1. The PUD application fails to comply with EC 9:8320 Safe and Adequate Transportation. <br />The applicant and City Staff have based their compliance determinations on the wrong traffic standard. <br />The Eugene Arterial & Collector Street Plan (1999) sets forth the current local street standards. Based <br />upon these standards, if is clear that Oakleigh Lane is an access lane, and not a low-volume residential <br />street. "Access Lanes ...are designed for primary access to a limited number of properties. On this street <br />type, the residential environment is dominant and traffic is subservient....Access lanes generally serve 25 <br />o r fewer homes and traffic volumes are less than 2 5 0 Average Daily Traffic (ADT)." The City Staff report <br />incorrectly interprets the relevant code standards that underpin their decision to find the proposal in <br />compliance-with traffic standards, and not require the necessary traffic impact assessment'. <br />The Lower River Road Concept Plan indicates, "An Operations and Safety Analysis conducted for the <br />Lower River Road corridor concluded that although River Road is functioning well as a main <br />thoroughfare for significant volumes of traffic, and will continue to do so in the future, access onto, off of <br />and across River Road for local auto, pedestrian, and bicycle traffic is difficult and worsening. Vehicular, <br />pedestrian and bicycle travel to, from, and between residential neighborhoods in the River Road corridor, <br />businesses on River Road, Rasor Park and the West Bank Bike Path will grow increasingly more difficult <br />in the future with increasing River Road traffic volumes." LRRCP, p.-18. <br />Traffic safety and volume were of upmost concern to the neighbors on Oakleigh and McClure Lanes. <br />Oakleigh Lane is approximately. 2 S miles long, is a narrow dead-end street with an approximate 20 foot <br />wide paving surface and no internal street connections, and has 23 residential tax lots and 20 residential <br />units; not 2 5 residential lots as the Staff report incorrectly states. Evidence, including the City of Eugene <br />Geographic Information Systems (GIS) street layer and other historic documents demonstrate that <br />Oakleigh Lane has been established as a Lane Access Road and is not a low volume residential road as set <br />forth in the applicants' materials and the City Staff report, p. 12. As a result, Oakleigh is only designed for <br />less than 250 ADT. ACSP, November, 1999. If the Institute of Transportation Engineer (ITE) Trip <br />'Generation Manual models the number of ADT per day for a single family detached dwelling as 10 ADT, <br />this would result in 200 ADT for the current size of Oakleigh Lane. The Staff Report indicates that the <br />proposed development would increase the ADT on Oakleigh by 164. City Staff report, p. 15. The <br />anticipated ADT for the intersection of Oakleigh and RR would thus result in 364 ADT, which significantly <br />exceeds the Access Lane APT maximum of 250 and thus-fails to adhere to the current Street Plan criteria. <br />The applicant has failed to provide substantial evidence establishing compliance with the Eugene Arterial <br />& Collector Street Plan (1999) and thus must be denied. <br />Further,,the PUD does not comply with EC 9.6850 (Dedication of Public Ways), and EC 9.6870 (Street <br />Width). The existing narrow, dead-end lane would be egregiously unsafe if the residential population <br />were to more than double in size and traffic. City Public Works staff voiced numerous concerns regarding <br />deficits in the existing lane's right of ways, lack of sidewalks, and safe access. The existing neighbors use <br />the lane extensively for bike commuting, walking, and as an area.for children and neighbors to gather and <br />talk. The end of the lane receives virtually no car traffic at this time. The addition of 29 cars driving all <br />the way to the very terminus of this dead end, will greatly increase traffic felt by the majority of the <br />households. The buildings that currently observe the most traffic are those located near River Road: a car <br />dealership, a library, and a doctor's office-not the family homes further down the street.' In addition, <br />because the lane is small, all of the neighbors know and recognize each other on Oakleigh Lane and drive <br />extremely slowly and can identify safety issues posed by unfamiliar vehicles. Between the units <br />1 The Hearings Official must determine "whether the interpretation underpinning the local government's decision is <br />2 <br />798 <br />