11/11/2008
Supplemental Submission from Councilman Weiner to WILMAPCO for consideration at 11/13/08 WILMAPCO Council meeting

Statement from New Castle County Councilman Robert Weiner supplementing my 10/5/08 submission to WILMAPCO

Referenced appended letters and emails:

9/10/08 Representatives Valihura, Lavelle & Hudson request for regional traffic study directed to Secretary of Transportation Carol Ann Wicks

9/19/08 response from Secretary of Transportation Carol Anne Wicks to 10/10/08 letter which does not grant request

10/10/08 Representatives Valihura, Lavelle & Hudson response to Secretary of Transportation Wicks seeking DelDOT meeting to understand her 9/19/08 response to legislators

10/23/08 Representative Valihura again asks DelDOT for a meeting

10/5/08 Councilman Robert Weiner’s request directed to WILMAPCO for a Northern DE Land Use and Development Capacity Assessment-proposed amendment for FY 2009-2012 TIP

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Secretary of Transportation Carol Ann Wicks’ 9/19/08 response to area state legislators appears to raise as many questions as it provides responsive answers.

There are 5 Stoltz organization [Stoltz] projects pending before the New Castle County Land Use Department and the State Department of Transportation. One of the Stoltz proposals is located south of the requested study area in New Castle and is not part of the community’s written concerns. Our community’s collective request, from both legislators and community leaders, is to perform a regional traffic study in northern New Castle County. The request clearly defines the scope of the requested review as limited to the region on both sides of the Brandywine River surrounding the 4 Stoltz proposals in northern New Castle County. [Please refer to my 10/5/08 submission which explains why the 4 Stoltz projects are synergistically inter-connected.] Secretary of Transportation Carol Ann Wicks’ letter appears to reject the concept of a regional traffic study in part because the Stoltz project in New Castle is far from the other Stoltz proposals in northern New Castle County. This response appears to indicate a misreading of the initial request for a regional study, which did not request that the New Castle project be included in the scope of review.

Secretary of Transportation Carol Ann Wicks response also appears to conclude that selecting an applicable traffic analysis or methodology is an “either/or” decision [i.e. either perform a regional traffic study or study each of the 4 Stoltz proposals in a vacuum without consideration for the collective impact of each of the four proposals upon each other and upon the surrounding main and minor roadways]. Currently the Shoppes of Brandywine Valley proposal has been scoped for a Traffic Impact Study [TIS] while Greenville Center, Barley Mill Plaza and 20 Montchanin Road proposals have each been scoped for a Traffic Operational Analysis [TOA]. Secretary Wicks’ response does not explain how all four of these proposals, totaling 4 million square feet, will not collectively redirect traffic upon our country roads on both sides of the Brandywine River [including, but not limited to Thompson’s Bridge Road, Montchanin Road, Smiths Bridge Road, and Center Meeting Road, as well as upon Kennett Pike]. Elected state officials, community leaders and I have uniformly requested utilization of a methodology which integrates and extends the TIS/TOA for each project to overlap and thus operate as a regional study. This regional study should include the entire Brandywine Valley impacted collectively by these 4 proposals. It is not apparent in reviewing Secretary Wicks’ response what is the intended scope of review.

Does DelDOT intend to empirically measure the additional traffic load upon our country roads to assure us that these country roads will not lose their character? Does DelDOT intend to expand the TIS/TOA studies currently mandated, to have the same impact as a regional traffic study, considering our finite roadway capacity in the suggested study zone? Secretary Carol Ann Wicks acknowledges the special legal and intrinsic value of our country roads. Secretary Wicks further states that the importance of our country roads will not be overlooked. However, the lack of clarity of detail explaining how the country roads will not be overlooked if there is no regional study leaves the community guessing.

