Steve Linke found that Carlsbad has now reverted back to using its old discredited and unvalidated method for evaluating traffic. See .pdf files below that contain all of the communications he provided to the GMP update citizen committee (Carlsbad Tomorrow) on which he served.
He noted that for circulation/mobility staff’s recommendation to the Carlsbad Tomorrow committee was to completely eliminate the minimum GMP performance standard of Level Of Service (LOS) D for all modes of travel, both for annual GMP monitoring and for development reviews. Linke says that is consistent with past conduct in which Carlsbad used unvalidated vehicle LOS calculation methods for about the first 25 years (through 2015), which greatly exaggerated capacity and virtually eliminated the possibility of deficiencies, followed by a period in which a valid standard was used. But that Highway Capacity Manual (HCM) method was only slowly rolled out over several years and only on a subset of streets that had previously been monitored. The many street facilities correctly found to be deficient were largely just exempted from the GMP standard. Now the city wants to eliminate the LOS standard entirely.
The following three communications focus on Parks and Open Space (the rest largely relay his findings/recommendations on traffic to the committee):
1. 2022-10-07 Carlsbad Tomorrow letter from Linke on Parks and Open Space
2. 2023-01-11 Carlsbad Tomorrow open space and parks correspondence-Linke
3. 2023-03-23 Carlsbad Tomorrow reports-Linke proposals
Briefly on Parks, Linke argued to increase the standard from 3 to 4 acres per 1,000 residents and to not count as park acreage land that is contiguous with parks but is not accessible by humans. He also argued to restrict the Veterans Memorial Park acreage to the northwest quadrant where it is located instead of allocating it equally to all quadrants of the city. Linke failed to get a majority on any of those recommendations when the committee voted, but was able to achieve consensus that those ideas should be included in the final report as minority opinions. Linke also supported exploration of a new park standard based on walking/biking distance from homes.
In addition, he raised the point that a “fact sheet” provided to the committee by Parks staff contained multiple misleading statements, particularly related to funding land acquisition. Again, if staff re-focused the amount of time they spend spinning and propagandizing to actually working on improving things, he thinks we would all be better off.
Briefly on Open Space, he argued that we should reduce or eliminate the exempt status of zones that had after-the-fact planning changes that reduced open space, or that are now being redeveloped with denser residential or residential that is replacing commercial. He also kept asking for an additional column in the “open space by zone table” that would include an accounting of the subset of open space that meets the actual performance standard. Staff kept stating and writing that those numbers live in various documents, and that it was a complicated calculation that they are not going to provide. He is not sure how they can file the annual GMP Monitoring Reports with the claims that they are meeting this standard when they don’t seem to actually know.
This was a significant issue in NCA’s lawsuit vs. Carlsbad. Carlsbad only reports on the percentage of open space in each of it’s 25 LFMZ’s (local facilities management zones) but that includes lagoons, steep slopes and other constrained lands. The GMP performance standard is 15% of the developable land in each LFMZ must be left open. Those acres are not tabulated. Some of the zones have been “exempted” and are not monitored and a few others are surely deficient.
He also argued that a new inventory of parcels that are candidates for open space/parks should be created and reviewed.
Linke’s 2023-03-23 communication contains his specific proposed language for mobility, parks, and open space for the final report to City Council, which he was largely able to get accepted by the committee but mostly as minority opinions.
In 2020, he submitted communications to the Traffic and Mobility Commission (2020-10-05 T&MC…) and City Council (2020-10-20 CC…). Among many other things, these communications refer to reports by traffic consultants showing that, for GMP monitoring, the city had been using vehicle level of service (LOS) methods that did not reflect reality. These reports confirmed both the overall problem and the underlying reasons for the problem that he had been reporting to the city since 2011.
The traffic consultant reports are:
1. 2015-09-09 Fehr & Peers Memo – ICU v HCM
There are tables that do side-by-side comparisons of Carlsbad’s unvalidated custom “ICU” intersection LOS method with the gold standard (validated through decades of research) Highway Capacity Manual (HCM) method. The results tend to be around two letter grades too high (e.g., LOS C rather than LOS E) for the Carlsbad method. There is also discussion of why the city’s method does not reflect the reality on the streets.
2. 2019-06-19 2018 GMP Traffic Conditions Report – STC Traffic
In particular, note Section 3 (Previous Monitoring and Analysis Methodology), which confirms the observation that the Carlsbad methods did not reflect reality.
3. 2020-02-00 2019 Roadway LOS Analysis – Kimley Horn
In particular, note the Introduction, which again confirms the lack of reality in the Carlsbad methods. Also note Table 2 on Page 17, which shows a side-by-side comparison of Carlsbad’s unvalidated custom street segment LOS method with the new method they were finally using in Carlsbad that is based on the HCM. This Carlsbad method was particularly ridiculous. It always returned virtually all A’s (with a rare B), when the reality was anywhere from A to F–actually many F’s.
A few of the other areas of focus in his many communications are:
1. In September 2019, when the General Plan Mobility Element was under public review before the Planning Commission, in response to public concerns, staff included language that vehicle LOS exemptions would not be used until after the street system was built out (including completing the College Boulevard gap closure). However, staff secretly removed that language between the Planning Commission and City Council, which I feel was illegal. Of course, the underlying power to just exempt streets from the GMP when they fail is also questionable.
2. Although the city was supposed to start monitoring pedestrian, bicycle, and transit LOS on streets re-prioritized for those modes of travel in the 2015 General Plan update, they still have not done that. They are allegedly doing the very first monitoring right now, but they have said that pretty much every year. I can’t believe that is legal either.
3. When doing MMLOS studies for development projects over the past few years, staff has repeatedly tweaked the MMLOS point systems. In one case, they changed the grading system such that the identical underlying data produced A’s and B’s, instead of E’s and F’s. In another case–for transit LOS–they simply changed the scoring system to say that the existence of the TDM Ordinance provides 60 points, which is the minimum necessary to achieve LOS D, which is the minimum performance standard.
4. Even after the 2015 GP update, the city continued to use the old LOS method that gets all A’s in order to promote some projects, and they allowed at least one developer to take repeated traffic counts at different times–presumably to get different results–and a third-party had to step in to mediate a dispute.”
In summary, this material shows how the city puts its efforts into trying to make itself look good while doing nothing at all to solve traffic problems. Steve says there is a long history of Carlsbad helping developers get projects approved in spite of adverse traffic impacts that aren’t properly analyzed or mitigated.