Update, June 6: The City Council meets tonight and this topic will come up. The meeting begins at 6:30pm at City Hall; Public Comment is scheduled about 7:25pm. Mullor’s study may be accessed here.

Original post, June 5:

Sammamish manipulated its traffic concurrency code to allow new development despite daily vehicle counts exceeding the thresholds for pass-fail standards, a study shows.

Miki Mullor will present his study to the meeting tonight of the Citizens for Sammamish. The group meets at 7pm at the fire station at 1851 228th Ave. NE.

The City uses traffic count data it has to apply for concurrency testing. Most of the data is from 2012. Some 2014 data is used. No 2016 data is used, according to the study. Using 2014 data on key roads where 2012 data is used would have failed some concurrency testing and denied the applications for development, the study shows.

Miki Mullor, a Sammamish resident, used Public Records Request (PRR) to obtain 2014 traffic count data that the City has but does not generally use in its concurrency testing.

City withholds data

Mullor had to repeatedly press the City to obtain 2014 and 2016 data that the City did not produce under a PRR request. The City continues to withhold 2016 Level of Service data, he says.

Sammamish Comment has been aware for some time that 2016 traffic count data existed but that even City Council members had difficulty in obtaining it.

Refusing to produce records pursuant to a Public Records Request is a violation of state law. Sammamish previously lost a lawsuit in an unrelated matter, costing taxpayers $90,000 in fines in addition to the legal costs spent on defending the lawsuit.

Mullor filed May 19 to run for City Council but withdrew from the race on May 22, taking his findings out of the political arena.

The City Council received a copy of Mullor’s study June 5. It’s expected to come up at the Council meeting June 6. Initial reaction from some Council members was outrage.

Defining concurrency

There are two elements to concurrency testing: traffic volumes and intersection wait times.

Traffic volumes are vehicles on the street. Traffic lanes can carry only so many vehicles. If there are more than the lanes can carry, traffic slows and you get congestion.

Intersection wait times (stop lights, stop signs, roundabouts) measure the time it takes to go through the intersection. This is called Level of Service (LOS). The standards are LOS A through F. A is the best, F is Failing.

Concurrency manipulated

The study found that:

Sammamish is mostly using traffic counts from 2012 for its concurrency testing, rather than more recent counts.

Using older traffic counts that under-report current traffic allows concurrency tests to pass rather than fail when developers apply for approval of their projects.

Traffic on sections of 228 th and Issaquah-Pine Lake Road fail under more recent counts than the 2012 numbers used. Projects tested for concurrency would have failed with the more recent traffic numbers.

and Issaquah-Pine Lake Road fail under more recent counts than the 2012 numbers used. Projects tested for concurrency would have failed with the more recent traffic numbers. Concurrency testing used to be for the AM or PM peak hours, whichever was worse. The City Council changed this to the PM peak hour only upon staff recommendations. The PM peak hour generally is less onerous because schools let hour earlier in the afternoon. The AM peak hours are impacted by starting school times that are close together.

The concurrency testing Monday through Friday rather than, as policy states, Tuesday, Wednesday and Thursday traffic counts. Monday and Friday are generally less intense because of people takking long weekends.

LOS standards were set high by area standards when the City’s first Comprehensive Plan was adopted in 2003: LOS 3. (Disclosure: this writer was on the Planning Advisory Board and participated in writing the Comp Plan and recommending concurrency/LOS standards.) Today, the LOS is D.

East Lake Sammamish Parkway north of Inglewood Hill Road was taken out of concurrency calculations entirely.

Some of these findings—such as the ELSP removal and LOS degradation—were debated at Council meetings. But hiding the traffic counts appears to have been as staff-driven move.

LOS wait times

An intersection is considered failing if the average wait time to get through it is 80 seconds or more. Mullor lists examples in his 91-page study of wait times of more than 12 minutes on northbound Sahalee Way in the AM peak hour.

Sahalee empties onto SR202, outside the City, which has its own issues getting through SR 202 and East Lake Sammamish Parkway in Redmond.

Sammamish doesn’t control any intersection or road outside the City.

Falling back on the GMA

Mullor points out in his study that City officials, including City Manager Lyman Howard and Mayor Don Gerend, fall back on the reasoning that the “GMA makes us do it” to accept and approve growth.

The GMA, which stands for Growth Management Act, does require growth. But Mullor points out that another section of the GMA requires adequate infrastructure to accommodate growth. One of these requirements relates to concurrency. If concurrency fails, the projects can be denied.

Mullor concludes the City manipulates concurrency to approve growth.

City needs the revenue, taxes

Although Muller doesn’t address why, the reason is Sammamish relies on permit and development fees and property taxes for the vast majority of its revenue.

The budget is already under strain, largely because of inadequate roads. The 2015 Transportation Improvement Plan (TIP) identified $92m in road projects that should be done. The 2017 TIP currently being prepared ups this figure, a Council member told The Comment.

The widening of Issaquah-Fall City Road, a project promised to the greater Klahanie area if voters approved annexation to Issaquah, is becoming a cost nightmare. During the annexation campaign, City Manager Ben Yazici and Mayor Tom Vance claimed the project would cost $23m. This compared with the $34m estimated by King County and the figure used by Issaquah when it attempted to annex Klahanie.

The most recent public figure now used by Sammamish is $32m and The Comment has been told this may be heading up again.

Comparable with Mercer Island

During the preparation to write the first Comprehensive Plan in 2001-2003 and even during the run-up to the 1999 incorporation vote, Sammamish was often compared with Mercer Island.

Demographics were similar but more to the point, Mercer Island is, as its name suggests, an island. Sammamish is a land-locked island. Both have limited ways out of the city.

Mullor uses Mercer Island as a comparable to Sammamish in his study. He points out Mercer Island uses AM and PM peak hours for LOS calculations and has LOS C and D for its standards. It also uses 2014 traffic count data.

However, Mercer Island doesn’t have concurrency (traffic volume) testing, but is in the process of adding this to its tests for development applications. Mercer Island currently is under a building moratorium while this process is being established.

Action required

Mullor says the Sammamish City Council needs to immediately step up, reassess its own decisions weakening concurrency and LOS standards and investigate why 2014 and 2016 numbers are not used.

He calls for a building moratorium while the Council investigates the results of his study.

He also calls on citizens to contact the Council.