Memorandum

To:
From:
Date:
RE:

TISTWG Members
Dan Hardy
March 26, 2015
LATR CONCEPTS April 1 Status Report

This memorandum provides an update to the January LATR CONCEPTS status report, although the
primary addition is SA-3, the Very Low VMT concept on Page 8. Per the cover memo, our focus for April
is to start with consideration of changes that would be needed to the Subdivision Staging Policy itself
(including the SA-3 concept attached) and then move into the more detailed discussions of LATR/TPAR
Guidelines changes.

Otherwise, the changes between the January LATR Concepts report and this version are essentially
limited to status notes that are identified in bold italics text where they occur.

1
Prepared by Renaissance Planning Group
March 26, 2015

Table 1. Organization of LATR Concepts and Concerns

Scoping Concepts (Board #1)
Study Approaches (starting on page 7)
SA-1.
Alternative Review Procedure Metro Station Policy Areas TMAg (no change)
SA-2.
Alternative Review Procedure White Flint (no change)
SA-3.
Alternative Review Procedure Very Low VMT
Study Triggers (starting on page 11)
ST-1.
Trip Generation Threshold
ST-2.
Study Area
ST-3.
Background Traffic
ST-4.
Modal Analysis Triggers
Study Refinements (starting on page 24)
SR-1.
Potomac Two-Lane Policy (no change)
SR-2,
Exempt Second Improvement Mitigating < 5 CLV (no change)
SR-3.
Protected Intersections
SR-4.
Non-Transportation-Related Policies (no change)
Analysis Elements (Board #2)
Approach (starting on page 30)
AA-1.
Priority of mitigation approach
Measurements: (starting on page 32)
AM-1. Pedestrian System Measurement
AM-2. Bicycle System Measurement
AM-3. Transit System Measurement
AM-4. CLV Thresholds (no change)
AM-5. CLV/HCM Thresholds
Solutions: (starting on page 48)
AS-1.
CLV mitigation requirement (100% or 150%) (no change)
AS-2.
$12K per trip (no change)
AS-3.
Ped-bike gap contribution
Elements proposed to be dropped (Board #3) (starting on page 53)
D-1.
VMT based standards/thresholds
D-2.
Connectivity indices (as standalone may be part of bike/ped accessibility)
D-3.
Screenlines/cordon lines with person-throughput
D-4.
Traffic Mitigation Goals under SSP APF2
D-5.
Areawide trip caps or parking caps (with or without trading)
Other Issues (Board #4 no facilitated group discussion)
O-1.
Ensuring a balanced approach (i.e., test/tweak each concept so that a bunch of new rules arent death by a
thousand cuts)
O-2.
Effect on review processes/schedules by multiple agencies
O-3.
Defining area types (are BRT stations all urban areas?) in subsequent SSP Council actions
O-4.
Reflecting flexibility for evolution in land use-types over time (i.e., the millennials argument)
O-5.
Free rider issues new rules exacerbate the problem, but are there improvements to status quo?
O-6.
Defining peak periods for different modes (particularly midday pedestrian flows)
O-x.
Others to be added by meeting participants.

2
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

SA-1: Alternative Review Procedure Metro Station Policy Areas TMAg
Process: Scoping Elements
Sub-Process: Study Alternative Review Procedures

Concept in a Nutshell:
Enter into a Traffic Mitigation Agreement (TMAg) to agree to reduce
50% of peak period vehicle trips and pay twice the applicable
transportation impact tax in lieu of conducting any Local Area
Transportation Review or Transportation Policy Area Review actions.

-50%

Primary Purpose:
Incentivize trip reduction and eliminate need to examine and mitigate vehicular LOS in Metro Station
Policy Areas

Effect of current approach on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Strengths
Focuses private sector efforts
solely on trip reduction.

Weaknesses
None.

Improving predictability

Eliminates uncertainty
associated with LATR and TPAR.

Streamlining implementation

Places responsibility for

transportation implementation
on public sector.

Creates uncertainty associated

with the risk of non-performance
in reducing vehicle trip
generation by 50% over the
course of the TMAg performance
period.
None.

Relationship to Current LATR (or prior growth policy concepts)

This Alternative Review Procedure is an existing LATR approach within Metro Station Policy Areas
(Resolution 17-1203 TA1, p. 16; LATR/TPAR Guidelines, p. 23). No changes are proposed as of the date
of this memorandum.

Expected Application Area:

Metro Station Policy Areas only. No changes are proposed as of the date of this memorandum.

Examples of Application
Two applications have been approved under this Alternative Review Procedure:
3
Prepared by Renaissance Planning Group
March 26, 2015

Twinbrook Commons was approved (Preliminary Plan 1-04054) in May 2004 by the Planning
Board and subsequently annexed into the City of Rockville
North Bethesda Center (LCOR) was approved (Preliminary Plan 12004049A) in November 2007
by the Planning Board and is within the geographic area now covered by the White Flint Special
Taxing District.

The North Bethesda Center project has an executed Traffic Mitigation Agreement (TMAg) executed in
December 2006 and in effect for 55 years, or until the Planning Board determines it is no longer needed.
It is possible that over time the LCOR approach will be renegotiated at some point in the future to shift
from the TMAg approach to the broader Special Taxing District approach.
This procedure has rarely been applied, due primarily to the risk associated with its aggressive, and longterm, trip reduction performance requirements. However, it remains a logical option to retain in the
pantheon of LATR concepts as it is a key option in fulfilling the Countys vision for reducing reliance on
auto travel in transit-served areas.
This procedure requires what is commonly termed a hard TMAg with defined performance measures
for site outcomes (such as vehicle trip caps) and penalties (typically backed by a security agreement such
as a performance bond or letter of credit) that are guided by Section 42 of the County Code but are
ultimately a function of site-specific conditions negotiated at time of subdivision approval. (Conversely,
soft TMAgs require participation in Transportation Management District activities but do not have
specific performance measures.) . A continuing area of discussion common throughout Montgomery
County and transportation demand management programs nationwide is the disinclination to pursue
legal action, primarily due to the potential damage to the collaborative working nature that is the
hallmark of TDM success, but also due to the relatively low ratio between the punitive value of the fines
and the administrative cost of their pursuit.

Next Study Steps

Identify proposed language to:
Require performance bonds
Extend maximum period of performance beyond 12 years

4
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

SA-2: Alternative Review Procedure White Flint
Process: Scoping Elements
Sub-Process: Study Alternative Review Procedures
Concept in a Nutshell:
Within the White Flint Metrorail Station Policy Area, LATR and
TPAR requirements have been replaced with a Special Taxing
District and Sector Plan staging and monitoring approach.

Primary Purpose:
Leverage the property values in the White Flint Sector Plan
area to help fund needed transportation system
improvements, notably a robust street grid with significant
eminent domain requirements that make it infeasible to
implement under traditional LATR and TPAR exaction
processes.

Effect of current approach on:

Study Objective
Improving context-sensitivity
and multimodal analysis
Improving predictability
Streamlining implementation

Strengths
Monitoring program examines
periodic progress towards
multimodal goals
Removes uncertainty from
development proposal process
Facilitates implementation of
well-defined, multimodal
network improvements requiring
governmental actions such as
eminent domain to implement.

Weaknesses
Requires substantial advance
planning and negotiation to
establish alternative process
Staging plan entails some risk of
future areawide moratoriums
None, although the challenges
with a consolidated plan
implementation initiative may be
more visible than would be with
dozens of smaller projects.

Relationship to Current LATR (or prior growth policy concepts)

The White Flint Special Taxing District is an existing approach (Resolution 17-1203 TL2, p. 13, LATR/TPAR
Guidelines p. 4).

Expected Application Area:

White Flint Metro Station Policy Area only. No changes are proposed.

5
Prepared by Renaissance Planning Group
March 26, 2015

Examples of Application
The White Flint Sector Plan area is the only location in Montgomery County where LATR and TPAR are
fully replaced by an alternative review procedure.
This project classifies the establishment of such districts as Pro-Rata Share approach to addressing the
transportation impact of development.
The concept might be considered for other areas of the County where individual transportation impact
taxes could be replaced by a multimodal implementation district. Other jurisdictions in the literature
review utilizing a similar approach that replaces analysis with a pay-and-go approach include:

Multimodal Transportation Districts in Florida, including the City of Kissimmee and the City of
Destin
Plan Districts in the City of Portland, Oregon (covering about half the city acreage)
Traffic Mitigation Zones in the City of Baltimore, Maryland (covering about half the city acreage)

Next Study Steps

The process for establishing additional Pro-Rata Share zones generally requires establishment of
concurrence on planned transportation vision, needed transportation system improvements, and the
appropriate tax, fee, or other payment/implementation processes. These processes typically take
several years to develop. The 2016 Subdivision Staging Policy is not the appropriate study vehicle to
enact additional Pro-Rata Share zones in the County, but the concept should be included in
documentation and presentations to facilitate consideration of additional areas of the County where
such an approach could be developed in concert with a community Master Plan or Sector Plan process.

The White Oak Science Gateway Sector Plan may be the first additional area to move to a Pro-Rata
Share system. The PHED Committee is scheduled to meet on January 26 to consider Subdivision Staging
Policy Amendment #14-02, a proposal for identifying and managing a Pro-Rata Share approach. The
PHED committee packet is expected to include the December 10, 2014 draft developed by the
Montgomery County DOT and inserted on the following page.
Additional information on the background traffic concerns prompting the introduction of Subdivision
Staging Policy Amendment #14-02 is provided under the discussion of LATR Concept ST-3 on background
development.
As of the PHED Committees March 24 approval of the SSP Amendment #14-02, the language has been
incorporated in the track changes version of the SSP Resolution distributed for the April 1 TISTWG
teleconference.

6
Prepared by Renaissance Planning Group
March 26, 2015

12/10/14 Proposal Developed by MCDOT:

7
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

SA-3: Alternative Review Procedure for Very Low VMT
Process: Scoping Elements
Sub-Process: Study Alternative Review Procedures
Concept in a Nutshell:
Developments that generate a very low VMT should be able to be credited with the same types of
benefits as those that generate low vehicle trips. A development that, by virtue of increasing the overall
development density or diversity of its site context, reduces VMT generated by surrounding land uses
should be able to take credit for that reduced VMT as well. Three levels of Very Low VMT are
considered:

Type 1 Zero-VMT Development: M-NCPPC would identify development types and locations
that reduces areawide VMT and are automatically exempted from any transportation mitigation
action (i.e., no action under LATR, TPAR, or transportation impact taxes)
Type 2 Very Low VMT Development: M-NCPPC will identify development types and locations
that generate low VMT rates that could be considered to have a de minimis effect based on
reduced areawide VMT should follow the de minimis rules (i.e., no action under LATR, but still
action based on TPAR and payment of transportation impact taxes)
Type 3 Mitigated VMT Development: Applicants may propose that M-NCPPC consider their
development a Low-VMT case following the same logic currently applied under concept SA-1, a
50% reduction in vehicle impact monitored through a Traffic Mitigation Agreement (TMAg). The
Type 3 development would operate under the same approach as in SA-1, except that VMT
would be measured rather than vehicle trips:
o Applicant proposes analysis, mitigation, and monitoring to achieve site-generated VMT
that is 50% or lower than that VMT which would otherwise be assumed to be generated
by the site.
o No action under LATR or TPAR
o Payment of twice the applicable transportation impact tax
o TMAg with accepted monitoring, mitigation, and incentives/disincentives for achieving
the 50% VMT reduction.

Primary Purpose:
Recognize the benefits of density and diversity in urban areas not only in achieving a modal shift away
from auto drivers but also the benefits of shorter trip lengths for those who do use autos.

Effect on:
Study Objective
Improving context-sensitivity
and multimodal analysis

Strengths
Introduces combination of
development type and

Weaknesses
None
8

Prepared by Renaissance Planning Group

March 26, 2015

Improving predictability

Streamlining implementation

surrounding context
Enables applicants to consider
development proposals that
eliminate need for any action
under LATR
None

None

None

Relationship to Current LATR (or prior growth policy concepts)

Type 1 and Type 2 cases are new, based loosely upon the concepts emanating from initial SB 743
concepts in California jurisdiction and a desire to establish a baseline for potential VMT reduction
scenarios.
Type 3 cases are similar to, and framed to replicate, the current Alternative Review Procedure for
reducing vehicle trips by 50% in conjunction with a Traffic Mitigation Agreement (TMAg), as described in
LATR Concept SA-1.

