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HomeMy WebLinkAboutBikes and Peds - Revised DEIS FINAL - jkPage |Bicyclist and Pedestrian Impacts - 1 Rev 3b BICYCLE AND PEDESTRIAN IMPACTS The revised DEIS fails to adequately consider or evaluate the extent to which pedestrians and bicyclists will be impacted, especially in regards to their safety. It has also failed to adequately address the inadequacies identified by the Southold Planning Board in the original December 2021 DEIS. A major problem with both the DEIS and the Traffic Impact Study (TIS) (DEIS Appendix O) is that they consistently conflate, and fail to differentiate between, impacts associated with the extended construction period, and impacts associated with Project operation after the completion of construction. This is apparent throughout the discussion of impacts to bicyclists and pedestrians. Bicycle and Pedestrian Counts The DEIS scope calls for the DEIS to include a “Pedestrian and Cyclist Safety Evaluation”, including “a roadway user group safety study and analysis in the DEIS during all four seasons on the use of the roadways (route) by user groups, including potential adverse impacts on pedestrians walking (with strollers), jogging, biking and children waiting for the school bus that will could be adversely impacted by vehicles including loaded trucks” (p.13). The Planning Board’s May 9, 2022 memo summarizing DEIS inadequacies, states that the Board’s staff is “of the opinion that sampling methodologies were not representative of timeframes when user groups were expected to use the roadway (morning and evening hours). The sampling methodology was too narrow in scope and does not provide a comprehensive assessment of user groups along the entire route.” In addition, the Planning Board’s outside consultant (NPV) noted in their May 6, 2022 memo that the “pedestrian analysis must provide additional analysis to fully evaluate the potential for impacts to pedestrians along the entire construction route, including: a. A pedestrian and bicycle count along Cox Neck Road/W Mill Road between 6 am and 6 pm to quantify the number of pedestrians and bicyclists on this roadway segment during the period of the day when construction trucks are arriving and departing the site. . .” (emphasis added). The revised DEIS’ response to the Planning Board’s concerns, based upon the revised traffic study including data presented in the Supplemental Data Appendix, is reported as follows: “Pedestrian and bicycle counts were taken from 6:00 AM to 6:00 PM during a weekday on Cox Neck Road at Westphalia Road, West Mill Road at Bayview Drive/Selah Lane, Cox Neck Road/West Mill Road at Breakwater Road, and Bergen Avenue at Cooper’s Road” (p. xvii), and “Pedestrian and bicycle counts were taken from 6:00 AM to 6:00 PM during a weekday on Cox Neck Road at Westphalia Road, West Mill Road at Bayview Drive/Selah Lane, Cox Neck Road/West Mill Road at Breakwater Road, and Bergen Avenue at Cooper’s Road” (p. 194), and Page |Bicyclist and Pedestrian Impacts - 2 Rev 3b “. . . pedestrian and bicycle counts were taken in August of 2022 along Cox Neck Road and West Mill Road. The counts were taken between 6:00 AM and 6:00 PM on a weekday. The counts were done on Cox Neck Road at Westphalia Road, at Cox Neck Road/West Mill Road near Breakwater Road, and West Mill Road at Bayview Avenue/Selah Lane” (p.201). Although the Planning Board called for the revised DEIS to “fully evaluate the potential for impacts to pedestrians along the entire construction route” (emphasis added), the revised DEIS and TIS do not discuss, and contain no data relevant to, potential impacts to bicyclists and pedestrians along the portions of the Project Truck Route in the Town of Riverhead. The revised DEIS still fails to adequately address the original DEIS scope. It also fails to adequately address the specific inadequacies identified by the Planning Board in the original DEIS. The DEIS scope calls for “study and analysis in the DEIS during all four seasons on the use of the roadways (route) by user groups, including potential adverse impacts on pedestrians walking (with strollers), jogging, biking and children waiting for the school bus” (emphasis added). The revised November 2022 DEIS still fails to adequately address this requirement: 1. In the original December 2021 DEIS, bicycle and pedestrian counts were made only in association with intersection turning movements. This means that pedestrian counts were limited to intersections/crosswalks, and do not accurately represent the number of pedestrians walking along the Project truck route. In addition, both bicycle and pedestrian counts were limited to the 7:00 to 9:00 AM and 4:00 to 6:00 PM periods on three weekdays in 2021 (June 16, August 5, and November 4), and the 11:00 AM to 2:00 PM period on three Saturdays in 2021 (June 19, August 7 and November 6). The Saturday data is