688, which is still near the top of the "Low-Volume Residential Street" range <br />(i.e., 250 to 750 City-ADT). <br />Thus, the substantive outcome in this case does not depend on whether the traffic <br />analysis is based on 28 or 29 new dwelling units in the proposed PUD. <br />Dwelling Classification <br />The analysis in my testimony used the ITE Trip Generation Manual, 9th Edition <br />"condominium" classification (230) for the PUD dwellings. Thus, if anything, my <br />analysis probably understates the additional trips and "pass-by" impacts that would <br />arise from the PUD. <br />2. The same letter states: "I concur with staff findings that this development will not <br />require further traffic analysis or reduce safety or service levels in the area." <br />The letter provides no additional evidence, and does not reference anything in the <br />record, in support of the conclusion that the development will not reduce safety or <br />service levels in the area. <br />As demonstrated in my October 9 testimony, the development will reduce safety <br />and service levels in the area, and Oakleigh Lane cannot feasibly be widened and <br />improved to meet City standards for the projected traffic. <br />This conclusion is based on substantial evidence in the record regarding Oakleigh <br />Lane's current conditions, the projected traffic levels and impacts that would occur if <br />the PUD were approved, and the specific analysis of the Eugene Public Works staff <br />that concluded "safe vehicular, pedestrian and bicycle travel and emergency <br />response and access will be at risk" if the Oakleigh Lane right-of-way is not widened <br />to 45' and the roadway improved to City "Low Volume Residential Street" <br />standards. <br />The Hearings Official cannot rely on mere conclusory statements, even by experts, <br />when opponents have offered a detailed explanation, consistent with City staff's <br />specific analysis, for why Oakleigh Lane would not be able to safely and efficiently <br />accommodate the increased traffic under its current configuration and conditions. <br />"While the hearing official is entitled to rely on the expert opinion of the county <br />sanitarian, where opponents have offered a detailed explanation for why the <br />subject property may not be able to accommodate the required expansion and <br />replacement drain-field, we agree that more than an unexplained expression of <br />belief that it will be possible is required. Bartels v. City of Portland, 20 Or LUBA <br />303, 308 (1990)." Phillips v. Lane County, 62 Or LUBA 92 (2010). <br />This same principle applies to the unsupported, conclusory statements found in the <br />Public Works Referral Comments, as follows: <br />October 16, 2013 Conte supplemental testimony re PUD 13-1 2 1 Page <br />449 <br />