December 9, 2024

To: Tualatin City Council council@tualatin.gov
To: Tualatin Planning Department planning@tualatin.gov
To: Tualatin Engineering Department engineering@tualatin.gov

Dear City of Tualatin,

While researching the traffic impacts from Lam’s TUX project, members of the community have discovered that Lam’s proposal is not compatible with the Tualatin Comprehensive Plan 2040, and it would violate the Tualatin Development Code, both in spirit and letter.

For the reasons outlined below, we are asking the Tualatin Planning Department to consider Lam’s proposed entrance on Tualatin Road to not be approvable, and we ask the City Manager to use her authority to have the proposed entrance removed from the TUX project site plan so that alternative access can be designed.

SITE CIRCULATION

Existing driveways provide sufficient access points to the Lam Campus as a whole. Lam currently has 6 other access points. 3 on 108th and 3 on Leveton Drive. Adding a new access point on Tualatin Road is unnecessary.

Lam is responsible for designing reasonable site circulation. A lack of good site circulation is not a valid reason to add an additional driveway onto the street network.

The Tualatin Comprehensive Plan 2040 strongly supports the use of existing access points, rather than creating new ones, especially when a new access point would have negative impacts to the community. "Consider transportation options that make the best use of the existing network" (Goal 8.7)

SPIRIT OF THE LAW

Tualatin Road is currently functioning as an arterial, it was previously classified as an arterial, and it has the traffic volume of an arterial. Leveton Drive is currently functioning as a collector, it was previously classified as a collector, and it has the current traffic volume of a collector.

During the 2012-14 TSP update, the functional classifications of these streets were reversed in a failed attempt by the city to reduce the amount of traffic on Tualatin Road and encourage more trips to use Leveton Drive. While we appreciate the intent of this reversal, the impact is now exactly opposite of what was intended, and we ask that this reversal be deemed a mistake. We ask the city to remedy this mistake by restoring the correct functional classifications to their appropriate streets. Lam should not be allowed to rely on a classification error to put a new entrance on a road that, based on current conditions, should not have a new entrance.

If the streets were classified correctly, Lam Research would not be able to add an employee entrance on Tualatin Road because it would be an arterial. “No new driveways or streets on arterial roadways within the City, except where noted in the TDC, usually when no alternative access is available.” (TCP 2040 POLICY 8.10.1)

LETTER OF THE LAW

The Tualatin Development Code says “Lots that front on more than one street may be required to locate motor vehicle accesses on the street with the lower functional classification as determined by the City Manager.” TDC 75.040 (5) Currently the TSP shows 108th classified as a minor collector and Tualatin Road a major collector. Based on this, access should be provided from 108th not Tualatin Road.

Lam’s proposed entrance on Tualatin Road fails four of the new driveway approach criteria in TDC 75.020.5: "(d)(ii) Takes access from the lowest classification of street abutting the property … (g) The proposed driveway approach does not result in significant adverse impacts to the vicinity; (h) The proposed driveway approach minimizes impact to the functionality of adjacent streets and intersections; and (i) The proposed driveway approach balances the adverse impacts to residentially zoned property and the functionality of adjacent streets."

Tualatin Development Code 75.140.15 (a) grants the specific locations for Lam's three driveways on the north side of Leveton Drive. The applicant's proposal to relocate one of the three driveways is not compliant with the development code.

No matter which way you slice it, Tualatin Road is the worst option for carrying Lam’s new entrance and additional traffic volume. We ask the City Manager to use her discretion and require access from the most appropriate road which, by any metric, is Leveton Drive.

PROPOSED TRAFFIC SIGNAL

The proposed entrance on Tualatin Road would create the need for a new traffic signal on Tualatin Road which would have many negative impacts on the community. These impacts justify rejection of the proposed access. If Lam were to take access from Leveton Drive, no new traffic signal would be needed.

The community provided overwhelming feedback during the TSP update this summer about this issue and we asked that the proposed traffic signal be removed from the TSP. The city should take this feedback into account and "Conduct the planning process with adequate input and feedback from citizens in each affected neighborhood” (TCP 2040 Goal 8.7)

CONSIDER SAFETY

The Tualatin TSP Existing Conditions Report shows Tualatin Road and 115th Ave having higher Pedestrian Level of Traffic Stress than Leveton Drive and 108th Ave. (Figure 23) Adding more traffic to Tualatin Road and 115th Ave will degrade pedestrian safety even further.

Tualatin Road between 124th and 115th has higher concentration of collisions than Leveton and 108th, with a history of serious injury collision while Leveton does not. (Figure 31) Adding more traffic onto Tualatin Road and 115th will increase the traffic exposure and likely result in worse safety outcomes.

Tualatin Road has a history of collisions involving pedestrians and bicycles while Leveton and 108th do not. (Figure 32) Adding more traffic to Tualatin Road will likely make this safety issue worse.

Converting a driveway to full access or signalizing a driveway would likely increase traffic crashes. Per CMF ClearingHouse, changing driveway type to full access has a crash modification factor (CMF) of 2.25, and signalizing a driveway has a CMF of 3.98, which means that the two measures will likely increase traffic crashes by a factor of 2.25 and 3.98 respectively.

Lam’s traffic study also does not identify the locations of school bus routes at Hazelbrook Middle School or the potential impacts to school bus traffic. Student safety is one of the most important issues in our community, but so far it has been ignored in this process.

Also, the safety and congestion impacts from Lam’s proposal would be most concentrated on Tualatin Road between 115th and 124th which abuts a residential area with traditionally disadvantaged demographics and income limited apartments. This is not equitable.

BYPASS ROUTE

The route from Hazelbrook Road going west and turning right onto Hwy 99W is a "hidden" route that can bypass the traffic congestion at the west end of Tualatin Road. Adding a signal at 115th and Tualatin Road will encourage more cars to take this bypass. The potential impact of this new traffic pattern imposes significant safety concerns to communities all along the route. These impacts were not addressed in the traffic study.

SUMMARY

We urge the city to consider all the above concerns and require the applicant (Lam) to revise their site development plan accordingly. We believe that the current proposal does not meet Tualatin’s planning rules, and that the City Manager should use her authority to bring Lam’s proposal into compliance. No new roadway access on Tualatin Road.

Thank You