1 <br />1 I. Standing. <br />2 Oakleigh Meadows Cohousing (OMC) accepts that Paul Conte has <br />3 standing to appeal as an intervenor. <br />4 II. Statement of the Case <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />29 <br />30 <br />A. Nature of Decision and Relief Sought <br />OMC accepts that the intervenor is challenging the decision entitled <br />"Final Order of the Eugene Planning Commission on Appeal: Oakleigh <br />Meadows Cohousing (PDT 13-1)" whereby the Eugene Planning Commission <br />approved OMC's Tentative Planned Unit Development. Rec. 6-17. ER. 1-12. <br />B. Summary of Arguments <br />OMC rejects each of the arguments advanced for the reasons set forth in <br />detail below. In summary, the appeal should be denied because: <br />IA. The City's findings did not require a 45-foot right-of-way. <br />1B. The City properly determined that the PUD was subject to an <br />exception to the cul-de-sac standards and that street improvements <br />could be guaranteed by an irrevocable petition. <br />1C. The City's pedestrian and bicycle circulation standards did not <br />require OMC to improve Oakleigh Lane along its entire length. <br />1D. The City properly determined that no Traffic Impact Analysis <br />was required. <br />IE. The City properly determined that the PUD would not be an <br />impediment to emergency response under EC 9.8320(6). <br />IF. The City properly determined that road improvements are not <br />required before Final PUD approval. <br />