useless in evaluating impacts during the 5 ½ to 7 month-long excavation phase of the Project because haul trucks, which will constitute the vast majority of construction traffic, will only be used on weekdays. The three days of weekday data has very limited value as haul trucks will operate continuously from 7 AM until 5 PM. As no data was collected between 8:45 AM and 4:00 PM on weekdays, no data was collected for the hours during which most bicycle and pedestrian use would be expected. No data was collected during winter months although the DEIS scope calls for four seasons of data. This inadequacy has not been corrected in the revised DEIS. 2. The Planning Board’s consultant’s May 6, 2022 memo notes that the “timeframes for the various phases of construction described . . . in the DEIS are not consistent with the time frames evaluated in the Traffic Study. This should be corrected.” The revised DEIS has not addressed this issue. None of the pedestrian/bicycle counts in the original DEIS were made in the mid- Page |Bicyclist and Pedestrian Impacts - 3 Rev 3b December thru May time frame which constitutes the Project excavation phase when Project traffic volumes will be at their highest. The revised DEIS discusses and provides additional data collected over only two days--Tuesday August 9 and Saturday August 13, 2022--not for four seasons as called for. As with the data in the original DEIS, August is outside the period of the Project construction phase when potential impacts will be at their greatest. The DEIS refers readers to “Table 9 (Summary of Pedestrian and Bicycle Count Data, August 2022) in the TIS which presents a daily summary of the pedestrians and bicycles counted at three locations along Cox Neck Road/West Mill Road. As indicated in Table 9, the number of bicycles and pedestrians is very low during the weekday” (DEIS p.220). What the DEIS does not say is that the data in Table 9 consists of only a single weekday during a time of year when no Project construction is proposed. 3. Even if collected during the appropriate period, the amount of data collected would be inadequate to assess impacts to bicyclists. The Transportation Research Board’s National Cooperative Highway Research Program Report 797: Guidebook on Pedestrian and Bicycle Volume Data Collection found that “the error in estimating average annual bicycle traffic from two-hour, 12-hour, or even one-week counts can be up to 40%” (TRB, 2015:7). 4. The DEIS also failed to take into account weather conditions. According the Transportation Research Board’s Methods and Technologies for Pedestrian and Bicycle Volume Data Collection, “Weather – Seasonality and conditions affect traffic. Weather conditions should always be recorded (i.e., precipitation, temperature)” (2014:22). The TRB report also notes that other studies have concluded that “there can be considerable differences in bicycle volumes from one week to the next, both due to weather effects and the fact that bicycle volumes are often relatively small. As a result, longer count durations are required to get good results, compared to motorized vehicle counting. Short-term bicycle counts are not advised” (2014:24). On the one weekday, August 9, 2022, for which supplemental pedestrian/bicycle count data is provided in the revised DEIS, temperatures reached highs in the low-to-mid 90-degree range— approximately 10 degrees above normal. One study cited in the TRB report (Phung and Rose, 2007) found that winds in excess of 40 kph “had a statistically significant effect on Volumes.” The historical weather data for August 9, 2022 indicate that wind speeds and gusts approached or exceeded this speed during portions of the day. The temperature and wind conditions on August 9, 2022 suggest that bicycle/pedestrian counts on that day would be atypically low. 5. The revised DEIS includes no additional data specifically addressing potential traffic impacts to “children waiting for the school bus.” Language is unchanged from that in the original DEIS: “There are between 50 to 60 homes that front on Cox Neck Road/West Mill Road between Sound Avenue and the site. Some of these homes may generate school age children that will be bused to school each weekday during the school year from early September through June. These children will be picked up by Page |Bicyclist and Pedestrian Impacts - 4 Rev 3b school buses in the morning and dropped off in the evening. Due to the longer workdays of site construction, the drop-off will occur prior to construction workers leaving the site. The drop-offs may encounter a truck removing or bring material to the site. In the morning the pickup of students will likely encounter both construction workers headed to the site and occasional trucks also headed to the site. The NYS Vehicle and Traffic Law requires all traffic to stop for school buses with flashing red lights either dropping off or picking