Document Woodburn_doc_4148c08faf

Agenda Item TO: Planning Commission FROM: Chris Kerr, Community Development Director Fernando Torres, Associate Planner DATE: March 12, 2026 SUBJECT: Additional Public Testimony Please find attached public testimony received since the staff report was published. Attachments: Cascade Meadows Comments (Received 03-06-2026) Willamette Riverkeeper Comments (Received 03-09-2026) Chris Propeck Comments (Received 03-10-2026) UFCW Local 555 Comments (Received 03-11-2026) Kay McEwen Comments (Received 03-11-2026) Andrew Mulkey Comments & Exhibit A (Received 03-11-2026) Adria Young Comments (Received 03-12-2026) Silver Creek Senior Living Comments (Received 03-12-2026) Oregon Department of Transportation Comments (Received 03-12-2026) ---PAGE BREAK--- Outlook Re: Winco in Woodburn From Chris Kerr <[EMAIL REDACTED]> Date Fri 3/6/2026 2:50 PM To Cascade Meadow <[EMAIL REDACTED]> Cc Fernando Torres <[EMAIL REDACTED]> Thanks for the comment. I'll forward this recommendation to WinCo as well. Feel free to call me with any questions. Chris Kerr From: Cascade Meadow <[EMAIL REDACTED]> Sent: Friday, March 6, 2026 2:15 PM To: Chris Kerr <[EMAIL REDACTED]> Subject: RE: Winco in Woodburn This email is from an EXTERNAL sender. Exercise caution when opening attachments or click links from unknown senders or unexpected email. Hello Chris, I would like it included in the application request for Winco that the carts on the property be required to have perimeter locks on the wheels. Carts being all over the community has currently been a problem that will only get much worse if Winco does not have locks are on the cart wheels when they begin operation. I am a resident of this community at 311 S Evergreen Rd, Apt A100 Woodburn, OR 97301and would like legal standing. Please let me know if you have any questions or concerns. ---PAGE BREAK--- Eugene: 454 Willamette St. #218 I Eugene, OR 97401 Portland: 8940 N Bradford St. I Portland, OR 97203 [PHONE REDACTED] March 9, 2026 Dear Woodburn Planning Commissioners, I am writing today on behalf of Willamette Riverkeeper to encourage you to require stormwater runoff mitigation measures to be implemented for the proposed WinCo Food Grocery Store on Tax Lots 052W12C002100 and 052W12C002200. As this currently undeveloped lot covered in grass will be paved over for the WinCo development, there will be a large increase in stormwater runoff, bringing many pollutants into storm drains that lead into the river. With this in mind, Willamette Riverkeeper urges the commission to require: - Use of plants only on Marion County Soil and Water Conservation District’s Native Plant List1 and make sure the plants used are in the right place.2 Native plants are essential for creating sustainable, low-maintenance, and drought-resilient landscapes that support local ecosystems. - Use of permeable pavements to reduce pollutants in surface runoff. Permeable pavements can retain and reduce many pollutants, including 6PPD-quinone, a pollutant from tire wear particles that can be deadly to salmon species.3 Permeable pavements also allow for water inTiltration to ensure that the water table does not lower due to the inability of water to reach the ground. Additionally, Willamette Riverkeeper would like to urge commissioners to encourage the use of rain gardens with native plants to help with stormwater runoff and groundwater infiltration. Thank you for your consideration, Heather King Co-Executive Director and Lower Willamette Riverkeeper [EMAIL REDACTED] 1 2 To ensure plants are planted in the right place and can thrive with minimal maintenance please match species to their ideal light, soil, and moisture needs. 3 See Chelsea J. Mitchell & Anand D. Jayakaran, Mitigating tire wear particles and tire additive chemicals in stormwater with permeable pavements, Science of the Total Environment 908 (2024), ---PAGE BREAK--- Outlook Re: New Winco Store From Chris Kerr <[EMAIL REDACTED]> Date Tue 3/10/2026 8:20 AM To Chris Propeck <[EMAIL REDACTED]> Cc Fernando Torres <[EMAIL REDACTED]> Thanks - I will make sure that is provided to the Planning Commissioners for their hearing. If you get me your address I can mail you a copy of the Final Decision. CK From: Chris Propeck <[EMAIL REDACTED]> Sent: Monday, March 9, 2026 7:09 PM To: Chris Kerr <[EMAIL REDACTED]> Subject: New Winco Store This email is from an EXTERNAL sender. Exercise caution when opening attachments or click links from unknown senders or unexpected email. Greetings, I am one of the many non-emergency medical transport drivers who frequently transports people into/out of facilities on Evergreen Rd. The driveways of facilities such as French Prairie, and Country Meadows are already difficult to safely enter and exit due to fast moving traffic. I've witnessed speeding traffic, and cars running the stop signs on too many occasions. I have also experienced long waits to turn out of those driveways during heavy traffic periods such as when Nellie Muir Elementary School lets out. Adding the traffic of a grocery store will only exacerbate the traffic issue. I witnessed the same situation in Salem, when Costco opened a new store next to South Salem Clinic. Both the driveway and the parking lot are more congested and less safe due to the added traffic of the Costco customers. Kuebler Rd changed from a flowing road to a veritable parking lot. The I-5 interchange now experiences long back-ups. Access to the Boone Ridge retirement community has become challenging for medical transport, and even for emergency first responders. I would hate to see that situation happen in Woodburn. I was informed that a hearing and possible vote will occur on the 12th of March. I will not be able to attend in person, so I respectfully request that this email be entered into the record as testimony. It is my hope that the city of Woodburn will do the right thing, and find an alternate location for a new Winco grocery store - one which will work better for everyone. Thank you for your attention. Christopher Propeck Keizer, OR So amid the conflict whether great or small, Do not be disheartened, God is over all; Count your many blessings, angels will attend, Help and comfort give you, to your journey's end. ---PAGE BREAK--- March 11, 2026 Woodburn Planning Commission City of Woodburn 270 Montgomery Street Woodburn, OR 97071 Re: DR 25‑14 / VAR 25‑06 / PLA 25‑04 / SA 26‑01 — Proposed WinCo Foods Grocery Store Dear Planning Commissioners: UFCW Local 555 represents more than 35,000 grocery, retail, and food-processing workers across Oregon, and the Pacific NW, including many who live and work in Woodburn. We appreciate the opportunity to provide comments on the proposed 84,087-square-foot WinCo Foods development currently under Design Review. Our union supports responsible economic development that strengthens local employment, protects public infrastructure, and enhances community well-being. Based on our review of the application materials, we believe the record does not yet demonstrate that this project meets those standards. Labor and Economic Impacts WinCo is a non-union employer whose business model relies on low wages, unpredictable scheduling, and minimal staffing levels. In communities where large, non-union big-box grocers open, existing union and independent grocers often experience reduced sales, cuts to worker hours, and long-term job instability. These impacts are well-documented and will directly affect the livelihoods of hundreds of Woodburn-area grocery workers. The City should not approve a project of this scale without fully considering its effect on job quality, economic stability, and the long-term viability of existing employers who provide family-sustaining union jobs. Transportation and Safety Concerns The City’s February 18, 2026, completeness letter confirms that this project requires a Type III public hearing because of its scale and potential impacts. While the applicant has submitted a Traffic Impact Analysis (TIA), the document raises several unresolved issues that should be addressed before any approval is granted. Among the concerns are: • Unclear traffic assumptions. The TIA relies on assumptions about trip generation, distribution, and timing that may not reflect actual conditions once the store opens. • Potential underestimation of congestion. Key corridors such as Evergreen Road, Stacy Allison Way, and Highway 214 already experience heavy traffic. A store of this size will add significant new vehicle trips, and the TIA does not clearly demonstrate that nearby intersections and roadways can absorb this increase without degrading safety or mobility. • Lack of clear mitigation. The TIA identifies areas where traffic conditions may worsen but does not provide specific, enforceable mitigation measures or demonstrate that improvements would be in place before the store opens. ---PAGE BREAK--- • Pedestrian and neighborhood safety. The project will increase turning movements, truck activity, and pedestrian crossings near residential areas. The TIA does not fully evaluate how these changes will affect safety for nearby residents, workers, and school-related traffic. These issues are significant because transportation impacts directly affect emergency response, commute times, neighborhood livability, and the overall functioning of the city’s transportation system. Before approving a project of this size, the City should require a clearer, more complete analysis and ensure that any necessary improvements are identified, funded, and timed appropriately. Neighborhood and Community Impacts The site is adjacent to homes, apartments, and senior housing. A store of this size will introduce late-night noise and lighting, increased truck activity, hundreds of new daily vehicle trips, and additional turning movements near residential driveways. The proposed pedestrian improvements on Evergreen Road also require further evaluation to ensure they are appropriate and safe for the surrounding neighborhood. Need for Additional Review Before Approval Given the scale of the project, the gaps in the current traffic