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Home My WebLink AboutThe Proposed Fifth Avenue Urban Renewal Area Plan and Retail Center Project (IKEA) Comments on the October 2000 DEIS 12/14/2000 THE PROPOSED FIFTH AVENUE URBAN RENEWAL AREA PLAN AND RETAIL CENTER PROJECT (IKEA) Agi,„""\ •, 7/4, • • •S 14% ‘4"441.4111 (Cv kik 1 A `' Comments on the October 2000 DEIS Prepared on Behalf of the Town of Mamaroneck SFr' Prepared by Buckhurst, Fish & Jacquemart, Inc. December 14, 2000 Action: Public Hearing and Comments on a Draft Environmental Impact Statement (DEIS) Project: Fifth Avenue Urban Renewal Area and Retail Center Project (IKEA) Location: New Rochelle, New York This report supplements the verbal comments made to the New Rochelle City Council at the November 16, 2000 Public Hearing. The comments were made by the Town Supervisor, Town Board members of the Town of Mamaroneck, and by the consultant team to the Town. Prepared for Town of Mamaroneck Town Board Mamaroneck, New York Prepared by Buckhurst, Fish & Jacquemart, Inc. 881 Broadway New York, New York 10002-1216 In association with Earth Tech Inc., Visual Simulation TAMS, Inc., Air Quality December 14, 2000 TABLE OF CONTENTS: IKEA DEIS REVIEW FOR THE TOWN OF MAMARONECK 1.0 GOOD PLANS ARE IGNORED, MISLEADING PLANS ARE PROMOTED 1 1.1 New Rochelle 1996 Comprehensive Plan 1 1.2 Blight Study and Urban Renewal Plan 2 1.3 Patterns for Westchester: The Land and the People 3 2.0 REAL ALTERNATIVES ARE NEEDED 7 2.1 Upgrade the Existing Neighborhood 7 2.2 Mixed Uses Alternative 7 2.3 Industrial and Commercial Use Alternative 8 3.0 TRAFFIC IMPACT ANALYSIS IS DEFICIENT 14 3.1 Traffic Generation and Choice of Analysis Hours are Flawed 14 3.2 Distribution and Assignment of IKEA Traffic are Flawed 15 3.3. IKEA Impacts on 1-95: Fatal Flaw of IKEA DEIS 16 3.4 DEIS Mitigation Measures Are Not Realistic 18 4.0 COMMUNITY CHARACTER WILL BE DAMAGED 29 4.1 Neighborhood Roads 29 4.2 Visual Simulation 33 4.3 Air Quality 35 4.4 Noise 36 4.5 Lack of Mitigation Measures for Impacts on Neighborhood Character 38 5.0 OTHER ENVIRONMENTAL CONCERNS 43 5.1 New York State designated Significant Fish and Wildlife Habitat 43 5.2 Stormwater Drainage 45 1.0 GOOD PLANS ARE IGNORED, MISLEADING PLANS ARE PROMOTED 1.1 New Rochelle 1996 Comprehensive Plan In the DEIS section on Land Use, Zoning, and Public Policy, a short history of planning for the Fifth Avenue-City Park area is presented. The common theme through three decades of thoughtful planning is that this neighborhood offered New Rochelle some limited opportunities to fulfill a city- wide policy of encouraging commercial and industrial growth. For years, this area has been troubled by underutilization, lack of public investment, an inadequate street network, and insufficient parking, and loading areas. However, the city saw that it could be restored to health with an appropriate mix of uses and public investment. The city's current Comprehensive Plan, adopted by City Council in 1996, builds upon the preceding years of analysis. Despite the city's long involvement in thinking about the advantages and needs of Fifth Avenue's industrial area, little had been done to implement earlier recommendations. The Comprehensive Plan, now the successor to other land use plans, presents its own Planning Proposal — its vision - for Fifth Avenue. We use the word vision because that is the 1996 Plan's foundation. The plan took ten months to accomplish. Nearly the same amount of time — nine months — preceded this, in a community visions process. The whole planning process included city staff and officials, the Future Visions Advisory Committee, the Comprehensive Plan Advisory Committee, City Council, consultants, and meetings with key organizations, stakeholders, and the public. The resulting plan has the traditional components of a master plan, but more importantly it offers specific and imaginative physical land use plans for six critical areas. Each planning proposal — for the downtown, Center City (renamed from North Avenue), the waterfront, East Main and Echo, West Main and Weyman, and finally Fifth Avenue - finds strengths unique to the area and builds upon these; the areas are to be improved, not surgically altered. These six proposals were subjected to remarkable public involvement. Their ideas and recommendations have been vetted. In the Comprehensive Plan, there is a succinct discussion (page III-53) of the Fifth Avenue area's tangle of development possibilities and obstacles. The plan cites just three physical characteristics that make this area "an economic resource for the city even though several conditions make redevelopment difficult" — narrow streets, limited on-site parking, and truck congestion. The DEIS claims that the IKEA proposal conforms with the Comprehensive Plan, as the plan "slated the 16.4 acres along Fifth Avenue for redevelopment based upon their incompatible land uses, obsolete structures, and other blighting influences." This proposition cannot be found in the Comprehensive Plan's proposal for Fifth Avenue. IKEA does not conform to the Comprehensive Plan. The word blight, the word slum, the words negative and blighting influences are never used. The comprehensive plan's clear finding of three very specific traffic-related problems is followed by three, modest recommendations: 1. Combine unbuilt streets in the industrial area with other underutilized parcel to create large development sites, where possible. 2. New development should be light industry, commercial uses, or public service uses. 3. Development parcels and assembled sites should have adequate access and on-site parking to free up narrow roadways. There is no rezoning recommendation. There is no recommendation for a single, large retail store. There is no recommendation — there is no anticipation - of a single large, retail business, immensely different from its surroundings; one that will not only change its surroundings but those across a municipal border. There is no recommendation for urban renewal or redevelopment of over sixteen acres. There is no recommendation that fifteen acres of a 16.4 urban renewal area should be Page 1 assembled in one monolithic tract, for one non-industrial, private use. A scraped site swallowed by a big box was not the city's original vision for this area. The three modest recommendations are in line with the years of previous work. They were tested by local property owners and residents as part of the planning process. They are the City's vision. How can the City now act on impulse, turning its back on its own plan, its own vision? A plain and hard-working part of New Rochelle, requiring a few good actions on the part of the city, is transformed through an official study, into "a negative and blighting effect on the neighborhood and on the overall development plan for the City of New Rochelle." What is the larger significance of this ad hoc disregard of its own adopted development plan? The project allows the city to disavow all the earlier planning efforts. The community vision for the downtown, Center City, East Main and Echo, West Main and Weyman, and the Long Island Sound can now be disavowed. 1.2 Blight Study and Urban Renewal Plan New Rochelle has three primary documents addressing the Fifth Avenue area. The first, the 1996 Comprehensive Plan, is discussed above. The two others are the Fifth Avenue Urban Renewal Blight Study, prepared April 1999 by Ferrandino & Associates and adopted by the City Council in July 1999, and the Fifth Avenue Urban Renewal Area and Plan (draft dated April 2000). It is our view that the DEIS should include the text and maps of both documents, and discuss both. In the DEIS section on Land Use, Zoning, and Public Policy, we find incomplete information. In Section 3.1.6, Existing Public Policy, the DEIS discusses the blight study but not the urban renewal plan as part of New Rochelle's existing public policy for the Fifth Avenue area. In Section 3.1.9, Public Policy, the DEIS discusses the IKEA proposal's conformity with existing policy documents. In this section, the urban renewal plan is discussed, but not the blight study. In Volume 2 of the DEIS, the urban renewal plan is provided, (in its draft April 2000 version), but the blight study is not. In addition to these studies there should be a thorough discussion of the Religious Land Use and Institutionalized Persons Act signed by President Clinton in September 2000. This law requires that restrictions on church property that place a "substantial burden" on religious practice must have a "compelling government interest" and is the "least restrictive means" of doing so. It is not clear that New Rochelle could use its eminent domain powers to condemn two churches, and comply with this Act. The following comments on the blight study are based on the DEIS's presentation of that study (p.3.1-20) in Volume 1 and the summary presented in the Fifth Avenue Urban Renewal Area and Plan (draft dated April 2000) in Volume 2. The finding of blight was based on a field assessment, using a number of criteria. One part of the assessment ranked lots and structures to determine condition and blighting influence. The field assessment found that 70% of the buildings—46 out of 66 — were in fair or better condition. Nearly 50% of the lots were in fair or better condition regarding their blighting influence on the neighborhood. These two findings, based on the study's own assessment, contradict a finding of blight. We conducted our own field assessment; this is discussed in more detail in Section 2, Real Alternatives Are Needed. We found that 56 of the 66 were in fair or better condition, or 84 percent. Some of the other criteria used to make the blight finding were improper land use, incompatible land use, and visual cacophony. We question the validity of some of these criteria and their use in the Fifth Avenue area. In general, the planning literature recommends a mix of uses in urban and suburban areas. Downtowns are classic examples of the benefits of heterogeneous land uses and activities. Should New Rochelle's downtown or Center City be stigmatized as blighted, now that new housing and entertainment are joining stores, services, churches, and schools? The emerging American planning philosophy of New Urbanism is founded on an appreciation of a mix of uses, design, and scale. Blight can never be simply identified as the presence of different uses. Blight is Page 2 created by poor physical conditions. The blight study should be revisited to more carefully examine truly blighting influence and stress building conditions not mixture of uses. Our field visits to the area and our reading of the Visual Character and Socioeconomic sections of the DEIS have us question other criteria used in the blight study: obsolete layouts, irregular block and lot size, insufficient lot size for redevelopment, street inadequacy, stagnant and unproductive condition of land, vacant land, and economic underdevelopment or obsolescence. We see an area in transition from a mixed-use neighborhood, which includes a small residential community, to a commercial and industrial area, hampered by inadequate public investment and restrictive zoning. Some of the blighting conditions, such as street inadequacy, have persisted for years and are well- known to the city. The DEIS points out (p.3.6-7) "public investments have languished as well. Streets, curbs, sidewalks, and streetscape amenities such as street trees and turf, have all deteriorated over the years due to little capital improvement resources." Since 1965, New Rochelle has recognized in its official land use planning documents the need for public reinvestment in the