up school children. The professional drivers operating trucks engaged in the construction of the project will adhere to the law and the pick-up and drop-off of students is expected to be safe. Students waiting to be picked up in the morning are expected to wait off the road, usually in the driveways to their homes. This is also a safe practice not expected to be degraded by the passage of an occasional site bound truck or worker headed to the site. It should be remembered that similar activities take place every day within the Town on far busier roadways, such as along Route 25” (DEIS p.220-221; Rev Appendix O p.81). This entire paragraph is misleading and contains false statements. It reflects not only an attempt to downplay the danger associated with increased truck traffic, but a failure to even attempt to obtain relevant data upon which to base an analysis: a. no attempt appears to have been made to discuss this issue with the transportation department of the Mattituck-Cutchogue Union Free School District. The District could have provided information on the actual number of children and residences served along the truck route in Southold, and the location of designated stops along the school bus route. Instead, the DEIS only notes that “some of the homes may generate school-age children” (emphasis added); b. although the DEIS scope calls for a consideration of impacts along the entire Project truck route, it contains no discussion of possible safety issues Project construction traffic may pose to children being picked up or dropped-off in the Town of Riverhead. The Riverhead Central School District operates school buses along Sound Ave beginning at Herricks Lane, and along Northville Turnpike. The District was not contacted during DEIS preparation; c. the statement that “Due to the longer workdays of site construction, the drop-off will occur prior to construction workers leaving the site” completely ignores the fact that the primary traffic danger is not from end-of-day worker traffic, but is from construction phase trucks (especially haul trucks during the Excavation phases) which will be operating during drop-off periods; d. the statement that “drop-offs may [emphasis added] encounter a truck removing or bring material to the site” implies that such encounters are unlikely. Given the Page |Bicyclist and Pedestrian Impacts - 5 Rev 3b frequency of haul trucks (described inaccurately in the DEIS as “up to 4 trucks per hour” (DEIS p. 221)1, (but actually more than twice that), students being dropped off will almost certainly encounter these vehicles; e. the DEIS states that the “professional drivers operating trucks engaged in the construction of the Project will adhere to the law and the pick-up and drop-off of students is expected to be safe” (emphasis added). Although the DEIS scope calls for evaluation of “[S]ight distances at intersections and around curves in the roadways,” with a single exception (the location where the proposed haul road will intersect West Mill Road), this has not been done. No analysis has been made of the effects of limited sight-lines along portions of the truck route which correspond to school bus routes; or how this relates to stopping distances of the Project’s empty and loaded haul trucks; or to what effect the requirement for haul trucks to stop frequently when travelling behind school buses will have on the number of haul trucks which may be backed-up as a result; or the possibility that haul truck drivers may attempt to pass moving school buses. Although not taken for the purpose of evaluating sight-line distances, Photographs 3 and 6-10, included in the Traffic Study’s Supplemental Data Appendix, illustrate some locations where the curvature of the road limits sight-lines; f. the DEIS states that “Students waiting to be picked up in the morning are expected to wait off the road, usually in the driveways to their homes.”2 In fact, not all students waiting to be picked up along Cox Neck Road, West Mill Road, and Sound Avenue, can be “expected” to wait in the driveways of their homes. Several communal school bus pick-up locations exist along the haul truck route, which means students will be walking from their homes to the pick-up location along the truck routes. This may be even more likely to occur during inclement weather.3 Detailed information on where these pick-up locations are could have been obtained from the school districts; g. describing the haul truck traffic headed towards the site as “occasional” is a clear attempt to downplay the extent of potential impacts; and h. the statement “that similar activities take place every day within the Town on far busier roadways, such as along Route 25” is not relevant to situation along Cox Neck Road/West 1 The DEIS text says “up to 4 trucks per hour would travel both north bound and south bound to the site.” This language is clearly ambiguous and subject to misinterpretation. It is yet another example of the DEIS using language that deliberately underestimates the volume of Project-generated haul truck traffic. 