Commentary: Woeful Target traffic study reveals flaws

Final public comments regarding the Scotts Valley Target Supplemental Environmental Impact Report (SEIR) must be submitted to the city (

tb******@sc**********.org











) by November 4, 2009.
The final traffic study for Target in Scotts Valley is fatally flawed.
It fails to follow the city’s own preparation guidelines. Traffic counts are more than two years old and fail to clearly state the number of expected daily trips per weekend day. Traffic impacts from Target are comparable to the Town Center plan, which evaluated traffic impacts on the entire city. Despite the fact that Target will have regional impacts, only eight intersections were evaluated.
Cumulative impacts with the already approved Town Center would create a 50 percent increase in traffic volume on the Mt. Hermon corridor. Your “typical” Saturday would see an additional 1,000 cars per hour just from Target. The additional car trips per day from this project are equivalent to nearly the entire population of Scotts Valley traveling on La Madrona Drive, a two-lane country road.
Target’s own development guide recommends 572 parking spaces for this size project, 55 more than the 517 planned. And these parking spaces are perpendicular, not angled. Significantly, planned parking would be 212 spaces short — over 40 percent deficient during the holiday season. Add to this the usual summer peak traffic, and this corridor will be gridlocked half the year.
Finally, the SEIR concludes that there are eight significant, unavoidable impacts even after mitigation.
Once approved, the project would likely be completed in 18 months. Nothing is mentioned of the timing of the mitigations required for the project. Many of these, including Highway 17 on- and off-ramp modifications will likely take much longer to put in place.
Notably, city approvals would be required to amend the Gateway South Specific Plan to permit an increase in coverage from 151,000 to 262,650 square feet — a variance of nearly 75 percent! And how is this change to be achieved?
Building plans skirt the city’s “responsible hillside development” policy by cutting and blasting into the hillside, inserting 32-foot-high retaining walls, and front-filling the parcel on concrete pads 26 feet above La Madrona Drive, resulting in a 100-foot-tall Target logo. Aesthetically, Target’s big-box style is totally inconsistent with the chalet look and feel of other commercial development at Gateway South and much of the city.
A fire station is also planned across from the Hilton Scotts Valley. Thousands of additional car trips per day on La Madrona will have a significant impact on any fire response from this location. Also, a retail project of this size and amount of traffic will require significant additional policing.
Target’s questionable environmental record should also be of concern. California Attorney General Jerry Brown and 20 local district attorneys recently filed a suit against Target for repeated willful disregard for California’s hazardous waste laws. That lawsuit alleges that over an eight year period, Target has illegally dumped flammable liquids and toxic chemicals into local landfills.
Additionally, Target recently agreed to pay $600,000 in civil penalties for importing and selling a variety of toys with high levels of lead paint on their surfaces. The Consumer Product Safety Commission alleged that Target knowingly imported and sold the illegal toys between May 2006 and August 2007.
What possible reasons justify approving this project with a company whose ongoing business practices flout the law and have such a negative impact on our local environment and endanger our children?
After this SEIR is certified, it will be too late for feedback. Imagine a big-box store one third larger than Costco at the gateway to our city. If approved, this Target will put a bull’s-eye on the face of Scotts Valley.
• Frank Z. Kertai is president of the Heritage Parks Association, the housing tract adjacent to the proposed Target site on La Madrona Drive.