Fifth Avenue area in order to attract economic development. Now, the city discovers it has a "blighted" neighborhood whose only hope is to be razed to create a development site for one single retail business. The blight study preceded the urban renewal plan, as it should. But the urban renewal plan is really an IKEA plan. On page 6, the plan proposes "a large scale retail development" as the method for urban renewal. The proposed store would "encourage reinvestment in New Rochelle at large as the City is reestablished as a regional shopping destination." The plan is not an honest appraisal of real alternatives for the Fifth Avenue neighborhood. It is the rationale for sacrificing a neglected neighborhood. The public purposes of the urban renewal plan are insufficiently explained. On page 4 of the April 2000 plan, a partial list of redevelopment objectives is given. The objectives are also called development goals and are said to derive from the New Rochelle Comprehensive Plan "and subsequent studies." All nine of the objectives are sensible. What is not clear is why these goals can only be achieved through the destruction of a 15 to 16 acre neighborhood for the benefit of big box retail. The City of New Rochelle could still redeem its obligation to the owners and tenants of the Fifth Avenue neighborhood. The urban renewal plan could dedicate the city to the same redevelopment goals, but embark on an alternative journey on Fifth Avenue. The city should strengthen the neighborhood according to the specific Comprehensive Plan planning proposal, reinvest public funds in the neighborhood, amend local zoning to remove disincentives to residential property- owners, improve the street network and streetscape, rehabilitate existing commercial structures, target eminent domain toward truly blighted structures, and ensure sustained code enforcement. 1.3 Patterns for Westchester: The Land and the People Patterns(1996) is the county's general plan. It is a "broad policy framework for governmental action to guide the county's future physical development... [and] a coherent set of standards for the Westchester County Planning Board as it carries out its...Charter responsibilities." Patterns is not a substitute for home-rule based municipal planning; its policies and recommendations cannot replace those of the county's 45 individual cities, towns, and villages. The DEIS states that the IKEA proposal conforms to Policy 1, Policy 2, and Policy 4 of Patterns. The project does conform to certain parts of Policies 1, 2, and 4 by building in a major corridor where existing infrastructure is already established. However, the project is inconsistent with many of the other elements of the policies, as follows. The overall project fails to address Policy 2, since it does not "adapt already developed sections into efficient and attractive multi-use places." Moreover, it does not "protect the quality of scenic Page 3 routes by making road and transit improvements that will reduce congestion and ease movement on travel routes." Instead it will eradicate a multi-use area and create traffic congestion. The project is also inconsistent with Policy 3. This project does not "assure a diverse and interconnected system of open space to shape development, to provide contrast in the texture of the landscape, to separate developed areas and to relate to open space systems of the region." In effect, this project will cut off a major open space in New Rochelle, by making the playing fields and park area on Fifth Avenue almost inaccessible, due to traffic. The project also does not conform to Policy 4. It does not "nurture infrastructure, housing, and programs that support business enterprise, with particular attention on intermunicipal impacts." Although the DEIS acknowledges impacts on neighboring communities, it does not offer any mitigation to ease those negative effects. The project is inconsistent with Policy 6, since it does not "encourage a range of housing types that are affordable to renters and home buyers..." Instead the implementation of this project would eliminate many residences, many of which would be considered affordable housing. The Patterns' twelve policies are the guidelines that should underpin the county Planning Board's recommendations on "land use, land acquisition, capital projects, and matters referred to it by local governments" (p.5). The IKEA proposal is described in such a way that these general statements appear to support it. Patterns appears to indicate that the county plan is neutral on big box retail at this location, neither advocating or disapproving such a use. In our experience as consulting planners, regional plans now recognize large-scale development in non-city centers and plan for them. Our 1995 Regional Plan for the South Western Connecticut Planning Region recognizes the Merritt Seven Office Center at the juncture of the Merritt Parkway and Route 7 in Norwalk, as a commercial area within an intermediate center — a highly-built up office, retail, entertainment, and residential center with dense development and public infrastructure, located outside an established center where there is good highway access. Patterns does recognize that non-city centers are now occurring in Westchester, that these growth centers have "potential for significant growth through mixed-used development, in-fill construction and transportation hub enhancement." (p.36) This growth center or non-city center condition is not found in this part of New Rochelle and it is not part of the HDU classification. What does HDU mean? The area in which IKEA proposes to build is classified High Density Urban with a land use intensity rating of 4-6. (See Patterns Map 6). This corresponds to a commercial density of 0.2 — 0.8 FAR and a gross residential density range of 6 —26 dwelling units per acre. While the DEIS correctly reports the designations the county gives to the affected area, it gives an impression that large-scale non-residential use is favored in the HDU designation. And in fact, the commercial intensity for an HDU area might range from 130,000 square feet to 520,000 square feet, placing IKEA's 308,000 square feet in the middle of the range. However, there are other important aspects of the HDU designation, beyond commercial intensity. For Patterns, high density urban areas outside centers (such as downtown Larchmont on Palmer Avenue) tend to have "apartments, shopping centers, offices, highway oriented businesses, commercial, industry, or warehousing enterprises... Open spaces and community parks are an important component of the mix of land uses." To place this intensity rating of 4-6 in context, these are some of the other areas in the county so designated: Rte. 119 from Elmsford to Tarrytown, and the communities immediately surrounding the centers of Hastings, Dobbs Ferry, Chappaqua, Millwood, Thornwood, Goldens Bridge, Jefferson Valley, and Armonk. These areas are not at all similar to the Merritt Seven Office Center in Fairfield County What is the most relevant planning guidance that the county plan offers New Rochelle? Not the details of the HDU designation, not the amount of square footage that Patterns feels — in the Page 4 abstract — can be handled by HDU-designated areas, but some simple wisdom: "A most urgent hope is that Patterns will contribute to intermunicipal planning and will help municipalities make informed land use decisions in the context of a county under stress. Together we have learned that what happens in one community affects the surrounding area's economy, traffic, air, water, land and people, for better — and sometimes for worse. " " Municipalities, which will continue to have exclusive power of land use, must find ways to exercise those powers in the common interest." Page 5 ' I ''. p� fig �` LEWISBORO yyC � � �9,lYqkloWn 'E'` .? '- .i .�. Sir,,-- (� . s .'Hji9/116 1 �' - .. 3 -i ,' -0-'-`j ¶ INDr ., ,YOR O i/V l _ rvr \ j G� „� \ ` G q 179 „� ice. / iV t' ,r •EDFO C7 t zzy; \\,:\774' 3 Wt.; lii) t• 1R Croton i l -', • ND/ft on ► �: /1 ia; 1' ud p, T --, 1:,, :,i i• � f�i - - '� 1684/ { /� .11 i. idol r 172. r is2L r T« .! `,` + .,� _ -Olt? ` , L r{ -•' !� 'l ; SS'xu 1 \\\\ f li' IA 10,1 �V CA-- TLE / Gi NEwcAN4 Ossining-OS JN1 i, t • 1 `1 p 1 Briarcliff ' v'' STAMFORD Z ' ' Mait n Iw _ NORT CASTLE �\ > '.3easantville _-.-. I �t RECOMMENDED DENSITY RANGES: -r!i°!lMrw r; Category FAR range GRD range ',> 9" r" LDR 0-2 0.0125-0.05 .2- 1.5 � •n.n i.• 1' N, ' / N LEASANT ..j. MDs 1-3 0.025-0.1 1 -3 O 4 'A684 GREENWICH fi1Th!rrytown 4 t , ,- - - MDS 2-4 0.05-0.2 2-7 • # MDS 3-5 0.1-0.4 3 13 71 -r i ( I HDU 4-6 0.2-0.8 6-26 Tarrytown__ 1_ < , f v HDU5-7 0.4- 1.6 13-51 sford, ,.,; t ti �`' ' '2[3:, • - °' H' 'RISON ' HDU6-8 0.8-3.2 26- 102 �, GRErNBURGH'-'.• i sW -. i Irving,to 7 ` Ry IIM HDU 7-9 1.6-6.4 51-205 l : I ` f TE PLAINS' OOK LDR:Low Density Raga/ FAR:Floor Ares Reeo AIDS:Medium Density Suburban (Floor Area!Log Area) P• 'Dobbs! rdsl.., ". `. '11- HDU:Hs h Density Urben GRD:Gross Residers l Der r ty r•ur.,rus• Ai, X-'7 PGrt >' (Dwelling UmL^trey 4ao) (/� Ferry/r Che'''f DEFINITE OPEN SPACE ELEMENTS: HiSting ' ( .. County&State Parks&Parkways • '' SCARSDALE On r - s' Other Protected Open Space Lands I-ludsQr • 1 111111 1_ Il. e i' ;f, i 'ii m• f -' Other Publicly Owned Lands Major Water Bodies _ .,- ,_ ,,.fir .... �, - Tuck T- e (i' r , ,{'MAMA ?f' K. NEC •S,. RYE OPEN SPACE OVERLAY: • YO $RS! , �t ► ' it t�`r t NEW .M°? 6rine ck1., 1 Areas of Open Space Character - • -.CHELLE . �,•"11,-* CIO S . CENTERS: i ' ," ,Larehmont 5p ` _ / VERNON •Main r"' Hamlet O o �'F 6k y�,P • Local Y tU � \ ori • 9 /r' L Mah`' ._ 0� © Intermediate BRONX _1 re 17 Y ."' N.. (•) Major Figure 1.1 Patterns of Westchester County - Recommended Density Ranges 2.0 REAL ALTERNATIVES ARE NEEDED The DEIS has, as required, descriptions of alternatives (Section 4). Three of the seven alternatives are presented as redevelopment alternatives for the Fifth Avenue area, correcting the long- recognized problems and building upon the existing neighborhood' strength. These are Alternative 4.3, No Build Alternative, and the two aspects of Alternative 6. Alternative 4.3 discusses revitalization strategies, but does not build upon the Fifth Avenue planning proposal in the recent Comprehensive Plan. It relies on the Urban Renewal Plan, whose findings of physical blight are flawed and misleading. Alternative 6 has two aspects. Both are restricted to light industrial uses and involve: • A light industrial park that includes a mix of 13 one or two story industrial buildings. • An assembled light industrial concept that accommodates two large buildings. Both assume wholesale clearance of all existing buildings on the site, including a number of attractive residences and two churches. Neither alternative includes an option that attempts to strengthen the existing neighborhood through an upgrading of infrastructure while maintaining the current mix of land uses. (See Figure 2.1) The DEIS alternatives avoid any discussion of what could normally be viewed as the obvious alternative plan to the proposed action — the re-use of vacant or underutilized lots combined with the. rehabilitation of structurally sound buildings and with improvements to existing roads and streetscapes. There are at least three alternatives that could do this. These are discussed below. 