analysis, and the potential economic and community impacts, UFCW Local 555 respectfully urges the Planning Commission to require: • A more complete and transparent TIA that fully evaluates traffic, safety, and neighborhood impacts; • Clear, enforceable mitigation measures that are concurrent with development; • Evaluation of job quality, economic displacement, and impacts on existing employers; and • Additional public review once corrected materials are submitted. Until these issues are resolved, approval of the application is not supported by substantial evidence in the record. Thank you for your consideration and for your service to the residents and workers of Woodburn. Sincerely, Miles Eshaia Communications Director UFCW Local 555 ---PAGE BREAK--- Outlook Re: Re WinCo building plan From Chris Kerr <[EMAIL REDACTED]> Date Wed 3/11/2026 8:55 AM To Kay McEwen <[EMAIL REDACTED]> Cc Fernando Torres <[EMAIL REDACTED]> Thanks for providing comments. I'll will provide this email to the Planning Commission for their hearing. If provide your address I will send you a copy for the final decision when it is ready. Feel free to call me with any questions. Thanks CK From: Kay McEwen <[EMAIL REDACTED]> Sent: Wednesday, March 11, 2026 8:43 AM To: Chris Kerr <[EMAIL REDACTED]> Subject: Re WinCo building plan This email is from an EXTERNAL sender. Exercise caution when opening attachments or click links from unknown senders or unexpected email. Kay McEwen It is my opinion that WinCo should build its store on the west side of I-5, West Woodburn, rather than on the east side of I-5, which puts it in direct competition with the other grocery stores which have sustained our community all these years during which WinCo declined to build a store to serve our community.They should "serve" those who live on the west side of I-5, closer to their own distribution center, and reducing added traffic on the west side of the freeway. Years ago, I went to WinCo and asked them to provide a store here in Woodburn, since its distribution center was in Woodburn. They said No, that they were building a store in Las Vegas. so wouldn't be building one in Woodburn. Thus, Safeway, Walmart, Bimart and Megafoods sustained our community during those many years. Winco should build its store on the west side of the freeway, providing a grocery outlet for all of those Woodburn residents now living there, with increasing populations. They should NOT be allowed to build on this side of the freeway because we already have too much traffic gridlock obstructing and harming our population, and it would take away from the revenue of those grocery outlets which have served and sustained us throughout these may years during which Winco couldn't be bothered to serve and support our community. Don't put them in direct competition with Walmart! Don't be a "Yes Man" and rubber stamp every development application which crosses yout desk without heeding the wisdom of the native Woodburnians which live in our community, warning about the impact of rubber- stamped development approvals on our community, ,any of which have been short-sighted as to long-term ecological effects and human consequences detrimental to our community. your t ---PAGE BREAK--- Andrew Mulkey Attorney at Law PO Box 66562, Portland, OR 97290 • (503) 334-9899 • [EMAIL REDACTED] March 11, 2026 Via Email City of Woodburn Planning Commission c/o Chris Kerr, Community Development Director 270 Montgomery Street Woodburn, OR 97071 [EMAIL REDACTED] Re: Protect Our Valley Alliance, Planning Commission Comment Letter for Land Use Application for Proposed WinCo Foods — Transportation, Environmental, and Neighborhood Impacts Dear Chair and Members of the Planning Commission: I represent Protect Our Valley Alliance, a coalition of Woodburn residents, workers, and community stakeholders concerned about the transportation, environmental, and neighborhood impacts of the proposed WinCo Foods development. The Alliance supports growth that is consistent with the Woodburn Comprehensive Plan, protects public safety, and ensures that development does not impose disproportionate burdens on surrounding neighborhoods. At the Alliance’s request, Greenlight Engineering conducted an independent technical review of the applicant’s Traffic Impact Analysis revised January 21, 2026. The engineering review is attached as Exhibit A and incorporated herein. The review identifies multiple substantive deficiencies that prevent the City from making the findings required under the Woodburn Development Ordinance the Interchange Management Area (“IMA”) Overlay District, and applicable transportation standards. In addition to the technical transportation issues, the Alliance has identified significant concerns related to emergency access, neighborhood livability, noise and light pollution, pedestrian safety, environmental impacts, and compatibility Planning Commission Comment Letter: Protect Our Valley Alliance 1 of 12 ---PAGE BREAK--- with adjacent residential uses. These issues are supported by evidence in the record, by the City’s own adopted policies, and by the applicant’s materials. Based on the current record, the application does not demonstrate compliance with mandatory approval criteria and does not provide substantial evidence supporting approval. The Alliance respectfully requests that the Commission deny the application or, at minimum, require the applicant to submit corrected materials and return for further public review. A summary of the basis for denial or additional materials is included at the end of this letter. I. Summary of Findings The independent engineering review concludes that the TIA contains four fundamental deficiencies that materially undermine its conclusions: ● Impacts are understated ● IMA trip cap compliance is not demonstrated ● Intersection failures are identified but not mitigated ● Required engineering analyses are missing These deficiencies affect the core assumptions that drive all operational modeling, trip generation, and compliance findings. Until corrected, the City cannot make defensible findings that the project meets WDO transportation standards or that public safety will not be hindered. II. The Application Fails to Demonstrate Compliance with the IMA Trip Budget The subject property lies within Subarea K of the IMA Overlay District. Compliance with the PM peak-hour trip budget is mandatory, and exceedance is allowed only if the City makes explicit, evidence-based findings that the development “contributes substantially to the economic objectives” of the Comprehensive Plan. The TIA does not provide: ● The parcel’s remaining PM peak-hour trip allocation ● A comparison between project trips and remaining capacity Planning Commission Comment Letter: Protect Our Valley Alliance 2 of 12 ---PAGE BREAK--- ● Any accounting of prior approvals that may have consumed Subarea K’s allocation As the engineering review states: “The proposed WinCo would consume and vastly exceed whatever remaining capacity exists within Subarea K… Table 5 of the TIA illustrates that the WinCo itself will generate 672 weekday PM peak hour trips, substantially in excess of the 429-trip allocation.” Without a transparent trip-cap analysis, the City cannot determine whether the project complies with WDO 2.05.02 or whether an exception is justified. 1 See WDO 2.05.02(A), and As explained below, even if the City assumes that the peak hour vehicle trips generated will exceed the maximum peak hour trips allowed in Table 2.05A, the applicant fails to demonstrate that the development will “contribute substantially to the economic objectives found in the Comprehensive Plan.” WDO 2.05.02(G)(2)(a). III. The TIA Applies Improper Pass-By Trip Reductions The TIA assigns 80 pass-by trips on Highway 214 , even though the site has no driveway access on that roadway. As the engineering review explains: “Pass-by trips are not diverted from another roadway not adjacent to the site.” The TIA conflates diverted trips with pass-by trips, contrary to ITE methodology. Because trip generation is the foundation for all subsequent modeling, improper pass-by assumptions propagate errors throughout the entire analysis. IV. The TIA Uses an Incorrect Opening Year The TIA models a 2026 opening year, while the applicant’s narrative states the store will not open until mid-to-late 2027 . The engineering review notes: 1 2.05.02(D)(1) requires that the TIA meet OAR 734-051 requirements. The OAR requires that TIAs “assess peak hour and average daily trips,” “for the year of the analysis, the year of each phase opening, and future years beyond project completion or buildout.” OAR [PHONE REDACTED](5) The applicant’s failure to provide an adequate analysis of peak hour trips (or as described below, a correct analysis of the opening year) violates these provisions as well. Planning Commission Comment Letter: Protect Our Valley Alliance 3 of 12 ---PAGE BREAK--- “Even a one-year difference can meaningfully affect intersection performance… particularly at locations already operating near capacity.” This discrepancy results in understated background volumes and artificially improved operational results. V. The Study Area and Trip Distribution Are Incomplete The TIA assumes no project traffic will use Lawson Avenue, despite the likelihood that navigation apps will route drivers through that corridor during peak congestion. The review states: “It is likely that a meaningful share of eastbound drivers on Highway 214 would be routed via Lawson Avenue rather than Evergreen Road.” The TIA also omits several foreseeable intersections, including: ● Highway 214 / Lawson Avenue ● Lawson Avenue / Stacy Allison Road ● Evergreen Road / Center Street A defensible TIA must include all intersections where project traffic is reasonably expected to cause operational change. VI. Required Queueing and Simulation Analyses Are Missing The TIA does not include 95th-percentile queue analysis, despite ODOT requirements that simulation be used when v/c ratios exceed 0.70 and must be used when they exceed 0.90. The engineering review explains: “Without 95th