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Trip Generation. We are concerned that the trip generation assumptions used <br />in the DSEIS tend to understate the likely impacts of the Project and overstate <br />the traffic associated with existing and future industrial uses. <br />a. LUC 230 is not an appropriate trip rate to use for ground related <br />townhouses and attached single-family development. This category is <br />more consistent with high-rise multifamily structures, which tend to have <br />significantly lower trip rates that the kind of condominium units to be <br />included in the Project. SEPA requires that the City conduct a worst-case <br />review of potential impacts; in this light, the condominium product in the <br />Project is much more likely to generate trips in the range of single-family <br />detached units (LUC 210). This category should be used. <br />b. Similarly, LUC 223 (mid -rise apartments) is a category applicable to 5 to <br />10 story projects in the urban core, with much higher transit penetration <br />rates than are found in Southwest Everett. Again, use of LUC 210 would <br />be more likely to reflect the true trip generation characteristics of this <br />multifamily project in this location. <br />c. The use of LUC 130 (industrial park) for determining trip generation for <br />industrially -zoned areas is inappropriate in this context. It does not reflect <br />the actual pattern of industrial development in the Southwest Everett area <br />and will tend to overstate the impacts of future industrial development. <br />d. Industrial trip generation is derived in the DSEIS by using a 0.365 FAR <br />(floor area ratio) to determine likely development capacity of the <br />remaining 118.4 acres of industrial land in the area. No source or <br />justification is given for this assumed FAR. It would be more useful to <br />review existing industrial development patterns in the area to determine <br />likely FAR for future development. There is reason to believe that a FAR <br />of 0.25 if more likely to characterize such future development. <br />e. The DSEIS assumes that the full 118.4 acres of industrial land will fully <br />build out by 2018, the horizon year for the Project. This assumption is <br />inconsistent with the DSEIS itself. The Industrial Lands Study (at <br />Appendix C) concludes that the Southwest Everett industrial land supply <br />will be absorbed in approximately 17 years — or 8 years after the horizon <br />year of the Project. Assuming industrial land absorption in this 17 years <br />occurs ratably throughout the planning area, then only approximately 50% <br />of the 118.4 acres of industrial land near the Project site will develop by <br />2018. <br />f. It is not clear that the actual peak hour for industrial uses in the Southwest <br />Everett area corresponds to the peak -hour assumptions on which the ITE <br />trip generation figures are based. The use of flex -time and non-standard <br />shift changes would tend to reduce the impact of industrial use trips in the <br />traditional peak hours. This issue should be explored in the FSEIS. <br />2. Growth Factor, The DSEIS applies a 2% growth factor to existing "turning <br />movements" in order to establish a future baseline condition. It is not <br />explained why the growth factor is applied only to the turning movements and <br />not to all background traffic levels. If no growth factor has been applied to <br />