3. The October 9, 2013 letter from Willard C. Dixon (Exhibit PT-17) states that "the City <br />of Eugene's code mandates the use of the ITE manual, the same manual that Access <br />Engineering uses." <br />All of the analysis in my testimony used the ITE Trip Generation Manual, 9th Edition. <br />Note that Mr. Dixon's point supports the following argument in my October 9 <br />testimony, found on page 11, under the review of the application statements for <br />EC 9.8320(12): <br />"The findings [in the application] also provide aspirational and anecdotal <br />comments related to estimated trip generation, but without reliable, substantial <br />and probative evidence by a professionally-certified traffic engineer, the City's <br />normal standard of the ITE Trip Generation Manual must be used for both current <br />and projected estimates." <br />4. The October 15, 2013 letter from Access Engineering (submitted October 16) states: <br />"Mr. Conte also tries to increase the expected trip generation of the site by using <br />the number of parking spaces proposed as the number of vehicles that will <br />generate trips." <br />On page 5 of my October 9, 2013 testimony I provide estimated ITE-ADT for the <br />proposed PUD based on the ITE Trip Generation Manual "per dwelling" and "per <br />vehicle" rates. The results are 169 for 29 dwellings and 174 for 52 parking spaces. <br />This is not a large difference, but in any case, I used the lower figure in all further <br />calculations and discussion, based on the per dwelling rate. There is no substance to <br />the letter's complaint. The letter also asserts the projected ITE-ADT is 163, based on <br />28 dwelling units, rather than 29. As discussed under (1), above, the difference is <br />inconsequential in this case. <br />The letter argues that 163 ITE-ADT is "no where [sic] near 1.9 times the existing <br />volume on the street." My testimony actually stated: <br />"The additional traffic from the PUD will thus approximately double (1.9 times) <br />the ITE-ADT on Oakleigh Lane." <br />As noted under (1), above, even using the projections for 28 dwelling units, the <br />current IDE-ADT of 181 will approximately double (1.9 times) to 344 when you add <br />the 163 generated by the PUD. <br />5. Both the October 15, 2013 letter from Access Engineering and the October 15, 2013 <br />letter from Poage Engineering present arguments regarding the current Oakleigh <br />Lane right-of-way. These arguments are based on impermissible evidence submitted <br />after the record was closed to new evidence. However, nothing in the evidence or <br />arguments changes the fact that Oakleigh Lane must be widened to a 45 foot.right- <br />October 16, 2013 Conte supplemental testimony re PUD 13-1 4 1 Page <br />451 <br />