a I I <br />l i u 1. 4-~ I <br />Eugene Planning Commission <br />December 5, 2013 <br />Page 3 <br />EC 9.6875, which are the City's "Standards for Streets, Alleys, and Other Public Ways" and subsection <br />(b) of that provision explicitly requires the City to consider "adjacent and nearby residential areas, <br />transit stops, neighborhood activity centers, office parks, and industrial parks." <br />The first thing to note is that the provision nowhere mentions that it applies solely to the <br />requirement for dedication - the purpose of the provision is clear from the opening sentence - to provide <br />"safe and adequate transportation systems." The Planning Commission should also note that EC <br />9.8320(5)(b) specifically requires the consideration of the transportation system "to adjacent and nearby <br />residential areas, transit stops, neighborhood activity centers, office parks, and industrial parks." So the <br />provision is clearly not designed solely to address dedication requirements. The simple truth is that if, <br />as the hearings official concluded, the minimum right of way and paving width is required to provide <br />"safe access," then that safety requirement must also be applied to the nearby streets pursuant to EC <br />9.8320(5)(b). <br />Moreover, the hearings official was plainly wrong in suggesting that EC 9.6800 - 9.6875 apply <br />solely to dedication requirements. EC 9.6800 states the purpose of those sections: <br />"Sections 9.6800 through 9.6875 establish standards for the dedication, design and <br />location of public ways." <br />Contrary to the suggestion of the hearings official, those sections are concerned with far more than <br />simply the dedication requirement - they address location and design of public roads, such as Oakleigh <br />Lane. <br />Ultimately, EC 9.8320(5) is designed to do exactly what it says - ensure that a proposed PUD <br />provides a "safe and adequate transportation system," including a safe and adequate transportation <br />system connecting a proposed PUD to. nearby areas. A safe and adequate transportation system does not <br />rely on a small and obviously inadequate local street and dump an additional 164 vehicle trips on it <br />every day. If a PUD of this size wishes to use Oakleigh Lane, then Oakleigh Lane must meet the <br />minimum street standards in order for the proposal to comply with EC 9.8320(5) and the hearings <br />official was wrong to conclude otherwise. , <br />The inadequacy of the transportation system proposed by the applicant is only made more <br />apparent by the various exceptions to other street standards, including the standard for street <br />connectivity and cul-de-sac length. Although the applicant provided a street connectivity study to <br />justify the exception to street connectivity under EC 9.6815(2)(g), that study is wholly inadequate, as <br />explained in the testimony of Paul Conte. Additionally, there is simply no analysis of the exception for <br />cul-de-sacs under EC 9.6820(5). That exception is not justified through the street connectivity study and <br />may be allowed only by showing that one of two conditions have been met. Those conditions must <br />show that physical conditions or existing development preclude potential connections or re- <br />233 <br />