percentile queue estimates, it is not possible to determine whether turn lane storage is adequate, whether ramp terminals could experience spillback, or whether signals may queue into adjacent intersections.” Planning Commission Comment Letter: Protect Our Valley Alliance 4 of 12 ---PAGE BREAK--- Given the proximity of Highway 214 ramp terminals and closely spaced signals, queue spillback is a critical safety issue. VII. Intersection Failures Are Identified but Not Mitigated The TIA acknowledges that multiple intersections will operate below mobility standards yet provides no enforceable mitigation. Instead, it relies on: ● Speculative future signal timing changes ● Assumed future signals not supported by warrant analysis ● Improvements not identified as funded capital projects The engineering review highlights the internal inconsistency: “It is unclear how ‘All study locations will operate within the identified performance standard’ while simultaneously acknowledging that ‘Three City of Woodburn intersections are projected to operate below the LOS threshold.’” WDO 3.04.05 requires that mitigation be identified, effective, and concurrent with development. The applicant has not met this requirement. WDO 3.04.05(C), VIII. No Traffic Signal Warrant Analysis Is Provided The MUTCD requires an engineering study demonstrating that a signal is justified under one or more warrants. The TIA provides no warrant worksheets, no crash analysis, and no supporting data. As the review states: “Without a warrant analysis, there is no evidence that signal installation is justified, appropriate, or feasible.” The City cannot rely on unsubstantiated assumptions about future signals to meet mobility standards. IX. Access Management Standards Are Not Met Planning Commission Comment Letter: Protect Our Valley Alliance 5 of 12 ---PAGE BREAK--- The proposed driveway on Evergreen Road is only 162 feet from the Evergreen/Oxford intersection, far short of the 245-foot minimum in WDO Table 3.04A. The engineering review notes: “Meeting the 245-foot separation standard appears feasible, yet the applicant is choosing not to meet it.” The TIA also proposes a mid-block RRFB crossing without any engineering study of spacing, warrants, or safety implications. X. Pipeline Development and School Adjustments Are Not Documented The TIA lists numerous nearby developments but provides no trip tables, no distribution assumptions, and no documentation of how these projects were incorporated. Similarly, the TIA applies school-related adjustment factors (2.0 AM and 1.1 PM) without providing the underlying data. The review states: “No supporting documentation is provided to verify the methodology… a reviewer cannot independently confirm that the factors are appropriate.” Without transparency, the City cannot verify the accuracy of background volumes. XI. Additional Community, Environmental, and Neighborhood Impacts Beyond the technical transportation deficiencies, the Alliance has identified several additional concerns that independently prevent approval. A. Emergency Access and Response Times Residents in nearby apartments and senior communities rely on rapid emergency response. Increased congestion can slow ambulances, fire response, and police access to: ● Cascade Meadow Apartments ● Silver Creek Senior Living ● Country Meadows Village Planning Commission Comment Letter: Protect Our Valley Alliance 6 of 12 ---PAGE BREAK--- ● Barclay Square Apartments ● Evergreen Estates The TIA does not evaluate: ● Emergency vehicle delay ● Queue spillback affecting access to residential driveways ● Impacts on senior housing and high-needs populations WDO 3.04.05(C) requires evaluation of impacts that “hinder public safety.” The applicant has not met this requirement. B. Noise, Light, and Late-Night Operations The proposed store will operate 24 hours, with continuous truck activity, refrigeration units, and parking-lot lighting. Residents report concerns about: ● Sleep disruption ● Vibration from truck unloading ● Light trespass into homes ● Increased nighttime noise The applicant has not submitted: ● A noise study ● A lighting photometric plan ● Any analysis of nighttime operations near residential uses C. Pedestrian and Senior Safety The project is adjacent to multiple senior and multifamily housing communities. More turning movements near driveways and parking lots increase the risk of accidents involving seniors, mobility-device users, and pedestrians. The TIA does not evaluate: ● Pedestrian crossing delay Planning Commission Comment Letter: Protect Our Valley Alliance 7 of 12 ---PAGE BREAK--- ● Senior mobility impacts ● Safe routes to transit ● Conflicts at the proposed RRFB These are required components of a complete transportation analysis. WDO 3.04.05(C) D. Neighborhood Compatibility and Residential Character The surrounding area is a quiet residential corridor. Big-box stores often bring increased traffic, noise, and late-night activity, which can reduce the appeal of nearby residential communities. The applicant has not demonstrated: ● That the scale and intensity of the use is compatible with adjacent housing ● That residential quality of life will not be degraded ● That the project meets Comprehensive Plan policies on neighborhood protection E. Impacts on Local Businesses and Economic Stability The Alliance is also concerned about economic displacement and the long-term viability of existing businesses. A new WinCo threatens the visibility, foot traffic, and long-term viability of Woodburn’s independent businesses. The applicant has not provided: ● An economic impact analysis ● A retail leakage study ● Any evidence that the project will not displace existing employers These impacts are relevant to Comprehensive Plan economic policies and to the City’s findings on public welfare. See Policy F-1.3 (discouraging strip development, and encouraging developments to constitute urban districts that allow one-stop dining, shopping, and recreation opportunities). Planning Commission Comment Letter: Protect Our Valley Alliance 8 of 12 ---PAGE BREAK--- The applicant also fails to demonstrate compliance with the “economic objectives found in the Comprehensive Plan,” which is required if the proposed project exceeds the maximum peak hour vehicle trips specified in Table 2.05A. WDO 2.05.02(G)(2). The record fails to adequately address this requirement. At most, the applicant quotes the City’s Economic Opportunity Analysis, which states that “land… for large commercial employers is very limited.” However, the fact that land for such commercial uses is limited, or that the applicant proposes to use some of that limited land for a commercial use, does not in and of itself address any “economic objectives” of the comprehensive plan. The sections of the Economic Opportunity Analysis (“EOA”) quoted by the applicant in the staff report identify a deficit of land available for commercial uses. Those deficits do not identify an economic objective, much less one that the applicant could meet. At best, the EOA identifies the need for more land for commercial uses. Yet the applicant’s project does create more commercially zoned land. Therefore, the applicant’s project does not address that specific need, much less demonstrate that the development “will contribute substantially to the economic objectives found in the Comprehensive Plan.” Moreover, the applicant fails to demonstrate how a project that merely uses commercially zoned land for a commercial purpose “will contribute substantially ” to any of the City’s economic objectives. Rather than identify an economic objective of the comprehensive plan or explain how the proposed project would substantially contribute to the City’s goal of meeting that objective, the applicant simply points to an identified need for more commercially zoned land. Although the City identified this need in its EOA, the City has made a clear policy choice to promote more important economic goals. As the applicant points out, the City’s recent 2025 UGB expansion the City made a policy choice not to expand the number of acres for commercial land (at least not in this region of the City). Instead, the City chose to expand the UGB for the purpose of increasing the amount of land zoned as part of the Southwest Industrial Reserve. The City’s comprehensive plan map and zoning map demonstrates that a large portion of this Urban Reserve Area and protected industrial land occurs south of the subject property on the east side of Interstate 5. Planning Commission Comment Letter: Protect Our Valley Alliance 9 of 12 ---PAGE BREAK--- In this case, the applicant’s proposal to exceed the maximum peak hour vehicle trip limit for this part of the City demonstrates that the project presents a direct conflict with the comprehensive plan’s economic objectives. Specifically, the project’s traffic will impair the City’s economic objective to maintain and preserve land and infrastructure for industrial uses. For that reason, the applicant fails to demonstrate compliance with WDO 2.05.02(G)(2). The Comprehensive Plan explains that maintaining industrial land and that land’s access to Interstate 5 “is critical to the economic development efforts of the City.” The City’s EOA and the City’s Economic Development Strategy “provide[s] the basis and policy direction for Woodburn’s economic development efforts.” Comp. Plan at 17. To that end, the comprehensive plan explains that industrial land “requires good transportation access, served preferably, but not necessarily, by both railroad and highway facilities.” Id. at 17-18. The comprehensive plan continues, explaining that “[r]eserving industrial sites with direct access to Interstate 5 is critical to the economic development efforts of the City.” Id. By increasing non-industrial traffic beyond the limit allowed by WDO 2.05.02, the applicant’s proposal fails to comply with the provisions of the WDO and the City’s comprehensive plan. The plan explains that “lands for high traffic generating uses (shopping centers, malls, restaurants, etc.) should be located on well improved arterials.” Policy F-1.2 