I refer you to excerpts from Carol Ann Wicks’ response:

We have heard the suggestion that the Delaware Department of Transportation (DelDOT) undertake a regional traffic study encompassing all of the Stoltz sites.  While that may initially appear to have merit, there are several important factors to consider.  First, two of the proposed developments (New Castle Town Center and the Shops at Brandywine Valley) are widely separated geographically and share very little with Greenville Center and Barley Mill Plaza insofar as the surrounding development is concerned.  The Town Center and the Shops at Brandywine are best analyzed through the use of separate Traffic Impact Studies (TIS) which reflect the land use context of their respective areas.  

I do recognize the importance of and problems associated with Thompson Bridge Road, Montchanin Road, Smiths Bridge Road, and Center Meeting Road, as well as Kennett Pike.    I am aware that two of these roads have special status as Scenic Byways.  It is incumbent upon us to address traffic issues on these roads in a manner that accounts for both their importance as major thoroughfares and their unique qualities.  For the latter reason we have refrained from adding roadway capacity. Their importance will not be overlooked as part of our study process.

Thank you for your consideration.

Honorable Robert S. Weiner Esq.
Chairman, National Association of Counties Sustainability Leadership Team 2000-2008
Chairman, National Association of Counties Land Use & Growth Management Subcommittee 2002-2008
Member, National Association of Counties Energy, Environment & Land Use Steering Committee
County Councilman, New Castle County Council, DE, District 2
City/County Building, 800 N. French St, 8th floor, Wilmington, DE 19801
302-395-8362 Council Office
www.bobweiner.com www.nccde.org
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Dear Terry:
 
Thank you so much for responding to my email.
 
The expectations are in the letters that we sent. 
 
Please understand that there is a significant level of concern in the community about the interworkings of these four proposals, and DelDOT needs to work with the community with respect to those concerns.  Indeed, as I mentioned last night to the Kennett Pike Association annual meeting, there is no greater threat to the quality of life in northern Delaware than these projects.  The citizens have a right to understand that state government is working for them, and this meeting is the first step to assure them of that fact.
 
In our estimation, an effort akin to that which the state put into the AstraZeneca project is necessary here.
Let me repeat that:  An AstraZeneca-like process must be implemented here.
 
It would be our expectation that this meeting would be the first effort to put into place such a process.  That process, as you will recall, involved all levels of state government, from the governor on down, it involved the elected officials, both state and county, and most importantly, it involved the community in a dialogue that respected the interests, views, needs and wants of those who will be forced live with the development that will be occurring in the already overdeveloped area of the state.
 
As for when such a meeting can occur, please understand that the developer is pushing for immediate response, as a result of a Demand Letter last night, a copy of which is attached, and while the community has no intention to be railroaded into making a decision, the community, through its elected officials, would like to be able to discuss this with the Secretary promptly.  Accordingly, a very prompt meeting is requested, and certainly one by the end of the month.
 
Thank you again for your assistance with arranging this meeting.
 
Bob
 
Robert J. Valihura, Jr.
State Representative
10th Representative District
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         September 19, 2008

The Honorable Robert J.Valihura, Jr.   The Honorable Gregory F. Lavelle   The Honorable Deborah D. Hudson
11 Laurel Ridge Lane                            500 Whitby Drive                             1022 Oriente Avenue
Wilmington, Delaware 19807               Wilmington, Delaware 19803           Wilmington, Delaware 19807     

Dear Representatives Valihura, Lavelle, and Hudson:

I have received your jointly signed letter dated September 10, 2008, and can see that you have  given the subject of proposed developments in northern New Castle County careful thought.  Some of the comments that follow were sent previously to Senator Copeland, who expressed similar concerns. 

We have heard the suggestion that the Delaware Department of Transportation (DelDOT) undertake a regional traffic study encompassing all of the Stoltz sites.  While that may initially appear to have merit, there are several important factors to consider.  First, two of the proposed developments (New Castle Town Center and the Shops at Brandywine Valley) are widely separated geographically and share very little with Greenville Center and Barley Mill Plaza insofar as the surrounding development is concerned.  The Town Center and the Shops at Brandywine are best analyzed through the use of separate Traffic Impact Studies (TIS) which reflect the land use context of their respective areas.   The area of influence for these two studies will be large enough so that the traffic impact will not be underestimated. Streets, roads, and intersections will be carefully analyzed as part of the TIS process.  In particular the intersection of Naamans Road and Concord Pike will be included in the case of the proposed Shops of Brandywine Valley.

