Memorandum

To:
From:
Date:
RE:

TISTWG Members
Dan Hardy
January 4, 2015
LATR CONCEPT SHEETS AND DECEMBER 3 MEETING COMMENTS

This memorandum summarizes the comments made on the boards themselves during our December 3
TISTWG meeting, including placement of dots by folks at the meeting:
The first four pages summarize the dot-placement and comments received at the December 3 meeting
boards (essentially the same material sent via e-mail 12/23 with a few minor amendments based on
comments received through 12/31).
The remaining pages summarize the proposed responses to the individual comments received.
Dan

Key to dots for all boards:

Agency

Civic

Development
Community

Guest

Very good idea

Good idea
Warrants further
consideration

1
Prepared by Renaissance Planning Group
January 4, 2015

Scoping Elements (Board #1)

Dots
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)
Study Triggers (starting on page 11)
ST-1.
Trip Generation Threshold

ST-2.

Study Area

ST-3.

Background Traffic

ST-4.

Modal Analysis Triggers

Comments
No longer relevant within the
White Flint Sector Plan due to
special impact tax
TMAGs must include penalties if
they are not fulfilled
Weak in current condition not
good when expired
Need a better tie to impact tax
spending
Expand to other areas BRT
Might only apply to this particular
case
If below threshold still pay into a
sidewalk fund or similar
May be tough politically
Tripgen matters
But we are saying we will tolerate
more congestion
How do we address the
cumulative impacts over time?
Must acknowledge this is still a
LOS/congestion based measure
Must address threshold, rate,
context
Any benefit for presence of BRT
should not apply to suburban and
rural policy areas
Site proportion of traffic could
disincentivize development on 2
lane streets
Study area changes based on
context
Seven intersections/rings too big
for LATR
Cant ignore background traffic
better pipeline project
management
APFO validity timeframes make
pipleline difficult to manage
Weighting modes differently
why?
Make sure the trigger first is for
auto
Locating bikeshare within mile
doesnt make sense
Multiple triggers
Different triggers by Policy Area
Required in CBD Sector Plans and

2
Prepared by Renaissance Planning Group
January 4, 2015

in the CR Zones
Use a transect zone concept for
both land use and transportation
network
Require only in CBD/MSPA/LRT
station areas
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

Protected intersections and areas

Process needed to identify
intersections
Dont give up look at alternative
solutions
In CBD areas OK further out not
so good
Good idea!

SR-4.
Non-Transportation-Related Policies
(no change)

3
Prepared by Renaissance Planning Group
January 4, 2015

Analysis Elements (Board #2)

Dots
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

Comments
In past a lot of work for little
credit
Duration + enforcement of TMAgs
Should be strengthened in
CBD/MSPA/LRT/BRT areas
Accessibility should be measured
in travel time, not distance
(signals cause delay)
Capture quality of ped
environment
Add WMATA list/process for onsite access improvement needs
Analysis should be on whether trip
can be made, not on the
volume/demand
Should be strengthened in
CBD/MSPA/LRT/BRT areas
Include topography
Should be County responsibility to
define and provide metrics
Analysis should be on whether trip
can be made, not on the
volume/demand
Bikeshare should be consideration
Should be County responsibility to
define and provide metrics
Emphasis on transit facility size
Emphasis on ped access and
quality of bus stops
Purchasing a bus is expensive a
common fund or escrow account
payment is better
Eliminate CLV thresholds in four
CBDS
Different CLV for LRT,
programmed BRT
Not all Metro stations are alike not all should have 1800 CLV (ex.
Shady Grove should be lower)
Base threshold on building
location, not intersection location
Rename Mobility Assessment
Report
Do the simulation HCM+CLV are
not enough
Operational, not planning Hard
to explain to public
Should County maintain Synchro
files?

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Prepared by Renaissance Planning Group
January 4, 2015

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

What is the $ amount now?

What if an option exists for a
developer to pay >$12K/trip,
could they instead pay $12K/trip
and skip out of that higher
amount? Less critical for large
developments as this $12K/trip is
capped, but notable for smaller
developments
Recommend prioritizing this in
urban/CBD/MSPA areas
Prioritize bike/ped crossing
improvements
Provide table of what gaps in
sidewalk developer must fill rather
than requiring analysis

5
Prepared by Renaissance Planning Group
January 4, 2015

Elements proposed to be dropped (Board #3)

Dots
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 personthroughput
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)
Others to be added by meeting
participants.

Comments
Apply for MSPAs/urban areas only
could be use specific

Legally in code cannot change

without Council action.
Change APF at building permit to
be the regular test
Deserves some discussion federal
facilities have caps.
In CR zone and new zoning code
rewrite
Check downtown Boston and
Cambridge for examples
Appropriate planning tool but not
associated with APF level of service

Remove staging ceiling for Great

Seneca Science Corridor Plan Area
Allow for more density in
CBD/MSPA/LRT station areas

Impact tax helps address

6
Prepared by Renaissance Planning Group
January 4, 2015

SUMMARY TABLE OF PROPOSED RESPONSED TO DETAILED COMMENTS

Note: Action items identified by green shading in response box with additional detail provided in the TISTWG_Memo_010415.PDF file.

