In general, we have no objection to concepts:

1. hiding mechanical equipment vs. the FAR recalculation
2. density transfer preserving environmentally sensitive area (although we remain skeptical on the represented beneficence and extent of practical density on the transfer site)
3. the density increase at the restaurant is not going to cause peak hour traffic generation

However, we see a large potential traffic issue related to Tower Oaks density. While it seems like a cozy pocket, draw the traffic lines too narrowly and you miss an essential reality of critically clogged traffic infrastructure around the CPD.

The Tower Oaks CPD plan dates from 1987. The traffic impact plan dates from 1985. Points:

• Predates current City traffic methodology (1989)
• Produced before much of the road infrastructure in the study existed
• 15 years old in an area of rapid growth and change

• At the time it was undoubtedly a responsible effort. But it is no longer timely.
• Master Plan, Area 12 quote: "Traffic capacity analysis is an iterative process that uses the best available data."
• There has been no iteration on this study in 15 years.
• You've heard reasonable assessments, but they're based on 15-year-old data, which were best guesses at that time.
• Not only the cityscape, but use and behavior patterns have also changed in that time.
• Are you ready to be personally accountable for the accuracy of that data and the study conclusions?

Look at the map, our special concern is the eastbound Wootton Parkway traffic. There are few alternatives/outlets for this traffic flow. It mostly goes to the intersection of Wootton Parkway and Rockville Pike. MDOT has already declared this intersection critical. And just beyond it, on the same roadway, is the intersection of First St. and Viers Mill Rd., which MDOT has already declared a failed intersection. By any measure, the Tower Oaks build-out is going to send approx. 1000 more peak hour trips toward these intersections.

If/when these intersections fail, where are the outlets.

1. Going east on West Edmonston leads to another already failed intersection of Rockville Pike (two left-hand turn movements already prohibited). This further tangles with ingress/egress traffic from newly renovated Wintergreen Plaza. And even if the traffic clears the intersection, it leads to the residential streets of the Twinbrook neighborhood.
2. Going west on West Edmonston, or onto Ritchie Parkway or the Fleet St. stub (which is ostensibly just an extension of Ritchie Parkway as now configured), pours traffic directly onto the residential streets of Hungerford-Stoneridge. Further, with short stacking distances from Rockville Pike intersections, backed-up traffic may actually obstruct neighborhood-destined traffic from access to its own access streets.

Looking at the numbers for the Wootton Parkway/Rockville Pike intersection

929 am 906 pm

225 am 247 pm

296 am 247 pm

Master Plan quote: "… levels of service E & F are not acceptable traffic flow conditions." So this 15 year old analysis indicates we'll reach the threshold of unacceptable traffic conditions, at service level D. Still there are traffic analysis variations contained in the Master Plan for Planning Area 12 (the Tower Oaks area) when compared to the Traffic Impact Study.

Maximum rates suggested: 2.32 am 2.02 pm

25% More generated peak hour trips

1266 am 1235 pm

Already more than the Master Plan capacity (1154)

By either of these alternative factors, this intersection will already exceed its capacity with the existing approved Tower Oaks CPD planning based on 15-year-old assumptions of residual traffic. This suggests a problem.

Further, looking at the trip analysis numbers submitted with the CPD amendment.

At intersection: 829 am 820 pm

Remaining capacity: 325 am 334 pm

At intersection: 1130 am 1118 pm

Remaining capacity: 24 am 36 pm

Using the 22% assumption from the 1985 traffic study, maybe we squeak by. But using the 30% Master Plan assumption, only a very small capacity remains to accommodate all the existing residual traffic. This is not going to cut it.

We think there is a big looming problem here. When we presented these numbers to the Planning Commission, one member mentioned that this analysis suggests the CPD already has too high a density for the roads. We agree, but don't advocate changing the base density or penalizing this developer for a late build-out. However, this CPD amendment is an addition to the already expected bad conditions and is not necessary to pursue the existing approved CPD build-out.

One facet of the CPD process is the Council only gets one chance at getting this approval right. You can't change or withdraw this approval later. The applicant can, applying again for future changes if relevant. We also believe the CPD agreement gives you authority to require further traffic study (staging item IV, item 2) if "1) traffic problems have arisen, and 2) traffic generation trips from the planning area exceed those anticipated under the Plan."

In closing we urge further traffic study. I do so hesitantly because the study is not a solution and may not change the outcome. But moving now otherwise is really acting blindly.