2.1 Upgrade the Existing Neighborhood A plan to upgrade the neighborhood would in fact build on the existing assets of the Fifth Avenue site, where over 80 percent of existing buildings are in fair or good condition (Section 3.1-20 of the DEIS), including several houses that front on Plain Avenue and Pleasant Street. (See Figure 2.2 of this report.) Figure 2.3 illustrates some (although not all) of the better-maintained and more attractive buildings that would be demolished by the proposed IKEA development. A review of the City of New Rochelle's Comprehensive Plan and site visits to the Fifth Avenue area strongly suggest that a viable and attractive mixed-use neighborhood can be maintained and enhanced that would preserve many of the site's substantial buildings and at the same time address the need to improve access, servicing and streetscape. 2.2 Mixed Uses Alternative This alternative retains the mix of uses that presently characterize the site. (See Figure 2.4.) This plan includes a new road connection between Fifth Avenue and Plain Avenue. This road leads to the existing residences in the central portion of the site, fronting primarily on Plain Avenue. This small-scale residential neighborhood is consolidated through the addition of approximately 15-20 new residential buildings. The two churches are also retained. The plan adds six additional light industrial buildings, to be located on presently underutilized lots, and retains the seven existing commercial buildings. Page 7 2.3 Industrial and Commercial Use Alternative This alternative (Figure 2.5) retains all the existing light industrial and commercial structures that are in good or fair condition, as identified in the DEIS. This alternative includes an additional 10-12 new buildings that utilize the vacant or underutilized lots within the proposed urban renewal area. Accessibility is improved through a proposed new connecting road between Fifth and Plain Avenues. Off-street parking is provided within the new development sites and an employee parking area is included along Pleasant Street to reduce traffic congestion on the existing streets. This alternative retains three residences at the east end of Pleasant Street and the church at Plain Avenue and Valley Place. Page 8 ----\ '• ............, • \ •••-•,- .. . ....... .. •. ..., . .. -!.....1 .. . ... ..•.• t ') ..• wow° - . ----\ ''''''' ...•-..1 ---- ______—g , ... • - ----1' 74 ,1 . ..' FIFTH AVENUE i SI IN -- - 11! 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I - =-• - c ''' : ••••, .. .443r is;:-' ; . ,..:: -" -•-err "f4' ',//j : - : ' ,-- - ------'..---:t•-.4:-,----,?(1"/Z..,:— VI ..,et, _____.„---- _ , : • , el .'".• . • .. . . ! . . _-1------------------------------- ------- - , 1..' i ) ik„.:- ___.---- \,.1'-.-.-...../1 , ...._.‘,. .,/ .---------.-- .--------1 Vi ......c-N..\:e 3--C.-.) --------- .---,------ NEW ENGLAND THRUWAY (1-95) ____ ------- --------"-- Buckhurst Fish &Jacquemart, Inc. I 0 00 .10 DO E.,<41:v.11 F'sli(..',doornail In,. Figure 2.4 Alternative 1 - Mixed Use . , . . • .. ....., ......,.• \. ^ ------- • • , •"! i, _______J .•—•:. :: ___--- ., ... , .: •,.. ___ -----F._,,,.,..„ _rto _ ... .. r. 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' t • 1 i,- ,,,,,,,-_ -, .---„.„,. - -.: ------ -:f.!` _, 4,_:__& .• __ 1 iriV, t I- -- ' ... . .. . r — I -Igt ';- - ---7-•1 -27 ----1L-:-UE---.---L — , ---- , --, PLAIN:AVEN -- - --4.----!-— --r—'1--- Via • i • ., ,) . . . . . 1 ‘.,.._.11 • - 'i 1- .'-, • . i , _ _..,. ,,,ir ,_ - -4r• L , ..,,,,, ..: /,..,./.,.... ,... ,_ \,, ,•,, .---;-- --,..,:---______L_______Li • z iii . ...i.,,,, ,____,:,._41 _ _t,_ 2._- , .- —"............." , • --• - — f-hw-- , -.. ,re.,, _-_,__0—.__it,i‘ , - ...:__.._..14A--- .^ ' ,:, ___--- --- _. -- - I •'.1. 4 • *14. - • . ‘.,^.11,. _ 1 i.. . , .9' c• • "-sr•.-f"c"--------------:: , .A.- i‘ ) x. • I .,,.1 . ..4 .- • -!. l I------------------ 4 i :4 .? 2-„•••.,../ ' -: -------- rr-^r NEW ENGLAND THRUWAY (1-95) h7.......,_„.„. ..,. .., ...--------------"1"--------------- -----/----------------------j--- , Buckhurst Fish &Jacquemart, inc. ,q .50 ...., . 1 5„at..,,,i,..”.,NI.e,!woo 0 Irr Figure 2.5 Alternative 2 - Light Industrial and Commercial Use 3.0 TRAFFIC IMPACT ANALYSIS IS DEFICIENT 3.1 Traffic Generation and Choice of Analysis Hours are Flawed The DEIS authors chose the 5 to 6 pm hour on Fridays as the most critical hour for the weekday analysis and the hours of 2:30 p.m. to 3:30 p.m. and 4 to 5 pm for the Saturday analysis. In addition the January Sale period was chosen as the seasonal period representing a reasonable worst case. The DEIS mentions that this represents a condition that occurs maybe 10% of the time. The DEIS is misleading in that the hours chosen are not the highest IKEA traffic hours. Figures 3.1 and 3.2 show the traffic generation pattern of IKEA in Elizabeth, NJ. These graphs are based on the automatic traffic recorder (ATR) counts taken by IKEA's consultants at the Elizabeth store. They show very clearly that during the week of the automatic counts there were 17 hours that had higher traffic generation than the 5 to 6 pm hour chosen. These hours were often during the 2 to 3 pm or 3 to 4 pm period when school traffic peaks and when some intersections in the study area are at level of service E or F. For instance, the intersection of Myrtle and Weaver is operating at level F during the period around 3 pm. IKEA traffic tends to be higher during these hours. It should also be mentioned that the January Sale period does not represent the highest annual period of activity at IKEA. The busiest period is the period after the August catalog publication. During this period weekday traffic is 18% higher and Saturday traffic is 5% higher than the January period chosen for the DEIS. See page G.1-4 of Volume 2 of the DEIS. Figure 3.2 also shows that IKEA's hourly traffic generation on Sundays between 2 and 4 pm is higher than the highest Saturday hour chosen for the DEIS. To conclude, the EIS needs to analyze those intersections located near schools for the school pm peak hour, since the combination of IKEA traffic generation and base traffic are as high or higher than the chosen hour of analysis. The EIS also needs to correct the statement that the chosen period represents a condition that occurs 10% of the time. The condition occurs or is exceeded 10% of the time. The EIS needs to include the daily visitor count for the 364 days of operation of the IKEA store in Elizabeth, NJ so that the EIS reader has a clear understanding of the condition being analyzed. This traffic generation pattern also affects the community character impacts mentioned in the DEIS. The community character impact does not just occur during the three hours analyzed in the DEIS. It occurs on a daily basis (Monday through Sunday) from about noon to 9 pm. In fact the community character impact will be more substantial on Saturdays and Sundays because the IKEA traffic is higher than on weekdays and today's traffic volumes along these residential streets are very low. The IKEA EIS needs to clarify their assumptions regarding shuttle bus services for their customers and the commute modes for their employees. If the assumptions for the New Rochelle site are different from the travel patterns at the IKEA store in Elizabeth, adjustments need to be made. For instance, will IKEA operate similar shuttle buses in New Rochelle as they operated between Manhattan and Elizabeth? The IKEA DEIS makes the assumption that traffic generation is directly related to gross floor area. It uses the traffic generation figures from the IKEA store in Elizabeth, NJ and adjusts them for the proposed New Rochelle IKEA based on the floor areas of the two stores. Whereas this methodology represents customary practice in traffic engineering, it does not take into consideration the fact that traffic generation is also a function of the market forces surrounding the store. IKEA is a phenomenon, in terms of attracting customers. Relating the amount of customers to floor space is not adequate to this situation. Potential customers don't analyze the size of an IKEA store before Page 14 deciding to shop there. This would be the only IKEA this far north. The trade area is recognized to be wider and more far reaching than other stores. People are known to travel for hours to shop at IKEA. The EIS needs to substantiate their methodology by presenting visitor data from other stores and by relating them to the respective floor areas and trade areas, or IKEA needs higher traffic generation figures. 3.2 Distribution and Assignment of IKEA Traffic are Flawed BF) reviewed the distribution of the IKEA traffic coming from the east and the north. Three major regional highways serve the IKEA traffic coming from these directions: The Hutchinson River Parkway (connecting to the Merritt Parkway in Connecticut), 1-287 connecting also to the Saw Mill River Parkway, to the Sprain Brook Parkway, and 1-95 along the shore line. 1-684 connects to 1-287 and to the Hutchinson River Parkway. Two key traffic assignment issues are reviewed: 1) The choice of 1-95 or the Merritt/Hutch Parkway for traffic coming from the east along the Connecticut coast, and 2) for traffic driving through the interchange of 1-287 and the Hutchinson Parkway, how does it distribute between the three alternatives to reach the IKEA site: 1) Hutchinson Parkway to Weaver Street (Exit 20) to Murray Avenue to Myrtle Boulevard, 2) Hutchinson Parkway to Mamaroneck Ave (Exit 23) to 1-95 to exit 16, and 3) 1-287 to 1-95 to exit 16. The first route is a local route through Scarsdale and the Town of Mamaroneck, whereas the other two routes involve a portion of 1-95 and involve the use of a section of 1-95 beyond the project site to exit 16. Table 3.1 summarizes the assignments used in the IKEA DEIS. The zones are the same as those used in the DEIS, however, all towns located in each zone are spelled out. The third column shows the percentage of vehicles that are projected to use the I-287/Hutchinson interchange. In the case of the Connecticut coast-line origins the third column shows the percentage of traffic using the Merritt Parkway versus 1-95. The following are, in our opinion incorrect assignments: 4. The Town of Fairfield straddles the Merritt Parkway, therefore at least 50% should be assigned to the Merritt/Hutchinson (not 0% as the DEIS assumes). 5. Idem for zone 64B: Milford and Orange 6. The Town of Stratford in zone 66 is also straddling the Merritt and a large number of residents of zone 66 live closer to the Merritt then to 1-95. We feel that at least 30% of this zone should be assigned to the Merritt/Hutchinson (as opposed to 0%). 7. For zone 68B the Towns of Wilton and Weston are located entirely north of the Merritt Parkway and Westport straddles the Parkway. The overall percentage for this zone should be at least 80% (as opposed to 60%). 8. Similarly for zone 68C where New Canaan is on the North side of the Parkway. At least 75% of this zone should be assigned to the Parkway. The next issue is the choice of routes to IKEA for all the traffic passing through the I-287/Hutch interchange. The IKEA DEIS is very inconsistent in terms of the route assignment. For instance, for the traffic coming into the interchange from the Northeast on the Hutch the DEIS has sometimes 25% continuing to Weaver/Murray and sometimes 42%. And for traffic coming on 1-287 from the West sometimes 100% continues on 1-287 and sometimes 50% continues. We recommend the following more correct and consistent route assignments: 9. Traffic coming into the interchange from the Northeast on the Hutch would tend to continue to a large degree on the Hutch towards interchanges 23 or 20. We recommend that a consistent 50% of this stream be assigned to the Weaver/Murray route. 