Topic/
Comment #

Comment

Source

Response

LCOR project TMAg still applies but might

be subject to renegotiation. Could still be
applied to a residential project not
subject to the Special Taxing District.
Therefore; no need to prohibit its
applicability in White Flint.
See response to SA-1/6

SA-1: Metro Station Policy Areas TMAg

SA-1/1

No longer relevant within the White Flint Sector Plan due to

special impact tax

12/3 meeting
board

SA-1/2

TMAGs must include penalties if they are not fulfilled

SA-1/3

Weak in current condition not good when expired

SA-1/4

Need a better tie to impact tax spending

SA-1/5

Expand to other areas BRT

12/3 meeting
board
12/3 meeting
board
12/3 meeting
board
12/3 meeting
board

SA-1/6

TMAgs, in their present form, are limited in their effectiveness due

to several significant limitations:
Limited duration (typically 12 years). What happens to incentives
& services beyond that timespan, or how are subsequent increases
in vehicular traffic handled? We recommend that that these
agreements have much larger durations or that they be tied to
accomplishment of certain goals for several consecutive years.
Limited enforcement. If a developer fails at their TMAg

MCDOT, 12/5

See response to SA-1/6

See response to SA-1/6
Appropriate once new BRT station areas
are defined; this Subdivision Staging
Policy proposes to establish that concept
to facilitate future placetype evolution.
The concerns about TMAgs are apt; we
will pursue approaches for strengthening
language both in the Subdivision Staging
Policy (and in Section 42A of the County
Code) for this LATR Concept.
Some of these approaches may be
appropriate for other hard or soft
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January 4, 2015

Topic/
Comment #

Comment

Source

obligations, there are very few effective sticks that can be

applied, and very limited legal enforcement mechanisms or
penalties.
Limited transferability. TMAgs should have the ability to be
enforced if the developer changes jurisdiction, as in the case of
annexation by a municipality.

SA-1/7

Be careful with this options relationship with the Transportation

Impact Tax as there are many land uses that do not pay Impact
Taxes, and yet they contribute to the general congestion and use
of other transportation resources

MCDOT, 12/5

Response
TMAgs beyond Concept SA-1. Many
approaches are already under the
purview of the Planning Board and
Executive Branch. Given the complexity
of potential approaches and stakeholder
interests, we suggest more widespread
changes to all TMAg processes should not
be part of the current Subdivision Staging
Policy assessment. Rather, changes to
only SA-1 could provide a springboard for
further TMAg process discussions in
other regulatory venues.
No changes are proposed to this existing
LATR concept.

SA-2: White Flint Special Taxing District

SA-2/1
SA-2/2

SA-2/3

Might only apply to this particular (White Flint Special Taxing

District) case
This policy is still being actively implemented, and it is still too
early to determine whether it is felt to be a success. At this time it
feels like this mechanism may be best left to individual master
plans rather than consideration in the countywide LATR.

12/3 meeting
board
MCDOT, 12/5

A concern with White Flint (apart from whether acquired revenue

will be adequate to fund necessary infrastructure) is that new
developments still impact areas outside the policy area that are
subject to LATR and TPAR. This is particularly important as

MCDOT, 12/5

Agreed no changes to existing LATR

concept proposed.
Agreed no changes to White Flint are
proposed, although precedents set by
Pro-Rata Share concepts existing White
Flint or contemplated in White Oak under
Subdivision Staging Policy Amendment
#14-02 will be germane to the feasibility
of developing similar approaches in other
areas over time.
The degree to which a new Pro-Rata
Share approach addresses impact
mitigation beyond its application area is
an element for discussion in establishing
8

Prepared by Renaissance Planning Group

January 4, 2015

Topic/
Comment #

Comment

Source

intersections along the periphery of urban areas tend to be where

congestion is most notable, as traffic is metered at those points
upon entering the urban area.
SA-2/4

This does prompt some other ideas not explicitly limited to White
Flint:
Value Capture concepts are worth consideration, particularly
where major capital investments are needed that are likely to
create a large increase in land values. Options might focus on
taxing forecast value gains to pay for infrastructure up front (risk
primarily on developers), or taxing actual realized value gains to
pay off bonds after a project is built (risk primarily on the public).

Response
the policy for any given area.

MCDOT, 12/5

Agreed but expected to be beyond the

scope of this years Subdivision Staging
Policy.

To be investigated. May be appropriate if

part of a Pro-Rata Share approach with
identified projects not duplicative of
TPAR or impact taxes. Otherwise can be
achieved other mechanisms including
Urban Districts and impact tax funds.
Agreed. Requires branding of manage
the dollars and the pennies will take care
of themselves approach
Agreed.

ST-1: Trip Generation Threshold

ST-1/1

If below threshold, still pay into a sidewalk fund or similar fund

12/3 meeting
board

ST-1/2

May be tough politically

12/3 meeting
board

ST-1/3

Tripgen matters

ST-1/4

But we are saying we will tolerate more congestion

12/3 meeting
board
12/3 meeting
board

Not necessarily. The overarching concept

is to allow smaller projects to proceed to
streamline infill investment, but to
increase the multimodal analysis required
of larger projects (including traffic
operations that will better address actual
congestion).
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Prepared by Renaissance Planning Group

January 4, 2015

Topic/
Comment #
ST-1/5

Comment

Source

Response

How do we address the cumulative impacts over time?