Expected Application Area:

The Type 1 and Type 2 cases have been developed for new residential development within the Bethesda
and Silver Spring CBDs, which are selected because these two CBDs have:

development densities and J/HH ratios are both high enough that new residential development
of the right size and characteristics is arguably capable of reducing overall areawide VMT
Transportation Management Districts to help support and monitor effects across the CBDs

Examples of Application
The assessment of low VMT development types 1, 2, and 3 are described below.
Type 1: Zero VMT Development
The basic theory of a Zero-VMT Development is that, by virtue of its location or characteristics, the
activities it generates reduces VMT generation by nearby development sites to such an extent that the
change in total areawide VMT after introduction of the new development is at most zero (and possibly a
net reduction in areawide VMT occurs). In other words, the development site can take credit for
reducing VMT at other sites as part of its VMT calculation.
A basic challenge with this approach is that it is difficult to conclude that any new development actually
takes vehicle trips off the road from nearby developments. For instance, we would expect that a new
residential development in Bethesda or Silver Spring would generate a number of walk/bike trips to
adjacent retail locations, thereby positively affecting both the total number of person-trips, total
amount of sales, and the total non-auto driver mode share at those adjacent retail locations. However,
it is unlikely that the presence of new walk trips would also result in the removal of a prior auto trip to
9
Prepared by Renaissance Planning Group
March 26, 2015

the same retail location. The one exception could be for retail experiences (the most exclusive
restaurants or sold-out entertainment venues) but these are the rare exception rather than the rule.
However, the journey to work trip describes a case wherein the introduction of a new walk/bike trip
should result in the removal of another trip. The number of available jobs in Bethesda at any point in
time is finite; if a resident of a new development takes a job in a nearby building, it stands to reason that
that very same job/position must have been vacated by someone else who may or may not have been a
Bethesda resident. Since many of those jobs are held by persons who drive a long distance to work in
Bethesda, we can convert the typical Bethesda office workers journey to/from work VMT into a credit
for the new development. This approach is described in the attached table for a hypothetical 200 unit
development (the size of the residential development is not proposed as a factor in the mathematics at
hand, but using a specifically sized development makes it easier to conceptualize the data) and
summarized below:

Step A. Consider VMT generated by new development

o MWCOG Household Travel Survey indicate that Silver Spring and Bethesda households
generate an average of 16.19 VMT
o The residential development will generate trips by non-residents (deliveries, friends,
maintenance staff, etc.); estimated based on 85%/15% generic peak period directional split
and an estimate that non-resident trips are generally about half the length of resident trips
o The development generates about 3,481 daily VMT
Step B. Consider VMT generated by a typical CBD employee
o We know from the Bethesda TMD 2009 survey report (latest info readily available) that
theres a NADMS (all times of day) of about 38%, so in other words, 62% of Bethesda
employees drive to work.
o The average trip length (admittedly, for all modes) is 15.8 miles one way
o Therefore the typical Bethesda employee generates about 19.6 VMT daily
Step C. Consider how likely it is for the new residential development to generate employees in
Bethesda
o From the Bethesda TMD we know that about 4% of employees walk or bike to work; we use
this as a surrogate for local employees (some will walk from outside the CBD, and some
residents inside the CBD will take transit or drive to work)
o These 4% of employees total about 1538 employees, which works out to about 0.16
employee in every Bethesda CBD household
o The 200 unit residential unit may therefore produce about 33 Bethesda CBD residents
walking/biking to work, each of whom displaces a typical Bethesda employee generating
about 19.6 VMT traveling to/from work.
o The net benefit of the new development at reducing journey-to-work VMT is therefore
about 654 VMT.
Step D. Consider the residential site VMT generation in contrast to its effect in reducing areawide
VMT:
o 3,481 VMT generated by the site
10

Prepared by Renaissance Planning Group

March 26, 2015

o 654 VMT reduced by replacing typical Bethesda employees

o 19% reduction in site generated VMT attributable to the new residential development.
Step E. Consider parking restrictions to reduce VMT attributable to the new residential
development to be equal to the offset provided by reduced employee journey-to-work VMT
o Currently, average household owns 1.2 vehicles, or 240 total
o New building generates 14.5 VMT per owned vehicle (VMT includes that generated by
visitors, etc.)
o In order to limit VMT to 654 VMT offset associated with lower journey-to-work VMT in Step
C, the number of vehicles would need to be limited to 45, or 0.23 vehicles per household, or
equal to 0.23 spaces per vehicle.
o (Note: this value may be a tad high; as vehicles/DU drop, its reasonable to assume that the
proportion of non-resident vehicle VMT might increase due to increased deliveries and use
of taxis or carshare; from a policy perspective we would argue this is close enough).

Conclusion: M-NCPPC should grant a Very-Low VMT exemption to any residential building in the
Bethesda or Silver Spring CBDs that provide fewer than 0.16 resident parking spaces per unit.
Type 2: Very Low VMT Development
Using the assumptions in Type 1, we can postulate that whatever the de minimis rate ends up being for
Silver Spring and Bethesda CBD development, it can be increased to reflect the lower VMT associated
with residential development in jobs-heavy CBDs of Bethesda and Silver Spring, subject to parking
restrictions as noted below:
Using reasonable facsimiles of the current vehicle trip generation rates and a 30 vehicle trip level of de
minimis working out to about 60 vehicle trips
If parking is limited to
No limit
0.8 spaces per DU
0.6 spaces per DU
0.4 spaces per DU
0.2 spaces per DU

The number of units for a de

minimis finding would be
71
74
98
147
295

Next Study Steps

Respond to TISTWG comments. Note that this thresholds described for this approach would need to be
adjusted as we work on person-trip de minimis rates.

11
Prepared by Renaissance Planning Group
March 26, 2015

12
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

ST-1 TRIP GENERATION THRESHOLD
Process: Scoping Elements
Sub-Process: Study Triggers
Concept in a Nutshell:
The number of vehicle trips generated by a site is
used as a threshold trigger to determine whether
a Local Area Transportation Review (LATR) study is
required.
Currently, the trigger is set at 30 peak hour vehicle
trips, where peak hours occur between 6:30-9:30
AM and 4:00-7:00 PM (although staff has leeway to examine alternative peak periods for unusual uses
such as houses of worship).
The proposed concept would expand upon the current vehicle trip threshold to establish contextsensitive trip generation thresholds for different areas of the County to both encourage development in
smart growth areas and reduce the cost (to both the private sector and the staff) of development review

Primary Purpose:
The vehicle trip generation thresholds serves as a definition of de minimis impacts on the Local Area
Transportation system.

Effect of proposed changes on:

Study Objective
Improving context-sensitivity
and multimodal analysis
Improving predictability

Strengths
None

Weaknesses
None

Reduces cost of smaller projects

Streamlining implementation

Reduces complexity of multiple

smaller projects contributing to
individual improvements

Less data in public realm on

smaller projects, some minor
improvements may not be
required
None

Relationship to Current LATR (or prior growth policy concepts)

The 30-vehicle trip threshold is established in current procedures (Resolution 17-1203 TL1, p. 10;
LATR/TPAR Guidelines p. 3). The Subdivision Staging Policy does provide an option for applicants who
generate between 30 and 49 peak hour vehicle trips to pay an additional 50% surcharge on the
13
Prepared by Renaissance Planning Group
March 26, 2015

transportation impact tax in lieu of taking action under LATR. Under the proposed change to increase
the threshold to 50 or more vehicle trips countywide, this clause would become obsolete.
The Subdivision Staging Policy also notes that the 30-vehicle trip generation rate applies to both existing
and new trips, but that if the existing development is fairly well established (75% of approved use and
occupancy permits were issued more than 12 years prior to LATR study scoping) then the study scope
must be based on the increased vehicle trip generation rate rather than the total trip generation rate,
and that no LATR action is needed in such cases if the proposed development expansion would generate
5 or fewer new peak hour vehicle trips.

Expected Application Area:

The draft (straw-man) proposal would change the vehicle trip generation rates to:

75 peak hour vehicle trips in Metro Station Policy Areas and Central Business Districts
50 peak hour vehicle trips elsewhere in the County

The existing 30-peak hour vehicle trip threshold is the lowest threshold of any of the jurisdictions
included in the literature review (Rockville also has a 30-trip threshold). A threshold of 50 vehicle trips is
a fairly common threshold; most jurisdictions with a vehicle trip threshold use either 50 or 100 vehicle
trips. Further, the TPAR and transportation impact tax processes provide a belt-and-suspenders
approach toward addressing transportation impacts. Finally, since review of the MWCOG household
travel survey indicates that MSPAs tend to have non-auto-driver mode shares about 20-30% higher than
the rest of the County, a 75-vehicle trip threshold for MSPAs and CBDs might reasonable be equated to
the level of activity generated by a 100-vehicle trip threshold commonly used by other jurisdictions.
A higher trip generation rate threshold is appropriate in the most smart growth areas for several
reasons:

These are the areas where the County most wants to encourage private development, so
reducing the barrier to entry in these areas is a recurring theme for all LATR Concepts
These areas generally share a few common characteristics that suggest private and public sector
analysis efforts are better spent elsewhere:
o The overall levels of activity mean that a new neighbor generating 75 vehicle trips will
likely be less noticeable in an MSPA/CBD than one generating 50 vehicle trips in a less
developed community
o Adjacent intersections within CBDs tend to operate well below the congestion
standards; congestion requiring mitigation is generally outside the MSPA/CBD areas
where only larger studies requiring larger study areas would trigger analysis of
congested locations

14
Prepared by Renaissance Planning Group
March 26, 2015

Examples of Application
There is likely to be concern regarding loss of analytic information associated with the proposed
increase from 30 to 50 peak hour vehicle trips. Examples of urban jurisdictions that have adopted
mode-specific person trip generation rates include:

New York City has development thresholds that are based in development size descriptions,
such as 200 dwelling units, 115,000 square feet of office space for lower Manhattan designed
to establish 50 peak hour vehicle trips as an appropriate threshold
Conversely, the beta draft of Washington DCs Comprehensive Transportation Review
Guidelines recommends a threshold of 50 peak hour person trips, which in some cases could be
lower than 30 peak hour vehicle trips.
The City of San Francisco also uses the 50 peak hour person trip threshold

Next Study Steps

Consider the following approaches:

A two-tiered de minimis threshold in which a smaller application may trigger a payment-in-lieu

for infrastructure improvements (i.e., sidewalks, bicycle facilities, bus shelters) not covered by
TPAR or impact tax payments and a larger application triggers a traffic study.
Alternative person trip generation thresholds and approaches by context area, considering a
balance of multimodal placemaking objectives.
A stronger branding of the concept that the LATR changes need to allow smaller infill projects to
move forward with less administration/mitigation cost but that larger projects that create
greater multimodal impacts will have some greater analytic requirements. Sort of akin to
aphorisms like:
o Dont sweat the small stuff
o Manage the dollars and the pennies will take care of themselves

15
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

ST-2: Study Area
Process: Scoping Elements
Sub-Process: Study Triggers:
Concept in a Nutshell:
The need to consider Impact mitigation
at any given location should be
generally proportional to the amount
of increased travel demand at that
location. Sites that generate larger
numbers of trips should have a larger
study area; a concept common across multiple jurisdictions.
The proposed change to the study area determination would apply an Intersection Proportionality
Test, a comparison of site vehicle trip distribution to existing intersection entering volumes to screen
out intersections that are nominally within the LATR study area but for which the proportion of site
generated vehicles is relatively minor.

Primary Purpose:
The existing approach serves to identify intersections where the site trips generated are expected to
have a significant impact. The proposed changes to incorporate an Intersection Proportionality Test
streamline the identification process.

