Public Comment For DelDOT's Traffic Impact Studies Regulation Amendments Due Today

RE: Draft of proposed changes to Chapter 2 of DelDOT’s Standards and Regulations for Subdivision Streets and State Highway Access

T. William Brockenbrough, Jr., P.E., AICP

County Coordinator

Division of Planning

Delaware Department of Transportation

Bill, 

The public comment period closes on Oct. 20, 2012. Please include my comments below into the record. These comments follow those submitted to you by Chuck Mulholland on behalf of the Civic League for New Castle County.

There is far too much ambiguity retained in these proposed changes. In the following comments, I will delineate where I believe the level of specificity is unacceptable to the citizens of Delaware and indicate what must be amended further for clarity and certainty.

 - The first problematic ambiguity is the ill-defined "some measure of pubic involvement" as stated or implied throughout this document. The exact nature of public involvement must be defined within these Regulations for Traffic Impact Studies, Level of Service and in the planning of TIDs. A set schedule of public hearings for these project considerations must be included in these Regulations.

 - Concurrency means that road improvements will be paid for and implemented ahead of or during the construction of a project. A by-right plan can only be given permits for occupancy when the infrastructure is in place. There should be no wiggle room in TID funding schemes for concurrency. 

 - The true measure of the regional impact of a combination of projects within a TID cannot be limited to a "3rd Road Out" per project and still make sense - Sec. 2.5.2.2. 

 - Also, the use of may rather than must is a problem throughout this document. To assure public certainty and confidence that the procedures will not be applied subjectively, may is acceptable terminology.

• Service Standards MUST include Level of Service - Sec. 2.2.5.
• A new TIS MUST be required if projected future conditions have changed significantly - Sec. 2.13.2.6. 
• A TIS MUST be required for all large redevelopment projects - Sec. 2.1.

Thank you,

Nancy Willing

5 Francis Circle

Newark, DE 19711