To: Keith Leonard kleonard@tualatin.gov
To: Planning Department planning@tualatin.gov
Cc: City Council council@tualatin.gov
Cc: STR Outreach outreach@tualatinroad.org
Subject: Lam Traffic Impacts
To: Planning Department planning@tualatin.gov
Cc: City Council council@tualatin.gov
Cc: STR Outreach outreach@tualatinroad.org
Subject: Lam Traffic Impacts
Dear Tualatin Architectural Review Board,
Thank you for the opportunity to comment on Lam's updated TUX site plan, specifically the proposed expansion of the 108th Avenue north access point which is currently gated. Opening this gate to allow employee access would add traffic to Tualatin Road, making it more difficult for residents to enter and exit our neighborhoods. Peak traffic volume on Tualatin Road is already a major problem, and I would ask the city to take steps to reduce, not increase, traffic volumes on Tualatin Road.
Approved in 2023, Lam's Building G project is still under construction, and the full traffic impact of its two new parking lots on 108th has not yet been felt, but is already baked in. I am opposed to opening another access on 108th, and I respectfully request that Lam's existing 108th north access remain in its current configuration: closed to employee traffic but available for emergency and utility use.
For the majority of Riverpark residents, Tualatin Road is our ONLY option for local access. We do not have an alternate route, but Lam does: Leveton Drive. It has a higher speed limit and lower traffic volume than Tualatin Road. Leveton is a better route for Lam's trips.
SITE CIRCULATION
Lam's updated site plan shows a primary employee driveway connecting the north parking lots directly to Leveton Drive, providing more than adequate roadway access for these employees. Connecting these same parking lots to 108th is redundant and unnecessary, and would create unintended negative impacts in the surrounding neighborhoods.
Lam's site plan shows 6 other access points: 4 on Leveton Drive and 2 on 108th. Lam is responsible for designing reasonable site circulation. A lack of good site circulation is not a valid reason to open yet another access point.
DRIVEWAY CRITERIA
Lam's traffic study shows that the Hazelbrook Road on-ramp to Hwy 99W will fail to meet performance standards after adding the additional traffic volume from the proposed 108th entrance.
This proposed entrance fails three of the driveway approach criteria in TDC 75.020.5: "(g) The proposed driveway approach does not result in significant adverse impacts to the vicinity; (h) The proposed driveway approach minimizes impact to the functionality of adjacent streets and intersections; and (i) The proposed driveway approach balances the adverse impacts to residentially zoned property and the functionality of adjacent streets."
PLANNING GOALS
The Tualatin Comprehensive Plan 2040 asks us to "Consider transportation options that make the best use of the existing network." (Goal 8.7) Leveton Drive has a massive amount of unused capacity available and is currently under-utilized especially during peak traffic times. The highest and best use for Leveton Drive is to carry ALL of Lam's added site trips. It is unreasonable to put more strain on Tualatin Road (and its residents) when Leveton is sitting there mostly empty.
SCOPE OF IMPACT
The full impact of an expanded 108th access would extend well beyond the TUX project. Lam's latest site plan shows an abundance of open space available for future development, and based on current trends, Lam will continue to expand and build out their campus.
It is also common for semiconductor facilities to run multiple shifts, in order to double or triple their production capacity without expanding the physical plant. Adding shifts (and the accompanying traffic volume) would not require an Architectural Review, Industrial Master Plan update, or Conditional Use Permit. The potential for significantly increased intensity of use should be anticipated now and addressed during the current land use review cycle.
The Tualatin Planning Commission was advised to not consider ANY traffic or noise impacts during their IMP hearing, and was told that these concerns would be handled by the Architectural Review Board.
When measuring the traffic impact of Lam's proposed entrance, it is appropriate and justified to look at not only the impact from Lam's TUX project, but also look at the total anticipated impact from future developments that could use this entrance. At the IMP hearing, one of Lam's advocates mentioned that "this project has been part of Lam's master plan for quite some time." In order to evaluate the full impact of Lam's current proposal, it would be helpful to see how this entrance would interact with future projects, and how it fits into Lam's overall campus master plan.
ROAD SAFETY
An expansion at 108th would provide Lam's north parking lots with access to Tualatin Road. The intersection of 108th and Tualatin Road already has an elevated crash rate, and adding more traffic here would increase the risk of injury, not only for those who choose to turn here, but also for each person who travels along this section of Tualatin Road.
STUDENT SAFETY
The proposed expansion on 108th would also add traffic to 115th Avenue, which many students cross on foot each day going to and from school. Compared to existing conditions, the current TUX proposal represents a decrease in student safety, and that is a step in the wrong direction.
Lam’s traffic study also does not identify the locations of school bus routes or the potential impacts to school bus traffic. Student safety is one of the most important issues in our community, but so far it has been ignored in this process.
JUSTICE AND EQUITY
Although the negative traffic impacts from 108th would be felt along the entire length of Tualatin Road, these impacts would be most concentrated between 108th and 124th Avenues, an area which includes more than 600 high-density housing units, traditionally disadvantaged demographics, and income-limited apartments. Putting more traffic stress on these populations is not equitable, especially when a better alternative is available on the other side of Lam's campus.
PUBLIC FUNDS
Lam Research received $22 million in taxpayer-funded CHIPS Act grant funds to help pay for the TUX expansion. Any project built with taxpayer funds should be designed so that it does not harm the community.
ECONOMIC IMPACT
The total value of residential real estate located between the Tualatin River and Tualatin Road is well over $500 million. This tax base must be protected. The best economic solution would be for Lam to grow in a way that does not interfere with surrounding residential land uses. The current decision before you does not need to be a conflict between Lam and the surrounding community. With good site design and smart planning, this project can be a win-win.