Greenville Center and Barley Mill Plaza, on the other hand, are closer geographically and more similar with respect to the background area.  Along with the former Columbia Gas site, they represent an opportunity to undertake an area-wide Traffic Operational Analysis (TOA).  The flexibility to go beyond what is typically included in a TIS (under the county and our previous regulations, which apply to these development proposals) is available through the use of an area wide TOA. This could be used, if the county concurs, for these three sites.  In addition to road and intersection analysis using Level of Service (LOS) as the measure of operating conditions, the TOA provides the opportunity to look at safety concerns using accident information and adequacy of access using traffic queuing and highway capacity information. Thus, a TOA (and a TIS under our current regulations) can be broader in scope and tailored to meet the localized conditions present. The Tyler-McConnell Bridge would also be included as part of the TOA.

I do recognize the importance of and problems associated with Thompson Bridge Road, Montchanin Road, Smiths Bridge Road, and Center Meeting Road, as well as Kennett Pike.    I am aware that two of these roads have special status as Scenic Byways.  It is incumbent upon us to address traffic issues on these roads in a manner that accounts for both their importance as major thoroughfares and their unique qualities.  For the latter reason we have refrained from adding roadway capacity. Their importance will not be overlooked as part of our study process.

The approach I have outlined is my preferred approach to addressing the proposed developments.  I trust that you will find it acceptable as a means of evaluating the impacts and determining what traffic improvements, management techniques, and protective actions are required. 

Please let me know if you wish to discuss this further.

                                                                      Sincerely,
                                                                        
                                                                                  Carolann Wicks
                                                                                  Secretary
CW:rks
cc:        Carie Riley, Legislative Assistant
            Pam Price, Legislative Assistant
            Joan Wutka, Legislative Assistant
            Terry Gorlich, Legislative Liaison 
            Darrel Cole, Director, Public Relations
            Ted Bishop, Assistant Director, Planning & Development
            Michael Williams, Manager, Public Relations
            Robert King, Community Relations Officer, Public Relations
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                                                                                    October 10, 2008

The Honorable Carol Ann Wicks
Secretary
Department of Transportation
P.O. Box 778
Dover, DE 19903

Dear Secretary Wicks:

            Thank you for your thoughtful letter of September 19, 2008, addressing the concerns which you have indicated that DelDOT shares with us and our constituents regarding the impact of the four Stoltz organization proposals that are located in our districts (Shops At Brandywine Valley, 20 Montchanin Road, Greenville Center, and Barley Mill Plaza).

            The point you make about the geographic separation of the New Castle Town Center (which is not in any of our districts) from the other four proposals is well taken.  With respect to the three projects in the Greenville area, we are pleased to hear that Traffic Operational Analyses for each of them can be coordinated with the others to achieve an area-wide study, if the County consents.  To understand better how that would work, what it would encompass, and the nature of the consent that you are looking for from the County, we very much appreciate your invitation to engage in further discussions.  Could you please let us know when, within the next several weeks, we and a few key members of the community could meet with you and your staff for this purpose.

            A meeting with you would also give us an opportunity to explore together the interrelationship between traffic impacts in the area of Route 141, Route 52 and Route 100, on the one side of the Brandywine Valley, and Route 202, Beaver Valley Road, and Naamans Road on the other side.  We realize that a Traffic Impact Study for the Shops at Brandywine Valley will not fail to include the intersection on which it is located at Route 202 and Beaver Valley/Naamans Roads.  However, your assistance is needed to help us grasp how a separate TIS for that project, if not coordinated and interrelated with the TOA’s for the other three projects,

October 10, 2008
Page 2

can enable DelDOT to assess their joint impact on the Brandywine Valley, the Scenic Byway and those rural, historic and narrow roadway corridors connecting both sides of the Valley and their respective communities.