Effect of proposed change on:

Study Objective
Improving context-sensitivity
and multimodal analysis
Improving predictability

Streamlining implementation

Strengths
None

Weaknesses
None

Reduces cost of analysis by

identifying insignificant impacts
at time of study scoping
None

None

None

Relationship to Current LATR (or prior growth policy concepts)

The current Subdivision Staging Policy (Resolution 17-1203 TL1, p. 10; LATR/TPAR Guidelines p. 7)
identifies rings of study area intersections required as a minimum for an LATR study. For the smallest
study area, at least one intersection in each direction is required for sites generating fewer than 250
peak hour vehicle trips. For the largest study area, at least seven intersections in each direction are
required for sites generating more than 2,750 peak hour vehicle trips.
16
Prepared by Renaissance Planning Group
March 26, 2015

Per the Subdivision Staging Policy, the number of vehicle trips cited reflects the total trips (not the net
increase in trips), unless use and occupancy permits for at least 75% of the originally approved
development were issued more than 12 years before the LATR study scoping request.
The Subdivision Staging Policy also indicates that if a site requires improvements to at least one
intersection (or a TMAg is required or proffered by the applicant) and the site causes a second
intersection to have a < 5 CLV increase, then the applicant need take no action to mitigate that latter
intersection. The LATR/TPAR Guidelines indicate that this consideration can be applied at time of study
scoping, but the conditions to satisfy this characteristic can only be known after the study has been
completed.

Expected Application Area:

Countywide.

Examples of Application
Most jurisdictions have some level of relationship between the size of the development and the size of
the transportation impact analysis. Examples of precise guidance include:

The City of Rockville expresses minimum study parameters based on the number of new peak
hour trips generated that are somewhat similar to Montgomery Countys; the smallest study
area (for 30 peak hour vehicle trips) is expected to include at least 4 intersections within a
quarter mile of the site and the largest study (for more than 700 peak hour vehicle trips) is
expected to include at least 16 intersections within a mile of the site.
The Atlanta region has
square footage/dwelling unit
thresholds (for Cobb County,
within the Metropolitan Tier,
these thresholds include 400
DU, 400,000 GSF of office)
that trigger a Development of
Regional Impact (DRI)
processes administered by the Atlanta Regional Commission (ARC). For DRIs, a roadway
segment has a significant impact if the site generates at least 7% of the subject facilitys capacity
(an example shown in the table excerpted from the DRI guidelines). A similar process, using
Critical Lane Volume analysis, identifies significant impacts at intersections.
King County, Washington identifies a significant intersection impact as occurring when the site
will add more than 30 vehicles per hour to the intersection and those 30 vehicles constitute at
least 20% of the total site generated trips.
17

Prepared by Renaissance Planning Group

March 26, 2015

The proposed Intersection Proportionality Test adjustment to the study area would utilize these
concepts to better define locations without significant impact during the scoping process. Unlike the
current LATR/TPAR Guidelines process, the straw-man proposal would consider:

Peak hour vehicle-trip distribution and assignment

Existing intersection volumes as available from M-NCPPC or Maryland SHA

Intersections that would otherwise be included in the study area defined by the minimum number of
intersections in each direction may be excluded from analysis if:

The site-generated intersection volume is less than 1% of the total intersection entering volume
(note that the site entering volume is likely to constitute only 2 to 6 of the possible 12 turning
movements at a four-legged intersection and the total entering volume includes all 12
movements), or
The site-generated intersection volume is less than 5% of the total site generated traffic.

Next Study Steps

Consider:
Whether study area extent should be based on urban transect context (considering balancing
placemaking objectives)
Sample calculations for the Intersection Proportionality Test to consider the effect of
appropriate volume or percent volume thresholds as applied to total entering traffic or to CLV.

18
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

ST-3: Background Traffic
Process: Scoping Elements
Sub-Process: Study Triggers:
Concept in a Nutshell:
The baseline condition for establishing transportation impacts
should be one in which other development already approved and
in the pipeline is assumed to occur.

Primary Purpose:
To account for cumulative impacts of multiple development
projects.

Effect of existing concept on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Strengths
Recognizes increased travel
demand in background condition

Improving predictability

None

Streamlining implementation

Responsibility for improvements

can be shared among multiple
applicants

Weaknesses
Many legacy development
approvals do not reflect current
market trends
Addressing assumptions for
legacy approvals can create
uncertainty
Documenting/monitoring shared
responsibility for improvements
can be challenging.

Relationship to Current LATR (or prior growth policy concepts)

The Subdivision Staging Policy is silent on the treatment of background traffic and the LATR/TPAR
guidelines define background traffic as that generated by approved but unbuilt development
(LATR/TPAR Guidelines, p. 6, 22). Page 6 notes that pending developments may also be required to be
assumed as background traffic, primarily for the practical assessment of cumulative impacts for multiple
applications in the same study area.

Expected Application Area:

Countywide.
19
Prepared by Renaissance Planning Group
March 26, 2015

Examples of Application
The assessment of an appropriate analysis horizon year and level of background traffic is perhaps one of
the most widely divergent topics found in the literature review. Most jurisdictions that require
assessment of impacts from background traffic apply a high level of judgment in defining those
background developments compared to Montgomery County. However, many jurisdictions are more
conservative in the amount of additional growth beyond approved developments.
Traffic Growth Factor
Cobb County / GRTA (M)
VDOT 527 (F)

Background Developments
Montgomery County (J)
Pasadena (J)
San Francisco (J)

Both
Los Angeles (J, O)
San Jose (J, O)
Boulder (F, J, O)
Baltimore
New York City (J)

Key to abbreviations:
(F) = more than one future horizon year may be required (i.e., project open, longer term buildout)
(J) = considerable judgment applied in defining background developments re:
location, size, approval status
(O) = options for cumulative traffic (California term) may include pending plans in addition to approved
developments and/or a growth factor
(M) = travel model data may be used in lieu of historic trendline traffic growth

The simplest approach to background traffic is to use a common traffic growth factor in lieu of specific
background developments, such as applied by Cobb County, GA and in the Virginia statewide guidance
for Section 527 analyses. Many jurisdictions like Montgomery County, simply use the amount of
background traffic generated by approved but unbuilt developments. But many jurisdictions combine
the two approaches, recognizing that some background traffic will be generated by developments
beyond those near the subject site. In nearly all cases, the written guidance stresses the need to apply
judgment in determining an appropriate definition for background developments.
The background conditions also include transportation system improvements that are either
conditioned of prior development approvals or are fully funded in the first six years of the currently
approved County CIP or state CTP (LATR/TPAR Guidelines, p. 12).
Bill #14-02 would change the Subdivision Staging Policy for the White Oak Science Gateway Policy Area
by eliminating the provision of background traffic conditions. This proposal, as well as the Planning
Boards response proposing a proportional share payment approach, is described in the packet for the
October 20, 2014 PHED Committee packet:
http://www.montgomerycountymd.gov/council/Resources/Files/agenda/cm/2014/141020/20141020_P
HED1.pdf

20
Prepared by Renaissance Planning Group
March 26, 2015

The concerns currently paramount in the White Oak Science Gateway Policy Area echo similar concerns
that have surfaced as free rider concerns over the past several decades in different areas of the
County, so an approach that works countywide is desirable. The PHED discussion on October 20
directed the TISTWG to consider alternative approaches and develop a recommendation as part of the
comprehensive Subdivision Staging Policy recommendations.

Next Study Steps

The examination of equitable approaches to background traffic will need to accomplish the following
objectives; with a priority order suggested below and the value of using White Oak as a testbed for
known (i.e., Spectrum) and expected (i.e., Percontee) projects:

For White Oak, define whether sufficient knowledge is available to move from a negotiated
exaction approach to a true pro-rata share approach for all improvements in the White Oak
Science Gateway Policy Area, particularly given the uncertainty associated with BRT and
interchange specifics
Define the limitations associated with the payment in lieu of construction element of the
LATR/TPAR Guidelines (p. 26) as applies to the White Oak area concerns.
Identify other approaches in the current Subdivision Staging Policy that may be applicable and
cite pros and cons as applied to the White Oak area concerns, including:
o Approach for Multiple Applicants for intersection improvements (LATR/TPAR Guidelines
p. 19)
o Establishment of a development district and Provisional APF approval under TP4 of the
Subdivision Staging Policy
Identify additional alternative means for addressing proportional assignment of costs and
benefits for multiple public and private sector applicants.

Countywide, next steps include:

Determining whether additional clarity on background development definition is needed to

improve transparency to reviewers (from either agency staff or civic perspectives)
Developing a proposed approach to define when building or area vacancy rates are high enough
to warrant inclusion of re-occupancy as part of an increase to existing traffic volumes.
Determining whether APF trading, proposed in 2009 and reconsidered in 2012, should be
revisited.

21
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

ST-4: Modal Analysis Triggers
Process:
Sub-Process:
Concept in a Nutshell:
The level of quantitative analysis for autos, transit, bicycles, and
pedestrians should each be linked to the amount of travel demand
generated by each mode.

Primary Purpose:
Identify impacts and mitigation that are responsive to the types of
travel demand anticipated by each mode, based on the type of
development, location in the County, vision for the County, and
desired travel demand management approaches.

Effect of proposed change on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Improving predictability
Streamlining implementation

Strengths
Establishes context-sensitive
triggers for modal analysis based
on expected demand for each
mode
None
Helps identify specific
improvements for each mode of
travel

Weaknesses
None

None
None

Relationship to Current LATR (or prior growth policy concepts)

For the most part, LATR study analyses have focused solely on quantitative analysis of auto traffic.
(Traditionally, trucks and buses are also included in the analysis of traffic streams in jurisdictions
nationwide; for the purposes of simplicity they are also referred to as autos or vehicles in this
memorandum unless otherwise specified where the term is applied.) The primary exception to this rule
is when a Traffic Mitigation Agreement (TMAg) is required either to mitigate a specific number of vehicle
trips or achieve a specific trip reduction target such as the 50% auto trip reduction goal described in
Concept SA-1 or a master planned mode share goal. And in such cases, the focus has typically remained
on two particular elements of trip reduction:

achieving a non-auto driver mode share goal (NADMS), regardless of the submodal split
between auto passengers, transit riders, pedestrians, bicyclists, and/or number of trips not
made due to flex time or telework
22

Prepared by Renaissance Planning Group

March 26, 2015

focusing on the home-based work (HBW) trip, which usually consists of a journey-to-work trip
for which the US census (and its continuous and rolling American Community Survey element)
provides a robust data source at the census block level, and often an assumption that the return
journey home from work is made by the same mode as the journey to work

Across the nation, jurisdictions are realizing that the consideration of multimodal travel demands needs
to become both more accurate and more precise. The Institute of Transportation Engineers has
recognized this need in a full revamping of their how-to guide on trip generation, called the Trip
Generation Handbook, which is a companion
to the more frequently referenced Trip
Generation (aka Trip Generation Manual)
compendium of observed vehicle trip
generation rates compiled from studies
nationwide. The first two editions of the Trip
Generation Handbook, published in 2001 and
2004, provide guidance on nuances such as
pass-by trips and internal trip capture in mixed
use activity centers, but remain oriented on
vehicle trips. The 3rd edition of the Trip
Generation Handbook was published in draft
form (as a Proposed Recommended Practice)
in August 2014 and proposes a sweeping
change from a vehicle-trip orientation to a
person-trip orientation. In most suburban and
rural environments, the 3rd edition recognizes
that vehicle trips may continue to be the only
mode which warrants quantitative analysis.
However, the handbook recommends
thinking in terms of person trips and then
assigning those trips to each mode of travel,
particularly important in environments such as mixed use centers, transit-friendly developments, and
infill developments, where the NADMS will be substantially higher than the primarily suburban
environments for which the Trip Generation Manual has vehicle trip generation rates. The draft Trip
Generation Handbook provides available information to estimate NADMS for vehicle trip generation
rates for many common land use codes. In suburban environments, the primary component of NADMS
is auto passengers; Table C.3 of the draft Trip Generation Handbook demonstrates that for most uses,
each auto tends to carry between 1.1 and 1.4 persons (i.e., with an average auto occupancy of 1.25,
even if there are zero walk, bike, and transit trips, the NADMS equals 20%).
The Trip Generation Handbook will likely take a year or so to be adopted by ITE as a Recommended
Practice, following a formal comment period and editorial changes in response (ITEs Recommended
Practices go through an adoption process not too dissimilar from a master plan or sector plan adoption
23
Prepared by Renaissance Planning Group
March 26, 2015

process). In the interim, the Montgomery County Planning Department is proceeding with a separate
study to update trip generation rates and similarly convert from an auto-oriented approach to a persontrip oriented approach. The Planning Departments approach builds from the ITE approach to utilize
both the MWCOG Household Travel Household Surveys conducted between 2007 and 2012 which
report on all modes and purposes for some 144,000 individual trips in the region; as well as the MWCOG
travel demand model which is validated against those survey data points.
An assessment of NADMS for all purposes
and all times of day from the MWCOG Travel
Model for trips starting and ending in each of
the Countys policy areas provides a fairly
recognizable picture of travel demand in the
County. As indicated in Table C.3 of the draft
Trip Generation Handbook, the fact that auto
passengers are fairly common, particularly for
most non-home-based work trips, means that
every policy area in the County has a baseline
NADMS of about 26%, with many MSPAs and
CBDs having an NADMS of 38% to 43%. This
range may not seem as wide as
conventionally perceived in master plan discussions of NADMS, but is due to the inclusion of all trips,
rather than peak period journey-to-work trips (as well as the fact that even for work trips, a common
misperception is that the ITE rates are suburban and therefore reflect an NADMS of 0%, whereas even
the most suburban workplaces typically have an NAMDS of about 10% due to carpooling).