10. Traffic coming down on 1-684 has an easy split towards the Hutchinson Parkway or towards I- 287. At least 35% should be assigned to the Weaver/Murray route. Page 15 11. For traffic coming from the west on 1-287 it is easier to stay on 1-287. About 25% should be assigned to the Weaver/Murray route. The above assignments take into consideration the fact that the local route via Weaver/Murray is the shortest and most direct, whereas all routes that involve 1-95 are longer and involve "overshooting" the IKEA site and driving to exit 16 and backtracking. The conclusion from this analysis is that the percentage of IKEA traffic assigned to the Hutchinson Parkway and to Weaver/Murray is underestimated. Instead of the 3.9% coming from the Hutch onto Weaver Street, we feel that percentage should be significantly higher, probably in the range of 5% to 10%. To undertake a more accurate assignment the DEIS consultants need to break down the zones in the Connecticut region so that they can be assigned more correctly. Map 8A in Volume 2 of the DEIS needs to be improved so that the municipal boundaries are included as well as the Merritt/Hutch Parkways. On page G.3-1 of Volume 2 the DEIS states that 3% of the inbound IKEA traffic coming from the north on 1-95 was assigned to Exit 18B to use Palmer Avenue and 5% of outbound IKEA traffic was using this route. These numbers contradict the percentage assignments shown in Figures G.2-3, G.2-4 and G.2-5. These figures show 2.9% for inbound traffic and 4% for outbound traffic being assigned to exit 18B. 3.3. IKEA Impacts on 1-95: Fatal Flaw of IKEA DEIS The section of 1-95 between Exits 16 and 17 would be severely impacted by the proposed IKEA store. Compared to the rest of 1-95 this one-mile section is affected by all IKEA traffic flows: the inbound traffic from the north and from the south, and the outbound traffic to the north and to the south. This is because IKEA traffic to and from the North of 1-95 is expected to use Exit 16, and IKEA traffic to and from the South of 1-95 is expected to use Exit 17. The DEIS severely miscalculates the IKEA traffic impacts and underestimates its effects, and we consider this a fatal flaw of the DEIS. The following are three significant errors made in this section of the DEIS: 1) Existing traffic conditions on SB 1-95 for the weekday pm peak hour are misrepresented. The DEIS states that 1-95 is operating under capacity in the southbound direction during the weekday afternoon peak hour. It assumes that traffic volumes that are less than capacity represent automatically good or fluid traffic conditions. This is implied in Table 3.9-12 on page 3.9-39 (the DEIS indicates that there is reserve capacity to add the IKEA traffic) and also in the SB On-Ramp analysis for ramp 17 in Table 3.9-14 on page 3.9-40 (the DEIS indicates that the on-ramp merge operates at level of service D with a speed of 51.6 mph). In fact, a traffic count showing volumes below capacity can represent two conditions: Fluid conditions (levels of service in the range of A to E) or bumper-to-bumper conditions (level of service F). To determine the actual traffic flow conditions the counts need to be supplemented by speed observations and/or speed measurements. BFJ performed counts and speed observations and measurements on two consecutive Fridays in the fall of 2000. These counts and speed measurements are summarized in Table 3.2. On Friday October 27, 2000 SB 1-95 traffic was counted, observed and filmed from 5 pm to 6:30 pm. Southbound traffic was in a bumper-to-bumper condition (level of service F) during the whole period, with speeds estimated at 20 to 30 mph. Hourly volumes on this day varied between 5,152 and 5,169 vehicles, and the highest 15-minute flow was 1,330 vehicles, all less than the capacity of this three-lane section of 1-95. On Friday November 3, 2000 SB 1-95 traffic was counted and observed from 4 pm to 6:30 pm. Time-lapse video films were undertaken from 4 to 6 pm and speed measurements were done from 4:15 pm to 6:15 pm. Bumper-to-bumper conditions (level of service F) were observed between 4:30 and 6:15/6:30 pm. Level of service F was also observed up- stream between SB entrance 18B and entrance 17 between 4:45 pm and 6:15/6:30 pm. Hourly Page 16 volumes during the level of service (LOS) F periods were in the range of 4,323 and 5,431 vehicles and the highest 15-minute flow was 1,340 vehicles. The conclusion from this analysis is that 1-95 in the southbound direction has no excess capacity during the weekday pm peak period and that southbound traffic is backed up in this direction. In the northbound direction traffic volumes counted in the fall of 2000 are significantly higher than the counts shown in Table 3.9-12. Compared to the 3,048 vehicles shown in the IKEA DEIS, the Thruway Authority shows 3,817 vehicles from 5 to 6 pm for Friday Sept 29, 2000 and our counts show 3,791 vehicles for Friday Oct 27, 2000 and 3,238 vehicles for Friday Nov 3, 2000. See Table 3.3. 2) Miscalculation of 1-95 Capacity. Table 3.9-12 of the DEIS indicates capacities in the right-hand column that are in some cases exaggerated or incorrect. For full-service toll lanes the DEIS indicates a capacity of 500 vehicles per lane and for the southbound non-tolled direction the DEIS indicates a total capacity for all three lanes of 7,050 vehicles. For full-service toll lanes the New York State Thruway Authority estimates a capacity of 350 vehicles per hour instead of the 500 vehicles. The southbound capacity of 7,050 indicated in the DEIS implies a per-lane capacity of 2,350 vehicles per hour. Based on the 1997 Highway Capacity Manual we estimate a maximum service flow rate of 2,250 to 2,300 pcphpl (passenger cars per hour per lane). This flow rate assumes ideal highway conditions: all 12' lanes, 6' shoulders on both sides, all commuter traffic and only passenger cars. It takes into consideration the free-flow speed, the geometric configuration of this section of SB 1-95, and the fact that the two interchanges (16 and 17) are less than one mile apart. Taking into consideration the mix of heavy vehicles (6% during the afternoon peak hour, higher during the rest of the day) and the peaking within the afternoon peak hour, we estimate an hourly capacity of 2000 vehicles per lane, or a total capacity for SB 1-95 of 6000 vehicles. This capacity estimation is substantiated by the 15-minute peak-flow rate of 1484 vehicles counted between 4:30 and 4:45 pm on Friday November 3, 200 with an average speed of 48.7 mph. To conclude, the IKEA DEIS overestimates the capacity of 1-95 by about 1000 vehicles per hour. 3) Miscalculation of IKEA Traffic Assignment onto 1-95 Table 3.9-12 of the DEIS implies the following increases in hourly IKEA traffic on 1-95 between exits 16 and 17: - Weekday PM peak hour: 74 vehicles northbound, 45 vehicles southbound - Saturday Midday hour: 444 vehicles northbound, 389 vehicles southbound - Saturday PM peak hour: 383 vehicles northbound, 455 vehicles southbound The above numbers contradict the traffic assignments shown in the IKEA DEIS in Figures 3.9-7, 3.9- 8 and 3.9-9 (in Volume 2 of the DEIS) or those derived from applying the percent IKEA traffic distribution (shown in graphs G.2-3, G.2-4 and G.2-5 of Volume 2 of the IKEA DEIS) to the traffic generation figures shown in Table G.1-1 on page G.1-3 of Volume 2. Table 3.4 shows this calculation. As can be seen, the weekday PM peak traffic on 1-95 is expected to be 150 northbound and 161 southbound, on average 2.6 times higher than the figures shown in Table 3.9- 12. On Saturdays the hourly IKEA traffic is expected to be 53% to 57% higher than the DEIS predicts for 1-95. Why is this a fatal flaw? Page 17 We consider the combination of the above mistakes to be a fatal flaw for the DEIS not only because it substantially underestimates the IKEA impacts on 1-95, but also because it affects the distribution of IKEA traffic throughout the local network. Given the existing level of service F conditions during the weekday peak hours along southbound 1-95, the addition of 161 hourly vehicles will increase delays and air pollution significantly. IKEA would increase the number of hours with bumper-to- bumper traffic (LOS F) along 1-95. Given the delays and the backups along 1-95 IKEA traffic will use other routes to get to and from the IKEA site in New Rochelle. In fact the conclusions drawn from the travel time surveys conducted for the IKEA DEIS will not hold true under these conditions, and the percentages of IKEA traffic using local roads, such as Weaver Street, Murray Avenue or Palmer Avenue, will increase significantly beyond those indicated in the IKEA DEIS. The basis and justification for the traffic impact analysis during the weekday peak hour is thus rendered incorrect. To conclude, the EIS needs to redo this analysis. A background growth rate needs to be applied to the 1-95 traffic to forecast future conditions (levels of service and speeds) without IKEA, taking into consideration corrected capacities, volumes and levels of service. Traffic assignments need to be corrected for the weekday peak hour taking into consideration the travel times via the alternate routes for traffic coming from the north and the east (Hutchinson/Weaver versus Mamaroneck/I-95 and Palmer/Myrtle from Exit 18 versus 1-95 to Exit 16). Then the impact calculations need to be redone to determine the future conditions on 1-95 (levels of service, speeds, and the number of hours with levels F as compared to today's conditions). The analyst should assume that if there is no more capacity on 1-95, the IKEA traffic would either shift to earlier or later hours and worsen those conditions, or it would shift to other local routes. These impacts need to be clearly identified. 3.4 DEIS Mitigation Measures Are Not Realistic Several incorrect geometry and signalization assumptions were used in the analysis of levels of service at various intersections. The assumptions that need to be corrected are summarized below. In addition, the DEIS relies upon the questionable mitigation measure of adjusting the "green" time of traffic lights to accommodate the IKEA traffic. Such a mitigation measure cannot be controlled by IKEA. It is the responsibility of state, county and local municipal agencies to assess the efficiency of traffic signal timing on a periodic basis. The IKEA DEIS can suggest changes but with no assurance they will be implemented; or, if implemented, that they will not be changed at a future date. Fifth Avenue and Valley Place (Intersection 2) At the intersection of Fifth Avenue and Valley Place the DEIS recommends mitigating the impacts of the proposed action through the following measures: • installation of signal control; • the widening of Valley Place to provide exclusive left and right turn lanes using additional right-of-way on the west side of the street from within the redevelopment area; • re-striping Fifth Avenue to provide an exclusive left-turn lane for the westbound approach The mitigation diagram on the following page shows that the section of Fifth Avenue on the Mamaroneck side would be restriped to provide for one 10' wide westbound through lane, one 9' westbound left-turn lane and one eastbound 10' through lane. These lane widths are very substandard dimensions and would result in unsafe traffic conditions. These are unacceptable dimensions for a road that has to carry half of the IKEA traffic. Furthermore these dimensions are inconsistent with the assumptions made in the capacity analyses for this intersection: Here the DEIS analyst assumes that the lanes are all 12' wide. The analysis should be redone to reflect the correct geometry. Page 18 Chatsworth Avenue and Palmer Avenue (Intersection 5) The intersection of Chatsworth and Palmer Avenue operates at overall LOS F during both no-build and build conditions due to the saturated conditions of the northbound left turn