12/3 meeting
board

ST-1/6

Must acknowledge this is still a LOS/congestion based measure

12/3 meeting
board

ST-1/7

Must address threshold, rate, context

12/3 meeting
board

ST-1/8

Any benefit for presence of BRT should not apply to suburban and
rural policy areas
Any increases in trip generation thresholds will inherently result in
both a higher level of congestion, and a decrease in transportation
projects & funding from the private sector.
Might increases in the de minimis threshold be accompanied by
another gain that would serve the public interest, such as
something promoting non-auto modes, a TMAg, etc.? [noting that
such costs might exceed the costs of just going the route of LATR,
or they may have been otherwise required, anyway]
Regarding the bullet reading Adjacent intersections within CBDs
tend to operate well below the congestion standards, as noted in
the previous section regarding White Flint: this tends to partly be a

12/3 meeting
board
MCDOT, 12/5

Updated existing traffic counts account

for cumulative effects over time; not only
for approved / occupied pipeline
development, but also for effects of more
distant land development projects and
transportation system changes.
Not necessarily. By shifting to person-trip
generation rates, the focus is no longer
on auto congestion/LOS. It does remain
a quantitative trigger rather than a
qualitative trigger, which we believe
remains appropriate (e.g., we do not
propose different LATR triggers for
desired development types such as
affordable housing)
More examination / presentation to be
pursued; starting with 1/7/15 TISTWG
discussion on Balancing Multimodal
Placemaking Objectives.
See response to ST-1/7.

ST-1/9

ST-1/10

ST-1/11

See response to ST-1/4

MCDOT, 12/5

See response to ST-1/1.

MCDOT, 12/5

This concern can be addressed by the

application of operational analyses under
LATR Concept AM-5.
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January 4, 2015

Topic/
Comment #

Comment

Source

Response

result of metering at signals entering into the CBD.

ST-2: Study Area

ST-2/1
ST-2/2

Site proportion of traffic could disincentivize development on 2

lane streets
Study area changes based on context

12/3 meeting
board
12/3 meeting
board
12/3 meeting
board

ST-2/3

Seven intersections/rings too big for LATR

ST-2/4

Regarding the proposed intersection exclusion where sitegenerated volume is less than 1% of actual volume. We suggest
instead that a lower threshold be used (0.5%?) or even better just
a number of trips. But in any case it should be applied to trips that
are part of the critical movements, not all trips entering an
intersection.

MCDOT, 12/5

ST-2/5

Regarding the proposed intersection exclusion where sitegenerated volume is less than 5% of total site generated traffic,
consider a maximum limitation on how this exclusion may be
applied. For example, for a development generating 2000 trips:
5% would be 100 trips, which could be a substantial number at
some intersections (particularly if a new or critical movement, per
the preceding comment). So, this percentage is too high and
should be significantly reduced. As in the previous case, we
suggest the use of a number of trips, not a percentage.

MCDOT, 12/5

To be considered based on discussion on

balancing placemaking objectives
Objective of proposed vehicle trip
distribution screening process is to
reduce analytic burden; seven
intersections may still be appropriate in
one or more directions, but only if
application is large enough to warrant; in
most cases seven intersections would not
be studied in all directions even for the
largest development proposals.
To be tested with sample projects.
Concern about critical movements in lieu
of total volume is that it requires more
calculation/checking; testing will
determine whether this difference is
likely to be significant.
To be tested with sample projects.

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Prepared by Renaissance Planning Group
January 4, 2015

Topic/
Comment #

Comment

Source

Response

Consider LATR study documentation to

address concerns on pipeline project
management.
De-vesting pipeline projects has been
periodically proposed; value to those
vested remains significant; recession
even prompted APF extensions. Pipeline
capacity trading is an option that was
explored (as proposed TP-5) in the 2009
Growth Policy and reconsidered by the
Planning Board in 2012, but at a time
when TPAR was too new to vet the
proposal.
Consider proposed approach to define
when building or area vacancy rates are
high enough to warrant inclusion of reoccupancy as part of an increase to
existing traffic volumes.

ST-3: Background Traffic

ST-3/1

Cant ignore background traffic better pipeline project

management

12/3 meeting
board

ST-3/2

APFO validity timeframes make pipeline difficult to manage

12/3 meeting
board

ST-3/3

Buildings that are built but unoccupied are not currently included
in LATR analyses. It was noted in the 12/3 discussion that the
LCOR development is built (hence removed from background
traffic) but has a high vacancy rate (hence not being captured in
existing traffic). The occupancy of vacancy rates are captured
by the traffic counts used in the analysis. Occupancy and vacancy
rates are temporary in nature. The process must deal with the
long term effects, not just in the temporary condition at any one
point in time

MCDOT, 12/5

ST-4: Modal Analysis Triggers

ST-4/1

Weighting modes differently why?

12/3 meeting
board

The proposed number of trips for each

mode is based on an estimate primarily
informed by experiences in other
jurisdictions of an appropriate
threshold where both the significance of
modal demand, the production/review
effort of specific modal analyses, and the
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Prepared by Renaissance Planning Group

January 4, 2015

Topic/
Comment #

Comment

Source

ST-4/2

Make sure the trigger first is for auto

12/3 meeting
board

ST-4/3

Locating bikeshare within mile doesnt make sense

12/3 meeting
board

ST-4/4

Multiple triggers

12/3 meeting
board

ST-4/5

Different triggers by Policy Area

ST-4/6

Required in CBD Sector Plans and in the CR Zones

12/3 meeting
board
12/3 meeting
board

ST-4/7

Use a transect zone concept for both land use and transportation
network
Require only in CBD/MSPA/LRT station areas

ST-4/8

12/3 meeting
board
12/3 meeting

Response
likelihood of meaningful modal responses
is warranted. The thresholds for each
mode are unrelated to each other.
The proposed approach starts with
person trips and applies individual modal
thresholds. See example added to
1/4/15 LATR Concepts memorandum.
Further consideration needed; the
concern is that bicycle mode shares are
so low that a bike-mode analysis needs
another basis (or should be combined
with a pedestrian analysis). See
threshold analysis example added to
1/4/15 LATR Concepts memorandum.
Agreed see threshold analysis example
added to 1/4/15 LATR Concepts
memorandum.
To be considered based on discussion on
balancing placemaking objectives
Proposed concept would apply
Countywide, but transit, bike, and
pedestrian analyses would typically only
be triggered by medium to large
development proposals in more urban
areas. Defining thresholds numerically
rather than by geographic area actually
increases context-sensitivity; see
threshold analysis example added to
1/4/15 LATR Concepts memorandum.
See response to ST-4/6
See response to ST-4/6
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January 4, 2015