The plan goes on to explain that such “uses should provide the necessary access management and traffic control devices needed to ameliorate their traffic impact on the arterial streets.” Id. The applicant admits that the proposal will make traffic worse, not better. Here, the applicant falls far short of meeting the threshold needed to show that its project would contribute substantially to the economic objectives outlined in the comprehensive plan. WDO 2.05.02(G)(2). Here, by exceeding the maximum peak hour vehicle trip limit, the applicant’s proposal would threaten rather than serve the City’s economic objective of maintaining direct access for industrial lands to Interstate 5. The applicant’s project would increase non-industrial traffic on the arterials that the newly reserved industrial land south of the subject property would ultimately use to access the highway. As part of its industrial lands policies, the City has identified numerous economic objectives. These include Policy E-1.8, which protects industrial lands Planning Commission Comment Letter: Protect Our Valley Alliance 10 of 12 ---PAGE BREAK--- “from encroachment by commercial or other uses that will either increase the price of industrial land or generate traffic that will interfere with normal industrial practices The Comprehensive Plan explains that the City’s objective in protecting industrial land includes attracting industries that “should generate jobs that would upgrade the skills of the local labor pool Policy E-1.9. The applicant’s proposal runs counter to both of those economic objectives. For that reason, the proposal violates WDO 2.05.02(G)(2). XII. Conclusion The record does not contain substantial evidence demonstrating that the proposed WinCo complies with the Woodburn Development Ordinance, the IMA Overlay District, or applicable transportation, environmental, and neighborhood standards. The TIA contains significant methodological errors, omits required analyses, and fails to identify enforceable mitigation. Additional concerns related to emergency access, noise, light, pedestrian safety, neighborhood compatibility, and economic displacement further prevent approval. Protect Our Valley Alliance respectfully requests that the Planning Commission: ● Deny the application , or ● Require the applicant to submit a corrected, complete TIA and additional studies , including: ● A full IMA trip-cap accounting ● Corrected trip generation and distribution ● Queueing and simulation analyses ● Signal warrant studies ● Documented pipeline development assumptions ● Access spacing compliance ● Noise and lighting studies ● Pedestrian and senior safety analysis ● Emergency access evaluation Planning Commission Comment Letter: Protect Our Valley Alliance 11 of 12 ---PAGE BREAK--- ● Identified, funded, and concurrent mitigation The Alliance appreciates the Commission’s careful review and its commitment to ensuring that development proceeds responsibly and in accordance with adopted standards. Respectfully, Andrew Mulkey (OSB No. 171237) PO Box 66562 Portland, OR 97290 (503) 334-9989 [EMAIL REDACTED] On behalf of Protect Our Valley Alliance Attachments: Exhibit A — Greenlight Engineering Review of TIA Planning Commission Comment Letter: Protect Our Valley Alliance 12 of 12 ---PAGE BREAK--- Protect Our Valley Alliance Exhibit A Greenlight Engineering Review of TIA ---PAGE BREAK--- 13554 Rogers Road ● Lake Oswego, OR 97035 www.greenlightengineering.com ● [PHONE REDACTED] March 12, 2026 City of Woodburn Planning Commission 270 Montgomery St Woodburn, OR 97071 RE: Transportation Impacts of Proposed WinCo Planning Commissioners: Greenlight Engineering was retained by Protect Our Valley Alliance to conduct a technical review of the proposed WinCo Foods development and associated land use application. This review evaluated the Traffic Impact Analysis (TIA), revised January 21, 2026, the Design Review Project Narrative, submitted site plans, the City of Woodburn staff report, and supporting materials in the public record. The purpose of this review is to evaluate whether the methods, assumptions, and conclusions of the TIA comply with the Woodburn Development Ordinance (WDO), the Interchange Management Area (IMA) Overlay District requirements, the Woodburn Comprehensive Plan, applicable ODOT requirements, and generally accepted traffic engineering practice. Based on this review, the current record does not demonstrate that the proposed development complies with applicable transportation standards or that the project’s transportation impacts have been adequately identified or mitigated. The analysis supporting the application contains significant analytical omissions, unsupported assumptions, and inconsistencies with prior traffic studies prepared for nearby developments. Because transportation impacts form a central component of the City’s development review framework, particularly within the IMA Overlay District, the deficiencies identified in the TIA prevent the City from making defensible findings that the proposal complies with adopted standards or that required mitigation has been adequately identified. ---PAGE BREAK--- 2 Executive Summary This review identifies several fundamental deficiencies in the TIA and the supporting record: Intersection failures are identified but not mitigated Multiple intersections are projected to operate below adopted mobility standards under both opening-year and future conditions. In previous applications, two intersections were identified to fail ODOT mobility standards. However, this TIA illustrates those intersections to now to operate adequately without apparent improvements. Where the TIA identifies intersection failures, the TIA does not demonstrate that improvements are funded, or provide operational modeling showing that proposed improvements would restore acceptable operations. Instead, the analysis relies on speculative future signal installations and corridor signal timing adjustments that are not supported by engineering analysis, funding commitments, or traffic signal warrant studies. Project impacts are materially understated Several methodological issues result in an understatement of project traffic and operational impacts. These include the improper application of pass-by trip reductions on Highway 214, the omission of study intersections that should have been included, the use of an incorrect opening year, and the absence of 95th percentile queue analysis. Because trip generation and distribution form the foundation for all operational modeling, these errors propagate throughout the analysis and materially affect the reported intersection performance. Compliance with the Interchange Management Area (IMA) trip cap is not demonstrated. The site is located within the Interchange Management Area Overlay District, which establishes a cumulative PM peak hour trip budget intended to preserve the operational integrity of the I-5 interchange and surrounding arterial network. The TIA does not provide a clear accounting of remaining trip capacity within Subarea K or demonstrate how the project’s forecast PM peak hour trips compare to the available allocation. Moreover, the project’s trip generation appears to substantially exceed the parcel’s allocated trip budget. Additionally, the TIA relies on improper pass-by trip assumptions that artificially reduce the reported trip impact in the IMA. Without a transparent accounting of remaining trip capacity and a quantitative comparison to project demand, the City cannot determine whether the proposal complies with WDO 2.05 or whether an exception to the trip cap is justified. ---PAGE BREAK--- 3 Important engineering analyses is missing Several analyses typically required in transportation impact studies are absent from the TIA, including 95th percentile queue analysis and transparent documentation of how approved pipeline developments were incorporated into the forecast traffic volumes. Without these elements, the City and the public cannot independently verify the study’s assumptions or conclusions. These deficiencies are not minor technical disagreements. They affect foundational elements of the transportation analysis. Because trip generation and distribution drive all subsequent modeling of intersection operations, queuing, and mobility compliance, unsupported assumptions at the front end of the analysis undermine the reliability of the entire study. Until these issues are addressed, the City cannot make defensible findings that: • The proposal complies with the IMA Overlay District trip budgeting framework; • Adopted mobility standards will be met; or • Required mitigation measures are identified, feasible, and concurrent with development. For these reasons, approval of the application in its current form is not supported by substantial evidence in the record. TIS Results Discrepancies and Requirements Interestingly, a recent TIA prepared for the Specht Industrial Development application, which predates the WinCo TIA, illustrated that the intersections of Highway 214/Evergreen Road and Highway 214/Boones Ferry/Settlemier Road exceed the ODOT mobility standard. However, the subsequent WinCo TIA indicates there are not near-term congestion issues at the intersections even though it does not appear improvements are planned or constructed. Supposedly, the WinCo incorporates the Specht Industrial impacts, but the traffic studies present very different results. Table 10 of the WinCo TIA reports that the intersections of Highway 214/Evergreen Road and Highway 214/Oregon Way Settlemier Road) will both operate with volume-to- capacity (v/c) ratios of 0.94 with the development in place. These values are both just 0.01 below the ODOT mobility standard of 0.95. Table 10 also shows that without the proposed project, the Evergreen intersection would operate at a v/c ratio of 0.84 and the Settlemier intersection at 0.89. These baseline conditions already include the traffic associated with the Specht Industrial Development, yet the intersection operations in the WinCo TIA are significantly better than the Specht TIA despite no planned