            The community joins us in respecting your professionalism and wishing to have a better understanding of your preferred approach to addressing the proposed developments.  We look forward to arranging a convenient time in the near future when we can discuss this further with you and your staff in person.

                                                                                    Sincerely,
                                             
Robert J. Valihura, Jr.                        Gregory F. Lavelle                 Deborah D. Hudson
            State Representative               State Representative               State Representative
            10th District                            11th District                            12th District

RJV/jd

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September 10, 2008

The Honorable Carol Ann Wicks, Secretary
Department of Transportation
P.O. Box 778
Dover, DE  19903

Dear Secretary Wicks:
 
             We have been copied on an August 21, 2008 letter from The Council of Civic Organizations of Brandywine Hundred ("CCOBH"), the Civic League for New Castle County and the Kennett Pike Association, Inc. (“KPA”) and your response letter dated August 27, 2008 regarding the major land use zoning change proposal for development of Woodlawn Trustee's open space land bounded by Concord Pike and Beaver Valley Road (the "Woodlawn Development"), and the three new proposed redevelopment proposals in the Greenville area, the redevelopment of the former Dupont Barley Mill site, the former Columbia Gas site and an expansion of the Greenville Shopping Center (collectively, the “Greenville Development”) that will profoundly impact our districts and the country/community/local road network which directly connects those developments with the communities in our Districts.  While we have individually weighed in on these development proposals with representatives of your Department, we write to join formally with these community watchdog organizations to request that a Regional Traffic Impact Study be required by the developer with respect to the four development proposals as a whole.
 
            We truly appreciate your response to the legitimate concerns raised by CCOBH, KPA and the Civic League, and your commitment to requiring a Traffic Impact Study ("TIS") should the development proposals remain "the same as, or similar to," that shown on the concept plans.  As we have repeatedly made clear to the Department's representatives over the last two years since the original Woodlawn Development proposal was made, any development of that parcel must ensure that the traffic situation at the already failing intersection of Naamans and Concord Pike (the "Naamans Road Intersection") will not be further degraded.  With the three recently proposed Greenville Development projects, that position is just as applicable to the roadway circumstances surrounding these three projects as it is to the developer’s original Woodlawn project.
 
            With its latest Woodlawn Development proposal, the developer has chosen another, and more troubling, course of action: To move forward with its proposal without even addressing the critical need for improvements at the Naamans Road Intersection.  Rather than put forth a traffic proposal that would straightforwardly address the most pressing problem of this critical transportation corridor in north Wilmington, the developer has eschewed the need to address any concerns, and is, apparently, hoping that DelDOT will not so require a TIS (essentially asking your Department “to ignore the man behind the curtain.”).  Your commitment to requiring a TIS for the current proposal is reassuring, but more, much more, is necessary.
 
  
Page 2
September 10, 2008

            We need not repeat the well made points and issues raised by CCOBH, the Civic League and KPA.  Their letter fully explained the background and the basis for the belief of these combined entities that a Regional Traffic Impact Study is necessary.  We wholeheartedly adopt their position, and commend their views to your Office.
 
What we do need to point out is the current failure of the Naamans Road Intersection, the non-local cut through generated traffic congestion experienced on Thompson Bridge Road, Route 100, Smiths Bridge and Center Meeting Roads during peak hours and the concomitant dangers of adding more traffic on these already overburdened, narrow and uniquely situated roadways, and the seemingly endless through traffic backup problems on Kennett Pike at morning and evening rush hours.