Expected Application Area:

Countywide, with vehicle trip generation rates higher in CBDs/MSPAs. Other modal triggers would
remain constant countywide, but quantitative analysis would be more readily triggered in urban areas
and less likely to be triggered in suburban and rural areas.

Examples of Application
A straw man proposal would include the following triggers:
Location
CBD/MSPAs

Elsewhere

Triggers for quantitative analysis (all peak hour of site generator)

Auto
Pedestrian
Bicycle
Transit
100 person trips
and site located
75 vehicle trips
within a quarter
100 pedestrian
mile of an existing
50 transit trips
trips
or proposed
bikeshare
station,
50 vehicle trips
college, or high
school
24

Prepared by Renaissance Planning Group

March 26, 2015

Quantitative analysis would entail the concepts described in Analysis Methods Concepts:

AM-1 for pedestrians

AM-2 for bicyclists
AM-3 for transit

Next Study Steps

Consider the following:

Alternative examples of how the approach would apply (see next page) and potential for
different triggers for different Policy Areas or transect areas
Means for addressing, or eliminating, a bicycle-specific analysis
Incorporating preliminary results from the ongoing LATR trip generation study

25
Prepared by Renaissance Planning Group
March 26, 2015

26
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

SR-1: Potomac Policy Area Two Lane Roadway Policy
Process: Study Scoping
Sub-Process: Study Refinements

Concept in a Nutshell:
Most intersections in the Potomac Policy Area
are not subject to LATR review

Primary Purpose:
The vision of the Potomac Subregion master
plan is predicated on part of the retention of
narrow, two-lane roadways, which is more
important than addressing delays due to
congestion. For the most part, the Potomac
Subregion has been classified as a subregional
cul de sac in that its position adjacent to the
Potomac River limits its attraction to through vehicles. Eleven intersections in the Potomac Subregion,
where the prevailing environment is more suburban and economic and regional concerns outweigh the
desire for a rustic ambiance, are subject to LATR.
The Potomac two lane roadway policy is somewhat similar in approach to the Protected Intersection
concept in SR-3, although the latter concept applies to enhancing the pedestrian experience in urban
areas rather than preserving the rural ambiance of rural areas.

Effect of proposed change on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Improving predictability

Streamlining implementation

Strengths
Recognizes the balance between
rural preservation, local resident
interests, and broader
countywide mobility needs
Reduces uncertainty in
negotiating unpopular
intersection improvements
None

Weaknesses
None, as long as the policy
remains in place and the public
sector needs not make capacity
improvements to catch up.
None

None

Relationship to Current LATR (or prior growth policy concepts)

Included in the Subdivision Staging Policy (Resolution 17-1203 TL3, p. 12; LATR/TPAR Guidelines p. 23).

27
Prepared by Renaissance Planning Group
March 26, 2015

Expected Application Area:

Potomac Policy Area

Examples of Application
Common across all LATR studies for development proposals in or affecting the Potomac Policy area.

Next Study Steps

Consider slight modification of policy to require all Potomac intersections to be subject to LATR
analysis, but not findings of inadequacy or implementation of potential improvements, similar to the
Protected Intersections concept.

28
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

SR-2: Second Improvement Mitigating < 5 CLV
Process: Study Scoping
Sub-Process: Study Refinements
Concept in a Nutshell:
If an applicant is already required to make an intersection
improvement or participate in a Traffic Mitigation Agreement then
the same applicant should not be required to expend additional effort
on improvements for minor impacts (less than 5 CLV) at any other
intersection.

Primary Purpose:
Address one element of the free rider concern by recognizing that the first mitigating action
(intersection improvement or trip reduction program) likely creates more capacity than required so that
an additional minor impact elsewhere can also be considered to have been mitigated by the first
mitigating action.

Effect of current concept on:

Study Objective
Improving context-sensitivity
and multimodal analysis
Improving predictability
Streamlining implementation

Strengths
None

Weaknesses
None

Reduces risk of death by a

thousand cuts
None

None
None

Relationship to Current LATR (or prior growth policy concepts)

Included in the Subdivision Staging Policy (Resolution 17-1203 TL1, p. 10; LATR/TPAR Guidelines p. 21).

Expected Application Area:

Countywide.

Examples of Application
TBD.

Next Study Steps

Confirm retention of LATR concept.
29
Prepared by Renaissance Planning Group
March 26, 2015

30
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

SR-3: PROTECTED INTERSECTIONS
Process: Study Scoping
Sub-Process: Study Refinements
Concept in a Nutshell:
Establish a policy that certain intersections are not to be widened and
exempt them either from LATR analysis, or from requirements to make
any improvements that would be identified in an LATR analysis.

Primary Purpose:
Reduce propensity for widening intersections to provide vehicular
capacity at locations where additional widening is contrary to the established vision for an area.

Effect of proposed change on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Improving predictability

Streamlining implementation

Strengths
Reduces the identification of
auto-oriented solutions where
such solutions are contrary to
the vision
Reduces uncertainty in
identifying and negotiating costly
and unpopular vehicular capacity
improvements
Reduces the likelihood of a
conditioned improvement being
superseded or otherwise
affected by a public sector
improvement

Weaknesses
Detracts from finding other
negotiated-exaction solutions,
such as non-auto facilities at
$12K per trip
None

None

Relationship to Current LATR (or prior growth policy concepts)

The protected intersection concept is already applied in the Potomac Policy Area to preserve the socalled two-lane road policy in Potomac, except for twelve intersections specifically identified in the
Subdivision Staging Policy (Resolution 17-1203 TL3, p. 14; LATR/TPAR Guidelines p. 23).

Expected Application Area:

Intersections primarily in urban areas, although as with the Potomac Policy Area approach, the
Protected Intersections would be identified based on a countywide analysis of candidate locations and
then specified in the Subdivision Staging Policy.
31
Prepared by Renaissance Planning Group
March 26, 2015

Examples of Application
San Joses Protected Intersection policy provides a precedent for this approach
The concept of a protected intersection is most sound where:

Additional roadway capacity is likely not feasible or runs counter to established plans or visions
The county has already established a policy establishing a pedestrian priority in intersection
design, such as in the Countys urban areas
Appropriate alternative routes are available for traffic to avoid the protected intersection.

For instance, the intersection of Georgia Avenue (MD 97/US 29) and
Colesville Road (US 29/MD 384) in the Silver Spring CBD is a logical Protected
Intersection candidate as it is impractical to add additional roadway capacity,
it is located in a designated MSPA/CBD/urban area, and there is a robust
network of designated business district streets to allow traffic to disperse in
all four quadrants to avoid the subject intersection.
Conversely, the intersection of MD 355 and Gude Drive is not a logical
Protected Intersection as the Shady Grove Sector Plan recommends
additional capacity enhancements (either at-grade or grade separated) as
part of the staging plan, it is not located in a designated urban area, and
there are no designated business district or arterial routes within a half-mile
radius to allow traffic a bypass option; all traffic most flow through this
intersection.

Next Study Steps

The development of a Protected Intersections list entails the following steps:

Conduct a GIS analysis for candidate Protected Intersections by identifying

o Major Highway intersections with other Major Highways and Arterials
o The subset of those intersections with other master planned streets that provide
connectivity in some or all quadrants within a one-half mile radius
Consider definitions for candidate Protected Intersections, including
o Does the applicable master plan recommend additional through lanes or other capacity
improvement such as a grade-separated interchange?
o Is the intersection in a designated urban area?
o Is the intersection the location of an existing or future fixed-guideway transit station?
o How far from the intersection does the protected designation extend?
Review draft recommendations with TISTWG.

32
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

SR-4: Non-Transportation Related Policies
Process: Study Scoping
Sub-Process: Study Refinements
Concept in a Nutshell:
The Subdivision Staging Policy contains several policies that are not directly
related to transportation system adequacy, but whose origins arose from
other public policy initiatives. This one Concept Summary deviates from the
normal template approach by simply listing the policies and their current
status.
Because these policies are not directly related to transportation, we propose
no changes to them, but are listing them in the interests of providing as comprehensive a portrait of the
full LATR environment as is reasonably practical.

Itemization of Non-Transportation Related Policies

Per the Subdivision Staging Policy (Resolution 17-1203):

TA3 (p. 15) Automobile Related Uses in the Cherry Hill Employment Area: no action needed
under TPAR or LATR for APF-related submissions prior to July 26, 2016
TA4 (p. 15) Public Facility Project: no action under TPAR or LATR for projects constructed
solely for public use such as schools, libraries, or fire stations.

Next Study Steps

Confirm no changes to these policies, but clarify expectations for documentation as opposed to
mitigation

33
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

AA-1: Priority of Mitigation Approach
Process: Analysis
Sub-Process: Approach
Concept in a Nutshell:
Require consideration of priority improvements to
address LATR impacts, beginning with trip reduction
and proceeding through non-motorized improvements,
transit improvements, and finally vehicular capacity
improvements.

Primary Purpose:
Bring consideration of multimodal impacts to the
forefront of both the analytic approach of all LATR
studies and to public awareness.

Effect of proposed change on:

Study Objective
Improving context-sensitivity
and multimodal analysis
Improving predictability

Strengths
Promotes and codifies
multimodal approach consistent
with County priorities
None

Streamlining implementation

None

Weaknesses
None

Minor amount of additional

documentation required
None

Relationship to Current LATR (or prior growth policy concepts)

Subdivision Staging Policy (Resolution 17-1203 TL1, p. 12) notes that for the Planning Board to accept
an intersection improvement as a mitigation measure, the applicant must show that alternative nonauto mitigation measures are not feasible or desirable. The same statement occurs on p. 24 of the
LATR/TPAR Guidelines, except the word roadway is used in place of intersection.
The table of priority improvements above was included in LATR/TPAR Guidelines when Policy Area
Mobility Review (PAMR) was in effect (2008-2012). While the PAMR elements are no longer relevant,
the 5-stage priority remains relevant and should be raised in visibility from a two-line statement on page
24, but should be readjusted slightly (transit compared to non-motorized priority levels) to move from
least costly to most costly types of transportation: trip reduction, non-motorized travel, transit,
intersection capacity, roadway link capacity.
34
Prepared by Renaissance Planning Group
March 26, 2015

Expected Application Area:

Countywide, but with increasing levels of expectation for policy areas:
In CBDs and MSPAs, the consideration of each priority approach should include a statement of
mitigation approaches proposed and their expected effect on person trip generation by mode with an
attempt to achieve any mode share goals in applicable master or sector plans. Where intersection or
roadway widening is proposed as mitigation, the narrative must describe why the higher priority
approaches of trip reduction, non-auto facilities, or transit services were not sufficient to mitigate LATR
impacts (whether through true shifting of modal demand or through the LATR concepts such as the
$12K/vehicle trip mitigation exchange rate for non-auto facilities). Typical explanations may include the
fact that capacity improvements were required to satisfy access permit, or other safety, requirements;
that the LATR maximums for such non-auto facilities were reached; that the developer interests were
better served by a lower-priority improvement approach; or that appropriate non-auto mitigation sites
could not be identified in conjunction with agency staff. The statement should identify potential actions
that the public sector might consider to better support the higher priority approaches for interagency
staff consideration in CIP and operating budget commentary.
In other Urban Areas, the consideration of each priority approach should include a similar statement
regarding the examination of non-auto facilities, but without supporting quantitative assessments of
modal shift or plan mode share goal achievement.
In other areas of the county besides CBDs, MSPAs, and Urban Areas, the consideration of each priority
approach should include a paragraph describing options considered and why they were not pursued;
this statement may be brief and entirely qualitative.
An exception to the priority approach should be made so that any proposed mitigation that is explicitly
described in a master plan or sector plan can be elevated above a higher-priority approach.