or constructed improvements that improve operations. ---PAGE BREAK--- 4 The TIA prepared for the Specht Industrial Development in 2022 concluded that, with that development in place, the intersection of Highway 214/Evergreen Road would operate at a v/c ratio of 0.93 and the intersection of Highway 214/Settlemier/Boones Ferry Road would operate at a v/c ratio of 0.97, well above the ODOT mobility standard. In other words, the Specht TIA projected failing conditions at one of these intersections, whereas the WinCo TIA reports substantially lower v/c ratios and compliant operations. Excerpt of Specht Industrial Development TIA These analyses therefore report significantly different capacity outcomes for the same intersections under similar development assumptions. The basis for these differences is unclear from the materials provided and warrants clarification. It is notable that the Specht Industrial Development TIA recommended that the project provide proportionate-share contributions at several intersections based on PM peak- hour volumes, including: • 0.99% at OR 214/Settlemier • 0.28% at OR 214/Highway 99E • 4.19% at Evergreen Road/Hayes Street That TIA further noted that the City has commonly collected proportionate-share or mitigation fees from developments to address corridor capacity issues and recommended that the Specht project contribute similarly. It is unclear whether these deficiencies still exist. Similar inconsistencies appear in other referenced studies. For example, Table 8 of the Brighton Pointe Subdivision TIA (also referenced in the WinCo TIA) projected that the Highway 214/Settlemier intersection would operate above the ODOT mobility standard at a v/c ratio of 0.96, while the Highway 214/Evergreen intersection was projected to operate at 0.93. In contrast, the WinCo TIA establishes baseline operations at both ---PAGE BREAK--- 5 intersections below 0.90 v/c, substantially lower than the values projected in earlier studies. Excerpt of Brighton Pointe TIA (2022) The Smith Creek Subdivision TIA likewise identified operational deficiencies at the Highway 214/Settlemier intersection. Excerpt of Smith Creek Subdivision TIA (2018) All of these reports can be reviewed here: Projects. Accordingly, the record indicates that the City of Woodburn has previously been notified several times of capacity issues at these intersections, yet the current TIA identifies no capacity issues at these intersections in the near term. The WinCo TIA does not explain whether any improvements have been implemented with those funds or how previously identified deficiencies have been resolved. Nevertheless, years later, and with substantially more development proposed or underway, the intersections are now reported to operate within acceptable mobility standards. This apparent discrepancy should be clarified, and a consistent analytical approach between applications should be ensured. ---PAGE BREAK--- 6 In addition to these discrepancies, the WinCo TIA omits critical analysis that was included in prior studies such as the Specht Industrial TIA, Brighton Point TIA, and Hermanson Preserve TIA. Most notably, the WinCo TIA provides no estimate of intersection or corridor queuing. Queue analysis is a common requirement in ODOT traffic impact analyses because, without it, it is not possible to determine whether vehicle queues can be accommodated within available storage or whether they may spill back and affect upstream intersections. The absence of queue analysis is particularly unusual given that this corridor is approaching or at the ODOT mobility threshold. Additional discussion of this item is provided herein under “Queuing Analysis and Simulation Is Absent”. Highway 214/Evergreen Intersection ODOT Concerns ODOT’s February 6, 2026 letter states: “No mitigation measures to any state facility have been proposed. However, the study shows the development impacting the OR 214 at Evergreen Road intersection, projecting the intersection operating above mobility target in the future PM peak hour condition. Region 2 Traffic recommends mitigation at the intersection by signalizing the eastbound and northbound right-turn lanes which are currently yield and stop controlled, respectively… No further analysis work should be required. However, ODOT recommends mitigation measures, as noted above in comment to mitigate traffic effects of the proposed development. Additional work may be required to accompany approval requests for proposed mitigation measures (i.e. preliminary design layout, preliminary signal operations design, etc.). In contrast, the staff report states: ODOT provided comments to the City and applicant on the TIA, which was been revised to their satisfaction. Based on the ODOT approved TIA, no additional traffic mitigations were warranted. Although ODOT agreed that no additional traffic mitigations were warranted for the applicant's current proposal, they nevertheless offered recommendations for potential improvements to address future (2040) issues at the intersection for 214 and Evergreen. Specifically, ODOT recommended adding signals at the eastbound (from Evergreen) and southbound (from 214) movements. These mitigations would not be directly attributable to the applicant's proposal, which, as noted above, meets ODOT standards. Additionally, because the recommended mitigations address future (2040) issues, it is not possible to proportionally allocate a share of these future mitigations to the applicant's current proposal...” ODOT’s letter clearly states that the analysis shows the development affecting operations at the Highway 214/Evergreen Road intersection and recommends mitigation in the form of signalizing specific movements. The City’s staff report, however, characterizes ODOT’s opinion as indicating that no mitigation is warranted. ---PAGE BREAK--- 7 These interpretations conflict. ODOT identifies an operational deficiency associated with the development and recommends mitigation, while the staff report concludes that the recommended improvements are unrelated to the applicant’s proposal and therefore need not be addressed. The record does not provide a clear explanation reconciling these differing interpretations or explaining why mitigation recommended by ODOT cannot be proportionally attributed to the project. As discussed earlier in this review, multiple prior traffic studies have already identified operational deficiencies along the Highway 214 corridor, including at the Evergreen Road and Settlemier/Boones Ferry Road intersections. The WinCo development is projected to add traffic to this corridor, yet the application does not include any mitigation for impacts to these state highway intersections. Given the documented congestion conditions and the recommendations provided by ODOT, the absence of identified mitigation for project impacts to Highway 214 raises significant questions regarding whether the proposal satisfies applicable transportation performance standards. Interchange Management Area (IMA) Trip Cap Compliance The subject property is located within the Interchange Management Area (IMA) Overlay District (WDO 2.05), which establishes a cumulative PM peak hour trip budget intended to preserve the long-term operational integrity of the I-5 interchange and the surrounding arterial network. Compliance with the PM peak hour trip cap is mandatory. Exceedance is permitted only if a development “contributes substantially to the economic objectives found in the Comprehensive Plan,” and only after the City makes explicit policy findings supporting such an exception. This exception is not automatic. It is a discretionary mechanism that must be supported by substantial evidence and reasoned findings demonstrating that overriding economic objectives justify additional transportation demand within a capacity-constrained system. The proposed WinCo development would consume, and substantially exceed, whatever remaining capacity exists within Subarea K. As a result, it would constrain or preclude other properties within the subarea from developing under the adopted trip allocation and would shift the burden onto future applicants to demonstrate extraordinary economic justification for additional exceptions. In practical terms, approval would allocate more than Subarea K’s limited transportation capacity to a single use, thereby undermining the cumulative trip-budgeting framework established by the overlay district and impact the ability of other developments in other areas from developing. At the very least, ignoring the adopted cap will burden the interchange and transportation network. Although the Traffic Impact Analysis (TIA) references the IMA overlay, it omits critical information necessary to evaluate compliance. Specifically, the report does not identify the parcel’s remaining PM peak hour trip allocation or provide a comparison between the project’s forecast PM peak hour trips and the remaining allocation. No accounting is provided demonstrating ---PAGE BREAK--- 8 whether the 429 PM peak hour trip allocation identified in Table 2.05A has already been partially consumed by prior development approvals. The TIA also fails to address the policy implications of approving a high trip-generating development that could preclude other future development within the subarea due to exhaustion of the trip cap. The City staff report states: “The proposed development is expected to generate 511 new peak hour trips and encumbers two lots. Pursuant to Table 2.05A, these two lots have a maximum peak ‘allocation’ of 429 peak hour trips. Pursuant to 2.05.02(G)(2)(a), a development may exceed the allocated parcel budget if the development will contribute substantially to the economic objectives found in the Comprehensive Plan.” The TIA assumes a reduction of 161 pass-by trips to the total 672 trips generated by the WinCo, as shown in Table 5 of the TIA. As discussed in the section of this report titled “Pass-By Trip Assumptions Are Inappropriate,” these pass-by trips were not properly accounted for as pass-by trips were applied to Highway 214. Pass-by trips cannot be applied to