20 <br />3. Argument. <br />(a) Introduction. <br />As noted in the Statement of Material Fact, supra, the only access for the <br />estimated 168 daily trips generated by the proposed PUD is Oakleigh Lane, <br />which, as LUBA noted, has "a 19-foot wide unstriped, paved surface [that] <br />lacks curbs and gutters, storm drainage and sidewalks. ,5 ER p 8. The paved <br />surface is further constricted by residents' cars parked in the street. Because <br />there are no sidewalks or bike lanes, pedestrians and bicyclists must share the <br />19-feet of available pavement with moving vehicles, including emergency <br />vehicles. <br />When the application was submitted, the Eugene Public Works <br />Department (EPWD") analyzed the minimum required improvements for <br />Oakleigh Lane and submitted a report analyzing the impacts of the proposed <br />PUD on the City's transportation system. Rec pp 1255 - 1276. That report <br />reached two separate conclusions for two different portions of the Oakleigh <br />Lane right-of-way. This analysis was the only expert evidence regarding this <br />EC 9.6870 requires a minimum right of way width of 45 feet for low volume <br />residential streets. Even alleys require a minimum right of way width of 20 feet <br />if they provide primary access. This right of way width is intended to provide a <br />paved surface for vehicles, plus room for curbs, gutters and sidewalks, none of <br />which are present on Oakleigh Lane. <br />OCTOBER 2014 <br />