Examples of Application
TBD

Next Study Steps

Respond to comments from stakeholders.

35
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

AM-1: Pedestrian System Measurement
Process: Analysis
Sub-Process: Measurement
Concept in a Nutshell:
Refine the provision of off-site pedestrian connectivity
to reflect improved site accessibility to destinations
reachable by walking.

Primary Purpose:
Improve walkability and implement planned pedestrian
connections.

Effect of proposed change on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Improving predictability

Streamlining implementation

Strengths
Improve identification of the
most valuable pedestrian
connections in the vicinity of a
development site
Improve identification of
potential connections through
pre-screened candidate locations
provided by M-NCPPC
Improve implementation or
funding of pre-screened
candidate locations

Weaknesses
Potential for increased analytic
complexity, depending on
analysis details
Potential for increased
negotiation for potential
connections not on pre-screened
candidate location list
None.

Relationship to Current LATR (or prior growth policy concepts)

The Subdivision Staging Policy defers administrative findings on pedestrian and bicyclist safety to the
Planning Board. The LATR/TPAR Guidelines include the preparation of:

Assessment of sufficient pedestrian crossing time at signalized intersections (LATR/TPAR

Guidelines p. 10).
A Pedestrian and Bicycle Impact Statement (LATR/TPAR Guidelines, p. 13) which includes
quantitative data on pedestrian and bicycle counts at study intersections and a qualitative
inventory of conditions near the site and observed deficiencies.
36

Prepared by Renaissance Planning Group

March 26, 2015

Guidance (LATR/TPAR Guidelines, p. 25) on encouraging off-site pedestrian facilities near

pedestrian generators including transit stations, public facilities, public or private
recreation/amenities centers, retail centers with 20+ employees, housing developments of 27+
SFDUs, and office centers with 100+ employees.

The Pedestrian and Bicycle Impact Statement remains essentially a state of the practice assessment of
qualitative conditions, emblematic of similar requirements in most jurisdictions nationwide. It should be
retained essentially as is; but with additional quantitative considerations described below.

Expected Application Area

Countywide, but based on mode-specific trip generation (see Concept ST-4)

Examples of Application
Quantitative analysis thresholds and approaches for pedestrian system analysis include:

The New York City CEQR requires detailed pedestrian analyses for any pedestrian system
element such as a sidewalk segment, crosswalk, or intersection corner will increase by 200 or
more peak hour pedestrians (including pedestrians en route to transit). For these location, the
quantitative pedestrian assessment utilizes on Highway Capacity Manual approaches to
pedestrian level of service which focuses on pedestrian flow densities (pedestrians per square
foot of space). Qualitative assessments of safety are also required in a manner similar to the
current LATR Pedestrian and Bicycle Impact Statement.
The Washington DC draft CTR requires detailed pedestrian and bicycle system analysis for sites
that have at least 200 residential units, 50,000 GSF of commercial/retail, is more than one block
in size, or generates 100 combined pedestrian/bicycle trips. The pedestrian analysis walkshed is
one-quarter mile from the site. Quantitative analysis includes signal-related traffic delay along
pedestrian routes to major destinations such as
Metro stations. Simulation may be required showing
how pedestrian and bicyclist flow will be
accommodated at locations where a high
concentration of multimodal conflicts is judged to
occur. Qualitative analysis includes sidewalk widths,
condition, and gaps; ADA compliance, and presence
of pedestrian scaled lighting. Mitigation includes
addressing any characteristics that would preclude
achievement of the proposed mode splits for the site.
Any mitigation to address pedestrian improvements
must assess its delay on other modes.
The City of Rockville incorporated accessibility
analysis in the Transportation Element of its
Comprehensive Master Plan. The concept of
pedestrian walksheds that are based on travel time
37

Prepared by Renaissance Planning Group

March 26, 2015

rather than a fixed radius is shown in the page 4-24 exhibit from the plan showing walk travel
time to area schools. The concept of pedestrian accessibility is an element of the Citys Trip
Reduction Plan.
Considering the relative sizes and densities of the New York and Washington system environments, the
Washington DC approach (with lower thresholds
combined with a more flexible and collaborative
analysis approach) appears more appropriate for
Montgomery County.
Three potential means for incorporating pedestrian
accessibility in the LATR Guidelines are shown in the
following set of exhibits, with a focus on the Spectrum
development at 12345 Old Columbia Pike. The first
graphic shows a conceptual 4,000 radius distance from
the study site, with an overlay of the areas that could
be reached (labeled as the walkshed) by walking 4,000
along the local street network. The selection of 4,000 is only for illustrative purposes; a one-quarter
mile, one-half mile, or one-mile radius may be more appropriate for walking or bicycling trips. The ratio
of land accessible within the walkshed as compared to the crow-flies radius is roughly 50%.
The second graphic shows the effect of a hypothetical
new connection between Old Columbia Pike and Staley
Manor Drive and the Southern Asian Seventh Day
Adventist Church, which would increase the walkshed
by about 20 acres, or about 2% of the land area. This
could be one measure of the value of offsite pedestrian
system improvements for a given development site.
Of course, the White Oak Science Center is bounded
along its western edge by the Paint Branch Stream
Valley Park, which is a natural and passive recreational
resource, but not a high volume destination. A second
alternative would be to use destinations, rather than land area, as the measure of accessibility. Again,
hypothetically speaking, the original walkshed may provide access to only 50% of the land area within
the crow-flies radius, but perhaps that land area contains 90% of the jobs and housing units within the
crow-flies radius. Therefore, the same connection may increase walk and bike access to 3% or 4% of the
total jobs and housing units; a second measure of accessibility.
Finally, the relative value of proximity to the study site could be incorporated in the assessment by
applying a friction factor or decay curve, to the value of jobs and housing units that are more distant
from the site, reflecting the fact that most people will walk a short distance to a desired destination but
only a small proportion will walk 4,000 to the same destination. Applying a gravity weighted, or
38
Prepared by Renaissance Planning Group
March 26, 2015

decay-weighted value would increase the complexity of the analysis, but assign a more appropriate
value to the new connection by weighting connections that are closer to the study site higher than those
that are farther away.
The accessibility approach could be measured in terms of distance, as in the 12345 Columbia Pike
examples shown above, or it could be converted to consider walking time and incorporating signal
delays, as in the Rockville plan example.
The accessibility value would be
used to either augment or replace
the modal value associated with the
new connection. Currently, Table 6
in the LATR/TPAR Guidelines assigns
off-site sidewalks and bike paths an
equivalency between length of new facility and a number of vehicle trips to be discounted. A simple
replacement would be to replace the 100 linear feet specification with additional acreage,
jobs/housing units, or gravity-weighted jobs/housing units, depending on the independent variable
selected.
An alternative approach could be to establish context-sensitive standards for pedestrian accessibility.
For instance, in CBDs and MSPAs with good grid networks, the ratio between accessibility for the crowflies distance and the walking distance should be high (perhaps 75% or 80%). In contrast, rural areas
with sparse networks would have a much lower ratio (perhaps 25% or less). This concept can be
explored further, although given the wide range of possible parcel-specific accessibility scores, this
approach would likely have unintended consequences if established as a standard measure as opposed
to an incentive-based approach.
Predictability of application could be enhanced by the development of a list of desired pedestrian
system connections in each policy area that are pre-screened by M-NCPPC, MCDOT, SHA, and WMATA
as ready for implementation (including facilities in facility planning). Applicants should be encouraged
to identify potential valuable connections that are not already in master plans.

Next Study Steps

Respond to comments on the proposed pedestrian accessibility approach, including:

Desirability of an approach similar to that of Washington DC that assesses pedestrian delay

within a quarter-mile of the site for sites that generate 100 peak hour pedestrian trips.
Desirability of an accessibility-based measure of pedestrian accessibility.
o Desirability/cost-effectiveness of the three alternative approaches measuring
geographic area, total destinations, and gravity-weighted/decayed destinations
o Measures to require, incentivize or convert the increased accessibility to a unit value
that converts the LATR/TPAR Guidelines Table 6 linear feet of facility to an

39
Prepared by Renaissance Planning Group
March 26, 2015

accessibility value such as acreage, jobs/housing units, or gravity-weighted jobs/housing

units.
Consideration of significant improvements to quality of pedestrian experience.
Consideration of alternative peak period definitions

As of mid-March, the most effective approach appears to be a simple accessibility measure to value
off-site improvement proximity to site development in combination with a candidate list of specific
improvements for either construction (generally for projects where ROW is not needed) or payment-inlieu (generally where ROW is needed).

40
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

AM-2: Bicycle System Measurement
Process: Analysis
Sub-Process: Measurement
Concept in a Nutshell:
Incent the identification and implementation of onstreet network connectivity improvements.

Primary Purpose:
Increase the ability to move about the County in a lowstress bicycling environment, focusing on connections
between bicycling activity clusters.

Effect of proposed change on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Improving predictability

Streamlining implementation

Strengths
Improve identification of the
most valuable low-stress bicycle
connections in the vicinity of a
development site
None

Improve implementation of lowstress bicycle connectivity.

Weaknesses
Potential for increased analytic
complexity, depending on
analysis details
Potential for increased
negotiation for potential
connections
None.

Relationship to Current LATR (or prior growth policy concepts)

Not included in current Subdivision Staging Policy or LATR/TPAR Guidelines.

Expected Application Area

Countywide, but based on mode-specific trip generation (see Concept ST-4)

Examples of Application
Most jurisdictions, like Montgomery County, handle bicycle system impacts from a qualitative
perspective, with judgment applied where necessary. For instance, the San Francisco guidelines indicate
that if sufficient bicycle traffic exists or is anticipated on a study area street, it may be necessary to
include a quantitative analysis of the impacts using the methodology in the 2000 Highway Capacity
Manual or some similar technique.
41
Prepared by Renaissance Planning Group
March 26, 2015

The Washington DC draft CTR requires detailed pedestrian and bicycle system analysis for sites
that have at least 200 residential units, 50,000 GSF of commercial/retail, is more than one block
in size, or generates 100 combined pedestrian/bicycle trips. The bicycle analysis walkshed is
one mile from the site. Simulation may be required showing how pedestrian and bicyclist flow
will be accommodated at locations where a high concentration of multimodal conflicts is judged
to occur. The location of any proposed bikeshare stations must be shown. Any mitigation to
address bicycle improvements must assess its delay on other modes.

Most jurisdictions and staffs recognize that the methods for assessing on-road bicycle LOS such as those
in the Highway Capacity Manual are somewhat limited for an approach to development review.
Because they are based on stated and revealed preference surveys by on-road bicyclists themselves
(which is an appropriate and noble goal) the level or quality of service is more a function of adjacent
street traffic and truck percentage than it is a function of the on-road bicycle facility itself. The inability
to move the needle with mitigation makes such measures undesirable from a development review
perspective. Admittedly, the 2010 Highway Capacity Manual techniques were derived prior to the
advent of buffered bicycle lanes or cycle tracks, which may represent a notable improvement over
signing and marking techniques used for more conventional shared roadway and bicycle lane
treatments.
The Montgomery County Planning Department is exploring the concept of Low Stress Bicycling and
Network Connectivity following the techniques described in the Mineta Transportation Institute (MTI)
Report 11-19 from May 2012.
http://transweb.sjsu.edu/PDFs/research/1005-low-stress-bicycling-network-connectivity.pdf
This connectivity approach recognizes that many roads will not
practically be made comfortable (or low-stress) for most on-road
bicyclists, and examines ways to increase the connectivity
between places through a network of roadway that are low
stress.
This approach might be combined with the accessibility-based
concept described in AM-1 on pedestrian system measurement to
examine places that are accessible via low-stress bicycle facilities.
Considering for the moment that all the industrial streets east of
US 29 and south of Fairland Road might be found to be low-stress
bicycle routes, but that crossing US 29 might be high stress, the
area of low-stress bicycle connectivity within a 4,000 distance of
12345 Columbia Pike might be shown in the first diagram at right.
If an improved crossing of Columbia Pike were provided in the
vicinity of Industrial Parkway, then much of the neighborhood on
the west side of Columbia Pike might be found also within a
42
Prepared by Renaissance Planning Group
March 26, 2015

4,000 low-stress bicycle environment, as indicated in the second diagram at right.

