In addition, following the discussion of traffic-related issues, I document how the proposed <br />PUD fails to comply with approval criteria EC 9.8320(7) and EC 9.8320(11)(k) with respect to <br />adequate public facilities required for fire protection. <br />To counter any attempt to exclude portions of my prior testimony, I have resubmitted it during <br />the period when the record has been re-opened to evidence, as well as argument. <br />I want to express my respect and appreciation to Commissioners Barofsky, Mills and Baker for <br />respecting the public process and allowing me to provide full testimony. <br />PRELIMINARIES <br />Before reading further, please look at Attachment B, which provides an updated diagram and <br />table summarizing the dedicated Oakleigh Lane right-of-way. Although the information on this <br />attachment is not (and never was) "new evidence,"' your re-opening the record to new evidence <br />removes any doubt about of your legal ability to refer to this information in your findings. <br />I am also submitting a survey by a licensed surveyor that confirms the specific dimensions and <br />locations of Oakleigh Lane right-of-way and pavement along the easternmost segment of <br />Oakleigh Lane. See Attachment C, incorporated herein. This recent survey is augmented by a <br />survey conducted in June 2011 and provided as Attachment D, incorporated herein.2 <br />I would also suggest that you view the videos and photographs of Oakleigh Lane that <br />accompany this testimony, and which are incorporated herein by reference. The video files <br />provided include: <br />17August2015videoOfOakleighLane.mp4 - A visual examination of the pavement at <br />the northwest corner of the proposed development (as marked by a "Poage Eng & <br />Survey Inc.) survey marker. <br />2015August30PedestriansBicyclistAndVehicleSharingTheOakleighLanePavement.mp4 <br />- A visual demonstration of the shared use of Oakleigh Lane by pedestrians, bicyclists, <br />moving vehicles and parked cars. <br />2015August30TruckLeavingOakleighLaneResidence.mp4 - A visual demonstration of <br />the clearance for vehicles traversing Oakleigh Lane between legally-parked cars. <br />With that context in mind, you will see that there is clear and compelling evidence that <br />Oakleigh Lane does not meet Eugene Code (EC) mandatory approval criteria and adopted <br />standards. Further, Oakleigh Lane falls far short of reasonable right-of-way, pavement and <br />clearance for a safe and adequate street for emergency vehicles according to both Oregon <br />Department of Transportation (ODOT) neighborhood street design guidelines (which are <br />referenced in Eugene Fire Code) and the federal Occupational Safety and Health <br />Administration (OSHA) recommendations. <br />See the August 11, 2015 Letter from William Kabeiseman to Anne Davies clarifying the applicable <br />statutes. Attachment E, incorporated herein. <br />Attachment N provides supporting records of the Oakleigh Plat and deed descriptions for Tax Lots <br />5800, 5900 and 10100. The boundaries on Oakleigh Lane form a continuous straight line and meet the <br />northern boundary of the proposed development site. <br />Trautman Appeal Testimony PDT 13-1 Page 2 August 31, 2015 <br />27 <br />