Highway 214 by definition. Correcting this error, and applying the methodology used in Figure 7 of the TIA, results in a revised estimated 672 PM peak hour trips, rather than the 511 trips reported in the staff report. Table 5 of the TIA The site has a maximum peak hour vehicle trip budget of 429 trips under Table 2.05A of the WDO. The TIA notes that “pursuant to WDO section 2.05.02(G)(2)(a), development may exceed the identified Parcel Budget.” However, this is not merely a theoretical possibility. Table 5 demonstrates that the WinCo store alone would generate approximately 672 weekday PM peak hour trips, substantially exceeding the 429-trip allocation for Subarea K, while land within the subarea remains available for future development but without any corresponding IMA capacity and eroding the capacity for the entire IMA. Because the IMA overlay functions primarily as a transportation capacity preservation mechanism, the failure to provide a quantitative comparison between the project’s trip generation and the remaining trip allocation represents a substantive deficiency in the TIA. In ---PAGE BREAK--- 9 addition, both the City and the applicant have miscalculated the project’s trip generation by improperly accounting for pass-by trips, which understates the project’s actual PM peak hour trip generation. Without an accurate trip calculation and a clear accounting of the remaining trip capacity within Subarea K, the City cannot meaningfully evaluate how the proposed development affects the cumulative trip budget established under WDO 2.05. As a result, the record does not provide a sufficient basis for defensible findings that the proposal complies with WDO 2.05 or that an exception to the trip cap is warranted consistent with the Comprehensive Plan’s transportation policies and adopted system management framework. Pass-By Trip Assumptions Are Inappropriate The TIA applies pass-by trip credits at the Highway 214/Evergreen Road intersection where such credits are not permissible under accepted traffic engineering methodology. Figure 7 of the TIA incorrectly assigns 80 pass-by trips at the intersection, when by definition there can be zero pass- by trips on Highway 214 associated with this development. Figure 7 from the TIA Illustrating Where Pass-By Trips Were Applied The TIA correctly defines “Pass-by trips are trips made as an intermediate stop from an origin to a primary destination stopping to shop on the way home from work) by vehicles passing directly by the project driveway.” ---PAGE BREAK--- 10 According to the Institute of Transportation Engineers (ITE) Trip Generation Handbook, “A pass- by trip is made as an intermediate stop on the way from an origin to a primary trip destination without a route diversion. Pass-by trips are attracted from traffic passing the site on an adjacent street or roadway that offers direct access to the generator. Pass-by trips are not diverted from another roadway not adjacent to the site.” The method in which pass-by trips were estimated in the TIA is what the Trip Generation Handbook cautions against. This definition is clear and restrictive. Pass-by trips must originate from traffic already traveling on a roadway adjacent to the site and access the site directly without diverting from another roadway. Table 10 of the TIA establishes that with the project, the volume to capacity (v/c) ratio of this intersection will be 0.94. With the pass-by trip error, the TIA incorrectly reports the projected traffic volume at the intersection. A higher traffic volume may result in a different v/c at the intersection that may push against ODOT’s adopted mobility standard. And as noted previously, previous analysis found this intersection operating above the mobility standard. It appears the TIA is conflating diverted trips with pass-by trips, but the two are not interchangeable. The Trip Generation Handbook defines a diverted trip as: “A diverted trip is attracted from the traffic volume on roadways within the vicinity of the generator but without direct access to the site. A diverted trip requires a diversion from a roadway not adjacent to the site to another roadway to gain direct access to the site. A diverted trip adds traffic to streets adjacent to a site and could remove a trip on streets from which it diverted.” ITE further cautions: “Diverted trips are often difficult to identify. Consequently, diverted trips should be estimated in a traffic impact study only if • Reliable data reporting the percentage distribution of the three types of trips (primary, pass-by, and diverted trips) are available for the land use(s) being considered; and • The travel routes for diverted trips can be clearly established.” The TIA does not provide reliable empirical data establishing the percentage of diverted trips, nor does it clearly establish the travel routes of such trips. Instead, it attempts to apply pass-by trip reductions in circumstances that meet the ITE definition of diverted trips, not pass-by trips. Pass- by estimates cannot be used as a proxy for diverted trips, as has been done here. Because trip generation forms the foundation for all subsequent capacity, queuing, and v/c ratio modeling, improper application of pass-by credits propagates throughout the entire analysis. The result is an understatement of projected traffic volumes at a critical study intersection and a corresponding overstatement of operational performance. In order to provide an accurate traffic analysis, elements of the traffic analysis will need to be redone. ---PAGE BREAK--- 11 TIA Opening Year Is Not Accurate The TIA models a 2026 opening year, while the Design Review Project Narrative states that the store will not open until mid to late 2027. This discrepancy directly affects background traffic volumes, applied growth rates, and cumulative impact assumptions, resulting in an inconsistent analysis. The study year must align with the reasonably anticipated opening year in order to produce defensible operational conclusions. Even a one-year difference can meaningfully affect intersection performance particularly at locations already operating near capacity if assumed growth rates approach the 0.5% maximum. At near-capacity intersections, relatively small increases in background volume can shift level of service and increase v/c ratios. By modeling an earlier opening year than what is represented in the applicant’s own narrative, the TIA has understated actual opening-year conditions and associated impacts. As previously established, the Highway 214/Evergreen and Highway 214/Boones Ferry/Settlemier intersections are either over the mobility standard or very close to it. Intersection Failures Are Identified but Not Mitigated or Substantiated The TIA identifies multiple intersections projected to fail City mobility standards, yet it does not propose specific mitigation measures, evaluate feasible improvements, or demonstrate that any referenced improvements are funded or effective. The TIA states: “Based on the analysis described in this report, the following key findings have been identified: … • All study locations will operate within the identified performance standard for the 2026 opening year, after completion of the project. • Two ODOT intersections are projected to operate below the LOS threshold during the 2040 PM peak hour: Highway 214 at Evergreen Road and Highway 214 at Boones Ferry Road… • Three City of Woodburn intersections are projected to operate below the LOS threshold during the 2026 opening year: Stacy Allison Way at Evergreen Road, Hayes Street at Evergreen Road, and Harvard Drive at Evergreen Road…” These statements are internally inconsistent. It is unclear how “All study locations will operate within the identified performance standard for the 2026 opening year” while simultaneously acknowledging that “Three City of Woodburn intersections are projected to operate below the LOS threshold during the 2026 opening year.” ---PAGE BREAK--- 12 Highway 214 Intersections: Speculative Timing Adjustments Regarding deficiencies along Highway 214, the TIA relies on corridor signal timing adjustments identified as Project R10 in the City’s TSP. The TIA states “Preliminary analysis suggests that with a longer cycle length this location would operate within the LOS standard.” However: • There is no evidence that the signal timing project is funded. • No corridor-level operational modeling is provided. • No documentation is included demonstrating that longer cycle would achieve compliance. • No evaluation is provided of trade-offs increased delay or queue spillback at adjacent signals). It is acknowledged in the TIA that “the entire corridor should be analyzed.” That analysis is not provided in the TIA. Signal timing changes that improve one intersection can degrade operations at another, particularly on coordinated corridors. Without modeling evidence, there is not substantial evidence that Highway 214 /Evergreen Road or Highway 214 /Boones Ferry Road will operate adequately. City Intersections: Assumed Future Signals Without Evidence Regarding the failing intersections of “Stacy Allison Way at Evergreen Road, Hayes Street at Evergreen Road, and Harvard Drive at Evergreen Road”, the TIA states: “An analysis of traffic signal control at each location indicates that each will operate within the identified performance standard with the improvement.” The City staff report states: “The City had identified these projects in the recently adopted TSP for updates and the engineering work has already begun on designing new signal improvements at Stacy Allison/Evergreen and Hayes and Evergreen. Harvard/Evergreen is being designed with roundabout. Construction on these important public projects is expected to be underway later this year. The TIA includes an analysis of these intersections after these improvements are completed (and the store is open) and it indicates that all three will operate within the mobility standards.” However, no such analysis is provided in the TIA. There are no signalized intersection models, no phasing assumptions, no timing parameters, and no