The Planning Commission has once again continued the EIR certification hearing for the proposed 32-unit Forge Lodge bed and breakfast located at the intersection of PCH and Corral Canyon Road. The new date is currently Nov. 18. If you occupy one of the 30,000-plus vehicles that pass through this intersection daily, the facts presented and conclusions drawn by this EIR affect you.
The traffic impact analysis presented in the EIR is based largely on the results of a report prepared by KAKU Associates in June, 1999. The EIR concludes that (1) the impact upon traffic at the Corral Canyon intersection during weekday morning, weekday afternoon, and Saturday mid-day peak hours would be “less than significant,” and that (2) existing gaps in traffic are sufficient to allow left turns to be made safely into and out of the lodge entrance. These conclusions deserve your scrutiny.
The EIR’s “less than significant” conclusion is based on Level of Service (LOS) measurements. LOS is a traffic methodology that, when applied to current or projected traffic conditions, produces ratings ranging from excellent conditions (LOS “A”) to failing or overload conditions (LOS “F”). The EIR assigns separate LOS ratings based on projected 2003 traffic conditions at the Corral Canyon intersection with and without the Forge Lodge project.
What factors determine the LOS rating? Apparently just one. LOS ratings are based on “average vehicle delay.” Ratings for the Corral Canyon intersection are largely determined by the time it takes to turn left onto PCH from Corral Canyon Road. An average delay of 0-5 seconds equates to an optimal LOS rating of “A.” Forty-five seconds or more equates to a failing “F.” It’s all about throughput, not safety.
2003 LOS ratings were derived from measured traffic volumes. Weekday morning and afternoon traffic counts were “obtained from recent traffic counts conducted in 1997 and factored upward to reflect 1999 conditions.” These 1999 numbers were then “factored upward” once again to obtain the 2003 weekday estimates. A Saturday traffic count was conducted in March 1999, factored upward by 30 percent to reflect summer volume, then factored upward again to estimated 2003 summer levels. 1997 may be “recent” in geologic time, but the factored 1997 data supporting this EIR is yesterday’s news, and 30,000 daily travelers deserve better.
So how does the EIR use LOS ratings to arrive at its “less than significant” conclusion? It’s more simple than you might think. The projected 2003 LOS at the Corral Canyon intersection during weekday morning, weekday afternoon, and Saturday mid-day peak hours is a consistent failing “F” with or without the Forge Lodge project. The apparent logic is “it doesn’t get any worse than “F,” so what difference does a little more traffic make?” This is the “lost cause” argument, and it is often used to justify making a bad situation worse.
Missing from the EIR’s traffic impact assessment is any mention of the safety implications of failing LOS ratings. The EIR’s “less than significant” traffic assessment is a clinical application of mathematical queuing theory, and it completely ignores the fact that as “average vehicle delay” increases, so does traffic and the incidence of accidents, injury, and death. This type of analysis is well-suited to the check-out line at Ralphs, but it is woefully incomplete and inadequate when applied to issues of public safety.
The EIR contains a separate analysis of the hazards created by vehicles making left turns into and out of the proposed lodge site. This analysis is also dated, and is based on a gap/access analysis conducted on two successive Wednesday afternoons in March 1997. The EIR concludes that “the existing gaps along Pacific Coast Highway would be sufficient to allow the projected left-turns to occur safely.” The EIR does not attempt to reconcile this conclusion with its earlier assessment that the Corral Canyon intersection, just 100 yards west, will operate at LOS “F” with or without the lodge.
The incremental impact of the Forge Lodge traffic would be minimal, but not insignificant. The Corral Canyon intersection is currently maxed out, and any impact of any size is very significant.
The good news is that we can fix this. This is not the drug war, nor is it global terrorism. It’s a stretch of asphalt in need of a traffic signal. We’re also fortunate that it’s one of a dwindling number of problems that we can still kill with money.
Approval of Forge Lodge project in any form must be contingent on the concurrent installation of a traffic signal at the intersection of PCH and Corral Canyon Road. Approval otherwise would be to succumb to the “lost cause” argument put forth in a questionable EIR.
Al Whittemore