Topic/
Comment #
ST-4/9

ST-4/10

ST-4/11

ST-4/12

Comment

In general, additional data & analysis is a positive for the public in

that it enables a more informed response. However, such modespecific analyses can increase the complexity of studies, reducing
predictability and increasing project costs and delays. Consider
what the scope of each analysis might entail (as further noted in
the subsequent sections on each mode), and the effects on
predictability and the streamlining of the implementation.
Consider what methodologies are available for each mode
regarding each step of a potential analysis. For example, what
research / practice would support an estimate of person-trips or
pedestrian trips generated by a development?

Consider developing County-specific or TPB-region trip rates based

on percentages of limited land use types (Office, Retail,
Residential, Industrial, Other) and area type (urban vs. other). This
would allow for consistency in trip generation and remove the
variability that we have now based on varying modeling and trip
generation practices. It seems like this is what the text is hinting at
but this table does not reflect it. The goal should not necessarily be
to perfect or complicate the analysis, but rather focus on providing
the framework for accommodating non-auto travel demand safely
and adequately, which in the County's case is directly impacted by
NADMS goal setting and not just projected demand.
For each mode, consider not just analysis & providing data, but
also how these findings would be utilized toward rectifying
identified issues. What criteria will be used to designate required
infrastructure, modifications, and treatments? Comments on
specific triggers are made under the respective sections AM-1,

Source
board
MCDOT, 12/5

MCDOT, 12/5

MCDOT, 12/5

MCDOT, 12/5

Response

Agreed. Requires branding of manage

the dollars and the pennies will take care
of themselves approach.

To be developed as part of the LATR Trip

Generation Study underway on a
common timetable with Subdivision
Staging Policy; applicable
national/regional sources include the
MWCOG Household Travel Survey, the
MWCOG travel demand model, and the
ITE Trip Generation Handbook.
Agreed. See response to ST-4/6

Agreed these are elements of the

analysis measurement concepts AM-1,
AM-2, and AM-3.

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January 4, 2015

Topic/
Comment #
ST-4/13

ST-4/14

ST-4/15

Comment
AM-2, and AM-3.
Confirm that 100 person trips reflects net person trips and not
explicitly bicycle trips. If the latter, this value appears high: it
should at most be lower than the equivalent value for pedestrians
&/or vehicle trips.
Consider whether the statement referencing proximity to
Bikeshare, college, or high school should be an AND statement
or an OR statement. Consider whether the range to Bikeshare,
college, or high school should be mile direct, or if it should be a
mile walkingshed.
MCDOT is currently developing an internal policy for Bikeshare.
The current thinking is that it will designate near-term and longterm expansion areas. Note that this may change the nature of
this Bikeshare trigger from being distance-based to instead being
located within one of these expansion areas (assuming the
structure of our draft is unchanged into the final version).

Source

Response

MCDOT, 12/5

Confirmed.

MCDOT, 12/5

MCDOT, 12/5

Proposed as OR and using a crow-flies

radius (a quarter mile is a short distance
for a bicycle trip); any one of those
generators would be considered a bicycle
trip generator as proposed.
Comment noted.

MCDOT, 12/5

See response to ST-1/1.

Further consideration needed on how

far/wide the influence zone is for a
protected intersection (appropriate to
retain intersection as the basic unit of
protection because the trigger of concern
is a CLV finding).
Agreed. This step is underway and
should be reported on in February.

SR-2: Exempt Second Improvement < 5 CLV

SR-2/1

Even small subdivisions place trip on the roads, sidewalks and

bikeways; or use the transit systems. Whereas they could be
exempted from doing expensive and complex LATR analysis, they
should be expected to make financial contributions to provide
permanent transportation solutions.

SR-3: Protected Intersections

SR-3/1

Consider both protected intersections and areas

12/3 meeting
board

SR-3/2

Process needed to identify intersections

12/3 meeting
board

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January 4, 2015

Topic/
Comment #
SR-3/3

Comment

Source

Response

Dont give up look at alternative solutions

12/3 meeting
board

SR-3/4

In CBD areas OK further out not so good

SR-3/5

Good idea!

SR-3/6

Implementation of protected intersections will limit capabilities to

address congestion. This will inherently imply a higher level of
congestion, and potentially a decrease in transportation projects
and funding from the private sector

12/3 meeting
board
12/3 meeting
board
MCDOT, 12/5

Solutions would be developed and

implemented by the public sector,
perhaps using data generated by the
private sector.
See response to SR-3/2.

SR-3/7

While protected intersections may prompt some degree of mode

shift as congestion increases, most traffic will tend to remain in
their mode of choice: increasing use of use alternate routes.
Alternate routes likely will result in traffic using lower classification
streets (cut thru traffic), which is not a desirable outcome.

MCDOT, 12/5

SR-3/8

The Analysis weakness states that this would detract from finding
other negotiated-exaction solutions, such as non-auto facilities
for a per-trip fee. Clarify this statement. It is DOTs position that
alternative solutions need to be permanent in nature.

