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Home My WebLink AboutComments Miscellaneous 1/4/2008 Attorneys and Counselors at Law Es/obli.,hed 1970 1::'/"''';('1I1"n/,',/'-i,",' ill d COIIII'/".\ U~wl,J.'" 200 FORUM BUILDING 777 Hi~h Street Eugene, OreJton 97401-2782 PHONE 541 686-9160 FAX 541 343-8693 WW\\' ,cugem:.lu\\' .COIll J nmes K. Coons John G. Cox Douglas M. DuPriest Frank C. Gibson Stephen A. Ilutchinsol1 E. Brudley Litchfield Zuck P. ~littgc Thomas M. Orr William 1-1. Sherlock Putrick L. Stevens Murk ,\1. Williams pH'0.......T~ n J JAN 4 20Uo January 3, 2008 BY: Planning Director c/o Steve Hopkins City of Springfield Urban Development Division 225 Fifth Street Springfield, OR 97477 Re: Maple Elemelltanj School Replacemellt/Site Review Our File No, 8893/M1944 Dear Planning Director: This letter is in ,response to City's request for written comments and objections on the foregoing proposal. Our firm represents Mr, Ronald Herbert of 895 23'" Street in Springfield, Oregon, Mr, Herbert is a neighbor of the proposed Maple Elementary School Replacement who objects to the proposed site plan as the newly proposed southern staff parking loti delivery truck route will increase traffic congestion on surrounding residential streets, and exacerbate the growing problems of vandalism and crime in the area, Please include this letter in the record of these proceedings, and include us on your list for all future notices related to this site plan review, including, without limitation, notice of any future decision, As set forth in the City of Springfield's Development Code, the purpose of Site Plan Review is to: "lvIininlize adverse effects on surrounding property OV.lners and tl,e general public through specific approval conditions," 5.17-105(A), Unfortunately, neighbors of the existing Maple Elementary School are already experiencing "adverse effects" associated with the existing school. In particular, the existing school yard backs up against the back yards of a number of houses on Dubens Lane, 23"', and 25th Streets, Vandals and criminals have used the existing open and poorly lit schoolyard as a means to access these houses, and a means of escape, As a result, a number of houses have been burglarized or vandalized by assailants that have gained access from and/ or fled through the existing schoolyard, Additionally, a number of disturbances have occurred on the school property itself, including vandalism, theft and attempted arson, The City of Springfield police have apparently been so overtaxed by disturbances that they have been - Date Received:- \_ A - O<=U Planner: sH Springfield Community Development Department January 3, 2008 Page 2 required to rely on the school principal to attend to these disturbances, and he is routinely contacted to address most disturbances on the property at risk to his own personal safety, The site plan proposed will only make a bad situation worse, Specifically, the site plan calls for locating a staff parking lot in the rear of the site, in the area adjoining these residential homes, After hours, this lot, concealed from view by the school structure and by fencing and plantings on the neighboring properties will provide an ideal location for a variety of criminal activities (drug crimes, prostitution, etc), as well as a ready means of access to the surrounding residential homes, and means of escape, Additionally, the proposed southern access will place an additional burden of traffic congestion on surrounding streets, Currently, there is not southern access to the Maple Elementary School. By adding the new parking lot, the proposal will place substantial traffic burdens associated with the school on streets that currently experience almost no impacts, The Site Plan Review process calls for, amongst other things a "Traffic Impact Study" by a Traffic Engineer as specified in Section 4,2-105A.4, Pursuant to section 4,2-105A.4 the City of Springfield required that the Springfield School District "include an analysis of the new circulation pattern with estimates of the volume and times of entrance/ exit to the access point." Yet, while the Springfield School District contracted with Branch Engineering to prepare a "Nlinor Traffic Impact Study" its conclusions with regard to the new southern access are based almost wholly on conjecture, In particular, there is po analvsis of the raoacitv of the sUTroundin~ r~sidential streets that would be impacted by the proposed southern access, The report assumes (without any apparent basis) that traffic on 23m street is between 300 and 400 trips per day, and asserts that an estimated increase of between 30% and 50% of trips will "not be excessive or unreasonable," However, Branch's conclusions are strictly conjecture based on an assumption, and is not supported by any hard data, The reality for surrounding property owners is likely to be substantially different. First, although Branch Engineering identifies Dubens Lane as a "relevant roadway" and estimates that approximately 25% of the new traffic will use this roadway to access the site, However, Branch Engineering