As with the pedestrian accessibility approach suggested in LATR Concept AM-1, this approach could be
developed with any one of three basic metrics:

Geographic area of increased accessibility

Additional destinations (jobs and housing units) associated with increased accessibility
Gravity-weighted, or decayed value, destinations associated with increased accessibility.

Next Study Steps

Respond to comments on LATR Concept, including:

Response to comments on Mineta Institute process for identifying low-stress bicycle

connections
In conjunction with AM-1, assess:
o Desirability of an accessibility-based measure of bicyclist accessibility.
o Desirability/cost-effectiveness of the three alternative approaches measuring
geographic area, total destinations, and gravity-weighted/decayed destinations
o Measures to require, incentivize or convert the increased accessibility to a unit value
that converts the LATR/TPAR Guidelines Table 6 linear feet of facility to an
accessibility value such as acreage, jobs/housing units, or gravity-weighted jobs/housing
units.
Consideration of feasibility of modifying the Mineta Institute approach to incorporate
topography
Consideration of bikeshare implementation approach

As of mid-March, the most effective approach seems to be to combine AS-2 with AS-1 from an LATR
perspective and investigate the Mineta low-stress concept for planning and capital prioritization
efforts.

43
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

AM-3: Transit System Measurement
Process: Analysis
Sub-Process: Measurement

Concept in a Nutshell:
Assessing the degree to which additional transit trips
generated by site development create capacity constraints in
the transit system.

Primary Purpose:
Ensure transit system adequacy to support additional
development and encourage additional transit use.

Effect of proposed change on:

Study Objective
Improving context-sensitivity
and multimodal analysis
Improving predictability

Streamlining implementation

Strengths
Introduces transit system
analysis for significant transit trip
generators
None

Provides bases for consideration

of transit impacts and mitigation

Weaknesses
None

Introduces identification of
transit system mitigation
elements
None

Relationship to Current LATR (or prior growth policy concepts)

Not included in current Subdivision Staging Policy or the LATR/TPAR Guidelines as related to LATR (the
TPAR element does include areawide transit system adequacy).

Expected Application Area

Countywide, but based on mode-specific trip generation (see Concept ST-4)

Examples of Application
Most jurisdictions do not have a specific threshold for triggering a transit system analysis. For instance,
San Francisco publishes current and horizon year screenline capacities for different transit systems and a
quantitative analysis is required if the project would cause a screenline to exceed a 1.0 volume/capacity
44
Prepared by Renaissance Planning Group
March 26, 2015

ratio (which as of the current publication date was only 100 additional peak hour, peak direction riders
on the Third/Mission Street corridor, but more than 500 additional peak hour, peak direction riders on
all other screenlines.
Specific trip thresholds for transit analysis include:

The New York City CEQR requirements have fairly stringent transit analysis metrics but also fairly
high analysis triggers:
o A subway/rail analysis is required if the proposed action will increase the peak hour
volume at a single subway station (with multiple lines) or a single subway line (with
multiple stations) by 200 or more riders per hour. In such a case, the CEQR analysis
requires detailed assessments of line-haul, platform, farecard machine, fare array
turnstiles, stairway, and escalator capacities.
o A bus transit analysis is required if the proposed action will increase the peak hour
volume at a single bus line by 50 or more riders (in the peak direction) per hour.
The Washington DC draft CTR requires transit system analysis if the proposed site generates at
least 50 transit trips or the transit mode share exceeds 30%. A capacity analysis of transit
conditions will be performed for any site that generates 30 peak hour transit trips to any bus or
streetcar route that has headways greater than 20 minutes in the peak hour. Remaining
justification of the transit system to accommodate the projected transit volume is to be
performed qualitatively, considering the transit service characteristics and adequacy of the
pedestrian access between the transit station and the site. The Washington DC draft CTR refers
applicants to the WMATA Design and Placement of Bus Stops guidance for prioritization of
potential mitigating improvements.

Considering the relative sizes and densities of the New York and Washington system environments, the
Washington DC approach (with lower thresholds combined with a more flexible and collaborative
analysis approach) appears more appropriate for Montgomery County. It is unlikely that the 30% transit
mode share will be achieved in all but the most Metro-accessible residential locations (such as Wheaton
Safeway), and the use of the 50 transit trip threshold appears sufficient without combining it with a 30%
transit mode share criteria (i.e., an infill project of 20 townhomes might generate 10 peak hour person
trips with a 30% transit mode share, but quantitative analysis should not be required to assess the
impact of those three transit trips).

Next Study Steps

Develop concurrence on the following approaches:
Application of the Washington DC draft CTR triggers, modified slightly to use 50 new transit trips
as the trigger for quantitative analysis
Use of the Washington DC analysis to require:
o Coordination with WMATA on Metrorail station access and circulation if the site is
within a quarter mile of a Metrorail station

45
Prepared by Renaissance Planning Group
March 26, 2015

Assessment of bus system capacity if the site is currently served by buses with 20
minute or longer headways
Consideration of transit system facility size, function, and quality as an element of determining
value for transit system improvement (i.e., a BRT bus shelter may be worth more than a
standard bus shelter; a commuter bus system improvement may have a different value than a
local bus system improvement).
Consideration of bus operational impacts in coordination with WMATA.
Application of the pedestrian gap analysis described in Concept AS-3 to include connectivity to
the nearest bus stop or Metrorail station (if within one-quarter mile). In other words, even if
the AS-3 concept is not found supportable as a stand-alone approach, it should be considered
part of the transit analysis.
Consider payment-in-lieu approaches.

46
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

AM-4: CLV Thresholds
Process: Analysis
Sub-Process: Measurement
Concept in a Nutshell:
CLV standards are higher (i.e., more congestion
is allowed) in urban policy areas.

Primary Purpose:
More roadway congestion is appropriate in
urban areas where transit service is excellent;
more stringent roadway congestion standards
are needed in suburban and rural areas where
transit options are less robust.

Effect of existing concept on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Improving predictability
Streamlining implementation

Strengths
Provides multimodal equity by
balancing transit and auto
mobility (one, but not both,
modes must be adequate in all
areas of the County). Promotes
walkable TOD by reducing
pressure to widen intersections.
None
None

Weaknesses
None

None
None

Relationship to Current LATR (or prior growth policy concepts)

Defined in Subdivision Staging Policy (Resolution 17-1203 Table 2, p. 23; LATR/TPAR Guidelines Map 1, p.
5).

Expected Application Area:

Varies by Policy Area as shown in Map 1.

47
Prepared by Renaissance Planning Group
March 26, 2015

Examples of Application
Applies to each application based on the policy area that the intersection is located in.

Next Study Steps

Respond to comments, including:
Tailoring CLV thresholds for MSPAs to relate to adjacent suburban policy areas rather than a
constant 1800 CLV (i.e., apply an 1800/1600 ratio approach so that the Shady Grove CLV
standard, in an area surrounded by Derwood (1475) may more appropriately be 1650 this
concept is included in the March 26 Subdivision Staging Policy track changes document.
Elimination of CLV thresholds in downcounty MSPAs
Consideration of LRT/BRT station area threshold CLV adjustments, either based on current plans
and conditions, or to be adjusted as station areas are defined in master plans.

48
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

AM-5: HCM/simulation support for CLV
Process: Analysis
Sub-Process: Measurement
Concept in a Nutshell:
Refine thresholds for HCM or simulation analysis, in addition to the
current 1600 CLV threshold.

Primary Purpose:
Apply multimodal operational assessment of intersection operations
where CLV does not provide sufficient accuracy to gauge an appropriate
mitigation approach due to the potential for queueing/spillback.

Effect of proposed change on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Improving predictability

Streamlining implementation

Strengths
Potential for improved
assessment of quality/level of
service for all modes of travel,
including delay-based measures
of effectiveness
Improved constituent buy-in on
problem identification and
appropriateness of solutions

Improved identification of
appropriate solutions

Weaknesses
Increased cost of analysis
preparation, review, and impact
determination/negotiation

Increase in number of analysis

variables results in both
increased analytic flexibility and
uncertainty, particularly for
stochastic models (where
different random number seeds
produce different results)
None

Relationship to Current LATR (or prior growth policy concepts)

The current LATR process requires Highway Capacity Manual (Resolution 17-1203 TL1, p. 12; LATR/TPAR
Guidelines p. 6) for intersections where the CLV is 1600 or greater. The County Council Resolution
defers the details of this application to the Planning Board.
The proposed changes would expand the analysis to intersections that are identified as near capacity
(equal to a CLV of 1450 or greater) if they meet any of the following criteria:
49
Prepared by Renaissance Planning Group
March 26, 2015

Within 600 feet or less (an industry standard for desired intersection spacing to facilitate traffic
flow) of another signalized intersection, or
On a segment of roadway identified by MNCPPC in the most recently published
Mobility Assessment Report as congested
(the graphic from the 2009 Highway
Mobility Report is no longer current, but
shown as an example of the potential for
agency designation of congested corridors
where operational analysis would be
triggered at a 1450 CLV.

Expected Application Area:

Countywide (although the occurrences requiring analysis will be greater in or near urban areas where
congestion is highest and intersections tend to be more closely spaced).

Examples of Application
Many jurisdictions use Highway Capacity Manual techniques, including simulation programs such as
Synchro or VISSIM, as the primary tool for intersection adequacy analysis. Examples of additional
guidance includes:

Alexandria, VA uses HCM where V/C ratios are < 0.85 and VISSIM for more congested locations
as well as locations where there is a dedicated transitway or interstate highway access. The city
provides guidance on VISSIM calibration acceptance targets for modeled link volumes.
Washington DC indicates that an increase in 5-seconds of delay per vehicle at an intersection or
a queue length increase of more than 150 feet are significant impacts to be mitigated, and that
solutions to mitigate vehicle LOS must not add significant delay to other modes.
New York City describes significant impacts as 3 seconds (if already at LOS F) to 5 seconds (if
already at LOS D) in an increase to average vehicular delay and indicates spillback should be
addressed, although without a specific definition or mitigation requirement.

Next Study Steps

Define more study parameters, such as:

Triggers for operational analysis as initially proposed above

Whether HCM is acceptable as a stand-alone methodology or whether all operational analysis
should require a simulation tool such as Synchro, CORSIM, or other cited analysis tools (such as
VISSIM)
Whether the operational analysis needs to incorporate pedestrian and transit analyses, perhaps:
50

Prepared by Renaissance Planning Group

March 26, 2015

o
o
o

Pedestrian analyses for minimum crossing times conducted countywide

Pedestrian analyses for impedance to vehicular traffic flow conducted in urban areas
Transit analyses for bus stop locations and current bus service frequency conducted in
CBDs and Metro Station Policy Areas
Whether to focus on intersection performance measures (most commonly described in
literature) or network-wide performance measures (in which case average delay values would
reflect a weighted average for multiple intersections).
Defining study area boundaries which would be influenced both by the extent of queuing and
the definition of intersection or network performance measures
What the appropriate operational triggers are for queuing, if any. (The operational
considerations for vehicular LOS are defined in terms of V/C ratio for the intersection in Table 5
on p. 22)
What standards for validation are required (suggest staff judgment)
What types of assumptions may be changed during evaluation of mitigation (suggest signal
phasing and timing, but with the requirement that the same level of vehicle throughput be
required to attain an acceptable level of mitigation)
Whether transit or pedestrian delay should be considered as a measure of effectiveness.
How to document baseline conditions where operational experience doesnt correspond to
customer experience (such as where spillback may contribute to delays at intersections where
observed CLVs are below the operational threshold), such as via the Highway Mobility Report or
other formal agency documents.