MCDOT, 12/5

Comment noted.
Agreed that as proposed, the private
sector funding would be decreased.
Otherwise, capabilities to address
congestion can still be undertaken by the
public sector. Selection of candidate
protected intersections is dependent on
sufficient network redundancy to
develop a comfort level with the policy
approach (akin to the Potomac Policy
Area 2-lane policy).
The concept of sufficient network
redundancy, as proposed, requires traffic
dispersion on designated arterial or
business district streets that are of an
appropriate functional classification to
accommodate diverted traffic.
The objective of the Protected
Intersection concept is to streamline
development approvals from seeking
incremental traffic capacity additions
(i.e., turn lanes) where none are actually
desired by policy. However, one sideeffect of the exemption would be that
a $12K/trip non-auto facility that would
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January 4, 2015

Topic/
Comment #

SR-3/9

SR-3/10

SR-3/11

Comment

Source

Response

Criteria for selection as a protected intersection will be critical in

ensuring that congestion is desirable at a location and in its
vicinity, alternate routes are acceptable for absorbing increases in
traffic, and future desirable infrastructure (such as implementation
of transit facilities, managed lanes, dynamic lanes, reversible lanes,
master planned widening, future turning movements, new
intersection legs/accesses, implementation of queue jumpers for
transit or BRT, additional / modification / removal of traffic signals
/ lighting / other traffic control devices, etc.) are not inadvertently
restricted.
How would protected intersections affect implementation of nonauto treatments, such as the addition of bicycle or pedestrian
facilities (particularly if additional ROW, roadway widening, or
other changes to geometry are necessary)?

MCDOT, 12/5

have mitigated the CLV impact at a

protected intersection is not put on the
table for consideration.
See response to SR-3/2.

Improves predictability; formally establishes understood

constraints linked to policy goals.

WMATA,
12/31

MCDOT, 12/5

As proposed, the protected intersection

concept only exempts the location from
requiring mitigation of CLV impacts; it
does not prohibit physical changes being
a condition of development approval.
Comment noted.

SR-4: Non-Transportation Related Policies

SR-4/1

Consider clarifying whether any of these exempted facilities are

obligated to provide other types of analyses or impact statements.

MCDOT, 12/5

To be clarified.

Comment noted; proposed clarifications

designed to improve context-sensitivity
of approach.
See response to SA-1/6

AA-1: Priority of Mitigation Approach

AA-1/1

In past a lot of work for little credit

12/3 meeting
board

AA-1/2

Concern about duration + enforcement of TMAgs

AA-1/3

From our Departments perspective, the most important approach

12/3 meeting
board and
MCDOT, 12/5
MCDOT, 12/5

Comment noted.
17

Prepared by Renaissance Planning Group

January 4, 2015

Topic/
Comment #

AA-1/4

Comment

Source

Response

is that the mitigation is of a permanent nature, or as close to that

as legally feasible.
Consider whether such a priority approach might affect the
capability to have developments construct master planned
roadway treatments.

MCDOT, 12/5

Modify approach to elevate the priority

of any type of improvement if specifically
identified in a master plan or sector plan.
Comment noted; standards varying
according to context are currently under
consideration.
Comment noted; both time and distance
are currently under consideration.
To be considered, although qualitative
aspects expected to be an exception (part
of desired flexibility) rather than the rule.
As an extreme example, the quality of a
sidewalk improved by trimming unruly
hedges should not be considered
mitigation of a pedestrian gap, but
removing utility pole obstructions might
qualify.
To be added to approach.

AM-1: Pedestrian System Measurement

AM-1/1

Should be strengthened in CBD/MSPA/LRT/BRT areas

12/3 meeting
board

AM-1/2
AM-1/3

Accessibility should be measured in travel time, not distance

(signals cause delay)
Capture quality of ped environment

12/3 meeting
board
12/3 meeting
board

AM-1/4

Add WMATA list/process for on-site access improvement needs

AM-1/5

Analysis should be on whether trip can be made, not on the

volume/demand
Consider the degree of detail that would be required:

12/3 meeting
board
12/3 meeting
board
MCDOT, 12/5

AM-1/6

If an impact statement, the goal should be to identify needs &

formalize the process that already exists. As it stands, impact
statements vary widely in scope & quality between each TIS. A
more structured approach (as with vehicular analysis) may
improve consistency, predictability, review, and implementation.

The proposed approach achieves this

objective.
To be considered further; current
accessibility-based proposal would not
require data collection

18
Prepared by Renaissance Planning Group
January 4, 2015

Topic/
Comment #

Comment

Source

Response

MCDOT, 12/5

MCDOT, 12/5

To be considered further; walksheds

analysis should reflect crossings at
intersections, but incorporating ADA
compliance may be cost-prohibitive (or
lead back to a proliferation of handicap
ramps at mitigation if defined as a gap)
See response to AM-1/2

MCDOT, 12/5

To be considered further.

MCDOT, 12/5

To be considered further.

This should have a very weak trigger which would be activated in

most cases.

AM-1/7

AM-1/8

AM-1/9

AM-1/10

If a full quantitative analysis, note that this may entail significant

data collection for locations where pedestrian counts are
unavailable or inadequate. If analyses find that, for example,
sidewalk is too narrow: consider how enforceable widened
sidewalk would be if it requires additional right-of-way either onsite or off-site. For purposes of ROW and conditioning
costs/construction upon a developer: could a sidewalk widening
driven by high demand / limited capacity be just like adding an
additional turn lane at an intersection? Or as another example: if
pedestrian timings are inadequate would the developer only need
to make a note of this, with the impetus still on the County (or
other applicable agency) to rectify it?
Walksheds should consider that not all roadways are freely
traversable. Midblock crossings should not be assumed to be
feasible everywhere, except possibly for lower-class roads (and
even then not advisable considering walksheds should be
reflective of ADA compliance).
Consider evaluations of travel times rather than travel distances.
Travel times can be more reflective of the actual conditions,
particularly where signal timings can pose a significant delay to
pedestrian access.
Consider whether lunch peak periods should be evaluated. Past
evaluations have identified that in urban areas pedestrian volumes
can surge dramatically, as in these cases of Silver Spring and
Friendship Heights from 2010.
The last of the Next Steps notes identifying methods to incentivize
this issue. Also consider situations where we may wish to require
action upon this issue.

