Sammamish city manager addresses ‘offensive,’ ‘inaccurate’ presentation on concurrency analysis

Before public comment during Tuesday’s Sammamish City Council meeting, Sammamish City Manager Lyman Howard took a moment to address an issue that he called “deeply offensive” and inaccurate.

Howard was referring to a presentation Sammamish resident Miki Mullor gave to a Citizens for Sammamish meeting Monday. The presentation was also shared in a Sammamish Facebook group, Save Sammamish, and written about in a local blog, Sammamish Comment. It sparked much outrage from citizens online.

“Before we get to public comment I’d like to take a moment to address an issue that seems to have taken on a life of its own in the past 24 hours, despite the fact that it’s not based on accurate information,” Howard said Tuesday night. “Let me begin by saying that this PowerPoint presentation, which I’ve now seen, is mistaken in many dimensions. But the biggest mistake the presenter made was to allege that our city staff is not being honest with the public.”

Mullor, who previously filed for the upcoming City Council Position 1 seat before withdrawing, had conducted a “study” of Sammamish city traffic concurrency data, alleging the city was purposefully misleading the public and using outdated data to approve development.

In the presentation, Mullor called the city’s concurrency analysis a “sham.”

“Sammamish concurrency has been manipulated, twisted and neutralized to enable illegal development,” Mullor wrote in his PowerPoint presentation.

Concurrency, a mandate of the Growth Management Act, “refers to the timely provision of public facilities and services relative to the demand for them,” according to the Municipal Research and Services Center, a nonprofit organization that provides legal and policy guidance to local governments across the state. “To maintain concurrency means that adequate public facilities are in place to serve new development as it occurs or within a specified time period.”

This includes adequate roads and a passing level-of-service on those roads.

Mullor claims the city came up with three ways to “make the numbers always ‘work’” — or that the city knowingly avoided using “‘bad’ traffic counts,” ignored morning commute data and ignored the “‘choking points’ outside the city” to fudge level-of-service ratings, therefore giving development a passing concurrency test and allowing development within the city.

“There was innuendo that the staff was manipulating the data,” Howard told the Reporter.

The city contracts services for the traffic model it uses to project traffic impacts a development would have on the system. It also contracts for services to collect traffic counts, which it now conducts annually.

And while city staff are involved, Howard told the Reporter that “there’s no way we can fudge the numbers.”

Mullor asserts that the city was using traffic count data from 2012, and some from 2014, to manipulate the concurrency test, showing a passing level-of-service instead of what Mullor believed to be a failing level-of-service. He questioned why the city would not use all daily traffic counts from the most recent year, in this case 2016.

It is true the city’s traffic model uses 2012 traffic counts as a base line, with some of those data points updated with real-time counts in 2014. The model, however is an accumulative one, constantly being updated every time a concurrency test is done to evaluate the accumulative impacts. So while the base data is from 2012 counts, it’s been continuously updated with each new development.

“It’s not out of date,” Director of Public Works Steve Leniszewski said.

Additionally, the city is not hiding the most recent data, Howard said. It just finished collecting and verifying new base data collected in 2016 to be used this year.

The Sammamish Planning Commission just looked at the 2016 numbers as part of the city’s Comprehensive Plan update process. The council will see these numbers at its July 11 meeting.

When the city compares traffic counts from first 2014 and then 2016 to its model, it finds that there is only a 2-3 percent relative error — which is pretty good, Howard told the Reporter.

Additionally, Howard said Tuesday that Mullor made another mistake that rendered many of his conclusions “flawed.”

In one example, Mullor examined the road section on 228th Avenue Southeast in front of City Hall south of the Southeast Eighth Street, stating that according to 2014 average weekday daily traffic count of 25,233, the count did not meet the concurrency threshold of 23,700.

“He made a 14-year mistake,” Howard said. “He was using a concurrency threshold from 2006 instead of 2020. That threw his vehicle numbers off by more than 11,000. In reality, the road in front of City Hall easily passes the concurrency test.”

A concurrency threshold can change for many reasons. It can increase when improvements are made to the roadway — like widening the shoulders, adding a median or even improving the traffic signals — and it can also increase when improvements are made to side streets that connect to the road.

Regarding the city “ignoring” a.m. peak traffic, to only use peak data from the evening was a policy decision the City Council made in 2015. Mullor asserted the city was “ignoring” a.m. data because traffic is worse in the morning. Howard told the Reporter that a traffic engineer would generally say that p.m. traffic is worse.

Finally, Howard addressed the four choke points Mullor pointed to as grounds to stop development within the city.

“The problem is, all four choke points are outside Sammamish city limits, and the law does not allow us to stop development inside Sammamish because there are traffic jams outside Sammamish,” Howard said Tuesday.

The end of Mullor’s presentation makes a comparison to the city of Mercer Island. He states that Mercer Island had this year enacted a moratorium stopping all development due to concerns about levels-of-service at some of its intersections. The city has not enacted such a moratorium.

Finally, Mullor calls upon citizens to address the City Council and “demand action.”

Prior to the meeting and in light of Mullor’s presentation, the Sammamish Comment called for the City Council to enact an emergency development moratorium. The council did not address such a moratorium.

In Howard’s speech before public comment, he extended an offer to Mullor, any citizens, council and reporters to have a sit down meeting to discuss concurrency.

“It’s very complicated,” Howard told the Reporter. “We really do want to work with the community.”

Council will have a more in-depth conversation about concurrency at its study session on July 10.

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