51
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

AS-1: CLV Mitigation Requirement
Process: Analysis Elements
Sub-Process: Solutions
Concept in a Nutshell:
Where intersection congestion is not substandard in a baseline condition,
the applicant must mitigate 100% of their impact that exceeds the
congestion standard. Where intersection congestion is substandard in a
baseline condition, the applicant must mitigate 150% of their impact or an
amount required to achieve the congestion standard.

Primary Purpose:
An applicant should not be held fully responsible for substandard
intersection performance that they do not cause, but in such cases the applicant should be required to
not only mitigate their own trips but help improve the baseline condition in an effort to return to (or
towards) the congestion standard. This has been informally described in prior Subdivision Staging Policy
discussions as akin to the Boy Scouts motto of leave things better than you found them.

Effect of existing concept on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Improving predictability
Streamlining implementation

Strengths
Focuses additional private sector
attention and resources where
intersection performance is
substandard.
None
Minimizes the likelihood that an
applicant improvement and
public sector improvement will
both be pursued simultaneously

Weaknesses
None

None
None

Relationship to Current LATR (or prior growth policy concepts)

Included in the Subdivision Staging Policy (Resolution 17-1203 TL1, p. 10; LATR/TPAR Guidelines p. 19)

Expected Application Area:

Countywide

Examples of Application
Existing applications in Montgomery County; this approach was not found in the literature review.

Next Study Steps

Confirm adequacy of current concept.
52
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

AS-2: $12,000 per Vehicle Trip Mitigation
Process: Analysis Elements
Sub-Process: Solutions
Concept in a Nutshell:
Incentivize the provision of non-auto facilities by allowing applicants to
mitigate vehicle trips through provision of non-auto facilities valued at
$12,000 per vehicle trip

$12K

Primary Purpose:
Improve ability to provide safe and convenient pedestrian travel and
support the creation of facilities that encourage transit use, walking, and bicycling (as stated in the
Subdivision Staging Policy TLI, p. 11)

Effect of existing concept on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Strengths
Facilitates consideration of
multimodal solutions

Improving predictability

Establishes a known dollar value

of mitigation (up to the
applicable maximum trip credit
limits)
Requires Board to report on trip
credits issued and status of
construction of any required
improvements.

Streamlining implementation

Weaknesses
Policy does not relate to value of
actual vehicle trip reduction
achievement
None

None

Relationship to Current LATR (or prior growth policy concepts)

The Subdivision Staging Policy provides the Planning Board the ability to adopt administrative guidelines
regarding the provision of peak hour vehicle trip credits for providing non-auto facilities (Resolution 171203 TL1, p. 12; LATR/TPAR Guidelines, p. 25).

Expected Application Area

Countywide (no changes proposed), with the maximum number of trip credits allowable increasing in
areas with higher congestion standards (60 trips for policy areas with a 1350-1500 CLV standard, 90 trips
for policy areas with a 1550-1600 CLV standard, and 120 trips for policy areas with an 1800 CLV
standard).

53
Prepared by Renaissance Planning Group
March 26, 2015

Examples of Application
The payment of a fee to mitigate peak hour vehicle trips was applied fairly regularly for Preliminary
Plans under the Policy Area Mobility Review (PAMR) procedure (e.g., BB&T Bank Kensington-Wheaton
120110350, Bethesda Center 120120070, Olney Assisted Living 120120090, Travilah Grove 120120290).
The PAMR procedure is no longer relevant under the Subdivision Staging Policy but the fee payment
remains available as a mitigation approach for LATR.
The Planning Board established the value as $11,000 per trip in 2009 based on a literature review and
analysis as part of the 2009-2011 Growth Policy (details in Appendix M) and has periodically adjusted
the rate for inflation since then.

Next Study Steps

Confirm no change to current concept, except for identifying the inflation-adjusted value to take effect
as part of the 2016 Subdivision Staging Policy.

54
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

AS-3: Bicycle/Pedestrian Gap Contribution
Process: Analysis Elements
Sub-Process: Solutions
Concept in a Nutshell:
A project providing a significant increase in pedestrian/bicycle traffic
has a nexus to connect its sidewalk connections to a logical nearby
terminus or destination to avoid creating a safety hazard through
increased exposure to a network gap or severe inadequacy.

Primary Purpose:
Address gaps in pedestrian and/or bicycle connectivity in areas with
high levels of non-motorized demand.

Effect of proposed change on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Improving predictability

Streamlining implementation

Strengths
Facilitates identification of
meaningful gaps in the
pedestrian/bicycle network and
identification of solutions
None

Increases attention and

resources to resolving pedestrian
and bicycle network gaps

Weaknesses
None

Increases negotiation of solution

unless a pay-and-go approach is
implemented
Presumes timely public sector
follow-through

Relationship to Current LATR (or prior growth policy concepts)

Not included in current Subdivision Staging Policy or LATR/TPAR Guidelines. This concept would provide
additional context to the Pedestrian and Bicycle Impact Statement (LATR/TPAR Guidelines, p. 13).

Expected Application Area:

Urban areas, with further clarification that action would only be required where pedestrian and/or
bicycle trip generation increases would be significant.

55
Prepared by Renaissance Planning Group
March 26, 2015

Examples of Application
The definition of significant pedestrian impacts is likely to require some discussion. Two jurisdictions in
the literature review have quantitative definitions for significant pedestrian generation that are fairly
disparate:

New York, NY requires detailed pedestrian analysis for increases of 200 or more pedestrians per
hour at any sidewalk, crosswalk, or intersection corner.
Washington DC proposes detailed pedestrian analysis for increases of 100 or more pedestrians
per hour generated by the site, or by site characteristics including more than 200 residential
units, 50,000 square feet of commercial/retail space, or a site encompassing more than a small
block grid.

The Washington DC draft CTR notes that if deficiencies in the study area would preclude achievement of
the proposed mode split, then those deficiencies must be mitigated. The 2013 TRB paper by Zimbabwe
et al states that if pedestrian, bike, or automobile exposure is substantially increased in any area where
a safety deficiency has been documented, then a developer must provide partial mitigation of the issue,
so as to not significantly exacerbate an existing condition.

Next Study Steps

Define more study parameters, such as what constitutes:

A sidewalk or bicycle network deficiency. A straw man proposal might include:

o A missing segment of sidewalk or bicycle path that connects the development site to a
significant pedestrian or bicycle generator within a quarter mile, including a bus stop or
bikeshare station
Significant additional exposure. A straw man proposal might :
o blend the New York and Washington definitions, using an increase of 200 peak hour
pedestrian and bicycle trips (including walk trips to transit) generated by the site
(without regard to pedestrian trip assignment).
Mitigation. A straw man proposal might include either completion of the missing sidewalk gap,
or else payment in lieu of construction based on a per-linear foot construction cost based on
urban area sidewalk projects in the current CIP.
The relationship between information required as part of site development and identification of
gaps or needed projects that can be maintained and provided by the public sector.

56
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

D-1: Vehicle Miles of Travel
Process: Concept Proposed to be Dropped
Concept in a Nutshell:
VMT combines vehicle trip generation with average trip
length. From a holistic planning perspective, VMT is
more directly correlated than vehicle trip generation
with most auto-related measures of effectiveness,
including congestion, emissions, fuel consumption, and
carbon footprint.
The adoption of Californias senate bill (SB 743)
removing the state requirement for auto Level of
Service (LOS) in the California Environmental Quality
Act (CEQA) requirements has focused renewed
attention on VMT as a potential evaluation metric. This
is partly because Californias Office of Planning and
Research (OPR) has suggested that state agencies and
local jurisdictions conducting CEQA reviews consider
VMT as a replacement measure for auto LOS. The conversation at both state and local levels is
expected to continue through most of 2015 as individual jurisdictions consider whether they want to
retain auto LOS (which is an option SB 743 removes the mandate to consider auto LOS, but does not
mandate local jurisdictions stop using auto LOS) or replace with VMT or any other metric.
The OPR also suggests VMT be used first as a means for identifying a trigger for further study, with a
suggestion that any development (or public agency action such as building a road or transit line) that
generates per-unit VMT (i.e., per capita, per square foot, etc.) at a rate less than the regional average be
considered to have no significant impact on transportation, unless any of several safety-related
measures are triggered. There are two basic structural problems with the OPR proposal:

The comparison to a regional average is unclear, but has many potential adverse consequences:
o If not separated from land use type, it may have the effect of making low-intensity uses
(i.e., self-storage) more desirable than high-intensity uses (i.e., grocery stores)
o If segregated by land use type, it would likely penalize non-core jurisdictions where VMT
rates are usually lower than even smart-growth locations in suburban jurisdictions. For
instance, from a regional perspective, it is likely than any hospital in DC, Arlington, or
Alexandria would generated lower than average VMTs for hospitals, therefore having no
significant impact, and that any hospital in Montgomery County would generate higher
than average VMTs for hospitals, a significant impact. Or, if the comparison was simply
within-County, the Washington Adventist Hospital location in Takoma Park may be
57

Prepared by Renaissance Planning Group

March 26, 2015

found to have no traffic impacts based on its infill location, whereas the White Oak
location would have traffic impacts.
The analysis of safety impacts complicates the reliance on VMT. There is widespread
concurrence nationwide that safety for all modes of travel is of paramount importance. The
OPR draft suggests that safety impacts would be triggered if additional traffic generated by a
new development (regardless of its location or VMT generation characteristics) created a 15MPH speed differential between adjacent roadway travel lanes, or an off-ramp backup onto a
freeway. These safety concerns are important, but both require the analysis the initiative was
designed to minimize and suggest auto-oriented mitigation actions the initiative was designed
to avoid.

From a broader perspective of potential application to LATR, there are three key reasons that VMT
should be dropped from further consideration, without delving further into the philosophical and
technical concerns above:

LATR focuses on localized impacts; very few vehicle trips generated are likely to be shorter than
the LATR study area,
VMT is already implicitly incorporated in the TPAR approach, and
LATR already has many other existing tools for mitigating auto trips with non-auto-oriented
solutions, and many additional concepts are being investigated as part of this study.

A slightly broader summary of SB 743 is included in the TISTWG meeting packets for September 3 and
October 1. The full OPR report currently under discussion is available here:
http://www.opr.ca.gov/docs/Final_Preliminary_Discussion_Draft_of_Updates_Implementing_SB_743_0
80614.pdf
The Western District of ITE has prepared a letter of commentary on concerns related to SB 743 as
related to land use policy, planning and implementation. The final letter (November 21) has not yet
been posted to the westernite.org website but a copy in PDF form can be provided upon request.
http://www.westernite.org/ITE%20Draft%20Letter%20to%20OPR%2010-27-14.pdf

Primary Purpose:
The genesis for SB 743 was to exempt transit-oriented or infill development projects from CEQA
transportation analyses, as such projects would have lesser impacts on typically congested roadways,
thereby supporting both the private sector investment in TOD/infill projects and removing the need to
mitigate congestion impacts in environments where even small projects often triggered auto LOS
mitigation in CEQA in congested areas where the state and local agencies frankly did not intend to
uphold LOS standards by adding vehicular capacity.

58
Prepared by Renaissance Planning Group
March 26, 2015

Effect of concept on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Strengths
Intent is to exempt infill/TOD
projects from transportation
requirements.

Improving predictability

None

Streamlining transportation
project implementation

None

Weaknesses
Californias exemption process
would not capture community
concerns about understanding
congestion and addressing
multimodal needs.
Most vehicle trips are longer
than LATR study areas, so VMT
does not add much more
information than vehicle trip
generation.
Requires more information on
trip purpose and trip length,
generally reliant on MWCOG
travel demand model data
None

Relationship to Current LATR (or other current or prior growth policy

concepts)
No direct relationship to LATR, but VMT is implicitly incorporated in the Transportation Policy Area
Review (TPAR) analyses which uses forecast VMT aggregated at the TAZ level to assess areawide arterial
network adequacy countywide (i.e., beyond the bounds of the Local Area Transportation Review study
area).
Should TISTWG members be interested in better incorporating VMT into the transportation mitigation
process, an adjustment to the transportation impact tax might be a more logical venue to do so.
Currently, the transportation impact tax is based on vehicle trip generation rates.