2 This was obviously written by someone with no school-age children. 3 The Mattituck-Cutchogue School District’s website describes the special procedure for pick-ups and drop-offs when ice, snow, or floods, may affect a driver’s ability to drop students at regularly scheduled stops. Page |Bicyclist and Pedestrian Impacts - 6 Rev 3b Mill Road, which have narrower travel lanes and road shoulders, and ignores the fact that those “far busier roadways” have wider travel lanes and wider shoulders. 6. The methodology used to collect pedestrian/bicycle count data is described in the DEIS and TIS as follows: “. . . activity was captured and recorded with video and the videos were observed in the office with the data transcribed into tables giving the number of vehicles, cyclists and pedestrians observed in 15-minute intervals over the observation period” (DEIS p.220). No information is provided about the number or location of video recorders, or the fields of view captured by each camera. As a result, it is impossible to independently evaluate count accuracy. 7. The DEIS scope specifically calls for the collection of data on “pedestrians walking (with strollers) [and] jogging”. No information on these user groups is provided in the DEIS or the TIS. Although not called for in the scope, no information on individuals walking dogs is included. In the course of preparing the revised DEIS, the preparers have revised language in the “Impacts on Pedestrian and Bicycle Use” section to deliberately downplay potentially significant impacts. The revised language also fails to clearly correct inaccuracies noted by the Planning Board in the course of their adequacy review. In addition, the DEIS text has selectively edited the text in the TIS to obfuscate impacts. Language in the original DEIS reads as follows: “The highest number of truck trips would occur during the Phase 1 Excavation of the site, which is scheduled from the end of September to beginning of April. It includes the entire winter season when pedestrian and bicycle use is typically lower. During this period up to 4 trucks per hour would travel both north bound and south bound to the site. Heavy trucks, such as sanitary trucks and fuel oil delivery trucks currently use the roadway and there were no accidents evidenced in the accident study, which included over three years of data indicating that trucks were not causing any problems. The addition of four trucks an hour in each direction would not create any capacity issues or create additional hazards not currently experienced by bicycles and pedestrians using the road” (p.211). The original traffic study (DEIS Appendix O) states that: “The highest number of truck trips will occur during the Phase 1 Excavation of the site, which is scheduled from the end of September to beginning of April. It includes the entire winter season when pedestrian and bicycle use is typically lower. During this period up to 4 trucks per hour will travel both north bound and south bound to the site”. The revised DEIS reads as follows: Page |Bicyclist and Pedestrian Impacts - 7 Rev 3b “The highest number of truck trips would occur during the Excavation phase, which includes the entire winter season when pedestrian and bicycle use is typically lower. During this period, up to 4 trucks per hour would travel both north bound and south bound to the site. Heavy trucks, such as sanitary trucks and fuel oil delivery trucks currently use the roadway and there was one accident evidenced in the accident study, which included five years of data. The addition of four trucks an hour in each direction would not create any capacity issues or create additional hazards not currently experienced by bicycles and pedestrians using the road” (p.221; Appendix O, p.80). The revised Traffic Study reads as follows: “The highest number of truck trips will occur during the Phase 1 and 2 Excavation of the site, which is scheduled from mid-December to beginning of June. It includes the entire winter season when pedestrian and bicycle use is typically lower. During this period up to 4 trucks per hour will travel both north bound and south bound to the site.” The revised DEIS text, unlike the original DEIS and the revised Traffic Study, no longer references the months during which Excavation phase haul trucks will be travelling on local roads. The revised DEIS text (unlike the TIS text) can easily be taken to imply that the Excavation phase will be limited to the winter months when, in fact only half of the Excavation phase occurs during that period. In addition, both documents, in the original and revised versions, use language that fail to clearly indicate that approximately eight trucks per hour will travelling along the Project’s truck