The Naamans Road Intersection reached its capacity long ago, and any further development in the area will, in our estimation, create a virtual shut down of the roadway network at critical times with attendant quality of life problems for the residents in the surrounding communities as traffic backs up making it hard to traverse the area and as traffic seeks to avoid that intersection and migrates off into secondary roads.  The original Woodlawn Development proposal attempted to address the problem in an unworkable and community abusive manner, and following the opposition led by our offices as well as the assistance of Senators Charlie Copeland and Cathy Cloutier, and County Councilman Bob Weiner, the developer abandoned that meritless plan.
 
            Now, however, our communities are faced with an even more significant threat.  Not only is there a revised Woodlawn Development proposal which is virtually similar in size and scale to its now abandoned proposal, but the same developer is planning three more projects in one of the most massive planned development schemes Delaware has seen in decades.  One need only watch the burgeoning traffic problems here in our Districts to understand the horrendous potential that each of these developments, individually, and more importantly, collectively, is poised to slam down on our communities.   These proposals have the potential to create chaos and degradation in an area which is the showcase of northern Delaware:  The scenic Brandywine Valley, as well as to defeat the purpose behind creating our first Scenic Byway.
 
            We can no longer take a “blinders on” approach to looking at traffic impact from development. We can no longer avoid the obvious.  Traffic generators in close proximity generate traffic reactions throughout the interconnected area.  It is incumbent for our Transportation officials to take a holistic approach to understanding how traffic will be strained, and, indeed, overwhelmed in areas not directly surrounding any proposed development.  These four development proposals represent a text-book example of how a fully integrated transportation network will be completely and irreparably impacted by multiple development projects.  Only a regional Transportation Impact Study will be able to fully capture the depth and breadth of the traffic problems that will be inflicted upon the residents of Northern Delaware by these proposals, separately, and in conjunction with each other.
 
            Accordingly, rather than waiting to see what may or may not be forthcoming as the developer moves forward and since the developer has made public its intention to link these developments together as a massive investment in the economic growth of Delaware, we are respectfully requesting that your office take a stand now, and mandate that the developer, before any of the four proposals mature, be required to undertake a Regional TIS which accounts for all of the proposed developments.  It is better to be prepared for the hurricane of development heading right for us, rather than be swamped and overwhelmed by it.
 

Page 3
September 10, 2008

            If your office is not in a position to mandate this now, and commit to making such a regional study a priority, we would ask for a meeting with you at the earliest possible time such that we can fully provide you and your offices with the details of the problems that will ensue if such a study is not mandated in the first instance.

            Thank you for your consideration of our request, and we look forward to your favorable response.

Sincerely,
                                                                                   
                     

Robert J. Valihura, Jr.               Gregory F. Lavelle                    Deborah Hudson
State Representative                 State Representative                 State Representative
10th District                               11th District                               12th District

RV/GF/DH/jd

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From: Bob Weiner [mailto:bob@bobweiner.com]
Sent: Wednesday, September 10, 2008 3:37 PM
Subject: Northern DE Land Use and Development Capacity Assessment-proposed amdt for Fy 2009-2012 TIP

Tigist Zegeye, Executive Director
Wilmington Area Regional Planning Council [WILMAPCO]
150 Library Avenue, Newark, DE 19711 (302) 737-6205

THIS LETTER IS TO REQUEST THAT WILMAPCO, AS THE REGIONAL COORDINATING AGENCY FOR TRANSPORTATION AND LAND USE ISSUES, ADDRESS A POTENTIAL TRANSPORTATION CRISIS IN NORTHERN NEW CASTLE COUNTY.

I understand that the WILMAPCO Council is meeting tomorrow September 11, 2008 at 6:30 pm. As I am unable to attend, I ask that this letter be submitted into the record on behalf of my constituents in northern Delaware.