Expected Application Area:

None recommended

Examples of Application
None recommended

Proposed Next Study Steps

Developed further as Concept SA-3.

59
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

D-2: Connectivity Indices
Process: Concept Proposed to be Dropped
Concept in a Nutshell:
Requirement for new subdivisions to have a minimum level of street
connectivity.

Primary Purpose:
The objective of high levels of street network connectivity is to
improve walkability through short block lengths and more direct
connections between potential origins and destinations. Better
connectivity between adjacent subdivisions also increases the ability
for trips by all modes to be made without burdening the arterial
roadway network.

Effect of concept on:

Study Objective
Improving context-sensitivity
and multimodal analysis
Improving predictability

Streamlining transportation
project implementation

Strengths
Intent is to improve walkability
through more robust, dense
street networks
None

None

Weaknesses
Topological requirements alone
do not guarantee effective
connectivity
Definitional challenges
associated with connectivity
increase level of required
negotiation
None

Relationship to Current LATR (or other current or prior growth policy

concepts)
Not incorporated in current LATR. The CR Zone provides incentive density for through-block
connections as part of a site plan (Section 59-C-15.853).

Expected Application Area:

None recommended

Examples of Application
The concept of street connectivity is useful for developing general guidelines for design elements such
as maximum block lengths and cul-de-sac lengths. Several jurisdictions include street connectivity in
their subdivision design standards, although they are generally not part of a transportation adequacy or
concurrency test. The most common approach is a connectivity ratio defined as the number of street
60
Prepared by Renaissance Planning Group
March 26, 2015

intersections divided by the number of street segments, with a ratio of 1.4 often defined as a desired or
required ratio.

The state of Delaware adopted a connectivity ratio requirement of 1.4 in Title 2 of the Delaware
Administrative Code in 2009.
The City of Durham, NC has a connectivity ratio requirement of 1.4 in Section 13 of their Unified
Development Ordinance, adopted in 2006.
The state of Virginia enacted a connectivity requirement in the inaugural Secondary Street
Acceptance Requirements (SSAR) legislation in spring 2009, with compact areas requiring a
connectivity ratio of 1.6, suburban areas a ratio of 1.4, and no requirement for rural areas. The
requirement was removed in the 2011 edition and replaced with a requirement for a multiple
subdivision entrances for each 200 dwelling units or 2,000 ADT trip generation.

A key objective of a connectivity ratio or index is to promote internal and external connectivity in cases
where community opposition or market preferences would tend to result in a greater reliance on cul-desacs. A challenge for connectivity requirements is the recognition that site constraints often preclude
achievement of the desired connectivity ratios, particularly for smaller subdivisions. The short-lived
Virginia requirement recognized exceptions for constraints created by railroads, freeways, bodies of
water greater than 4 feet deep, grades greater than 20%, and protected government lands or
conservation easements. The connectivity ratio was found to be somewhat confusing and raised
concern that it did not actually increase cross-subdivision easements (as artificial internal street
connections could be designed to meet the connectivity ratio requirements without significantly
affecting actual mobility.

Proposed Next Study Steps

None - connectivity indices dropped from further consideration in LATR.

61
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

D-3: Screenline Analyses
Process: Concept Proposed to be Dropped

Concept in a Nutshell:
Definition of significant auto travel
impact based on the amount of traffic
traversing a specific roadway segment
as opposed to an intersection analysis.

Primary Purpose:
The use of screenline analyses to
identify area capacity is a simplifying
approach to identifying capacity
constraints, particularly where traffic
may distribute itself across several
parallel routes, so that identification of
an impact on Road A may not need to be mitigated if parallel Road B has additional roadway capacity to
accommodate diverted trips.

Effect of concept on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Improving predictability
Streamlining transportation
project implementation

Strengths
Intent is to avoid adding
vehicular capacity on any given
route when capacity may exist
on parallel routes
Remaining system capacity on
screenlines easy to calculate
None

Weaknesses
Does not account for congestion
due to intersection performance.

None
None

Relationship to Current LATR (or other current or prior growth policy

concepts)
No direct relationship to LATR, but the concept of aggregating available capacity on parallel routes is
implicitly incorporated in the Transportation Policy Area Review (TPAR) analyses which uses average
areawide VMT / VMC (vehicle miles of capacity) to assess areawide arterial network adequacy.
Screenlines (or cordon lines, a screenline drawn around an activity center) are often effective tools for
assessing and communicating transportation system capacity at choke points for master planning or
62
Prepared by Renaissance Planning Group
March 26, 2015

transportation facility planning. The screenline analysis is not likely appropriate for development
review, however, as it is a far simpler tool than CLV to assess capacity and the prevailing stakeholder
sentiment at this time appears to be that CLV is too coarse a tool to assess many intersection
operations.
The establishment and definitions of screenline or cordon line capacity also requires time and effort to
gain consensus. Screenlines and cordon lines are only sensitive to improvements made on the links that
cross the screenline or cordon line themselves, not adjacent intersection or link improvements that may
meaningfully improve operations.

Expected Application Area:

None recommended

Examples of Application
The City of Seattle uses a screenline approach to track transportation concurrency. Under this approach,
a transportation analysis estimates the auto trips generated by the project that will cross one or more
screenlines near the project site. Project volumes plus background traffic volumes for a screenline are
compared to the established capacity for the screenline.

Proposed Next Study Steps

None - screenline or cordon analyses dropped from further consideration in LATR.

63
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

D-4: Traffic Mitigation Goals Under SSP APF-2
Process: Concept Proposed to be Dropped
Concept in a Nutshell:
Establish a range of non-auto driver mode
share goals for traffic mitigation
agreements.

Primary Purpose:
To reflect reasonable goals for Traffic Mitigation Agreement mode share goals.

Effect of current concept on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Strengths
Focuses attention towards trip
reduction

Improving predictability

Supposes a trip reduction goal

Streamlining transportation
project implementation

None

Weaknesses
Legacy approach outdated and
therefore unused for many
years.
Legacy approach; goals
expressed in imprecise terms
and not maintained to reflect
increasing number of policy
areas with goals set in SSP TL4
None

Relationship to Current LATR (or other current or prior growth policy

concepts)
The Subdivision Staging Policy (Resolution 17-1203 APF2, p. 20) identifies Traffic Mitigation Goals as
shown in the table above describing the required percentage greater than prevailing non-auto driver
mode share. The legislative history of this approach to mode share goals would require additional
research to determine, but the APF2 table supersedes goals identified in Section 42A-9A (a) 4 of the
Montgomery County Code on Traffic mitigation agreements for certain developments. Specifically,
Section 42A-9 (a) 4

Set peak period non-auto driver goals for policy area employees that are the same as the
currently observed non-auto driver share for residents in the policy area
Referenced that the goal in the previous bullet would be superseded by commuting goals
specified in the Growth Policy (sic), which is the intent of the APF2 table above

APF-2 notes the Silver Spring CBD goals in TL4.1, but does not note those subsequently added in TL4.2
through TL4.6.

64
Prepared by Renaissance Planning Group
March 26, 2015

Recent history indicates that most Traffic Mitigation Agreements tend to develop goals that are either
based on master plan or sector plan mode share goals (an intent suggested both by Section 42A-9A and
APF-2) or to achieve specific trip reduction necessary to achieve LATR requirements. To be consistent
with the Exempt Second Improvement Mitigating < 5 CLV concept, it seems unreasonable to require
TMAg mode share goals in excess of those required to satisfy LATR (or TPAR) requirements.
Any historic Traffic Mitigation Agreements whose goals were predicated on APF-2 should, if still in
operation, be presumed able to stand on their own merits for trip reduction goal achievement so that
the removal of APF-2 from the next Subdivision Staging Policy will not have any adverse effects.

Expected Application Area:

None recommended

Examples of Application
N/A

Proposed Next Study Steps

Track changes markup to remove from Subdivision Staging Policy.

65
Prepared by Renaissance Planning Group
March 26, 2015

LATR CONCEPT SUMMARY

D-5: Areawide Trip and Parking Caps
Process: Concept Proposed to be Dropped
Concept in a Nutshell:
Restrict the total number of parking spaces or vehicle trips
allowed in a geographic area and potentially allow
applicants to trade capacity for the allotted resource
amongst themselves in either a free or regulated
marketplace.

Primary Purpose:
Placing areawide restrictions on parking or vehicle trips
reduces the propensity for vehicle trip generation. Establishing a cap and trade system where capacity
for vehicle trips or parking spaces is a scarce resource would incentivize developers to use less of their
allotted resource

Effect of concept on:

Study Objective
Improving context-sensitivity
and multimodal analysis

Improving predictability

Streamlining implementation

Strengths
Potential for aggregating and
simplifying vehicle trip impacts
across multiple shared
applications
Areawide parking constraints (as
currently applied in Silver Spring
CBD) provide known levels of
additional capacity.
None

Weaknesses
Cap and trade systems can be
difficult to establish and manage.

Requires periodic public sector

monitoring of private sector
parking or trip capacity inventory
None

Relationship to Current LATR (or prior growth policy concepts)

The Subdivision Staging Policy (Resolution 17-1203 TL4.1, p. 13) identifies a parking constraint of 17,500
long-range public and private parking spaces within the Silver Spring CBD. This constraint is not included
in the LATR/TPAR Guidelines because it is not directly relevant to vehicle trip generation rates in the CBD
(in part because the limit is not close to being reached; a 2010 Desman Associates study estimated
commercial parking space demand at about 14,600 spaces.)

Expected Application Area

None for LATR purposes; consideration may be given to expanding the Silver Spring CBD parking cap to
other Parking Lot Districts or urban areas as a separate Subdivision Staging Policy element.

66
Prepared by Renaissance Planning Group
March 26, 2015

Examples of Application
Several jurisdictions are exploring the concept of trip caps or parking caps with the concept of allowing
development applicants to share or trade capacity in either an open or regulated market, but the
practice is not yet sufficiently established to be implementable in Montgomery County during the
timeframe of this study.

The District of Columbia Department of Transportation (DDOT) is examining the concept of

parking caps or trip caps with a focus on the emerging Navy Yard/Ballpark Metro station area.
As described in a 2014 TRB paper by Henson et al (available upon request). The concept of a cap
and trade program is particularly attractive in highly urbanized environments with shared
parking (whether privately and/or publicly managed) in which observed travel patterns are
often not correlated to trip purpose and destination (i.e., a pedestrian entering a downtown
building may have parked two blocks away, or may be walking through the lobby en route to a
different destination.
The White Flint Sector Plan identifies a desired maximum number of long term parking spaces
and Montgomery County has explored the creation of Secondary Parking Benefit Districts in
which the County would not act as a property owner or garage operator (functions the County
performs in the four current Parking Lot Districts).
The City of Rockville participated in a MWCOG Transportation Land Use Connections study in
2013 in which a cap-and-trade program for either vehicle trips or parking credits was identified
as a potential approach.
http://www.mwcog.org/transportation/activities/tlc/pdf/Rockville-Dev.pdf

Follow-up to comments at the 12/3 TISTWG

meeting included research on two potential
jurisdictions where comments suggested
parking caps may exist.
The City of Boston, MA has a parking
freeze program that caps the number of
parking spaces that can be operated as
public parking lots or garages. The parking
freeze was established as part of air quality
regulations established by the
Environmental Protection Agency in the
early 1970s, and applies within three areas
of the city (Boston Proper, South Boston,
and East Boston). A slightly larger area is
defined as the Restricted Parking District; an
area where proposed non-residential
private development parking garages and
lots are treated as conditional uses and
67
Prepared by Renaissance Planning Group
March 26, 2015

subject to additional context-sensitive guidelines under review by the Zoning Board of Appeals.
Guidance provided by the Boston Transportation Department for the Zoning Board of Appeals includes
ranges of parking spaces appropriate for different use types, with guidance that each project should be
considered on its unique merits.
The City of Cambridge, MA includes minimum off-street parking space requirements for all land uses in
Article 6 of the citys Zoning Ordinance. Article 6 also includes maximum off-street parking space
requirements for many commercial uses, but does not apply areawide parking caps.

Next Study Steps

None concept dropped from LATR.

68
Prepared by Renaissance Planning Group
March 26, 2015