route. For all of the above reasons, the conclusion in the DEIS that “Counts of pedestrian and bicycle usage along Cox Neck Road/Mill Road indicated only minimal usage by pedestrians and bicycles” (pp. xviii and 226), cannot be supported. In addition, the revised November 2022 DEIS fails to adequately address the inadequacies relating to bicycle/pedestrian impacts identified by the Planning Board in the original December 2021 DEIS. Specifically, it does not address the concerns of the Planning Board in regard to use of inappropriate time frames for data collection, and the narrowness of the original sampling methodology. Road Width, Capacity, and Configuration The DEIS scope also call for “an analysis of the proposed truck route's road width and the capacity to accommodate two vehicles passing at the same time and location as a pedestrian or cyclist, and whether the roads are currently safe for such an interaction, including the perceived safety from the perspective of the pedestrian or cyclist”; an “Assessment of the amount of space a pedestrian or cyclist would have on the pavement when two vehicles pass each other”; an “Assessment of the perceived safety by pedestrians and cyclists given the pavement width and speed limits along the route and expected traffic generated by this project”; and an “Assessment of the safety of a pedestrian when two vehicles pass each other while a cyclist or pedestrian is traveling on the shoulder” (pp.13, 15). Page |Bicyclist and Pedestrian Impacts - 8 Rev 3b The DEIS notes that the Southold town roads that comprise the Project truck routes, Cox Neck Road and West Mill Road, have a minimum paved width of 22 feet. The DEIS fails to note that along the entire length of the truck routes north of Sound Avenue there is no fog line or paved shoulder. According to the revised DEIS Project haul trucks will have a width of eight feet—the maximum allowed by state law. That leaves a total of six feet that must include space between two passing vehicles and space for a bicyclist or pedestrian. Suffolk County Local Law No. 13-2021 requires “The operator of a vehicle which is overtaking, from behind, a bicycle proceeding on the same side of the road [to] pass to the left of such bicycle at a distance of at least three (3) feet until safely clear thereof.”4 In other words, the paved surface width available to a bicyclist (or pedestrian) is effectively reduced to two feet (16 feet for the two trucks + a conservative minimum of one foot between them 5 + the required 3-foot safety zone = 20 feet—leaving two feet). This is not a safe condition. It should also be noted, that maintaining even the two-foot-wide area for pedestrians and bicyclists, would require the near-side truck to cross the double- yellow line into the on-coming traffic lane. COMMENT FIGURE BICYCLES/PEDESTRIANS-1, 2, and 3 illustrate the narrowness of West Mill and Cox Neck Roads, and demonstrate the potentially dangerous conditions created for pedestrians and bicyclists when large vehicles try to pass one another. COMMENT FIGURE BICYCLES/PEDESTRIANS 4 illustrates how Project haul trucks, because of narrow road conditions and deteriorated pavements, will create dangers for pedestrians and bicyclists along West Mill and Cox Neck Roads. Both the DEIS and the TIS note that “Almost all trucks operating in NYS are 8 feet wide including sanitation trucks, fuel oil, landscaping, and box delivery trucks commonly operating on these roadways” (DEIS p. 220, TIS p.78). Neither document seems to understand the significance of the presence of “landscaping trucks.” These vehicles don’t just travel West Mill and Cox Neck Road. They frequently park for extended periods on those roads while servicing customers (COMMENT FIGURE BICYCLES/PEDESTRIANS 5). This creates a hazard, not only for pedestrians and bicyclists, but for vehicular traffic as well. That hazard will increase significantly with addition of Project haul trucks which will have to cross into the oncoming traffic lane in order to pass. Landscaping trucks parking on the road will be a regular feature of the traffic environment from the late spring thru the following fall. This period overlaps with the latter portion of the Project’s excavation phase when Project truck traffic will be at its peak. Additionally, there are stretches of both roads where the existence of utility poles and roadside vegetation effectively limit, and even, eliminate, the availability of even unpaved areas adjacent to the paved roadway (see, for example, Photograph No. 1 in DEIS Appendix G, and Photographs 5, 8 and 10 in 4 https://www.scnylegislature.us/DocumentCenter/View/73791/Introductory-Resolution-1830-20-PDF. This law was widely publicized and should have been known to the preparers of the DEIS. 5 This does include the fact that truck mirrors may increase the effective width of passing trucks. This would necessitate the distance between them when passing to be greater than one foot, further reducing the width of paved roadway available to bicyclists and pedestrians. Page |Bicyclist and Pedestrian Impacts - 9 Rev 3b the TIS Supplemental Data Appendix). Although the DEIS scope calls for an evaluation of “[l]ocations and width of shoulders along the route” no information about this was included in the original December 2021 DEIS, despite its significance in regard to pedestrian/bicyclist safety. The revised DEIS does contain information on shoulder width for those portions of the truck route in the Town of Riverhead and along Sound Avenue in Southold. No information about actual shoulder widths is provided for the portions of the truck route along Cox Neck Road and West Mill Road. These concerns are especially acute when one considers that some pedestrians will be walking dogs. As noted above, no analysis has been made of the effects of limited sight-lines along portions of the truck route. Although the DEIS (quoting the TIS) notes the existence of several dangerous locations, it provides no quantitative or qualitative analysis of the dangers to pedestrians and bicyclists posed by the limited sight-lines and narrow road widths at these locations. According to the DEIS: “Much of the Cox Neck Road/West Mill Road is slightly rolling but there are two areas of significant curves. The first is just north of Bergen Avenue where, going north, the roadway curves sharply to the east turning about 90 degrees and then turns less sharply to the north. Within the curves the road drops to the area between the curves just west of Breakwater Road and then rises in the second curve to peak north of Jackson Landing and the end of the curved section. No warning signs are posted for either north bound south bound traffic. On the westerly side of the southern curve guide rail has been placed to prevent vehicles from leaving the road. The guide rail is substandard and not properly anchored on the ends. We question whether the two curves should be posted with curve warning signs indicating the “S” curvature of the road and the use of additional chevron signing along the back of both curves. “North of the two curves the roadway straightens out and continues north in a relatively straight line on gently rolling terrain. West and south of Naugle’s Drive the roadway turns fairly sharply to the east. Curve warning signs were posted for northbound traffic approaching the curve and for southbound traffic approaching the same curve. The southbound signs seem to be placed too close to the curve and chevron warning signs along the back of the curve would be useful. To the east of Naugle’s Drive West Mill Road turns to the south and drops vertically. There is a curve warning sign posted for eastbound traffic and an additional sign stating, “SLOW POPULATED AREA”. That sign is posted behind a utility pole and not readily visible” (DEIS pp. 195-6; TIS p.12). According to the revised DEIS and TIS, during Project Excavation Phase 2 “trucks will arrive and depart directly from the site at the north end of West Mill Road. The trucks will be required to negotiate the curves east and west of Naugles Road. The curve west of Naugles Road is tighter than the curves to the south and trucks negotiating this section of the road will not be able to stay within their travel lane. East of Naugles Road the curve is also tight, and it will be difficult for the trucks to stay in Page |Bicyclist and Pedestrian Impacts - 10 Rev 3b lane. To overcome this, it is proposed that flaggers be used to control traffic as truck pass through this area” (emphasis added) (DEIS p. 219, TIS p.77). The DEIS contains no discussion of how any of the conditions described above impact bicyclist/pedestrian safety. Until a detailed study is made of the relationship between limited sight-lines and the stopping distance of loaded and unloaded Project construction vehicles, in all weather conditions, no proper evaluation of construction traffic impacts to bicyclists and pedestrians (as well as vehicular traffic) can be made. The DEIS attempts to minimize the impacts of Project construction traffic on bicyclists and pedestrians along Cox Neck and West Mill Roads and concludes that “any motor vehicle will have to give way to pedestrians and bicyclists using the road. In most 6 cases, they [Project haul trucks] will be able to move over and pass the slower moving bicycles and pedestrians” (DEIS pp. xviii and 226; TIS pp.73, 80). The DEIS does not indicate that this can be done safely, especially along parts of the truck routes with limited sight distances. Although the DEIS also notes that “Cox Neck Road/West Mill Road is marked with a double barrier line separating opposing directions of traffic” (p.190) it fails to indicate the significance of this fact. The entire truck route north of Sound Avenue/Route 48 is a designated no-passing zone. Accident