The four Stoltz organization proposals [Stoltz] currently pending before the New Castle County Land Use Department are located in Greenville and Brandywine Hundred. The four proposals collectively total over 4 million square feet and will draw an immense amount of regional traffic. The four projects are (1) Barley Mill Plaza site redevelopment, (2) Greenville Center redevelopment, (3) #20 Montchanin Road/old Columbia Gas site redevelopment, and (4) Shops of Brandywine Valley. All four development proposals have currently been deemed “unacceptable” by the New Castle County Land Use Department but Stoltz intends to re-file all 4 applications. See http://www.bobweiner.com/stoltz.asp and www.nccde.org for details. The scale and scope of the collective impact is greater than any other development proposals in the history of Delaware. In fact, in addition to its impact on major corridors, much of its impact will be felt in an area designated by WILMAPCO as a Rural Transportation Investment Area. It is critical that agencies such as WILMAPCO, DelDOT and New Castle County look beyond the scope of the Traffic Operational Analysis [TOA] and Traffic Impact Study [TIS] intersections currently being studied.
 
I therefore propose that WILMAPCO support a regional traffic study that assesses the land use and development capacity of this area of northern Delaware, similar to the assessment approach that led to improvements for the city of Wilmington. The study should extend along the Route 141 corridor from the I-95 exit in Newport to the I-95 exit at Route 202, north along Route 202 to the PA State Line, along Naamans Road [Route 92] to the I-95 exit, and north along Route 52 to the PA State line. Route 52, Route 48 and the "country roads" in between [on both sides of the Brandywine River] should be included in the study area.

Studies have been conducted for the Route 40 Corridor, Route 301, and for Southern New Castle County, and yet these areas lack the population density and traffic burdens of the Brandywine Hundred/Greenville/Centreville area.
 
The assessment process should also incorporate an environmental assessment (EA) element due to the rural and historic nature of the Brandywine Valley and its creek beds. The National Environmental Policy Act and Section 4f application would be highly appropriate given the Brandywine Valley National Scenic Byway, Brandywine Creek State Park, and the many sites of national, state, and local significance. This expanded process would provide an opportunity to better protect the integrity of our limited roadway infrastructure and our quality of life.  The goal: new regional traffic should not utilize our country roads but instead should be incentivized to use major bike/ped and public transportation systems improvements ALONG MAJOR ARTERIAL ROADWAYS, such as those recommendations spelled out in the Tyler McConnell Bridge Project. Supportive documentation already exists from the Brandywine Valley Scenic Byway and Tyler McConnell Bridge projects and would provide a foundation for a regional EA.
 
Do we want the Brandywine (River) Valley to become another King of Prussia/Philadelphia [which long ago lost the charm of its country roads], or do we want to maintain the unique charm of our Brandywine Valley? If we do not adopt a regional assessment approach and require a commitment to enforce previously WILMAPCO-recommended mitigation strategies, we will forever lose the charm of our country roads in the Centreville/Greenville/Brandywine Hundred areas, on both sides of the Brandywine River. Northern Delaware will become congested like the worst suburbs of Philadelphia. Astra Zeneca relocated to Delaware in part because this is a great place to work and to live. We can all retreat to the peace and serenity of a country setting which is no more than 10 minutes from our collective homes. In light of the 4 Stoltz proposals, we have only one opportunity to make the right decisions. Our decisions now will be irreversible forever. We cannot allow the 4 Stoltz proposals to each be considered in a vacuum. A regional approach is essential.

I recommend that WILMAPCO member agencies recommend phasing of the Stoltz projects with a requirement that the Stoltz organization pay its fair share of major bike/ped and public transportation systems improvements. The Tyler McConnell Bridge project, which would double the number of current bridge lanes is on the CTP but has no allocated funding. The Stoltz organization should be required to fund this project as a precondition to approval of any of its 4 regional projects in Greenville and Brandywine Hundred to reduce traffic on country roads.  Almost 3 million square feet is proposed at the Barley Mill Plaza site. Only an expensive light rail line connecting to both I-95 intersections, could possibly service the final proposed 3 million square feet phase build out of the Barley Mill Plaza parcel. Stoltz should be required to fund all public transportation system improvements as a condition to project approval.
 