makes no assessment of capacity or even an assumption regarding average daily tri ps on this road, This is particular! y significant in light of the fact that on- street parking presently occurs on both sides of Dubens Lane, which effectively limits it to one-way travel due to the width of the street. This likely will create substantial additional traffic congestion which will adversely impact area residents, _ A .0'6 , ed' \ Date ReceIV . Planner: SH Springfield Community Development Deparbnent January 3,2008 Page 3 Second, Branch Engineering fails to acknowledge that the 30%-50% traffic increase that it estimates on these quiet residential streets will all be concentrated on 23'd street on or about the morning peak hour when the residents are trying to leave their homes to go to work, This will likely create substantial additional congestion during a peak travel time which will be a substantial adverse effect to surrounding property owners, Third, although the Branch Engineering study acknowledges that children and delivery trucks will now be accessing the site through the south entrance, it does not factor in the additional congestion that these pedestrians, cyclists, and trucks will have during the morning rush hour, The proposed sidewalk that would run along the east side of 23ro street for redestrians will not alleviate this congestion as children will have to cross 23' / access at the intersection of "G", 23ro and the site access in order to reach the sidewalk on school grounds leading to the school. Thus, this sidewalk will not alleviate congestion but will only create additional problems for neighbors, who will now have the use of their driveways limited by the presence of the sidewalk. Again, there are likely to be substantial and as yet unassessed adverse effects from the proposed development caused by the traffic congestion at the southern access, Finally, queuing of staff vehicles for morning parking is not addressed, City Engineering and Design Standards require a "throat length" of at least 75 feet "to prevent vehicles from waiting in through lanes to enter the site or causing unsafe conflicts with on-site circulation and parking," 5,08,02, This "throat length" does not appear to have been met for the proposed on-site parking, creating an additional risk that waiting vehicles will back traffic up further into 23'd and "G" Street exit. This gridlock will only have adverse impacts on surrounding property owners in terms of additional congestion on their streets, Additionally, our client, Mr, Herbert would be particularly impacted, as he currently uses oxygen to address a persistent medical condition and the exhaust from the queuing vehicles and parking lot adjoining his property would pose significant health risks, These are substantial adverse effects that should be addressed, Site Review Criteria 5.17-125D requires that: "Parking areas and ingress-egress points have been designed to: facili tate vehicular traffic, bicycle and pedestrian safety to avoid ti " conges on.., As the proposed southern parking lot would create substantial congestion, and jeopardize vehicular traffic, bicycle and pedestrian safety, the site plan c.L should be conditioned to address these concerns, ~ oecei'led: Date" 5\'\ Planner: Springfield Community Development Deparbnent January 3, 2008 Page 4 In particular, Section 5,17-130 of the Springfield Development Code provides that the Director may impose "approval conditions" to "mitigate identified negative impacts to surrounding properties," Based on the foregoing identified negative impacts, and pursuant to the director's authority to "restric[t] and strategically locat[e] driveways" under section 5,17-130C and his inherent authority to require the relocation of portions of the development, we hereby request that the proposed staff parking lot be relocated to the northern portion of the property, This relocation could be merged with existing visitor parking (with appropriate reserved spaces) and configured so as to require no additional access points onto "J Street." This would consolidate the multiple driveways into a single access point, and remove traffic pressure on the surrounding residential streets, Moreover, as staff are currently parking on or near "j" street there would be little if any additional impact on this residential street. Additionally, this parking could be configured such that school staff's vehicles would be visible from the office in the northern lot and would alleviate concerns related to car prowling and vandalism of staff vehicles, Moreover, eliminating the rear lot would eliminate any additional criminal activity associated with the proposed lot, and would also remove the need for several improvements including sidewalks, cross-walks and signage in the area and the expense of those improvements to the project, Conclusion For all the foregoing reasons, the proposed site plan should be conditioned as set forth above, Sincerely. HUTCHINSON, Cox, COONS, DUPRIEST, ORR & SHERLOCK, p,c. -~ ~ william H, Sherlock Zack p, Mittge ZPM/ arc \_A-Oct: Reeei"ed:~ Date SH Planner: