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Home My WebLink About05.1 KALIN, ALAN EMAIL 022426Danville Planning Commission February 23, 2026 Town of Danville Danville, CA Subject: Documented Bicycle Volumes, Collision History, and Insufficient Public Safety Findings – San Ramon Valley Boulevard Corridor Chair and Commissioners: I respectfully submit this letter to address whether the administrative record contains substantial evidence to support a finding that the proposed Danville Village Apartments project “would not result in significant public health or safety impacts,” particularly along the San Ramon Valley Boulevard (SRV Boulevard) corridor at: • The Town & Country Drive signalized intersection • The north and south Town & Country shopping center driveways • The adjacent Sycamore Valley Road intersection This letter addresses: 1. Documented existing collision history 2. Measured multimodal corridor volumes 3. Projected increases in exposure and turning conflicts 4. Deficiencies in the Transportation Impact Study 5. The legal standard governing public safety findings (Photo E-Bike vs. Vehicle Collision at Town & Country Driveway, SRV Boulevard) I. Documented Collision History in the Project Area The Town’s Collision Summary Reports (January 1, 2017 – January 31, 2025) document: • 113 bicycle–vehicle collisions, including 92 injury collisions and 2 fatalities • 59 pedestrian–vehicle collisions, including 50 injury collisions and 2 fatalities A disproportionate share of injured pedestrians were children and seniors, who together account for more than half of injured victims. Importantly, bicycle and pedestrian collisions have occurred on or immediately adjacent to SRV Boulevard — particularly at the Town & Country intersection and the high-volume Town & Country driveways. The documented collision patterns are consistent and recurring: • Right-turn-across-through movements • Left-turn conflicts • Driveway ingress and egress conflicts • Backing movements within commercial access areas These are established multimodal conflict zones — not isolated incidents. The injury history reflects recurring vehicle turning movements crossing bicycle and pedestrian travel paths at the same locations where this project will concentrate additional turning volumes. II. Measured Bicycle Volumes on the Corridor In Fall 2024, the Town installed No Traffic Analytics camera systems at: • SRV Boulevard / Town & Country Drive • SRV Boulevard / Livery Shopping Center • SRV Boulevard / Sycamore Valley Road • SRV Boulevard / Iron Horse Regional Trail These systems quantify vehicle, bicycle, and pedestrian volumes. Therefore, measured bicycle count data exists for this corridor. SRV Boulevard functions not only as a vehicle arterial but as a primary north–south bicycle corridor serving thousands of students, commuters, and recreational riders each week. Measured bicycle volumes are part of the factual safety baseline. Any defensible public safety finding must incorporate this existing multimodal data into the analysis. III. Projected Increase in Exposure and Turning Conflicts The proposed development includes approximately 200 residential units plus commercial activity. Using standard Institute of Transportation Engineers (ITE) trip generation rates, the project would reasonably generate approximately 1,200 to 1,500 additional vehicle trips per day, with concentrated peak-hour turning movements. Those additional turning movements will occur at: • The Town & Country / SRV Boulevard signalized intersection • The north Town & Country driveway • The south Town & Country driveway • The Sycamore Valley Road intersection Crash research consistently demonstrates that a majority of bicycle–vehicle collisions occur during turning movements at intersections and high-volume driveways where vehicles cross bicycle travel paths. Collision probability is driven by exposure. When turning volumes increase and intersection geometry remains unchanged, expected crash frequency increases proportionally. From a transportation safety engineering standpoint, each added right turn across a bicycle’s path and each added left turn across a pedestrian crossing increases conflict opportunities. Without geometric redesign, physical separation, or targeted mitigation measures, the statistical probability of vehicle–bicycle and vehicle–pedestrian collisions increases. IV. Deficiencies in the Transportation Impact Study The Transportation Impact Study – Danville Village Apartments (Kimley-Horn, February 2026) concludes: “The project would not result in significant transportation impacts.” However, the study evaluates vehicle delay and intersection level-of-service. It does not provide a quantitative multimodal safety evaluation. While operational analysis is thorough, the study does not: • Analyze documented bicycle collision history at the Town & Country intersection or driveways • Incorporate measured bicycle volumes from the Town’s No Traffic Analytics system • Quantify turning-movement conflict exposure involving cyclists • Model bicycle–vehicle crash probability • Evaluate pedestrian exposure increases at driveway conflict points “No significant traffic impact” is not equivalent to “no public safety impact.”Operational adequacy is not a substitute for multimodal safety analysis. V. Legal Standard – Substantial Evidence Requirement Under CEQA, a finding of no significant impact must be supported by substantial evidence in the record. Substantial evidence consists of facts, reasonable assumptions predicated on facts, and expert analysis — not conclusory statements. Even where a project is statutorily exempt from CEQA, Development Plan findings and Density Bonus waiver findings concerning public health and safety must still be supported by substantial evidence. The State Density Bonus Law permits denial of waivers only upon identification of a “specific, adverse impact upon health or safety” based on objective standards. Conversely, approval findings must likewise be supported by evidence demonstrating that no such adverse impact exists. Where: • There is documented multimodal injury history, • Measured bicycle volumes exist, • Additional turning exposure is introduced, and • No quantitative multimodal safety modeling has been performed, The record does not contain substantial evidence demonstrating that collision probability will not increase. VI. Minimum Record Necessary Before Public Safety Findings Before public safety findings are made, the administrative record should include: • Disclosure of measured bicycle volumes from the No Traffic Analytics system; • Turning-movement conflict modeling incorporating those volumes; • Focused safety evaluation of the two SRV Boulevard shopping center driveways; • Quantified evaluation of pedestrian exposure increases; and • Defined mitigation measures specifically designed to reduce bicycle–vehicle and pedestrian–vehicle conflict exposure. Conclusion This is not a question of opposing housing. It is a question of whether documented, measurable, and recurring multimodal injury patterns are being properly analyzed before additional turning exposure is introduced. Housing growth does not eliminate the Town’s responsibility to evaluate known safety conditions. Public health and safety findings must be supported by quantified evidence — particularly in a corridor with established injury history and measured bicycle, pedestrian, and vehicle volumes. Approval without a rigorous multimodal safety analysis would leave the Commission’s public safety findings unsupported by substantial evidence in the administrative record. Thank you for your consideration. Respectfully submitted, Alan Kalin COL, U.S. Army (Ret.) Co-Chair, Danville Safety Advocates (BikeDanville.org) President, Mount Diablo Cyclists (MountDiabloCyclists.org) James Oberstar Award – Excellence in Bicycle Advocacy California Outdoors Hall of Fame