The level of service in the traffic corridors surrounding the proposed study zone incorporating all four of the Stoltz proposals is already in or near service failure [LOS D for Route 141 including its intersection with Route 48 & LOS F for Tyler McConnell Bridge]. I refer you to the attachment. Source: DelDOT [2006 Average Annual Daily Traffic].
 
For as long as I have been engaged in the process, going back to the mid 1980's, there has been the perception that DelDOT and New Castle County Land Use Department can never say “no” to any proposal on the basis of traffic capacity. The perception is that each agency avoids responsibility for the final outcome by simply pointing its figurative finger at the other agency. The perception is that the collective mindset of both DelDOT and New Castle County is that its true collective mission, as traffic engineers and planners, is simply to facilitate whatever any developer proposes. However, with the adoption of the density bonuses and larger magnitude development afforded by the New Castle County mixed use and redevelopment ordinances, we are at a critical crossroad.
 
In the Philadelphia/King of Prussia corridor, given the magnitude of traffic congestion, SEPTA has committed to spend in excess of 300 million dollars to construct a light rail system connecting Philadelphia with King of Prussia. However, SEPTA's own studies indicate that even with this huge expenditure, the light rail system, once implemented, will be overwhelmed the day it opens and it will fail in its traffic congestion management mission.
 
With the adoption of density bonuses by New Castle County to foster economic redevelopment and mixed use, we are in a new era with both opportunities and challenges. DelDOT and New Castle County have to prove to the public that
both agencies are willing to communicate and work together more effectively than ever before. New Castle County has made a commitment via its 2007 Comprehensive Plan update to demonstrate to the community that density and compact mixed use development is essential for sound land use planning in order to avoid building more auto-dominated suburban sprawl patterns. If government fails to properly implement the vision of the 2007 Comprehensive Plan, we will give those who opposed the adoption of the 2007 Comprehensive Plan ample ammunition to win the hearts and minds of the majority of reasonable citizens who either directly supported the 2007 Comprehensive Plan or who indirectly support the concept of compact transit oriented mixed use pedestrian friendly development. If the detractors who opposed shifting from a pattern of sprawl can harness this negativity, we will lose our opportunity to implement the vision of the Comprehensive Plan. The same holds true for WILMAPCO’s RTP and Livable Delaware goals.

In conclusion:

Since the TOA and TIS processes only address intersections surrounding the proposed developments, the longer local two lane roads and arterials are neglected when in fact they will be placed under a tremendous burden. Movement of traffic does not stop at intersections - it moves along roadways! Therefore, I recommend that the WILMAPCO Council consider looking a regional transportation analysis that would incorporate all of the impacted roads between these projects. The study could take the form of a Land Use and Development Capacity Assessment so that the community is assured that the capacity of roads and extent of development are in sync with one another. I request that this topic be considered as a regular agenda item for the Council.

Due to the threat of major development abutting the environmentally sensitive Brandywine Valley and its numerous significant resources, an environmental assessment component should be part of the traffic and development assessment. Much of this area has been designated by WILMAPCO as a Rural Transportation Investment Area, meaning that little change is anticipated for transportation infrastructure (despite the obvious pressures that will be placed on it).  An environmental assessment should cover a full range of National Environmental Policy Act resources as spelled out in the FHWA Environmental Guidebook. This would include Section 4f resources of national, state, and local significance, including the Brandywine Valley National Scenic Byway and resources, Brandywine Creek State Park, and the Hagley Historic District.
 
I urge the WILMAPCO Council to place this request onto its permanent agenda for further discussion. In light of the major development proposals within a small geographic area, the traffic issues facing northern New Castle County are serious and a great deal is at stake.
 
Thank you for your consideration.

Councilman Robert S. Weiner
Council District 2, New Castle County Council
Louis L. Redding City/County Building
800 North French Street, 8th floor, Wilmington, DE 19801
302-395-8362 Louis Hinkle, aide to Councilman Weiner
www.bobweiner.com    www.nccde.org 

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