Keeping the 108th north access in its current configuration and utilizing Leveton for all of Lam's new site trips is a solution that will allow Lam's campus to grow long into the future while protecting the quality of life and property values of the taxpayers who live along Tualatin Road.
Thank you for your consideration.
Thank you for the opportunity to comment on Lam's updated TUX site plan, specifically the proposed expansion of the 108th Avenue north access point which is currently gated. Opening this gate to allow employee access would add traffic to Tualatin Road, making it more difficult for residents to enter and exit our neighborhoods. Peak traffic volume on Tualatin Road is already a major problem, and I would ask the city to take steps to reduce, not increase, traffic volumes on Tualatin Road.
Approved in 2023, Lam's Building G project is still under construction, and the full traffic impact of its two new parking lots on 108th has not yet been felt, but is already baked in. I am opposed to opening another access on 108th, and I respectfully request that Lam's existing 108th north access remain in its current configuration: closed to employee traffic but available for emergency and utility use.
For the majority of Riverpark residents, Tualatin Road is our ONLY option for local access. We do not have an alternate route, but Lam does: Leveton Drive. It has a higher speed limit and lower traffic volume than Tualatin Road. Leveton is a better route for Lam's trips.
SITE CIRCULATION
Lam's updated site plan shows a primary employee driveway connecting the north parking lots directly to Leveton Drive, providing more than adequate roadway access for these employees. Connecting these same parking lots to 108th is redundant and unnecessary, and would create unintended negative impacts in the surrounding neighborhoods.
Lam's site plan shows 6 other access points: 4 on Leveton Drive and 2 on 108th. Lam is responsible for designing reasonable site circulation. A lack of good site circulation is not a valid reason to open yet another access point.
DRIVEWAY CRITERIA
Lam's traffic study shows that the Hazelbrook Road on-ramp to Hwy 99W will fail to meet performance standards after adding the additional traffic volume from the proposed 108th entrance.
This proposed entrance fails three of the driveway approach criteria in TDC 75.020.5: "(g) The proposed driveway approach does not result in significant adverse impacts to the vicinity; (h) The proposed driveway approach minimizes impact to the functionality of adjacent streets and intersections; and (i) The proposed driveway approach balances the adverse impacts to residentially zoned property and the functionality of adjacent streets."
PLANNING GOALS
The Tualatin Comprehensive Plan 2040 asks us to "Consider transportation options that make the best use of the existing network." (Goal 8.7) Leveton Drive has a massive amount of unused capacity available and is currently under-utilized especially during peak traffic times. The highest and best use for Leveton Drive is to carry ALL of Lam's added site trips. It is unreasonable to put more strain on Tualatin Road (and its residents) when Leveton is sitting there mostly empty.
SCOPE OF IMPACT
The full impact of an expanded 108th access would extend well beyond the TUX project. Lam's latest site plan shows an abundance of open space available for future development, and based on current trends, Lam will continue to expand and build out their campus.
It is also common for semiconductor facilities to run multiple shifts, in order to double or triple their production capacity without expanding the physical plant. Adding shifts (and the accompanying traffic volume) would not require an Architectural Review, Industrial Master Plan update, or Conditional Use Permit. The potential for significantly increased intensity of use should be anticipated now and addressed during the current land use review cycle.
The Tualatin Planning Commission was advised to not consider ANY traffic or noise impacts during their IMP hearing, and was told that these concerns would be handled by the Architectural Review Board.
When measuring the traffic impact of Lam's proposed entrance, it is appropriate and justified to look at not only the impact from Lam's TUX project, but also look at the total anticipated impact from future developments that could use this entrance. At the IMP hearing, one of Lam's advocates mentioned that "this project has been part of Lam's master plan for quite some time." In order to evaluate the full impact of Lam's current proposal, it would be helpful to see how this entrance would interact with future projects, and how it fits into Lam's overall campus master plan.
ROAD SAFETY
An expansion at 108th would provide Lam's north parking lots with access to Tualatin Road. The intersection of 108th and Tualatin Road already has an elevated crash rate, and adding more traffic here would increase the risk of injury, not only for those who choose to turn here, but also for each person who travels along this section of Tualatin Road.
STUDENT SAFETY
The proposed expansion on 108th would also add traffic to 115th Avenue, which many students cross on foot each day going to and from school. Compared to existing conditions, the current TUX proposal represents a decrease in student safety, and that is a step in the wrong direction.
Lam’s traffic study also does not identify the locations of school bus routes or the potential impacts to school bus traffic. Student safety is one of the most important issues in our community, but so far it has been ignored in this process.
JUSTICE AND EQUITY
Although the negative traffic impacts from 108th would be felt along the entire length of Tualatin Road, these impacts would be most concentrated between 108th and 124th Avenues, an area which includes more than 600 high-density housing units, traditionally disadvantaged demographics, and income-limited apartments. Putting more traffic stress on these populations is not equitable, especially when a better alternative is available on the other side of Lam's campus.
PUBLIC FUNDS
Lam Research received $22 million in taxpayer-funded CHIPS Act grant funds to help pay for the TUX expansion. Any project built with taxpayer funds should be designed so that it does not harm the community.
ECONOMIC IMPACT
The total value of residential real estate located between the Tualatin River and Tualatin Road is well over $500 million. This tax base must be protected. The best economic solution would be for Lam to grow in a way that does not interfere with surrounding residential land uses. The current decision before you does not need to be a conflict between Lam and the surrounding community. With good site design and smart planning, this project can be a win-win.
Keeping the 108th north access in its current configuration and utilizing Leveton for all of Lam's new site trips is a solution that will allow Lam's campus to grow long into the future while protecting the quality of life and property values of the taxpayers who live along Tualatin Road.
Thank you for your consideration.