AVCA Response to Harry Road/IBM EIR Traffic Impact Section

Page 35 of the Harry Road/IBM Residential Project Draft EIR states that the implementation of the proposed project, "will not result in significant traffic impacts."

That conclusion is disputed here.

The city of San Jose recognizes Level of Service, (LOS), "D" as its lowest level of acceptable service for traffic.  This also is the nationally recognized minimum standard.

The County of Santa Clara, which has jurisdiction over the Almaden Expressway, has accepted a lower standard for minimum service of LOS "E" since 1990.  Looking at definitions of LOS "E", this seems a doubtful decision.

Examination of existing levels of service as of 10/98, page 31, show the Camden/Almaden intersection at LOS levels of "E-" in the AM peak and "E" in the PM peak.

On page 33 of the draft EIR, the addition of already approved but not yet constructed projects will cause the intersection to drop to LOS "F" levels in both the AM and PM peaks.  Clearly these already approved projects should not have been approved.

Attention is called to the descriptions of the LOS levels below.  Allowing this major intersection to descend to LOS "F" means that traffic has reached the saturated level, there is no more road capacity to handle it.

One of the arguments for approval of the Harry Road/IBM project is the fact that the LOS is not degraded.  This criteria is flawed;  LOS "F" is the very bottom;  there is nothing below it.  It is impossible to degrade that LOS further.  Another argument is that the addition of delay is less than 4.0 seconds.  If the cumulative delays of other projects are ignored, all projects can be sized to be approved.

We are focusing on this particular project, but one wonders, looking at the data, how the project that dropped this intersection to LOS "F" managed to be approved.

The addition of traffic is not linear.  It is exponentially dependent on the state of existing traffic, as expressed in the Highway Capacity Manual.  The impact of one more car at LOS "F" is far more than one at LOS "D" for instance.

Clearly the artificial criteria for project approval are not working.  When the project that dropped the Camden/Almaden intersection below LOS "E" was considered, it should have not been approved until highway changes had been made to accommodate the project at the minimum acceptable level.  Until that time, projects should have been put on hold.

In 1995 this intersection was at LOS "D" and has been allowed to deteriorate continuously.

Level of Service Definitions, Signalized Intersections

Level of
Delay in
Volume to
D 25.1-40.0 0.80-0.89 Approaching Unstable, Tolerable Delays:
Drivers may have to wait through more than one
red signal indication. Queues may develop but
dissipate rapidly, without excessive delays.
E 40.1-60.0 0.90-0.99 Unstable Operation, Significant Delays:
Volumes at or near capacity. Vehicles may wait
through several signal cycles. Long queues
form upstream from intersection.
F >60.0 N/A Forced Flow, Excessive Delays: Represents
jammed conditions. Intersection operates below
capacity with low volumes. Queues may block
upstream intersections.

Source: Highway Capacity Manual, Special Report No. 209, Transportation Research Board
Washington, D.C., 1985.