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County Council is now addressing. In our view, one-and-a-quarter parking spaces for each <br />studio apartment may be reasonable, but one- and two-bedroom apartments should have at least <br />two spaces per unit plus space for guests. Indeed, the ordinance that’s currently before the <br />County Council requires two parking spaces per residential unit plus one for every two units for <br />guests; that totals 765 for this project. Accordingly, we believe that many more spaces, perhaps <br />at least as much as 600, are required for the proposed number of residential units. And <br />additional parking will of course be needed for the commercial building. We urge, however, that <br />parking needs be balanced with the need for green areas, which might dictate the need to reduce <br />the number of rental units contemplated in the application, given that’s only 10 acres all together. <br />The third concern is alternative transportation. Because this development is more than a mile <br />from the nearest grocery store, and even farther from educational, civic and other commercial <br />centers, all of which currently require travel along Highway 19, we believe that autos and school <br />buses will necessarily be the primary modes of transportation. To encourage safe walking and <br />cycling, we suggest that the developer provide shared-use paths connecting to civic, education, <br />and commercial centers in the general area. The traffic analysis and circulation plans should <br />include appropriate bicycle and pedestrian facilities connecting this development to the <br />community, and provision for public transportation and shuttle service capabilities. <br />We have some other concerns. Although the State is responsible for public school education, the <br />County has to note the effect of a large, school-age population on road infrastructure and traffic <br />safety issues. Incredibly, neither this application nor the accompanying TIAR mentions schools, <br />or the significant school traffic that will be generated by this and adjacent developments. Here, <br />because the nearest schools are not within a safe or reasonable walking distance, we can expect <br />that 200 or more school-age children will require bus or other transportation along Highway 19, <br />Kaiminani, and Highway 190/Palani Road, adding greatly to the congestion on those roads <br />during peak hours. <br />In that regard, we question the applicant’s failure to recommend any traffic congestion mitigation <br />at several key area intersections, because, as asserted by the applicant, the Levels of Service with <br />or without this project wouldn’t change. That assertion is misleading, because Level of “E,” for <br />example, means delays of between 30.1 to 45 seconds. So if the average delay had been 30.1 <br />seconds before this development, and the development increased the delay by 14 seconds, it <br />would still be Level of Service “E” despite the delay having increased nearly 50%. Therefore, <br />even if the additional delays inevitably caused by this development don’t change the Level of <br />Service, we believe that mitigation measures are appropriate and should be required. <br />We also note that the TIAR accompanying the application was based on a traffic count that is <br />more than one-and-a-half years old, and that traffic has notably increased since then. Perhaps, an <br />updated TIAR prepared by a traffic consultant chosen by the County and using more recent <br />traffic counts and paid for by the applicant will be more objective. <br />Finally, the developer ought to include traffic calming features in the internal road layout and on <br />the roads immediately external to the project. <br />So to summarize our recommendations in interest of better traffic safety and flow, we urge: 1) <br />require a second access route, 2) require at least 600 parking spaces, or better yet, require what <br />the current draft ordinance before the County Council requires, or reduce the number of dwelling <br />EXHIBIT B <br />7 <br /> <br />