Oakleigh Lane is approximately 1,000 feet long and EC 9.6820(4) makes absolutely clear that the <br />City Council intended to require improvements to such long cul-de-sacs in order to "provide safe <br />circulation for pedestrians, bicyclists and emergency vehicles." <br />Not only does EC 9.6820(4) provide context, it's also one of the required standards. However, the <br />Hearings Official erroneously exempted the application from this standard altogether, as <br />explained under "Subassignment of error 2.A - EC 9.6820 Cul-de-Sacs and Turnarounds" on pages <br />6 and 7 of the Appeal Statement (which see). <br />In summary, the Decision erroneously found the application, with Conditions of Approval 3, 4 and <br />7 was consistent with EC 9.6800, EC 9.6805, EC 9.6820(4,) and therefor EC 9.8320(5)(a), by not <br />requiring that Oakleigh Lane have adequate right-of-way and improvements between River Road <br />and the PUD development site. <br />Under EC 9.8320(5)(b) <br />This subelement of EC 9.8320(5) requires that the PUD provide safe and adequate transportation <br />systems for pedestrian and bicycle circulation to residential areas, transit stops, neighborhood <br />activity centers and office parks within 1/4 mile that can reasonably be expected to be used by <br />pedestrians and/or within 2 miles that can reasonably be expected to be used by bicyclists. <br />River Road is less than 1/4 mile from the development site, and Oakleigh Lane provides the only <br />direct route to River Road for pedestrians and bicyclists from the PUD and other residences along <br />Oakleigh Lane. <br />Here again, the Hearings Official erroneously "compartmentalized" the PWD assessment, which <br />made perfectly clear that without widening and improving Oakleigh Lane, "pedestrian and bicycle <br />traffic generated by the proposed development, will not be assured of safe access via Oakleigh . <br />Lane." Based on his ignoring the PWD analysis, the Hearings Official erroneously claimed: <br />"Once again, the Hearings Official has not been directed to evidence that shows that <br />pedestrian safety will necessarily be decreased to unacceptable levels simply because 16411 <br />ADT are added to Oakleigh Lane." (Decision at 27) <br />The PWD analysis provides substantial and reliable evidence that contradicts the Hearings Official <br />in no uncertain terms: <br />"(w)ithout the additional right-of-way, Oakleigh Lane cannot be improved to the City's <br />minimum street design standards 12 and the 16413 new vehicle trips per day generated by the <br />proposed development, along with the additional pedestrian and bicycle traffic generated by <br />the proposed development, will not be assured of safe access via Oakleigh Lane" (Cited above) <br />The PWD analysis further made clear that a 45 feet of right-of-way was necessary in order to <br />ensure safety f or pedestrians and bicyclists traveling on Oakleigh Lane. <br />"The PWD analysis used an incorrect ADTvalue that was lower than the correct value of 168 or 169. See <br />Footnote 2. <br />is Which are specified in Eugene Code Table 9.6870 as a 45 foot right-of-way and 20 foot paving width. <br />The correct number of projected new round trips is 168 or 169, not 164. See Footnote 2. <br />Conte Testimony- December 5, 2013 PDT 13-1 Page 10 <br />266 <br />