• staff has no concerns related to traffic safety issues or poor service levels <br />which will result from this development." (Under EC 9.8320(5)(c), page 11) <br />This unsupported conclusion is rebutted in detail on page 16 of my <br />October 9 testimony. <br />• the existing paved surface in Oakleigh Street will continue to adequately <br />provide for motorized and foot traffic, as well as for emergency vehicles and <br />delivery services, provided the paved surface is not blocked by parked <br />vehicles.... there is nothing to suggest that the impacts of the proposed <br />development will result in unsafe conditions in Oakleigh Lane,...." (Under <br />EC 9.8320(11)(b), page 14) <br />These two unsupported conclusions are rebutted in detail on pages 15 and <br />16-17 of my October 9 testimony. <br />• "The development will have minimal off-site traffic impacts per the findings <br />provided previously at criterion (5)(c) regarding traffic generation...." (Under <br />EC 9.8320(12), page 20. Note reliance on EC 9.8320(5)(c), which is cited in the <br />first bullet, above.) <br />This unsupported conclusion is rebutted in detail on pages 17-20 of my <br />October 9 testimony. <br />The situation in this case is straightforward: The City finds that the additional traffic <br />that the proposed PUD would generate will cause Average Daily Traffic levels that <br />require Oakleigh Lane to meet the minimal standards for a "Low Volume <br />Residential Street," which includes a 45-foot right-of-way and improvements. On <br />the face of it, these right-of-way and improvement standards were adopted by City <br />Council and must be presumed to be the City's determination of what's required for <br />a safe and efficient street to handle projected vehicle, pedestrian and bicyclist use. <br />If "expert opinion" is to be relied upon in a finding that an unimproved street with a <br />right-of-way that is less than half the width of the adopted standard, is adequate, <br />then the expert opinion must specifically explain why this proposed development <br />and Oakleigh Lane are so different than what the adopted 1999 Eugene Arterial and <br />Collector Street Plan covers. Neither the applicant's consultants nor the Eugene <br />Public Works staff have provided Any such analysis and have simply provided <br />unsupported conclusions that conflict with Public Works staff's own specific <br />analysis. <br />The applicant has thus not come close to meeting their burden of proof of satisfying <br />any of the approval criteria related to traffic. <br />October 16, 2013 Conte supplemental testimony re PUD 13-1 3 1 Page <br />450 <br />