Data The revised DEIS and TIS note that along the Cox Neck Road/West Mill Road portion of the truck route only one accident involving a pedestrian was identified in the five years of data examined. Given that the qualitative nature of the traffic along this portion of the truck route will change significantly—from virtually no large 5- and 6-axle vehicles to more than 80 trips by such vehicles per day—there is no basis for assuming that the potential for accidents involving pedestrians/bicyclists will not also increase. There is no basis for assuming that historical data is indicative of the likelihood of accidents during the Project construction period. The DEIS fails to note that most of the first and last hours of each workday during much of the excavation phase of the Project will require use of the truck route before sunrise or after sundown. There is no discussion in the DEIS or TIS as to how this might affect the safety of bicyclists and pedestrians. The greater part of the excavation phase of the Project will occur during winter months. No discussion is provided as to how heavy truck traffic might affect pedestrian safety during snow events when visibility will be reduced and road conditions may be slippery. While the number of pedestrians can be expected be low during such periods, it will not be zero (dog walkers will be out in all weather conditions). 6 “most”?—what about cases where they will not be able to move over? Page |Bicyclist and Pedestrian Impacts - 11 Rev 3b The Town of Riverhead Comprehensive Plan notes that “there have been a number of accidents on Sound Avenue, some involving agriculture workers walking or bicycling along the road to and from their places of employment” (2003:G-10). Given that traffic volumes on Sound Avenue are presently much higher than they were at the time the comprehensive plan was prepared, the dangers to pedestrian and bicyclists traveling Sound Avenue have certainly increased. No historical information on bicyclist/pedestrian accidents for the portions of the truck route west of Cox Neck Road is included in the DEIS or the TIS. Proposed Mitigation The DEIS scope calls for evaluation of “perceived safety from the perspective of the pedestrian or cyclist.” Measures proposed in the DEIS to mitigate the impact of Project-related traffic and bicyclists and pedestrians are unlikely to reduce, and may actually increase the actual, as well as perceived, safety of these user groups. The mitigation measures proposed in the DEIS include: 1. Prior to the commencement of Project construction, restriping the shoulder edge lines defining the edge of 10-foot travel lanes on Cox Neck Road and West Mill Road is recommended. (Presumably this will be the responsibility of the Town of Southold). According to the DEIS, this “will provide the motorist with the appearance of narrower roadway while providing an area for pedestrians” (DEIS pp. xxxvi, xxxix, 229, 293, 298; TIS p.93). As the current paved roadway width along portions of these roads is only 22-feet, this would leave only one foot on either side of the paved area for bicycles and pedestrians. It seems that this recommendation is actually designed to aid Project truck traffic at the expense of local residents walking, jogging, or bicycling in this area. 2. “High grass and any brush should be mowed and removed [by whom?] providing a walkable surface where feasible” (DEIS pp. xxxvi, xxxix and 225). The DEIS fails to denote where these areas are located, or what percentage of the Project truck route along Cox Neck Road and West Mill Road could be improved. Photos of this portion of the truck route clearly demonstrate that this measure would result in only a minimal improvement over existing conditions; and 3. a suggestion that “during the construction period, the speed limit be reduced along Cox Neck Road/West Mill Road. The current speed limit is 35 miles per hour and could be reduced to 30 or even 25 miles per hour for the duration of the construction activity. The speed limit change would require approval of the NYSDOT or the Southold Town Board depending on the Town's ability to set speed limits” (revised TIS p.93, DEIS 225, 293). The authors of the DEIS and the Traffic Study do not seem to be aware that the speed limit along West Mill Road is presently posted at 30 mph. The statement that limiting truck traffic to a Page |Bicyclist and Pedestrian Impacts - 12 Rev 3b 30-mph speed limit will “assuage community concerns” (TIS p.73) is pure conjecture and has no basis in fact.7 Impacts along the Western Portions of the Truck Route As noted above, the Planning Board’s consultant’s completeness review of the original DEIS noted that the DEIS failed to address impacts to pedestrians and bicyclists “along the entire construction route” (emphasis in original). The completeness review goes on to state that “The width of all the roadways along the entire proposed truck route and the capacity to accommodate two vehicles passing at the same time and location as a pedestrian or cyclist, and whether the roads are currently safe for such an interaction. This should account for the perceived safety from the perspective of the pedestrian or cyclist, as well as areas with known high pedestrian activity for road crossings, particularly during peak tourist activity in the fall months (crosswalks at Harbe’s Family Farm on Sound Ave., and similar crossings frequented by pedestrians in peak season)” (NPV 2022:6). While the revised DEIS and TIS provide descriptions of conditions relative to pedestrian and bicycle use along the western portions of the truck route, little analysis of this information is provided, especially as it relates to pedestrian and bicyclist safety. For example, the DEIS and TIS note that “Except between Northville Turnpike and the vicinity of Oliver Street shoulders are one foot wide and do not accommodate either pedestrians or bicyclists.” This would seem to suggest that an unsafe condition presently exists, but no analysis of how this might be exacerbated by Project-related traffic—especially the large number of large 22-wheelers. DEIS Conclusions The DEIS (p.226) concludes that “[D]espite the relative narrowness of the road the small numbers of additional vehicles the Project will generate during construction and after completion should not increase the hazards to bicycles and pedestrians also using the road. . . The minor increase in truck trips in unlikely to cause any additional problems.” This conclusion is not supported by the data in the DEIS or the TIS. The characterization of the increase in Project-generated traffic as “small” is not accurate.8 The statement that “the project will generate a small number of additional vehicles” is misleading in that it combines all classes of vehicles—from motorcycles to 22-wheel tractor-trailers into a single number. The same is true of the characterization of the increase in truck trips as “minor.” In fact, there will be a very large and significant increase in the number of large trucks, notably Class 10 vehicles (the Project’s 7 The statement in the TIS (DEIS Appendix O) does not appear in the main body of the DEIS. 8 This is another example of the DEIS conflating post-construction/operation phase impacts with construction phase impacts. Page |Bicyclist and Pedestrian Impacts - 13 Rev 3b six-axle haul trucks) traveling the portions of the truck route in Southold Town. Over the 20 weekdays, spread over four seasons in 2021, for which traffic counts were made, only one Class 9 vehicle (5 axle tractor-trailer/18-wheeler) was counted on West Mill Road north of Bayview Ave. Not a single Class 10 vehicle was counted in this area. In addition, only four Class 10 vehicles were counted over the 20 weekdays on Cox Neck Road north of Westphalia. The increase in truck traffic of the type associated with Project construction will effectively increase from zero to more than 80 trips per day along Cox Neck and West Mill Roads. This is NOT a “minor” increase. Referring specifically to Cox Neck and West Mill Roads, the DEIS states that the “minor increase in truck trips in unlikely to cause any additional problems” (DEIS xvii, 226). As noted above, the increase in truck traffic is NOT “minor”. The conclusion that the increase in “truck traffic is unlikely to cause any additional problems” is not supported by the data. The DEIS’ conclusion that the “addition of four trucks an hour in each direction would not create . . . additional hazards not currently experienced by bicycles and pedestrians using the road” (p.211) is unsupported and is, in fact, contradicted by available data. Although called for in the DEIS scope, the DEIS contains no discussion of how pedestrian and cyclists might “perceive” their safety when being passed by construction vehicles. The conclusion that the “proposed 30 mile per hour maximum speed to be observed by Project trucks on Cox Neck Road/West Mill Road will mitigate concerns of the community” is not only not supported by any data in the DEIS—it is completely untrue. Page |Bicyclist and Pedestrian Impacts - 14 Rev 3b COMMENT FIGURE BICYLCES/PEDESTRIANS-1 West Mill Road (2021) Page |Bicyclist and Pedestrian Impacts - 15 Rev 3b COMMENT FIGURE BICYLCES/PEDESTRIANS-2 West Mill Road (2021) Page |Bicyclist and Pedestrian Impacts - 16 Rev 3b COMMENT FIGURE BICYLCES/PEDESTRIANS-3 Cox Neck Road in the vicinity of Rosewood Drive (Spring 2021) The construction vehicles were involved in the delivery of fill for a single residential lot at the corner of Rosewood Drive and Cox Neck Road. Page |Bicyclist and Pedestrian Impacts - 17 Rev 3b COMMENT FIGURE BICYLCES/PEDESTRIANS-4 January 2023 March 2023 Page |Bicyclist and Pedestrian Impacts - 18 Rev 3b COMMENT FIGURE BICYLCES/PEDESTRIANS-5 Landscaping truck parked on West Mill Road (April 2023)