movement. The DEIS proposes extending the green time for this movement to improve conditions. The extension of green time for this movement would reduce the delay, however the movement and the intersection overall would still operate at LOS F. The improvements in LOS for the left turn movement would be at the expense of the LOS of the other movements. Page 19 FIGURE 3.9-5 (page 2 of 9) INTERSECTIONS REQUIRING PHYSICAL MITIGATION FIFTH AVENUE AND VALLEY PLACE (2) III Traffic Signal N Lane Use I Stop Sign EXISTING INTERSECTION 13' 12' FIFTH AVENUE 18' I > 17' II A 10- 32' VALLEY PLACE INTERSECTION WITH MITIGATION 17 � 10' C 1 I' ■ �' 9 FIFTH AVENUE 12' b 10' 10' ,EJ, ' 417> 1 10' 12' 22' 1 1' VALLEY PLACE Source: Fifth Avenue Urban Renewal Plan and Retail Center Project DEIS Chatsworth and Myrtle (Intersection 6) For the analysis of Chatsworth and Myrtle, incorrect geometry assumptions were entered and need to be corrected. The Highway Capacity Software (HCS) worksheets indicate that the eastbound approach was analyzed with three 11' lanes. The EB approach actually has one 10' lane for the left turn movement and one 14' lane for the combined thru and right movements. The northbound approach was analyzed with one left turn lane and one shared lane for the through and right movement. This should be corrected to reflect one 11' shared thru and left lane and one 13' right turn lane. The southbound approach should be corrected to reflect one 11' left lane and one 15' combined left, thru and right lane. Finally, the westbound approach should be corrected to reflect three 11' lanes for exclusive left, right and thru movements. Murray Avenue and Myrtle Boulevard (Intersection 7) To mitigate the LOS F for the eastbound right turn movement, the DEIS proposes extending the green time for this movement. Because this intersection is located so close to the intersection of Chatsworth Avenue and Myrtle, any analysis of the changes in the signalization should test both intersections together to see how the signal timing of each affects the other. Madison Avenue and New Jefferson/I-95 (Intersection 10) The DEIS recommends adding a traffic signal to this intersection and adding turn lanes at this intersection to mitigate the impacts of the IKEA project. The LOS analysis of these mitigation measures should take into account that parallel parking is allowed on both sides of Madison west of New Jefferson and parking movements will affect LOS. Murray Avenue and Weaver Street (Intersection 17) At the intersection of Murray Avenue and Weaver Street, signalization is recommended to mitigate the impacts of the proposed action. The LOS analysis for the proposed action tested 14' lanes for the northbound and southbound traffic on Weaver, however the northbound approach is only 12' wide as Figure 3.9-5 (page 6) of the existing and mitigated intersection shows. The analysis should be redone to reflect the correct geometry. 3.5. IKEA Parking is Insufficient. The parking demand estimation for the New Rochelle IKEA is based on an accumulation calculation for the IKEA in Elizabeth, NJ. Based on the automatic tube counts performed at the Elizabeth store the DEIS authors subtract the cumulative exiting vehicles from the cumulative entering vehicles to calculate the number of vehicles parked in the parking lot. These numbers are then adjusted for the floor area of the New Rochelle store and for the "sale week." There are three problems or errors with this analysis: 1. The accumulation count does not include the vehicles that entered the IKEA lot from the Toys R'Us lot and did not get included in any of the tube counts. 2. The count was done for a Friday and a Saturday, but not for a Sunday. The tube counts show that Sunday traffic is higher than Saturday traffic by about 5.6%. 3. The parking estimation does not take into consideration the highest sales period in the month of August. Visitor counts show that the August Saturdays are about 5% higher than the January Sales Saturdays. To conclude the accumulation analysis needs to be corrected to include the traffic cutting across parking lots, to take into consideration the Sunday accumulation, as well as the August visitor Page 21 numbers. Our estimation is that the parking demand will be more in the range of 1,600 to 1,700 spaces on busy weekends. In the DEIS discussion of insufficient parking, no mention is made of the possibility of spill-over parking to the playing field parking lot (thus making soccer game parking difficult on Saturdays) or possibly to the Town lot adjacent to the 1-95 exit or to other existing retail lots on Fifth Avenue. 3.6 Other Intersections and Interactions between Adjacent Intersections The major impact of IKEA on the Town of Mamaroneck occurs in the Washington Square neighborhood in the Town of Mamaroneck. Half of the IKEA traffic is driving through this neighborhood. The EIS does not analyze the traffic impacts at the intersection of Maxwell Avenue and Madison Avenue, immediately adjacent to the 1-95 ramp intersection. Maxwell Avenue serves the Mamaroneck Town yard and other adjacent uses. The area along Maxwell Avenue has been the subject of a planning study by the Town of Mamaroneck and may change in the future. It is important that the Maxwell Avenue intersection will continue to function without interference from queues and backups from the intersection with the 1-95 ramps. A queuing analysis needs to be performed for the intersection of Madison and 1-95 ramps and mitigation measures need to be developed that maintain a clear operation for Maxwell Avenue traffic. A queuing analysis also needs to be performed for the intersections of Myrtle and Chatsworth and Myrtle and Murray. As is shown in Figure 4.3 of this report, and as was demonstrated by the Synchro simulation, the lack of sufficient storage capacity at the intersection of Myrtle and Chatsworth for southbound left turns creates substantial backups along Murray Avenue because the Murray Avenue traffic does not get a chance to get into that left-turn lane. These impacts have not been mitigated in the DEIS and need to be mitigated. Any signal timing changes at the intersection of Myrtle and Chatsworth need to be evaluated in terms of queuing impacts on the intersection of Chatsworth and Palmer. Page 22 Figure 3 . 1 IKEA Weekday Traffic Pattern ( 10 AM - 10 PM) MONDAY TUESDAY 600 600 GC 500 cg 500 X 400 ac 1 J �' ii yll ' W �' 300- -- -r — ■Outbound 300 v. W •Inbound IL ■Outbound u 200 - — — — — — — u200— — — — too iIIIiiiiiiib0' 11111 ' 10:0011:00 12:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 &00 9:00 10:00 11:00 12:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 AM AM PM PM PM PM PM PM PM PM PM PM AM AM PM PM PM PM PM PM PM PM PM PM WEDNESDAY THURSDAY 600 600 500- 500 GC m = 400 ---- — = 4.. 300 IX if, Mill W [11611W— bound ■Outbound C.1 200. ound •v 200 " " " ' Inbound ' 1 ' too-- '.1100 1111111111111' ' 0 0 10:0011:0012:00 1:00 2:00 3:00 4:00 500 6:00 7:00 8:00 9:00 10:00 11:0012:00 100 2:00 3:00 4:00 5:00 600 7:00 8:00 9:00 • 4 AM AM PM PM PM PM PM PM PM PM PM PM AM AM PM PM PM PM PM PM PM PM PM PM FRIDAY 600 500 GC D i4.. m ' ' ' ' IL 300 — , ■Outbound ?"1200 ' ' — ■Inbound too — II — ' ' 0 I 10:0011:0012:00 1:00 2:00 3.00 4:00 5:00 6:00 7:00 8:00 9:00 AM AM PM FM PM PM FM 174 PM °M PM PM Figure 3 .2 IKEA Weekend Traffic Pattern ( 10 AM - 10 PM) SATURDAY 1800 1600ce 0 1400 = 1200 - - -I - cc i 1000 - W 800 ■Outbound d 600 - . II . - - - ■Inbound 400 - I , , ,2000 - I I ■ ■ ■ o° o° o° o° o° .o° .o° o° o° .o° o° o° N 11 �1 'y D (0 1• 0• �7 SUNDAY 1800 1600 - - ice 0 1400 -- - - I 1200 - - -I- - ce 14-1 4 1000 ■■Outbound d L`,1, 800 - - - - d Inboun U 600 -r- - - 400 , 1 ; 200 - - o'ooe�oe�oe�oe�oe�oe�oe�oe�oe�oe� 1.0 1,`O 1,L0 N" "1" ,�O t° ho �o ,\.•o �•O or Table 3.1 Assignment of IKEA Traffic Passing thru I-287/Hutchinson Interchange Percent Split of IKEA Traffic Passing thru Interchange of Traffic Hutch Pkway Hutch Pkw to 1-287 to Assignment Origin Origin Passing to Weaver Mamaron Ave 1-95 SB/WB to Zone Towns through Entering to Murray 1-95 SB/WB to Exit 16 1-96 SB/WB Interch. Via to Exit 16 All the way 64A Fairfield ",„01,,. 100% 64B Milford, � Orange VIA V-#�� 100% Trumbull,Monroe, . � 64C Shelton, Easton 100% Hutch A 4:' 15% 60% 0% 64D Newtown 100% 1-684 , , .' 15% 60% 0% 66 Bridgeport,Stratford r""I V 100% 68A Greenwich 60% Hutch 42% 25% 33% 40% Westport,Wilton, � " 68B Weston :- wail^ Hutch 42% 25% 33% 40% Darien, Norwalk, New <3 68C Canaan '�. .e Hutch 42% 25% 33% 40% Danbury, Redding, Ridgefield, Bethel, 1-684 A *A 68D New Fairfield 100% Hutch ,, 4 15% 60% 0% 69 Stamford 60% Hutch 42% 25% 33% 40% Harrison, Scarsdale, Port Chester, Rye Brook, Rye C. White Plains, Larchmont, 105B Mamaroneck Town 10% Hutch 100% 0% 0% 20% White Plains, Sleepy Hollow, Tarrytown, '- Irvington, _ Greenburgh, Dobbs 105C Ferry, Ardsley 56% 1-287 , ,K `' ?' Ooo 0% 100% 105D West Putnam County 100% 1-287 * lrt#n 0% 100% 105E East Putnam County 100% 1-684a '` 15% 60% Bedford, Pound Ridge Lewisboro, North 105F Salem, Somers 100% 1-684 30% 20% 50% Peekskill, Cortlandt, 105G Croton, Yorktown 100% 1-287 30% 20% 50% Pleasantville, North Castle, Ossining t&v, Mt Pleasant, New 105H Castle 100% 1-287 30% 20% 50% 109 Rockland co 100% 1-287 V X;6;i9400% 100% 125A West Dutchess Co 100% 287/684 -'. , : 0% 0% 100% 125B East Dutchess Co 100% 1-684 71 ,11 0% 100% Source:IKEA DEIS, the numbers in bold and with shading are percentages that BFJ feels are to low. Table 3.2 1-95 Southbound Traffic Volumes and Conditions Friday PM Peak Period Total Vehicles Running LOS Fri, Oct 27, 00 Exit 17to16 1-Hour 17 to 16 5:00-5:15 1279 F 5:15-5:30 1270 F 5:30-5:45 1330 F 5:45-6:00 1290 5169 F 6:00-6:15 1267 5157 F 6:15-6:30 1265 5152 F 5:00-6:00 5169 F Total Average Average Vehicles Running Speed LOS Speed LOS Fri, Nov 3, 00 Exit 17tol 6 1-Hour 17 to 16 7 to 16 8B to 17 18B to 17 4:00-4:15 1268 E 4:15-4:30 1351 51 .8 E 60.2 E 4:30-4:45 1498 48.7 E/F 57.5 E 4:45-5:00 1314 5431 27.1 F 44.3 F 5:00-5:15 1303 5466 26.9 F 27.7 F 5:15-5:30 1340 5455 23.2 F 24.8 F 5:30-5:45 1261 5218 26.7 F 28.7 F 5:45-6:00 883 4787 29.6 F 25.2 F 6:00-6:15 1017 4501 26.5 F 26.1 F 6:15-6:30 1162 4323 E/F E/F 5:00-6:00 4787 F F 4:15-5:15 5466 Peak Hour F F Note: Levels of service (LOS) based on observed or measured speeds Source: Counts, measurements and observations by BFJ, Oct, Nov 2000 Table 3.3 1-95 Northbound Traffic Volumes and Conditions Friday PM Peak Period Total Vehicles Running LOS Fri, Oct 27, 00 Exit 16 to 17 1-Hour 16 to 17 5:00-5:15 997 D 5:15-5:30 1000 D 5:30-5:45 903 C 5:45-6:00 891 3791 C 6:00-6:15 889 3683 C 6:15-6:30 746 3429 C 5:00-6:00 3791 C Total Average Average Vehicles Running Speed LOS Speed LOS Fri, Nov 3, 00 Exit 16 to 17 1-Hour 16 to 17* 16 to 17 17 to 18B 17 to 18B 4:00-4:15 672 C 4:15-4:30 901 45.3 C 57.4 D/E 4:30-4:45 1034 43.9 D 58.6 D/E 4:45-5:00 941 3548 48.2 C 61.3 D/E 5:00-5:15 794 3670 41.9 C 59.1 DIE 5:15-5:30 937 3706 C D/E 5:30-5:45 765 3437 45.9 C 57.1 D/E 5:45-6:00 742 3238 41 C 58.1 D/E 6:00-6:15 722 3166 41.9 C 58.9 D/E 6:15-6:30 771 3000 C 5:00-6:00 3238 4:30-5:30 3706 Peak Hour Note: Levels of service based on speeds for section 17-18B and on vol/cap ratios for section 16-17 * Includes effect of EZPass toll lane on 0.9 mile section Source: Counts, measurements and observations by BFJ, Oct, Nov 2000 aIIII Table 3.4 IKEA Traffic Assignment on 1-95 between Exits 16 and 17 Weekday PM PH Saturday Midday PH Saturday PM PH Percent Total IKEA Trips Total IKEA Trips Total IKEA Trips Assignmt IKEA Trips on 1-95 IKEA Trips on 1-95 IKEA Trips on 1-95 SB/WB 1-95 IKEA Outbound Traffic 43.1 % 203 87 765 330 869 375 IKEA Inbound Traffic 34.2% 216 74 998 341 