documentation of operational results with signals in place. Additionally, it is unclear whether these improvements are fully funded. No Traffic Signal Warrant Analysis The TIA also fails to provide any traffic signal warrant analysis. ---PAGE BREAK--- 13 The Manual on Uniform Traffic Control Devices (MUTCD) requires “An engineering study of traffic conditions, pedestrian characteristics, and physical characteristics of the location shall be performed to determine whether installation of a traffic control signal is justified at a particular location.” The MUTCD further requires evaluation under the following warrants: • Warrant 1 — Eight-Hour Vehicular Volume • Warrant 2 — Four-Hour Vehicular Volume • Warrant 3 — Peak Hour • Warrant 4 — Pedestrian Volume • Warrant 5 — School Crossing • Warrant 6 — Coordinated Signal System • Warrant 7 — Crash Experience • Warrant 8 — Roadway Network • Warrant 9 — Intersection Near a Grade Crossing No warrant worksheets, traffic counts, crash evaluations, or engineering study findings are provided. Without a warrant analysis, there is no evidence that signal installation is justified, appropriate, or feasible. Driveway Access to Evergreen Road The TIA states: “According to the access requirements identified within the WDO Table 3.04A, Evergreen Road, which is a minor arterial, has a minimum driveway separation of 245 feet. The proposed driveway location provides more than 245 feet to the north (Stacy Allison Way). To the south, it provides approximately 162 feet measured from edge to edge. The project will work with City staff to provide the necessary variance documentation for the proposed driveway location.” Note 1 of Table 3.04A specifies that for corner clearance and driveway spacing, “the separation should be maximized.” Meeting the 245-foot separation standard appears feasible and it is unclear why the standard cannot be met. The applicant’s narrative states that “Per City staff the 245-foot separation… is a guideline rather than a required standard.” The City staff report similarly states, “The 245-foot separation shown in Table 3.04A is a guideline rather than a required standard. Staff can support this driveway location.” This conclusion conflicts with the WDO section title, 3.04.03 Access Management: Driveway Guidelines and Standards, and with the title of Table 3.04A as “Access Requirements”, with the table title quite clear that access spacing is a standard rather than a discretionary guideline. Regardless of interpretation, the spacing standard could reasonably be met in this case, yet the applicant has chosen not to meet it. ---PAGE BREAK--- 14 WDO Section 5.03.12 establishes the criteria for granting a variance and states: “A variance may be granted to allow a deviation from a development standard of this ordinance where the following criteria are met… Strict adherence to the standards of this ordinance is not possible or imposes an excessive burden on the property owner…” It does not appear that the City has processed this deviation from the code through the variance procedures required by the WDO and it is unclear why. In addressing this criterion, the applicant’s checklist states: “The Applicant is proposing this driveway location to allow easier (less circuitous) vehicle access into the site as well as more direct fire access to the building Fire Department Connection (FDC) that is on the southwest side of the building…” There is no evidence that the Fire District has requested this deviation. Neither the applicant’s narrative nor the City staff report demonstrates that the access spacing standard cannot be met or that compliance would impose an excessive burden on the property owner. Rather, the minimal justification provided reflects a preference for a more convenient driveway location. The purpose of access spacing standards is safety. Convenience alone does not appear to satisfy the variance criteria established in WDO 5.03.12. RRFB and Proximity to Evergreen Driveway The site plan shows a proposed “Mid-Block Crossing with RRFB @ Intersection of Oxford St. & Evergreen Rd.” An RRFB (Rectangular Rapid Flashing Beacon) is intended to enhance pedestrian safety at uncontrolled crossings by providing a high-visibility, active warning to motorists. It is unclear whether the crossing would be mid-block or at the Oxford Street intersection. In either case, its proximity to the proposed driveway may affect RRFB operations, which should be studied to ensure there are not conflicts. The TIA notes that “…WinCo will be installing RFFB’s (or similar) at an existing crosswalk on Evergreen Road to provide a safe crossing of Evergreen Road to/from the project site and the existing residential properties to the east.” However, no similar treatment nor marked crosswalk is evaluated or proposed at Evergreen Road/Center Street, which would provide a more direct pedestrian connection from the northeast. The TIA does not evaluate whether the proposed crossing location, treatment type, or spacing from adjacent intersections is appropriate. On pedestrian hybrid beacons (including the Manual on Uniform Traffic Control Devices states: ---PAGE BREAK--- 15 “A pedestrian hybrid beacon may be considered for installation to facilitate pedestrian crossings at a location that does not meet traffic signal warrants (see Chapter 4C), or at a location that meets traffic signal warrants under Sections 4C.05 and/or 4C.06 but a decision is made to not install a traffic control signal… If a traffic control signal is not justified under the signal warrants of Chapter 4C and if gaps in traffic are not adequate to permit pedestrians to cross, or if the speed for vehicles approaching on the major street is too high to permit pedestrians to cross, or if pedestrian delay is excessive, the need for a pedestrian hybrid beacon should be considered on the basis of an engineering study that considers major- street volumes, speeds, widths, and gaps in conjunction with pedestrian volumes, walking speeds, and delay.” The TIA provides no evidence of traffic signal warrants or any study of the proposed pedestrian crossing location. Without such an analysis, it is not possible to determine whether the proposed crossing adequately addresses pedestrian safety or operational concerns. Approved Developments Not Clearly Accounted For The TIA states: “In addition to the background traffic growth, the following pipeline development projects have been identified near the study area and have been included in the forecast: • Allison Way Apartments (Phases 1 & 2) • Specht Industrial Development • Brighton Pointe Subdivision (Phases 1 & 2) • 9008 Parr Rd Subdivision (assumed 75% complete) • Smith Creek Development (assumed 75% complete) • Unitus Community Credit Union • US Market Gas Station (Newberg Hwy location) • Mill Creek Meadows subdivision • Mill Creek Meadows II subdivision • Dove Landing subdivision (assumed 50% complete) • Marion Pointe subdivision (assumed 50% complete) • Commerce Way Industrial Park • Boones Crossing Townhouses • Parr Rd Cottages” However, the TIA does not provide sufficient detail to verify how these developments were incorporated into the analysis. No information is provided regarding land use type, size, approved trip generation, assumed build-out year, trip distribution, or the methodology used to determine partial completion percentages 50% or 75%). There ---PAGE BREAK--- 16 are no trip tables, volume adjustments, or modeling summaries that isolate the contribution of each development. Without this documentation, a reviewer cannot confirm whether the correct trip generation rates were used, whether the assumed completion percentages are accurate, or whether traffic was distributed logically within the network. The absence of this supporting data prevents independent verification and limits the transparency and reproducibility of the forecast assumptions. Intersection Study Area Incomplete The TIA omits at the intersection of Evergreen Road/Center Street which could reasonably be expected to receive project-generated traffic based on logical distribution patterns and existing roadway connectivity. A defensible traffic study area should encompass all intersections where project traffic is reasonably anticipated to cause measurable operational change. Queuing Analysis and Simulation Is Absent As noted previously, the TIA does not evaluate vehicle queuing at study despite other similar traffic studies in the area having included that analysis. This omission is particularly significant given the documented congestion on Highway 214 and the proximity of ramp terminals, and closely spaced intersections. Capacity metrics such as v/c ratio or level of service alone do not capture 95th percentile queues, spillback probability, blocked intersections, or the potential to impede upstream intersections. These operational effects are often the primary concern at facilities operating near capacity. The ODOT Analysis Procedures Manual (APM) states that “Simulation to determine queues or other measures of effectiveness should be used if v/c’s exceed 0.70 and simulation shall be used if v/c’s are equal to or exceed 0.90. Simulation shall also be used if existing conditions show congested conditions, (i.e. intersection queuing backs into adjacent intersections/connections) or if Agency requires it.” The Highway 214 corridor certainly has several intersections that fall into this category. Similarly, the ODOT Development Review Guidelines (DRG) states: “Intersection operations analysis needs to include the effects of queuing and blocking… If traffic from the proposed development adds to or creates an overflowing storage lane and/or spills back into another intersection or rail crossing, the TIA should explore whether there are potential mitigation measures to fix overflow or spillback problems. The same goes for storage blocking queues. In cases where a TIA includes a queue analysis for an Interstate or Expressway ---PAGE BREAK--- 17 offramp, vehicles should have enough stopping sight distance (determined from the recent AASHTO A Policy on Geometric Design of Highways and