This understates the estimated ADT of 712 for 29 dwellings, almost at the top <br />of the Low Volume Residential Street range of 250-750 ADT. <br />"The construction of the new (structures will result in an increase of <br />vehicular traffic onto Oakleigh Lane by approximately 164 new vehicular <br />trips per day." (Decision at 22) <br />The actual number is 169 new vehicular trips per day for 29 additional <br />residential units. <br />"Even with the added trips attributable to the co-housing proposal, the <br />ADT for Oakleigh will be closer to 400 ADT at most." (Decision at 27) <br />The estimated ADT is 712 for 29 dwellings, almost at the top of the Low <br />Volume Residential Street range of 250-750 ADT. The Hearings Official <br />appears to have confused ITE-ADT (Average Daily Trips), which are round <br />trips and City-ADT (Average Daily Traffic), which are one-way trips. <br />See Conte 10/9 pages 5 to 6 and Conte 10/16 pages 1 to 2 and 4. <br />SUBASSIGNMENT OF ERROR 10.13 <br />The Hearings Official erroneously allowed the impermissible new and non- <br />responsive evidence submitted by the applicant's representatives on October <br />16, 2013 without providing an opportunity for opponents to respond, despite <br />the timely, written request by Paul Conte. <br />The Planning Commission must exclude this evidence and must not rely <br />upon it in their decision. <br />CONCLUSION <br />The multiple errors and misinterpretations made by the hearings official require <br />the Planning Commission overturn this decision and deny this planned unit <br />development (tentative) application must be denied. <br />Respectfully submitted this 22nd day of November, 2013. <br />FOR APPELLANTS <br />Bryn Thorns <br />River Road Community Organization <br />Appeal Statement PDT 13-1 21 November 22, 2013 <br />