The circles are the intersections mentioned in the report, the letter/number in red represent the TIS grade/seconds from the current study and the future projections.  Meaning, "E-36-F103” means current grade and seconds at the indicated intersection (E-36) and projected grade and seconds (F-103). All intersections will degrade.

Re:    Traffic Impact Study (TIS) for the Incyte Office Expansion (Protocol Tax Parcel 06-136.00-028)


On behalf of various neighbors affected by the proposed Incyte Office Expansion on property now known as 20 Granite Road and by the related proposed development by Wilmington Friends School on its property at 101 School Road (the “WFS Proposal”), we write to raise concerns about the Incyte TIS, and your review letter dated May 24, 2021 (the “DelDOT Letter”).


Traffic Count and “Delabear”.


We understand that the Incyte TIS is based on traffic counts taken on Thursday, December 5, 2019 from 7:00 to 9:00 AM and from 4:00 to 6:00 PM.  As you can see from news reports,[1] on Thursday, December 5, 2019, during the crucial afternoon period, Alapocas Run State Park and Alapocas Drive were closed because a bear had been sighted in parts of Wilmington and then in Alapocas Run State Park.  


Accordingly counts taken at affected intersections on December 5, 2019 are not accurate representation of normal traffic conditions.


Improper Reliance on Incorrect Comprehensive Plan Designation.


The DelDOT Letter references the New Castle County Comprehensive Update, 2012 and says that the 20 Granite Road “site is located in an area with a Future Land Use designated as an Office / Commercial / Industrial Development Area (OCI)” and that “[b]ased on the above description, [Incyte’s] proposed development generally adheres to the New Castle County Comprehensive Plan.


This is not correct.  The referenced Plan shows the 20 Granite Road site as Low Density Residential.  As such Incyte’s proposed development in no way adheres to the Comprehensive Plan.


Unqualified Engineer.


We believe that at the time Duffield prepared the Incyte traffic study their personnel did not include a qualified (PTOE) traffic engineer.  If that is the case, DelDOT should consider carefully whether to accept the Duffield TIS.  A project of this magnitude with serious effects on traffic in the surrounding areas demands the skills and expertise of a qualified (PTOE) traffic engineer.


The TIS does not take into account the WFS Proposal.


The TIS takes into account only Committed Developments and these do not include the WFS Proposal.  While we understand this is consistent with DelDOT policy, Incyte and its advisors were well aware of the WFS Proposal and should have taken it into account.


Moreover we understand from the New Castle County Land Use Department (the “Land Use Department”) that they determined that the WFS Proposal would be handled as a Minor Land Development Plan based in part on their view that the Incyte TIS adequately represents the traffic impact of the WFS Proposal.  


This determination by the Land Use Department has far reaching effects that DelDOT and the Land Use Department should carefully consider, including, without limitation:


·      Even if treated as a Minor Land Development Plan, because the WFS Proposal includes a new entranceway off of Norris Road, which is not a collector or arterial street, UDC 40.03.307 requires the Land Use Department and DelDOT to determine that vehicular and pedestrian safety is not compromised by the WFS Proposal, and that the local neighborhood is not adversely impacted.

·      Norris Road is a narrow road where individuals mainly associated with WFS park their cars every day.  This parking pattern limits access and affects safety and emergency access from Norris Road.

·      There will be a substantial increase in traffic on the neighborhood streets, especially on Alapocas Drive where the WFS Proposal calls for four entrance/exits with cars coming in and out and turning in either direction onto and off of Alapocas Drive.

·      The WFS Proposal suggests that there will be a traffic signal.  The present plan does not locate it specifically.


The Limited Recommendations in the DelDOT Letter.


After reviewing the level of service in affected intersections (including an F level at Edgewood Road and Augustine Cutoff), the DelDOT Letter recommends only a traffic light at the entrance to the Incyte property on Augustine Cutoff.  While this improvement will enhance the ability of cars to leave and enter the Incyte property, it will only increase the backups on Augustine Cutoff which are already severe (and will be increased by some 2,400 trips per day) and make an already bad situation at the Edgewood Road/Augustine Cutoff intersection worse.  And notwithstanding significant adverse effects on traffic DelDOT does not require any other changes to mitigate the effects.


Lastly, while neither the TIS nor DelDOT’s Letter provides specific data about the duration of the existing and expected traffic jams along West Park Drive, it only stands to reason that those jams will get worse with the additional commuters that the Incyte proposal envisions.  Yet, a critical conclusion (at p.3) is that “the improvements (required to address these issues) are beyond what we could reasonably require the developer to do.”  That may be in accord with DelDOT policy, but as a matter of guidance to the County as it considers the rezoning application, what can be expected over the next decade if the expansion development is allowed?  Does DelDOT have any plans to remediate the congestion for drivers using West Park Drive to access Concord Pike or Foulk Road?


We hope that DelDOT and the Land Use Department will carefully consider these concerns in making their recommendations in the upcoming process.  The situation calls for much greater attention (revised TIS by Incyte, Major Subdivision Treatment of WFS Proposal with accompanying TIS etc.).


Sincerely yours,

Neighbors for Responsible Land Use



Dee Durham

Penrose Hollins

Krista Griffin

Sarah McBride

James Spadola

Nathan Field

Chris Jackson

Owen Robatino

Claudy Joinville

[1] See: and .