19
Prepared by Renaissance Planning Group
January 4, 2015

Topic/
Comment #
AM-1/11

Comment

Source

Response

Important to accurately assess walkability gaps & impact of links;

analysis can be done with ESRI Network Analyst; WMATA has
walk-shed maps at Metro station areas

WMATA,
12/31

To be considered further.

Comment noted; standards varying

according to context are currently under
consideration.
To be considered further.

AM-2: Bicycle System Measurement

AM-2/1

Should be strengthened in CBD/MSPA/LRT/BRT areas

12/3 meeting
board

AM-2/2

Include topography

AM-2/3

Should be County responsibility to define and provide metrics

AM-2/4

Analysis should be on whether trip can be made, not on the

volume/demand
Bikeshare should be consideration

12/3 meeting
board
12/3 meeting
board
12/3 meeting
board
12/3 meeting
board
MCDOT, 12/5

AM-2/5
AM-2/6

As with AM-1, consider the degree of detail that would be

required:

Comment noted; under consideration

The proposed approach achieves this
objective.
To be considered further.
To be considered further; current
accessibility-based proposal would not
require data collection

If an impact statement, the goal should be to identify needs &

formalize the process that already exists. As it stands, impact
statements vary widely in scope & quality between each TIS. A
more structured approach (as with vehicular analysis) may
improve consistency, predictability, review, and implementation.
This should have a very weak trigger which would be activated in
most cases.
If a full quantitative analysis, note that this may entail significant
data collection for locations where bicycle counts are unavailable
or inadequate (which is a much more prevalent issue than
pedestrians, compounded by difficulty in whether bicyclists are
sometimes counted as either vehicles or pedestrians). As with the
20
Prepared by Renaissance Planning Group
January 4, 2015

Topic/
Comment #

AM-2/7

AM-2/8
AM-2/9

AM-2/10

Comment
sidewalk case mentioned in AM-1, consider what implementation,
conditions, enforcement, etc. can be levied based on the findings
of an analysis, be it adequacies identified in capacity or operations.
The trigger given at the top of p38 (regarding the Washington DC
draft CTR) appears to list particularly large values. Consider
whether these thresholds should be smaller. (for comparison, the
reference to the draft CTR in the AM-3 appears to have a more
reasonable trigger threshold)
Consider how topography might be factored in, as steep terrain
can affect the level of comfort for bicyclists.
The last of the Next Steps notes identifying methods to incentivize
this issue. Also consider situations where we may wish to require
action upon this issue.
Yes, a valuable tool like AM-1

Source

Response

MCDOT, 12/5

The proposed trigger in ST-4 is 100

person trips but proximity to
bikeshare/land uses indicating a high
degree of bike propensity.

MCDOT, 12/5

See response to AM-2/2

MCDOT, 12/5

To be considered further.

WMATA,
12/31

Comment noted.

12/3 meeting
board
12/3 meeting
board
12/3 meeting
board
12/3 meeting
board
MCDOT, 12/5

Comment noted; under consideration

MCDOT, 12/5

Comment noted.

AM-3: Transit System Measurement

AM-3/1

Should be County responsibility to define and provide metrics

AM-3/2

Emphasis on transit facility size

AM-3/3

Emphasis on ped access and quality of bus stops

AM-3/4

Purchasing a bus is expensive a common fund or escrow account

payment is better
Consider whether this should separate transit trips by mode, such
as those generated by local bus, commuter bus, BRT, LRT,
Metrorail, etc., both in scoping as well as in potentially differing
analyses methodologies for each.
In the 12/3 discussion groups it was asked what was local about
transit, an inherently regional subject. Id counter that apart from
peds & bikes, evaluating transit is much like evaluating autos:

AM-3/5

AM-3/6

To be considered further.
Ped access under consideration; quality
of bus stops to be considered further.
To be considered further.
To be considered further.

21
Prepared by Renaissance Planning Group
January 4, 2015

Topic/
Comment #

AM-3/7

AM-3/8

AM-3/9

Comment
TPAR addresses their overarching issues, but the operational
issues are the focus of LATR. Transit TPAR does not look at
demand and capacity, and therefore we feel there is a nexus to
include these considerations in LATR.
While I think transit analyses may be very important, note that this
has a potential to significantly increase complexity. For example, a
detailed analysis may be cyclical: the site generates X trips, this
prompts additional buses to increase frequency, now because of
better service the site generates X+Y trips, which might prompt
additional service, etc. We would need to establish criteria as to
how to handle such potential iterations.

Coordination with WMATA may be important. If an analysis finds

that Red Line capacity is inadequate, could a development be
conditioned to contribute toward 8-car trains, increased
headways, or parallel bus services? Or if station capacity is
inadequate: could a development be conditioned to contribute
toward an additional access, or additional stairs to/from
platform/mezzanine, etc? How are these issues handled between
DDOT and WMATA? Keep in mind that most funding from
WMATAs capital and operating costs come from the State, not
from the County.
Agreed on basic approach, including pedestrian gap analysis. Also
suggest explicit analysis of impacts to bus service (crowding, etc.)
perhaps as part of coordination step.