Streets) to decelerate from the beginning of the off-ramp to stop at the end of the 95th- percentile queue. If the total traffic does not allow reasonable stopping sight distance, the TIA should state what if any mitigation measure(s) would reduce the queue on the off-ramp.” Along corridors such as Highway 214 where signal spacing, ramp proximity, and high peak-hour demand are present, queue spillback can materially degrade system performance even if average delay metrics appear acceptable. Without 95th percentile queue estimates, it is not possible to determine whether turn lane storage is adequate, whether ramp terminals could experience spillback, or whether signals may queue into adjacent intersections. Failure to estimate and compare projected queues to available storage is therefore a substantial analytical omission. Because queuing directly affects safety, access management, and interchange performance, its absence materially limits the City’s ability to assess compliance with ODOT operational standards and adopted system management policies. Conclusion Based on this review, the Transportation Impact Analysis does not provide substantial evidence that the proposed development complies with the Woodburn Development Ordinance, the Interchange Management Area (IMA) Overlay requirements, or applicable ODOT transportation analysis requirements. The record, as currently constituted, contains material analytical gaps, internal inconsistencies, and unsupported assumptions that prevent the City from making defensible findings of compliance. The deficiencies identified in this review are not minor technical issues. They affect foundational components of the transportation analysis, including trip generation, trip distribution, study area definition, queuing evaluation, safety analysis, mitigation feasibility, and IMA trip cap compliance. Because trip generation and distribution form the basis for all subsequent operational modeling, errors or unsupported assumptions in these areas propagate throughout the analysis and undermine the reliability of the study’s conclusions. Specifically: • Previous traffic analysis illustrates that the Highway 214/Evergreen and Highway 214/Boones Ferry/Settlemier failed to meet ODOT mobility standards with no evidence that these intersections have been mitigated. The WinCo TIA illustrates no near-term issues. • Multiple intersections are projected to fail mobility standards without identified, funded, or technically supported mitigation. • The application does not demonstrate compliance with the Subarea K PM peak hour trip allocation or provide sufficient accounting to support an exception under WDO 2.05. ---PAGE BREAK--- 18 • Pass-by trip credits are applied inappropriately, materially understating net new traffic on Highway 214 and for the project as a whole. • The opening-year analysis does not align with the applicant’s stated construction timeline. • No analysis, including traffic signal warrant analysis, is provided to justify assumed signalization. • Safety, pedestrian crossing, and access management issues are not evaluated. • Adjustments to background traffic and pipeline development assumptions are not documented in a manner that allows independent verification. Under WDO 3.04.05, where a development would fail to meet a transportation performance standard or could hinder public safety, mitigation must be clearly identified and demonstrated to be effective and concurrent with development. The current TIA instead relies on speculative future improvements, unverified signal timing adjustments and fails to consider previous results that illustrated failed intersections. These elements do not provide the evidentiary basis necessary for the City to conclude that transportation impacts have been adequately mitigated. Until these deficiencies are corrected, the City cannot make defensible findings that: • The proposal complies with the IMA Overlay District trip budgeting framework; • Adopted mobility standards will be met; or • Required mitigation is identified, feasible, and concurrent with development. For these reasons, approval of the application in its current form is not supported by substantial evidence in the record. Sincerely, Rick Nys, P.E. Principal Traffic Engineer Rick Nys Digitally signed by Rick Nys Date: 2026.03.09 21:11:58 -07'00' ---PAGE BREAK--- Outlook Fw: We want WinCo!! From Chris Kerr <[EMAIL REDACTED]> Date Thu 3/12/2026 11:28 AM To [EMAIL REDACTED] <[EMAIL REDACTED]> Cc Fernando Torres <[EMAIL REDACTED]> Thanks - I'll enter this into the record and get it to Planning Commissioners before the meeting tonight. If you provide your address, I can provide you with notices of other hearings on this item as well. CK From: Andria Young <[EMAIL REDACTED]> Sent: Thursday, March 12, 2026 11:21 AM To: Chris Kerr <[EMAIL REDACTED]> Subject: We want WinCo!! This email is from an EXTERNAL sender. Exercise caution when opening attachments or click links from unknown senders or unexpected email. I have seen a group on Facebook who is trying to stir up opposition to WinCo building a store off of Evergreen in Woodburn. I am writing to express my SUPPORT OF WINCO moving into this space! WinCo is an excellent store, with great selection and prices. Something everyone in Woodburn could use. Walmart has little by little been taking out their competition by removing brands that they sell and replacing them with lower quality Walmart products. And Safeway is simply too expensive. Winco would be a very welcome addition, and the land they are proposing to build on is the perfect location for it. Please bring WinCo to Woodburn! Sincerely, Andria Young ---PAGE BREAK--- Outlook Re: WinCo Concerns from Silver Creek Residents From Chris Kerr <[EMAIL REDACTED]> Date Thu 3/12/2026 11:15 AM To Carla Arriaga Perez <[EMAIL REDACTED]> Cc Fernando Torres <[EMAIL REDACTED]> Thanks - I'll provide your comments to the Planning Commissioners before the hearing tonight. CK From: Carla Arriaga Perez <[EMAIL REDACTED]> Sent: Thursday, March 12, 2026 10:46 AM To: Chris Kerr <[EMAIL REDACTED]> Subject: WinCo Concerns from Silver Creek Residents This email is from an EXTERNAL sender. Exercise caution when opening attachments or click links from unknown senders or unexpected email. Hello! our residents got together and spoke about the New WinCo, and these were their concerns/comments Winco hearing flier: Talked about what comments and concerns the residents wanted addressed. The main concern was the location due to the additional traffic on Evergreen and Stacey Allison Way. Most liked the idea about having the Winco store in Woodburn but not the location would like to see the store where other retailers are. Carla Arriaga I Life Enrichment Director 703 Evergreen Road I Woodburn, Oregon 97071 O: [PHONE REDACTED] I F: [PHONE REDACTED] Guided by Goodness, Loyalty, Faith, and Fun ---PAGE BREAK--- Oregon Tina Kotek, Governor March 12, 2026 Chris Kerr, Director Woodburn Community Development Department 270 Montgomery Street Woodburn, Oregon 97071 Dear Chris, This letter is in response to a public hearing notice received by ODOT Development Review staff, Brion Scott, via the US Postal Service for a WinCo supermarket with access taken from Center Street and Stacy Allison Way. Comments concerning transportation impacts related to the WinCo development proposal were provided by Brion in February 2026 (Attached). This correspondence ties those comments to overall transportation planning considerations in the identified interchange management area (IMA) for Woodburn. Mitigation measures addressing transportation impacts at the intersection of Evergreen Road and OR214 were recommended in Brion’s comment letter to protect the safety and operations of local state highways. Those recommendations have not been reflected in the conditions of approval found in a March 5th 2026, staff report articulating the Winco proposal. ODOT requests that the mitigation measures detailed in the attached comment letter be included in the conditions of approval to protect the safety and operations of local state highways. The proposed WinCo development applies to a parcel within the IMA (see Table 2.05A in the currently adopted WDO). As you are aware, local ordinance provisions implementing the Woodburn Interchange Area Management Plan (IAMP), and governing the IMA, are the mechanism that assures compliance with Transportation Planning Rule (TPR) provisions addressing highway capacity, particularly where development proposals could significantly affect highway operations. A significant effect determination (per OAR [PHONE REDACTED]) is triggered when planned traffic generation, measured by volume to capacity exceeds the mobility target for a facility identified in the Oregon Highway Plan. ODOT also recommends the City and ODOT work together to update and amend the local IAMP. An amendment to the IAMP could focus on the peak hour vehicle trips and could be expedited via a refinement or update to the established IAMP process. Amending the Woodburn IAMP to address current capacity issues would be in the best interest of ODOT Region 2 and the City. Doing so could benefit Woodburn by addressing constraints on economic development while ensuring that ODOT protects the safety and function of roads in the vicinity of the Woodburn I-5 interchange. This is particularly important when considering potential safety impacts related to ramp congestion and queue spillage onto the travel lanes of I-5. Having recurring back-ups from the ramp terminal intersections onto I-5 is a major safety concern. Please include this correspondence in the record of proceedings for DR 25-14, PLA 25-04, SA 26-01 & VAR 25-06 and send the final decision to [EMAIL REDACTED] and [EMAIL REDACTED]. Thank you. Sincerely yours, Naomi Zwerdling Naomi Zwerdling Region 2 Planning and Development Review Manager Oregon Department of Transportation Department of Transportation Delivery & Operations Division-Region 2 Headquarters & Tech Center 455 Airport Road SE Building B Salem, Oregon 97301-5395 Telephone (503) 986-2600 Fax (503) 986-2630