REBUTTAL TESTIMONY RE "OAKLEIGH CO-HOUSING'S PUD <br />(PDT 13-1) APPLICATION. <br />Submitted on October 16, 2013 by: IVY <br />Paul Conte <br />1461 W. 10th Ave. <br />Eugene, OR 97402 <br />OCT 1 6 110`13 <br />CITY 0 F ~l1GK <br />BUILDING & PERMIT SVCS <br />This testimony provides arguments in opposition to the proposed Oakleigh Meadows <br />Co-Housing PUD. <br />It supplements my testimony submitted October 9, 2013 (Exhibit PT-4). All arguments <br />support findings that the proposed PUD, with or without the conditions of approval <br />recommended in the staff report, are not consistent with the approval criteria at: . <br />EC 9.8320(1), EC 9.8320(5)(a) and (b), EC 9.8320(6), EC 9.8320(11)(b), EC 9.8320(12) and <br />EC 9.8320(13). <br />1. The September 27, 2013 letter from Access Engineering (Exhibit PT-17) states that the <br />projected traffic counts should be based on 28 condominiums. <br />Dwelling Count <br />The development is legally 29 dwelling units, which must be the dwelling count <br />used for all traffic analysis of the proposed PUD. Nevertheless, even if a dwelling <br />count of 28 were used, all analysis presented in my October 9, 2013 testimony would <br />remain valid. Should the Hearings Official find that the traffic impacts must be <br />analyzed based on 28 dwelling units, the following provides the results of the <br />adjusted calculations, based on evidence in the record: <br />• The estimated ITE-ADT for 28 condominiums with 52 parking spaces is in the <br />range of 163 to 174. <br />• The additional traffic from 28 new dwelling units would still approximately <br />double (still 1.9 times) the current ITE-ADT on Oakleigh Lane. <br />• 28 dwelling units would generate at least 5,856 "pass-bys" per day on <br />Oakleigh Lane. <br />• Based on "pass-bys;" 28 new dwelling units at the end of the road would still <br />almost triple (precisely, 2.8 times) the traffic impact from current levels. <br />• Using the ITE Trip Generation Manual estimates, the projected Average Daily <br />Traffic (City-ADT) with an additiona128 dwelling units would actually be <br />October 16, 2013 Conte supplemental testimony re PUD 13-1 1 1 Page <br />448 <br />