Source

Response

MCDOT, 12/5

To be considered further; links to the

definition of modal analysis thresholds in
ST-4. Ideally, the proposed mode split
should reflect not only current
observations but incorporate
expectations for TDM programs and
anticipated mitigation. The consideration
of latent demand should not be
overthought (the same argument could
be made for CLV turn-lane improvements
but its generally accepted nationwide
that latent demand effects of such
improvements are insignificant).
Agreed on coordination with WMATA.
Current proposal would not examine
WMATA or MARC line-haul effects, but
would consider access and circulation
effects (see also response to AM-1/4).

MCDOT, 12/5

WMATA,
12/31

To be considered further.

AM-4: CLV Thresholds

22
Prepared by Renaissance Planning Group
January 4, 2015

Topic/
Comment #
AM-4/1

Comment

Source

Response

Eliminate CLV thresholds in four CBDS

To be considered

AM-4/2

Different CLV for LRT, programmed BRT

AM-4/3

Not all Metro stations are alike - not all should have 1800 CLV (ex.
Shady Grove should be lower)
Base threshold on building location, not intersection location

12/3 meeting
board
12/3 meeting
board
12/3 meeting
board
12/3 meeting
board

AM-4/4

AM-4/5

AM-4/6

AM-4/7

As noted in ST-1, increases in CLV thresholds will inherently result

in both a higher tolerance for congestion, and a decrease in
transportation projects & funding. This may shift more traffic onto
alternate routes (as noted in SR-3) as well as reduce the
capabilities of transit operating in mixed traffic.
In the 12/3 discussions it was raised that there may be a need for a
BRT/LRT policy area which is not as high as MSPAs, but still
elevated from background thresholds. If implemented, any such
increases in CLV thresholds should be strictly limited to
implementation of the associated facilities. Estimated opening
dates should be used as a target for when the increased threshold
would become active. Developers utilizing the higher threshold
would only be able to obtain building (or occupancy?) permits at
(or within a defined timespan of) opening.
Not all MSPAs are equal, as some (such as Glenmont & Shady
Grove) cater strongly toward Park & Rides. Furthermore, the
background thresholds around some MSPAs can vary considerably,
creating a potentially significant differential at the borders. This

To be considered
To be considered

MCDOT, 12/5

This proposal has been considered in the

past. It complicates both stakeholder
expectations (i.e., congestion is more
acceptable in urban areas), and can result
in undesirable requirements (i.e., a nonMSPA development conditioned to add a
turn lane at an MSPA intersection that
otherwise would pass the test).
Comment noted.

MCDOT, 12/5

To be considered.

MCDOT, 12/5

To be considered.

23
Prepared by Renaissance Planning Group
January 4, 2015

Topic/
Comment #

AM-4/8

Comment

Source

Response

may create situations where signals at the borders meter traffic

into the MSPA, but ultimately congest traffic into the preceding
policy area.
need higher threshold in walkable Metro Station (CBD) areas.

WMATA

To be considered.
To be considered as this report, or a
similar document, may become a logical
repository for a wide variety of
multimodal transportation system
performance measures developed and
maintained by M-NCPPC for Subdivision
Staging Policy purposes.
Under consideration

AM-5: HCM/CLV Thresholds

AM-5/1

Rename Mobility Assessment Report

12/3 meeting
board

AM-5/2

Do the simulation HCM+CLV are not enough

AM-5/3

Operational, not planning Hard to explain to public

12/3 meeting
board
12/3 meeting
board

AM-5/4

Should County maintain Synchro files?

AM-5/5

The increased information available from HCM & simulations

would be very helpful toward ensuring that informed actions can
be made, particularly in areas where signals cannot be reasonably
assumed to operate in isolation (as CLV assumes).
However, note that increased use of such models also increases
the complexity and cost of developing the analyses and reviewing.
Consider establishing guidance on inputs, assumptions,
methodologies, etc. (and whether this may require specifying
specific modeling packages for specific purposes). Also consider
whether it may be beneficial to develop master micro- &/or
mesoscopic models for use by developers (in the past it has been

AM-5/6

12/3 meeting
board
MCDOT, 12/5

MCDOT, 12/5

Often the public is interested in this

information because CLV doesnt reflect
their experience. Tools for explanation
need to be developed.
Under consideration
Comment noted.

Under consideration.

24
Prepared by Renaissance Planning Group
January 4, 2015

Topic/
Comment #
AM-5/7

Comment

Source

Response

noted that the Univ of MD may be a resource in this regard).

Need to balance added complexity of simulations with required
numbers of applications (expense/time).

WMATA,
12/31

Under consideration.

MCDOT, 12/5

Comment noted; applies to a variety of

LATR Concepts see Other comments
under O-5
The current amount (per the January
2013 LATR/TPAR Guidelines Table 6) is
$12,000 per peak hour vehicle trip. The
Planning Board established the value as
$11,000 per trip based on a literature
review and analysis as part of the 2009
Growth Policy (details in Appendix M)
and has periodically adjusted the rate for
inflation since then.
This scenario would only occur if the
developer had an option to construct
additional vehicular capacity at an
intersection and instead opted for a
lower-cost payment in lieu option for
non-auto facilities.
See response to AS-2/3. The rate should
be increased based on inflation for the
2016 Subdivision Staging Policy.

AS-1: CLV Mitigation Requirement

AS-1/1

Issues of proportionality of treatments; Free Rider issues.

AS-2: $12K Fee Per Trip

AS-2/1

What is the $ amount now?

12/3 meeting
board

AS-2/2

What if an option exists for a developer to pay >$12K/trip, could

they instead pay $12K/trip and skip out of paying that higher
amount? Less critical for large developments as this $12K/trip is
capped, but notable for smaller developments

12/3 meeting
board

AS-2/3

Confirm the current fee, which has likely increased beyond the
$12,000/trip listed. An escalation feature must be included in the
concept, and the value of $12,000 to start should be updated, if
necessary.

