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through movements at any intersection in the study area, then it is not clear <br />how the future baseline condition can be validated. <br />Intersection Operations. <br />a. The Project will include the installation of several roundabouts in the <br />study area. Given background and future truck traffic in this area, the <br />assumptions about radius and design of the roundabouts will critically <br />affect the results of the traffic analysis. Future roundabouts need to be <br />designed to accommodate existing and expected truck traffic, but it is <br />impossible to determine from the DSEIS: (i) the character of the existing <br />and future truck traffic (i.e., length of trucks, volume of truck traffic); (ii) <br />the intended design of the roundabouts, and (iii) how the two relate. <br />b. The DSEIS only provides average level of service (LOS) for study area <br />intersections. Such average LOS output masks the LOS for worst-case <br />turning movements. For example, significant left -turn volumes at the <br />Hardeson Road/Sievers Ducey Road intersection and Glenwood <br />Avenue/Sievers Ducey Road intersection will impact operations at these <br />intersections, but are not disclosed in the DSEIS. Similarly, the new <br />Project intersection on Sievers Ducey Road west of Glenwood Avenue <br />shows significant eastbound -to -northbound left -turning movements in the <br />PM peak hour, but the effects of these volumes on intersection operation is <br />not disclosed. The FSEIS should provide intersection LOS by turning <br />movement. <br />c. Likewise, the FSEIS should provide a queuing analysis for these and other <br />key turning movements in order to fully evaluate intersection operations. <br />d. Comparative turning volumes in the horizon -year conditions for the with - <br />Project vs. baseline conditions provide counterintuitive results. For <br />example, the west -bound to south -bound left -turning volumes at Hardeson <br />Road/Sievers Ducey Road intersection in the PM peak hour are 70% <br />higher in the 2018 industrial development baseline than for the 2018 <br />Project scenario. One would assume that this represents an afternoon <br />exodus of industrial employees in the future condition, but in the 2018 <br />Project scenario there is no corresponding increased level of homebound <br />trips. Part of this discrepancy can be explained by the inordinately high <br />level of 2018 industrial trips (see above), but further investigation will be <br />required to evaluate the trip generation and trip assignment assumptions <br />that lead to such unexpected results. <br />4. Safety. The DSEIS lacks any discussion of traffic or pedestrian safety. <br />5. Concurrency. The DSEIS lacks any discussion of transportation concurrency. <br />5. Relationship to Prior EIS. The DSEIS should clarify how this SEPA review <br />relates to the City's long-standing use of the programmatic EIS approach in <br />Southwest Everett. It is not clear that the DSEIS is intended to replicate the <br />level of analysis included in the City's original programmatic EIS for 4 <br />