860 294 Total vehicle Trips 161 671 669 NB/EB 1-95 IKEA Outbound Traffic 32.6% 203 66 765 249 869 283 IKEA Inbound Traffic 38.8% 216 84 998 387 860 334 Total vehicle Trips 150 637 617 Total IKEA Traffic on 1-95 both directions: 311 1308 1286 Source: IKEA DEIS BFJ Nov 2, 2000 4.0 COMMUNITY CHARACTER WILL BE DAMAGED 4.1 Neighborhood Roads The increased volume of traffic and the pattern of extended peaks resulting from IKEA will change the feel of Mamaroneck's, Larchmont's and New Rochelle's neighborhood streets, many of which are quiet, narrow streets lined with trees, schools, churches and homes that lie close to existing travel lanes. In addition to the impact on character, various studies in other areas have shown that increased traffic volumes on neighborhood streets can negatively impact property values. The DEIS recognizes these impacts but does not take these character impacts into account, nor does it address the issue that some of the site related traffic will use neighborhood roads to avoid congestion in place of more appropriate major roads. These issues are further addressed below. Existing Character The following photographs are representative of the character of the neighborhoods north of the proposed IKEA site. This character will be impacted by traffic that cuts through neighborhoods to reach the project site. As shown on the map in Figure 4.1, common local routes would include the following 1) traveling south from the Hutchinson Parkway on Pine Brook Boulevard to Beechmont Drive to Pine Brook Road to Fifth Avenue, 2) travelling south on Route 125 (Weaver Street) to Murray Avenue to Myrtle to Madison to Fifth, 3) travelling south on Mamaroneck Avenue to Mount Pleasant Avenue to Palmer Avenue to Chatsworth to Fifth. Murray Avenue and Weaver Street have been identified in the DEIS as routes by which traffic from Scarsdale and White Plains as well as the Hutchinson Parkway will reach the IKEA site. However only a few trips have been assigned to Pine Brook Boulevard in the DEIS, this road is also a likely cut-through route for vehicles traveling from Scarsdale and White Plains as well as the Hutchinson Parkway to the IKEA site. It is currently a commonly used local route. As the photographs demonstrate, these neighborhood roads are narrow with stone walls, trees, sidewalks, homes and schools close to the travel lane. It would not be possible to widen these roads without substantially changing the character of these neighborhoods. For example long queues will occur for southbound traffic traveling on Weaver from the Hutchinson Parkway as vehicles turn left onto Griffin Road immediately north of Quaker Ridge Road. Mitigating this delay by widening the street to allow through vehicles to move around the left turning vehicles would affect the character of this road. Even without widening, the increased traffic volumes would negatively impact these roads. Murray Avenue "-,4,-. h zii r `,re-...4.,.... " * f`aE`, 4{W iiffinO 9 '' kd kL!Ar.t' e 4 $ w • A Y Ys i'I ifh 4ii. "�ql� fib. r,ii y { '�fy�S X"v pry ` el "p,� .,1'-',...t �Ei+�[ moi` `m s G . ._7w, off!" - t} R q0... t ,• su ,,;,,t,,, ,.0'S s - Murray Avenue near Colonial Murray School Page 29 IWeaver Street +s ^a ` ----- —_ Weaver Street near Colonial Saints.John and Paul Church and School on Weaver Street Pine Brook Boulevard 79ti s • 1__ . v _1 �4 .,ct! '!,_ ',1'.., w :( a 1 ,' :�yTat _ �:�. ;two " .'..'•-;"y„ , ' �.�,�y e.1 F..r fie i . .— Pine Brook Boulevard near Albert Leonard Pine Brook near Overhill Beechmont Drive °'S t�$sT'#� �,Sj� e ) s ` "4-,,... Yi r� -.,.,td''.2t; c �—� e f y -.64'1','-f-;•- -..--1• :•• e Jc x+� (w L 1 t 4,,,.. ..• ..,-F . ... _ -„,-„,t.,,,,-..=,Yf „ .AF` y I . iA1,1- A►- L* 7: '1. 4 f '..,-_1-, L''6..1...-.-, ', . s. •. Beechmont Drive near Montgomery Beechmont Drive near Montgomery Page 30 Figure 4.1 Through Routes to IKEA on Local Roads : ,' fie° ° �' 40,' 1Nr- -i' . .,_ r�` /" •ate ! .%' s r. 00 .„..t-,>.,,,6. `�� Traveling south rl A -- j Q ' c �. . from the ' )+ f r��, Hutchinson ) 6 4 I//i?. 'i' .•••--t ,"V\:',.':'3'‘..• `! `' Parkway using 1) �,1 b I/ ':,� ,, ,r,- ', � r} ,l 1 Route 125 (Weaver ;,, it,_., '4 ,, . •\.' ,„• ,, . .� Street), 2) Murray -• •1f`(i ��.� 7.` Avenue 3) Myrtle ->-? :-s \•\-\\,N, `' ,-O o 7D �c 4) Madison , and 5) r• -dl �,ua' _ . F ',�... Fifth Avenue irf I. %'ter, y ;i'a� < < .r r•' e fly / I J--1 _t, - 1.�'�o a ` _07 ir- k ,, I.:of, vits..... „ , ,, A. - •- . - , - s.?..i )i- AIi, i ,t. -4 .• .Ing�10 • 4 4 •_`,,e-,5,-... � fT f. ti' a r•- 11 •�� -ice r ,.,s 1_ Traveling south , . ,I' ' �'from the ` �4 Hutchinson '�”` `� ,' S .,� I,I {yy Parkway using 1) ;�� 1.-C.12-...1-Q 1 I=ii' '' � _ �r 4, ,iA; , ,,, ., Pine Brook 'z ,,, / / ,: , ,% Boulevard, 2) �,� ��: A ?s� f Beechmont Drive, � ,;,r ;Is a . ; i•,,,, - = rio '% ,.p • f F 3) Pine Brook Cdr '. a " �• �r�� ,. i,;.- Road, and 5) Fifth ai 1� V i r ,, a� ,*:7:-.440.,v44,' ,0,-...,,A\ Avenue. I ti •) 4� �,_r f.. ,{� -� ,( 1 4.------_,,,,,.::(--4, .. tx ,, �� G, 38.E .I. i': 1 ' '' ,� Traveling south '� 2 Of 11 ,;,ie-or 'a: ‘k y �1 i from h `0 0 o the s( j�_ � ' t'; ,1 � , > Hutchinson .k 111.,, ,a • Parkway/using 1) `/\L _ r 4,rte A , Mamaroneck _.1HI:j �, `3 �'� - .i:ti�tiQ7+' 1i;yf>t� j j<�S '''� , ® ( '1 aI ` >'?� --.. ÷44.,0'.14°1 r/".- 1, -- Avenue, 2) Mount 1 �:� �Gi', , 3 J `� bi �, ' `, c/,V Pleasant Avenue, -,i, .'�' Cy yam -fl 0, � .4 .� ,,/ - 3) Palmer r41, 11 , � T , ,�,. ;- k, .L.� I 1.111., Avenue, 4) ii 5_� ' i'K' ,) �. y ;� }'S� yy ' Chatsworth, and ,_ V"..-51TY 1-�� !�L'2-'1,:+e,,.-. ' 1`;\ ,.�' .'ry� ,,IL,y n:: LJ 1 F;`�;1 T ;L'?{{y�' ��V ;� u � , r ,, (.<\ ,k��j ��•G, a1 S) Fifth Avenue.• • . , : 06 —)C t " `• / 11,,, 'mak q �O��•PQ �� ' ' ,g.'I r , ej J '-o w . Q<< _ �1e`•I' a' 1e•�, ;, r1 :+ i ( '� �. �" - ums,.aPL 7�riiP .,, .....!•,,,,I-,_�pF -, ,:5, ._a �) ,.\\J.,,- ,.,..„-1 � /,: ,27".''i n„ Peak Hour Impacts Figure 4.2 shows the number of vehicles that will be added to neighborhood roads as a result of the IKEA project, according to the DEIS. While the increase in volume on some streets is estimated to be low, other streets will see as many as 80 to 150 new vehicles added. In an extreme case on Madison Avenue, adjacent to the site, 872 vehicles will be added during just one hour on Saturday afternoons. As pointed out in Section 3.1 of this report, the "peak hours" selected for analysis are not the peak hours of IKEA's traffic generation. On local roads, any increase in traffic, regardless of how it is mitigated at the intersections, will negatively impact the character of the existing neighborhoods shown in the photographs above. Figure 4.2. Impact On Neighborhood Character IKEA-Generated Vehicles Neighborhood Road Weekday Saturday Saturday 5:00 - 6:00 p.m. 2:30-3:30 p.m. 4:00 - 5:00 p.m. Weaver Street 20 85 83 Murray Avenue 20 85 83 Myrtle Blvd. (near Chatsworth) 37 155 153 Madison Avenue (near New Jefferson) 209 872 862 Chatsworth Avenue 8 35 34 Pine Brook Blvd. 5 25 24 Beechmont Drive 5 25 24 North Avenue (S. of Fifth Avenue) 18 78 75 (N. of Beechmont Dr.) 31 131 129 Palmer Avenue 6 24 24 U.S. Route 1 (Huguenot St.) 2 6 7 (Main St.) 2 8 7 Source:Fifth Avenue Urban Renewal Area Plan and Retail Center Project DEIS,Volume 2, Diagrams 3.9-7 a-f;3.9-8 a-f;3.9-9 a-f Extended Peaks In addition to the peak hour impacts, the neighborhood roads will be affected by IKEA traffic throughout the entire day. Unlike residential or office uses that have distinct morning and evening weekday peaks, the retail nature of the proposed IKEA will generate high volumes of traffic continuously throughout the day as shown in Figures 3.1 and 3.2 in the previous section. This means that hours that have traditionally been relatively free of traffic on local roads will now experience heavier volumes. In neighborhoods where there are schools, homes and pedestrian activity close to the street, the extended peaks will have a negative impact on community character. In particular, IKEA will generate a high number of vehicles on Saturdays and Sundays, days that are traditionally quieter on neighborhood roads. Impacts of New Signals To mitigate congestion impacts, IKEA proposes installing new signals at the following locations: Fifth Avenue and Valley Place, Madison Avenue and New Jefferson/I-95, Hutchinson Avenue and • Page 32 Weaver Street, Murray Avenue and Weaver Street, Garden Street and Cedar Street, and Beechmont Drive and Pine Brook Boulevard West. While these new signals will help mitigate the impacts of the additional traffic at the intersections, these signals in themselves will change the character of the neighborhood roads. Roads without signals are perceived differently than those with signals. Property Values There is some indication that in addition to affecting a neighborhood's appearance and overall traffic level, increased volumes may also affect the property values in a neighborhood. According to Elliott Sclar, a professor of Urban Planning at Columbia University, residential properties on through streets have less market value than similar properties that are not on through streets. In Sclar's study of the neighborhoods north of the proposed IKEA site, he found that, with existing traffic, homes on Pine Brook and Beechmont are currently valued at about 16% less than similar properties on streets in the area that are not cut through streets. Thus it is reasonable to assume that additional cut through traffic related to IKEA may also negatively impact property values on these streets as well as on Weaver, Murray and other neighborhood roads likely to be used as cut-through routes. The EIS should include a review of potential property value impacts, and also provide information on similar impacts to other neighborhoods from IKEA stores. Pedestrian and School Impacts The IKEA EIS needs to examine impacts on pedestrian safety particularly in the Washington Square neighborhood and around the schools. There are four elementary schools, one parochial school, and one middle school and one high school that would be impacted by IKEA traffic. Of particular importance is a full analysis of the Murray Avenue School which would be the most affected by IKEA generated traffic. IKEA should provide a pre-build and post-build evaluation of its Hicksville store in terms of pedestrian and traffic conditions. Hicksville is the closest IKEA store to New Rochelle. 4.2 Visual Simulation The customary traffic impact report presents levels of service and measures of capacity in the terms of letters and numerical delay ratings which are technical and somewhat confusing to laypersons. In recent years the practice of using simulation software to model the existing and projected traffic conditions has matured and is now routinely used to examine microscopically traffic operations to be experienced in current and post project development phases. To model the projected impacts of the IKEA project Earth Tech used Synchro 4.0 and Sim Traffic software. Earth Tech developed the network of intersections in Mamaroneck and applied present and future volumes derived from the EIS report. The network was examined to determine queuing and traffic behaviors. Figure 4.3 on the following page shows the intersection of Murray Avenue and Myrtle Blvd. and the continuous line of traffic that will occur on much of Saturday and Sunday due to IKEA. While the levels of service presented in the traditional traffic impact report model the individual intersection the SIM TRAFFIC model analysis relates the intersections on a system basis. Thus the queuing which extends from one intersection to the next which would not be detected by traditional analysis is modeled. In the Mamaroneck analysis we found this issue and evaluated the impacts of the future IKEA traffic on the Town. Traffic operations which impede adjacent intersections can result in congestion conditions such as that pictured on the following figure. The visual simulation analysis shows congestion throughout the system in the Washington Square area of the Town (Madison, Myrtle, Chatsworth & Murray). Page 33 �tt r v yy i rv�sre w`I ` k# rJ sr I.s 1.. „~ s !k�+n, �N) i ky. , : kms+ 74 „^`f+',�;` T`�a ,,.,`t"'k,+'et;"1'r v ate i`:,brad 7aa w t . k"a V •M s r`40,1-70. `�' / '"}1* : +., ,.'