MCDOT, 12/5

AS-3: Ped-Bike Gap Contribution

AS-3/1

Recommend prioritizing this in urban/CBD/MSPA areas

12/3 meeting
board

Under consideration.
25

Prepared by Renaissance Planning Group

January 4, 2015

Topic/
Comment #
AS-3/2

Comment

Source

Response

Prioritize bike/ped crossing improvements

12/3 meeting
board

AS-3/3

Provide table of what gaps in sidewalk developer must fill rather

than requiring analysis

12/3 meeting
board

AS-3/4

This is already done as part of the DRC process. We do

occasionally experience pushback, however, particularly where the
nexus, proportionality, or benefits of such connections may not be
as firmly established. A more formalized policy would help to
enforce such off-site connections.

MCDOT, 12/5

To be considered. Defining a crossing

gap may from the perspective of a nexus
to safety may need to focus on logical
termini such as bus stops; also see
response to AM 1-7.
To be considered. As proposed, the
concept does require site-specific
analysis to create a nexus between the
site development and the proposed
improvement for required
improvements. A master listing of gaps is
desirable but may not be cost-effective to
maintain countywide.
Comment noted.

D-1: VMT
D-1/1

Apply for MSPAs/urban areas only could be use specific

12/3 meeting
board

D-1/2

We concur with removal of this alternative from consideration.

This may not be the most fitting metric in a local-oriented analysis.

MCDOT, 12/5

To be considered further, potentially as a

tool for refining use-specific or locationspecific policy parameters.
Comment noted.

MCDOT, 12/5

Comment noted.

MCDOT, 12/5

Comment noted.

D-2: Connectivity Indices

D-2/1

We concur with removal of this alternative from consideration.

This may be a subject better geared toward the zoning code.

D-3: Screenlines/Cordon Lines

D-3/1

We concur with removal of this alternative from consideration.

This may not be the most fitting metric in a local-oriented analysis,

26
Prepared by Renaissance Planning Group
January 4, 2015

Topic/
Comment #

Comment

Source

Response

Under consideration. Cleaning up the

code would likely be desirable, although
because the code reference defers to
commuting goals set by the County
Council in the Growth Policy, a change to
code is not required.
Further consideration needed. Beyond
the narrow scope of any particular LATR
concept, but a valid Subdivision Staging
Policy comment to be addressed.
Comment noted.

particularly given the limited size of our urban areas & lower
density of street networks / alternative routes.

D-4: Traffic Mitigation Goals (SSP APF2)

D-4/1

Legally in code cannot change without Council action.

12/3 meeting
board

D-4/2

Change APF at building permit to be the regular test

12/3 meeting
board

D-4/3

We concur with removal of this alternative from consideration.

NADMS values are better addressed by individual master plans
than county-wide policy.

MCDOT, 12/5

D-5: Areawide Trip/Parking Caps

D-5/1

Deserves some discussion federal facilities have caps.

12/3 meeting
board

D-5/2

In CR zone and new zoning code rewrite

D-5/3

Check downtown Boston and Cambridge for examples

12/3 meeting
board
12/3 meeting
board

The caps placed on federal facilities are

similar to maximum parking
requirements initiated during the
development of the CR Zone and now in
place more broadly through Article 59-6
of the Montgomery County Code.
Maximums for each use in Parking Lot
Districts and Reduced Parking Areas are
included in table 6.2.4B of Chapter 59.
Comment noted. See response to
comment D-5/1.
Comment noted. The City of Boston has
a series of parking restrictions for both
public and private parking facilities. A
27

Prepared by Renaissance Planning Group

January 4, 2015

Topic/
Comment #

D-5/4
D-5/5

Comment

Appropriate planning tool but not associated with APF level of

service
While we do not oppose this, we agree that at this time it is
something that is best handled as part of the Subdivision Staging
Policy. However, should available parking become constrained,
incorporating a limited parking supply into trip generation / mode
splits may become more important. Nonetheless, such an issue
may still not fall under the purview of LATR policy per se, but
rather the data sources that feed into the LATR analysis.

Source

12/3 meeting
board
MCDOT, 12/5.

Response
series of geographically-based caps have
been in place since the 1970s for
privately operated public garages in the
most urban portions of the city. More
recently, the city has developed a
broader set of parking space ratio
guidelines for a slightly larger geographic
area and made all off-street parking a
conditional use subject to the Citys
Zoning Board of Appeals, without
establishing any particular numeric caps
or other requirements. Additional detail
is provided in the revisions to D-5.
Comment noted. See responses above.
Under consideration.

O-2: Review Processes by Multiple Agencies

O-2/1

Remove staging ceiling for Great Seneca Science Corridor area

12/3 meeting
board

While certainly associated with LATR and

Subdivision Staging Policy concerns, such
a change requires a Master Plan
amendment; a process contemplated
under the monitoring provisions of the
Great Seneca Science Corridor Sector
Plan staging element.

O-3: Defining Area Types for Future SSPs

28
Prepared by Renaissance Planning Group
January 4, 2015

Topic/
Comment #
O-3/1

Comment

Source

Response

Allow for more density in CBD/MSPA/LRT station areas

12/3 meeting
board

The establishment of maximum allowable

densities is the jurisdiction of zoning and
master plans as adopted by the Council.

12/3 meeting
board

Comment noted.

O-6: Free Rider Issues

O-6/1

Impact tax helps address

29
Prepared by Renaissance Planning Group
January 4, 2015