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Comprehensive Transportation PlanComprehensive Transportation Plan/Moratorium The letter from Ed Wiltsie attempts to build a case for the adoption of a moratorium on big box retail development for reasons he cites from the Yelm Comprehensive Transportation Plan, updated in 2001. This reponse does not address the consistency review issues in the letter, which will be addressed through the consistency review process. General Assumptions The letter assumes that the area of the proposed Wal-Mart was not reviewed as part of the Comprehensive Transportation Plan as being large lot commercial (C-3). In fact, the area in question was annexed in 1993 and was designated, at that time, large lot commercial in the Growth Management Comprehensive Plan. It was assumed that the area was to develop as large lot commercial as part of the Comprehensive Transportation Plan traffic model. Mr. Wiltsie’s letter assumes that the area annexed last month (the Phill Annexation) is now zoned large lot commercial when, in fact, it is zoned heavy commercial (C-2). The ?????The letter assumes that the Phill Annexation area was zoned Rural Residential (1 home per 5 acres) prior to annexation. However, it was actually zoned Arterial Commercial when it was in unincorporated Thurston County. The letter assumes that the future zoning of Yelm’s urban growth area (UGA) was not considered in the 2001 Transportation Plan. However, the traffic model used to develop that plan assumed that the entire UGA would develop at the density and level of commercial activity has designated in the pre-zoning established by the GMA Comprehensive Plan. Point 1 – Level of Service The adopted level of service (LOS) at the intersection of Yelm Avenue and First Street is established as level F because it has been bad for years. If any higher LOS were adopted, any development (even one new single family dwelling on an existing lot) would not be able to meet the concurrency standard and would be denied. An adopted LOS is a failing intersection, but it means that the a failing intersection is accepted. Only if a development caused an intersection to drop, or fall below the adopted LOS, would improvements be required, or be needed to be planned for within the next six years. The City will have to make a finding of concurrency as part of the land use process, which can be appealed to the Hearing Examiner and City Council. Point 2 – ‘Conversion of land’ As noted above, both the GMA Comprehensive Plan and the Comprehensive Transportation Plan identify and analyze the urban growth area based on the adopted pre-zoning, which includes the C-2 area in the Phill Annexation. The Wal-Mart parcel was annexed prior to the GMA plan, and the C-3 zoning was adopted as part of that process. Point 3 – ‘Y2’ is required for consistency This point confuses consistency with policies of the Transportation Plan with concurrency. The City is fully involved with coordination on a regional level from long range planning and capital facilities planning to project review. This is consistent with the policies of the Transportation Plan. What improvements are required at what time is a concurrency issue at the time of development. The City code requires a Traffic Impact Analysis that shows pre-and post-levels of service for all intersections to which a development will add 20 trips a day. In the case of Wal-Mart, 43 intersections will be studied. Mitigation may be required if the development adversely impacts the levels of service at these intersections. Point 4 – Again, the commercial zoning at the east end of town has been in place since the adoption of the GMA plan and was reviewed as part of the Transportation Comprehensive Plan. It is not a change. The level of service is reviewed at the time of development. Nothing was ignored because it was part of the traffic model used for planning purposes. The commercial areas are coordinated with the construction of the SR 510 Yelm Loop. Point 5 – The Transportation Plan and traffic model includes the Phil annexation as Heavy Commercial. Point 6 – Biannual Update The update is a policy of the plan and is not required by any State or City Code.