. a'L t r 1t y + ,. r Y L • n 3'r R '.' >n.: ! eW Y : r"J7° � t x SF - 'i r- u� ^"u y�`I�t�X iv }k�Fs•�kkr��Rrt� i� t ,�Yp �h ,=t'',.10,1..,1. v I& i- , �"' y Y. / „,7 r tS�P� �' ? . 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However, the selected intersections with detailed modeling in the DEIS are unlikely to be critical locations for the worst-case CO impact modeling. Thus, compliance with the NAAQS for the project can not be concluded in the DEIS. 1) Selecting intersections only based on traffic impact might not include the critical locations with the potential worst-case air quality impacts As indicated in Appendix H of the DEIS, 10 intersections, from a total of 48 intersections in the traffic study, were pre-selected for air quality review. The criterion used for selecting these intersections was apparently those intersections that showed the greatest incremental traffic impacts — either increases in delay or total volume. However, an air quality impact is generally determined in terms of the absolute pollutant concentration level as compared to the NAAQS, rather than the incremental change in traffic at a specific intersection. In other words, the intersection with the highest percentile increase in volume or delay might not be the worst-case location for an air quality impact. Therefore, whether the worst-case air quality impact intersections were included in those 10 pre-selected air quality study intersections can not be determined from the DEIS. Thus, the conservativeness of the associated air quality impact assessment is in question. 2) Underestimating CO impact Furthermore, the ranking selection of the three intersections for detailed modeling analysis was not done in accordance with accepted procedures. The guidance provided in the NYSDOT EPM indicates that the intersections for a detailed microscale air quality analysis are those intersections with "the three highest levels of service and the three highest traffic volumes". It appears that the DEIS only considers the intersections with the highest percentile change in traffic volume as described in Appendix H as "The following intersections were determined to have the highest traffic impacts from the proposed traffic, resulting in 96 percent to 227 percent increase in traffic between no-build and building conditions." "There were additional intersections with level of service F or worse; however, the percent increase in traffic associated with the proposed project was significantly lower than the selected" This methodology in selecting intersections for a detailed CO analysis is inappropriate. For example, higher CO concentrations would likely be predicted at a congested three-lane intersection (such as Palmer Avenue and Chatsworth Avenue) with a 20-percent increase in traffic as compared to a single-lane intersection (such as 56 Avenue and Portman Road) with a 100-percent increase in traffic. In the summary table presented on Page H-6, among the 10 pre-selected intersections for air quality study, those intersections with the three highest level of service and the three highest volumes were not studied in the DEIS including such intersections as: • Petersville Road and Potter Avenue; • Myrtle Boulevard and Weaver Street; Page 35 • Chatsworth Avenue and Palmer Avenue; • Larchmont Avenue and Myrtle Boulevard; • Chatsworth Avenue and Myrtle Boulevard; and • Garden Street/I-95 Int#16 Therefore the worst-case air quality impact resulting from the proposed project was underestimated. The analysis is flawed, and the EIS must study these impacts again using the proper intersections based on worse case CO impacts. The analysis should also indicate whether the calculations were based solely on cars, or on a mixed group of suburban utility vehicles (SUVs) and cars, given the higher emissions from SUVs. The EIS should relate the CO impacts to the overall air quality issues in the area. It should be stated that the area is in a non-attainment zone for ozone, and that there is a relationship between vehicle miles traveled and ozone levels. It should also be noted that CO levels, while they may be within standard limits, will rise greatly, also affecting overall air quality. Moreover, EPA standards are based on impacts on adults. However, many of the worst impacts will occur in the vicinity of schools, and the impacts are even greater on children, whose lungs are more sensitive. 4.4 Noise Traffic noise impact was evaluated at 10 locations in this DEIS within a one-mile radius of the project site using the methodology described in the New York City Environmental Quality Review Technical Manual. Since no PCE calculation sheets were included in the DEIS, only the general comments are provided as follows: 1) Selection of receptor locations Five monitoring sites were selected at five intersections with a predicted doubling of traffic volumes, which would potentially result in a greater than 3-dBA noise increase. Since noise impact is generally considered at specific noise sensitive receptor locations, noise monitoring and analysis sites are typically related to a specific receptor rather than an intersection. Furthermore, the traffic noise impact at a sensitive receptor location is generally dominated by mid-block traffic adjacent to the receptor rather than traffic in whole at an intersection. Therefore, it is not clear whether the selection of those five intersections is sufficient to include the potential worst-case noise impact locations for the purposes of the DEIS. Traffic flow diagrams should be provided in the DEIS in order to determine these roadway mid- block locations where an adjacent noise sensitive receptor is subject to a doubling of traffic. Then, the worst-case noise impact can be evaluated. In addition to five intersection locations, five additional receptors were analyzed in the DEIS. However, these five additional receptors seem not to be adjacent to any major impacted roadways and they are all institutions or building complexes. It should be clarified in the DEIS that no more sensitive receptor locations including individual residential places would experience greater noise impact than those locations studied. 2) Noise impact criteria 5-dBA noise impact criterion is used in the DEIS to determine traffic noise impact. This level of noise increase is suggested to result in sporadic noise complaints according to the International Standard Organization in November 1969. A more stringent noise criterion of a 3-dBA increase Page 36 under the most circumstances has been widely used as noise significance in the New York City area. This criterion is described in the same document that provides the methodology used in the DEIS for noise impact analysis. Based on this 3-dBA criterion, the exceedances would occur at a couple of locations (Locations #1 and #2) for various time periods. Mitigation measures should then be discussed. 3) Noise monitoring results At four out of the 10 noise monitoring locations, Leq was found greater than L,o with a maximum of 6-dBA difference (Table 3.11-6). This is highly unusual and the explanation should be provided. Leq is the equivalent steady-state sound level during a stated period of time containing the same acoustic energy as a varying sound level during the same time period. L10 is the sound level that is exceeded 10 percent of the time for the period under consideration. 4) Worst-case analysis period On Page 3.11-10, the DEIS describes the differences between the existing traffic volumes during weekday evening, midday and night period with the midday and night traffic volumes are approximately 80 and 55 percent of the evening volume, respectively. The DEIS further states "Traffic volumes are greatest during the weekday evening period compared to the weekday midday and weekday night periods. Thus, the weekday evening PCE numbers have been used in the noise analysis and provide a reasonable worst case scenario." The assumption used is incorrect. The higher the existing PCE numbers are used, the less noise increases are forecasted. Therefore the DEIS underestimates noise impacts from both weekday midday and weekday night-time periods and the level of exceedance would become higher than reported. 5) Truck related PCEs Whether the truck-related trips (see Table 3.11-11) were considered in the noise impact analysis for applicable time periods should be clarified. 6) Other factors The potential impacts from leveling 16 acres currently occupied by structures and landscaping should be noted. If removal of trees and structures would reduce the noise buffers in this area, this should be addressed as an impact. Page 37 4.5 Lack of Mitigation Measures for Impacts on Neighborhood Character No mitigation measures have been proposed to address the impacts on neighborhood character. Effective mitigation of traffic on neighborhood streets can only be accomplished by reducing IKEA generated traffic on those streets. In order to accomplish this the Environmental Impact Statement must assess: 1) Alternative Development Scenarios Three alternative development alternatives are discussed in Section 2 of this report. All three alternatives outlined would substantially reduce traffic. 2) Reduced Scale Because IKEA represents a shopping phenomenon as previously discussed, scaling back the store only 5 or 10 % may not be effective in mitigating impacts. There may not be a direct correlation between size and traffic generation. However, scaling it back in size by 50% or more could substantially reduce traffic, and should be analyzed. A major reduction in size would mean correlate to some reduction in traffic. 