacked the technical back up and detailed calculations normally associated with traffic studies and as such, verifying the assertions and conclusions of the study is difficult. Whether it is the computation of the traffic projections, use of reduction factors, assignment of projected trips on the network, or the level-of-service analyses performed, the report included insufficient detail to properly validate the technical aspects of the work. This gap does not mean that ultimately we will not concur with the reports efforts and findings, but without the details we cannot concur or refute them. Key comments and observations regarding the review of the McMillan Site Traffic Studyas well as specific information we seekare listed below: General Comment: The original site plan suggests the site was developed with Smart Growth principals. The latest site plan actually seems to segregate the residential, retail and office/medical land use components and dramatically increases the need for driveway access to accomplish this. This is contrary to smart growth/sustainable concepts. Perhaps the developer should abandon the idea of a mixed use site and continue the surrounding street grid through the site and develop it accordingly. 1) Without a figure that clearly shows the immediate environs of the site and all anticipated access/egress points, it is hard to visualize the text on page 13 of the Executive Summary wherein 12 access driveways are described. This is a substantial change from the previous study and it merits an appropriate visual (or at minimum a reference) to accompany the text. 2) Figure 4.1 classifies the segment of North Capitol Street as Freeway. Although it may have limited access, the classification does not seem appropriate. 3) Existing Traffic Assessment, page 19. Three problems.

First, in discussing level of service (LOS) the report states that for signalized intersections, delay is evaluated for the overall intersection. Although the overall LOS is computed and provided in a study, the LOS of each movement should be computed and should be shown. Just showing the overall LOS masks the problems individual approaches and lanes experience. Good operations on an intersection approach on which the McMillan project has no direct impact should not be used to offset or somehow balance the deficiencies on another approach that are in fact caused by the McMillan project. It is necessary to know what potential deficiencies that the project may cause and where they are so adequate and appropriate mitigation be provided. Second, the study does not mention the volume-to-capacity ratio (v/c). This ratio is an equally important concept when determining intersection impacts and is a measurement that the analysis computes. It, along with the actual vehicle delay values, should be reported for each lane group, as well as the designated A thru F characterizations that the report has included. A full picture of the computational measurements is important to clearly show what the impacts are. Simply showing an F for instance does not tell you how bad an F or how bad the delays are expected to be in a future condition. The report lacks this information when conducting its capacity analyses. Lastly, the report fails to mention what analysis program is being used to calculate the levels of service. Although we assume HCS is being used, perhaps another program like Synchro was employed. The report does not mention if the signals are interconnected and are coordinated, as most within the District are. If they are, then a more suitable program to use would be Synchro because it takes into account this important timing aspect, and any timing adjustments proposed as mitigation in a future build condition would be programmed correctly in the roadway network. Treating each location as an independent intersection when each intersection is, in fact, within a coordinated pattern does not properly take into account vehicle queues and arrival patterns that are disrupted and thus could be misleading. These impacts would then not be considered by the level-of-service delay calculations. 4) Traffic Counts, page 20. Although standard professional practice is to analyze the a.m. and p.m. peak periods during the weekday, as the report had considered, because this development contains retail and significant residential land uses, a Saturday peak analysis may be warranted. Especially as many of the reduction factors taken rely on use of public transit, which generally is used less for weekend trips. 5) Existing Traffic Analysis, page 23. As previously mentioned, a detailed table showing the vehicle delays and v/c computations for EACH movement on each approach is warranted for proper assessment. Also, for the traffic signals included in the studyplease note whether they are fixed-time or actuated. The actual computed input and calculation pages should be included in an appendix so that inputs can be validated such as timing, phasing pedestrian movements, and geometry. 6) Future Traffic Impacts, page 24. Please provide a better justification for the 75% reduction in projected traffic for the Irving mixed-use and Washington Hospital Center project. The reduction seems very arbitrary and without valid justification or municipal concurrence. Also, the suggestion that less development may occur at Washington Hospital (page 2, Ex Summary) because of the increased medical office space proposed at McMillan hardly can be considered a positive for this proposal.