3) New Exit 17 Interchange It may be possible to reduce the traffic impact on local streets by improving access to 1-95. In order to determine whether this is possible, the Environmental Impact Statement must analyze the construction of new ramps at Exit 17. The main reason IKEA traffic chooses to use local roads in Mamaroneck (Weaver, Murray and Palmer) and New Rochelle (Pine Brook Boulevard and Beachmont Drive) is because access from the north and east to the IKEA site via 1-95 is poor. Vehicles have to "overshoot" the site to exit 16 and then backtrack. Drivers do not like to do this because they perceive the travel time to be longer. For this reason the IKEA DEIS has assigned some traffic to the local roads: 3.9% of IKEA traffic in both directions has been assigned to the Hutchinson Parkway and Weaver Street, 2.9% of inbound IKEA traffic to Palmer Avenue and 4.0% of outbound IKEA traffic to Palmer Avenue. (As explained in the section on "Distribution and Assignment of IKEA Traffic", BFJ projects that the amount of traffic assigned to the Weaver Street/Murray Avenue route has been underestimated significantly.) The DEIS recognizes that this traffic creates a community character impact on the streets of Mamaroneck and Larchmont. Similar community character impacts can be expected along many streets in New Rochelle such as Weaver Street, Pine Brook Boulevard and Beechmont Drive. Despite the recognition of the impact, however, no mitigation measures are analyzed or proposed. One possible way to mitigate these impacts (that was raised at the public hearing) is to construct a set of ramps at exit 17 to/from the north on 1-95. These additional ramps could complement the existing half interchange, thereby improving access to the IKEA site from the north and the east. In order to assess preliminarily the feasibility of such mitigation measures, BFJ undertook travel time surveys showing that vehicles that drive through the interchange of I-287/Hutchinson Parkway/I- 684 would save 5 minutes by choosing a route via 1-95 exit 17 rather than using Weaver and Murray Ave. See Table 4.4. Psychologically, drivers would be drawn to 1-95 because the new SB off-ramp at exit 17 would be identified with IKEA. We surmise that some portion (but not all) of the IKEA traffic assigned to Weaver Street, Murray Avenue and to Palmer Avenue might shift to 1-95. One possible configuration of these ramps is shown as option A in Figure 4.5. The new ramps shown in the attached figure as alternative A are only an example of how these ramps could be Page 38 built. The IKEA EIS needs to assess this mitigation measure and possibly develop other ramp configurations that would achieve similar benefits. Another possible configuration is shown as Alternative B. This configuration would involve ramps to and from the north similar to those shown in Alternative A and, in addition, would split the existing ramps to and from the south into two branches, one set of branches to and from Mamaroneck as they exist today, and a new set to and from New Rochelle. Fifth Avenue between the two sets of ramps could then be limited to emergency vehicles. A cul-de-sac can be constructed on Fifth Avenue in Mamaroneck and possibly one also in New Rochelle. These cul-de- sacs would be built in such a way where access to the local businesses would be maintained. See Figure 4.6 for a possible configuration of Alternative B. These figures are offered as illustrations of a concept that must be analyzed to assure that all possible methods of mitigation have been considered, and not as engineered proposals. These configurations are only two of presumably many alignments. While the Town does not endorse the concept of ramps, it does assert that the EIS must study the issue of new ramps. To conclude, the DEIS recognizes impacts on community character, but does not offer any mitigation measures. The ramps that were discussed at the public hearing could possibly provide mitigation. The EIS must analyze these measures fully and report its assumptions, data and conclusions. Page 39 Table 4.4 Travel Time Tests with New 1-95 Ramps to/from North at Exit 17 Measured between Hutch Parkway Exit 23 and IKEA Site/I-95 Exit 17 Via Hutch Parkway (exit 20) and Weaver St Via Mamaroneck Ave Via Forest&Chatsworth Via Murray & Myrtle & 1-95 to exit 17 Date & Time Inbound Outbound Inbound Outbound Inbound Outbound Sat, 10-28-00 12.53 9.18 9.77 10.47 5.67 5.17 2 pm - 4pm 10.5 8.85 10.12 9.17 5.42 4.8 Sat, 11-4-00 10.88 10.98 11.25 10.95 4.6 6.1 2 pm - 4pm 10.07 12.62 10.85 11.02 4.63 6.48 Averages 11.00 10.41 10.50 10.40 5.08 5.64 Average Time for Local Routes: 10.58 minutes Average Time for 1-95 Route: 5.36 minutes Source: BFJ October, November 2000 as r a r g $rte, . @ -} % 4.' _ �Ftl A't�� ?.: 4 it"ry i t ! „"{.; \f4 ,„-...-,,,,,,,-;:::-!--/ � "F.. .+i' Y ,� j t +.1,0:. '4,-1',. ...,.;.1..:14t'. � " yr r�`lw4 "`.. \ {, '�+ .-‘144..,‘„....;,,,,:,,,...,44'..4'.- a A4 a�• a'h ";� \ a ¢ a " < .it e�A ,�,!.."-,:::,,`:'..7.;,.;'•:-' �. g`+$,,...01,,,,,v R 1.m ,. '14 i t;.'. 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BF.y t .-..A, - _ -,k, -, ,.. - . .i,.- ----,,, ,,,,,- _ ':,,, 4.,,-,, '3y 4, z :E h ,, n M < -"-.'• , � , Figure 4.6 �'� R` NEW 1-95 RAMPS ALTERNATIVE B f Full InterchangeR+ ' ' � � r Separate New Rochelle Ramps + . �, b Fifth Avenue Disconnect Ar' �... ),...i7.-,,,,.k,..-„, a_..,_ t well', O.'� 4 - ISR �^g{��' IKEA o aoo 800 h [own of Mamaroneck, NY BFJ Buckhurst Fish &Jacquemart, Inc. 5.0 OTHER ENVIRONMENTAL CONCERNS Phyllis Wittner, Councilwoman from the Town of Mamaroneck, provided the following information and comments on ecological issues not adequately addressed in the DEIS, such as the Premium River-Pine Brook wetlands complex and stormwater drainage, as follows. 5.1 New York State designated Significant Fish and Wildlife Habitat The New York State designated Significant Fish and Wildlife Habitat, the Premium River-Pine Brook Wetlands Complex, was not mentioned in the DEIS because Pin Brook which flows into Beechmont Lake is then piped underground until it surfaces in Larchmont. Therefore, the DEIS did not take a hard look at the impacts of car and truck pollutants on Pine Brook. It failed to recognize that Pine Brook joins the Premium River, flows in to the Premium Mill Pond, and then into Echo Bay and Long Island Sound. A well-documented large heating oil spill from the Mac Leay apartments (located across the street from the Ikea site) cost the Town and Village a considerable amount to dredge and restore tidal flow to the Premium River. The amended Town of Mamaroneck-Village of Larchmont Local Waterfront Revitalization Program approved by the New York State Department of State in November 1995, describes the relevant aspects of state and local coastal zone policy as follows: Policy 7: Significant Coastal Fish and Wildlife Habitats, as identified on the Coastal Area Map, shall be protected, preserved, and, where practical, restored so as to maintain their viability as habitats. Explanation of Policy: The Premium River- Pine Brook Wetlands Complex was designed a Significant Coastal Fish and Wildlife Habitat by the New York State Secretary of State on November 15, 1987. It was approved for inclusion in New York State's Coastal Management Program on November 1, 1990... The Premium River- Pine Brook Wetlands are tributary to the Long Island Sound in the Town of Mamaroneck, the Village of Larchmont and the City of New Rochelle (7.5'Quadrangle:Mount Vernon, N.Y.). The fish and wildlife habitat is an approximately 65 acre area including Pine Brook south of the Boston Post Road, the Premium River, the Premium Mill Pond, the northeast portion of Echo Bay, the Pryor Manor Marsh, a former wetland between Dillon Road and Emerson Avenue, the salt marsh areas adjacent to the river and creek and the small portions of adjacent meadow. The Premium River-Pine Brook Wetlands area is a diverse and relatively undeveloped complex of tidal river, tidal flats, shallows, salt marsh, and freshwater wetlands which is unusual in Westchester County. The wetland complex remains undeveloped and the range of natural communities in this area support a diversity of fish and wildlife species. Although not comprehensive, examples of generic activities and impacts which could destroy or significantly impair the habitat are listed below to assist in applying the habitat impairment test to a proposed activity. Any activity that would further degrade the water quality in the Premium River, Pine Brook, Premium Mill Pond and associated wetlands would impair the biological productivity of this area. Species of fish and wildlife may be affected by water pollution such as chemical contamination including food chain effects, oil spills, excessive turbidity or sedimentation, waste disposal, and sewage discharges. Efforts should be made to improve water quality in the area by controlling runoff and waste discharge from adjacent upstream commercial and residential areas and by improving tidal flushing. Habitat Page 43 enhancement and restoration efforts are needed in several of the smaller, degraded, wetlands in this area. Elimination of freshwater wetlands, salt marsh and intertidal areas through excavation or filling, would result in a direct loss of valuable habitat area. Natural plant communities bordering the wetlands should be maintained to provide cover for wildlife, erosion control, and buffer zones. Opportunities for compatible public uses of the area (nature study, environmental education) should be maintained or enhanced to utilize this valuable fish and wildlife resource. A Habitat impairment test must be met for any activity that is subject to consistency review under federal and state laws, or under applicable local laws contained in an approved local waterfront revitalization program. If the proposed action is subject to consistency review, then the habitat protection policy applies, whether the proposed action is to occur within or outside the designated area. The specific habitat impairment test that must be met is as follows: In order to protect and preserve a Significant Habitat, land and water uses or development shall not be undertaken if such actions would destroy the habitat, or significantly impair the viability of the habitat. Habitat Destruction is defined as reduction in vital resources (e.g., food, shelter, living space)or change in environmental conditions(e.g., temperature, substrate, salinity)beyond the tolerance range of an organism. Indicators of a significantly impaired habitat focus on ecological alterations and may include, but are not limited to, reduced carrying capacity, changes in community structure (food Chain relationships, species diversity), reduced productivity and/or increased incidence of disease and mortality. • The tolerance range of an organism is not defined as the physiological range of conditions beyond which a species will not survive at all, but as the ecological range of conditions that supports the species population or has the potential to support a restored population, where practical. Either the loss of individuals through an increase in emigration or an increase in death rate indicates that the tolerance range of an organism has been exceeded An abrupt increase in death may occur as a environmental factors, however, do not have a sharply defined tolerance limit, but produce increasing emigration or death rates with increasing departure from conditions that are optimal for the species. • The range of parameters which should be considered in applying the habitat impairment test include but are not limited to the following: 1. physical parameters such as living space, circulation, flushing rates, tidal amplitude, turbidity, water temperature, depth (including loss of littoral zone), morphology, substrate type, vegetation, structure, erosion and sedimentation rates; 2. biological parameters such as community structure, food chain relationships, species diversity, predator/prey relationships, population size, mortality rates, reproductive rates meristic features, behavioral patterns and migratory patterns;and, Chemical parameters such as dissolved oxygen, carbon dioxide, acidity, dissolved solids, organics, salinity, and pollutants(heavy metals, toxics and hazardous materials). Page 44 5.2 Stormwater Drainage The "Stormceptors" mentioned in the DEIS would not deal adequately with the hydrocarbons, heavy metals, sand, sodium and chloride plus atmospheric pollutants produced by 1500+ parked cars, nor will the proposed grassy swale alone. Moreover, the DEIS fails to address the large number of cars and trucks that will traverse the roads and exacerbate the problems of nonpoint source pollutants on stormwater management during the construction period, and project operation. Nonpoint source pollution is an issue that all local municipalities are mandated to address in the very near future, and it should be addressed in more detail in the EIS. Finally, since the project is greater than the five acre cut off point of the EPA Phase I stormwater regulations, the project may be subject to a National Pollutant Discharge Elimination System (NPDES) permit. This should also be addressed in the EIS. • Page 45