7) Additional Network Traffic, page 25. The immediate area around McMillan appears to only experience a small percentage of the total new trips expected to be generated by the other expansion projects. A better breakdown of how the report assigns those trips would beneficial and thus, requested. Also, every segment showed a volume reduction from the August 2010 study except along First Street. First Street remained the sameis this correct? 8) Level-of-Service Analysis, page 26. Comments of #3 above apply here as well. The text mentions the value of a signal at First Street and Channing Street. During the report review, one did not appear to be programmed; however, in the final recommendation section, the signal was listed as mitigation. We suggest this be noted up front to make it clear that the project applicant would be responsible for this improvement. In fact, improvements proposed as part of other project mitigation need to be carefully reviewed and considered as some may not happen, and, therefore, without such roadway improvements, the actual traffic impacts of the McMillan project may be greater and as such, require more mitigation than currently offered by the development. Have signal warrant studies been conducted? 9) McMillan Site Development, page 27. The number of access points proposed seems excessive and inconsistent with access management concepts. Please justify the need for 12 access points on to local streets around this property. No rational was provided at all. 10) Traffic Projections, page 33. Please provide the calculations used to calculate trips. What land use codes were specifically applied and whether regression equations used or average trip rates? Please justify whatever you chose and provide the actual rates and computations for validation. The internal site-capture reduction of 5% and 8% for the A.M. and P.M. was reduced from 2% and 5% respectively, appears reasonablebut how was it ascertained and why was it dropped? Please provide specific documentation from WMATA that supports the very high 22% transit reduction factor used. The 35% retail pass-by trip reduction is excessive, and we do not think it is justifiable. Please explain why such a high figure was used. What such a number means is that one out of every three vehicles that access the retail component of the site will make an impulse decision to turn into the project site to buy groceries. This means that much of generated traffic of the retail component of the site will come from traffic already on the immediate adjacent roadways. This is not a gas station or coffee shop; these are destination land uses and as such, a far lower passerby trip credit seems more appropriate. However, unlike the August 2010 study, the 35% retail pass-by trip reduction is not shown in the table. Please explain. It is also noted, that despite a reduction in the size of several planned land uses the most recent trip generation table indicates substantially higher trips being generated by the McMillan project than the previous study. This is directly attributable to the much higher increased office space. It is further noted that medical office generates trips at a higher daily rate that typical office. The impacts can be substantial.

11) Figure 10.1, page 34. Two concerns. First, the distribution may be reasonable, but more information is requested concerning how the general percentages were derived. Second, the study only includes arrival patterns, but departure patterns need to be shown because several streets are one way and thus, cannot be used for return trips. The patterns for each land use should be provided to ascertain their reasonableness, because residential inhabitants, who may have a propensity to commute toward the DC business district, may have a significantly different pattern than the retail or site-generated office trips. 12) Figure 10.2, page 35. The additional, site-generated traffic needs to be shown in much greater detail. Specifically, the study will be useful only when the newly estimated traffic for each movement at each affected intersection and driveway location is included. Such figures are usually illustrated in traffic volume circle maps. 13) Table 10.2, page 37. See comment 3 above. 14) Transportation Management & Improvements, page 39. It is hard to comment at this stage because the capacity analysis requires a review in much greater detail, which will occur once all the requested information is provided. However, we just note the following: (a) With regard to the proposed infrastructure mitigation most of the proposed mitigation involves installing numerous traffic signalswhich are necessary to specifically enter and leave the McMillan property. It is hard to call these benefits to the community as invariably greater overall traffic delay will be created than currently exists. If a vehicle needs to stop at a driveway location where a signal was not present before, this adds delay to the system. That is a by-product of traffic signals. (b) Signal warrant studies need to be conducted. (c) The analysis must be conducted as a network even more so now as the proposal of so many signals MUST be evaluated as a system and not as independent locations. (d) The other recommendations include a number of widenings along Michigan Avenue, North Capitol Street, and First Street. We can only assume the necessary right of way exists and such road widenings are in fact feasible. Have conceptual drawings been prepared to investigate the viability of the roadway recommendations?

We look forward to reviewing your detailed explanations and report modifications address the above concerns. Please feel free to call 516 318-8529 to speak with our reviewer should you wish to discuss any of the above matters. Sincerely,

Richard Marsanico, PE Sound Engineering