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it is pure speculation as to what the decision will be and whether the applicant will be able to provide private facilities and services on the site or access other parts of the cemetery. (The issues discussed above were raised in my Testimony submitted on June 28, 2016, pp.l- 3 and throughout the remainder of that testimony; and in my Response Testimony dated July 15, 2016, p. 2). Issue 3. There is insufficient evidence in the record regarding the proposed private stormwater services and the proposed private street in violation of the requirements of EC 9.724(2)(a)(2). The Commission should therefore hold that the Hearings Official erred in finding that there was sufficient evidence regarding the proposed private stormwater services and the proposed private street, should reverse the decision and should deny the application. As noted above, Public Works summarized its findings at the very beginning of its Referral Response by stating that "staff does not find there is sufficient information to recommend approval of the Conditional Use Permit based on the following evaluation of the criteria specific to our area of expertise, per the Eugene code in effect at the time of application". Public Works Referral Response, p.l. The staff then evaluated the wastewater service (discussed above), streets and sidewalks, and stormwater service. At the end of the Public Works Referral Response, the staff repeated that "there is insufficient information and evidence in the application materials to date, in order to find compliance with the applicable approval criteria". Id p.4. No subsequent evidence was provided by the applicant to counter Public Works concerns. Among other findings, Public Works specifically concluded that there is insufficient information to determine that two of the proposed private facilities and services meet the code criterion. Public Works found that 1) the applicant has not demonstrated that the proposed dwelling units will be served by a storm drainage system. The Public Works Response specifically noted that "staff does not concur that this criterion has been met...". Id p.3; and 2) there is insufficient information to determine that the private street, Cathedral Way, which will run through the development can feasibly be constructed to meet the local street standards in effect at the time of the application. (Id. pp 2-3). (These issues were raised in my Post Hearing Submittal submitted June 8, 2016, p.2 where I incorporated the Public Works Referral Response into my testimony by reference. The issue of the street was also raised in my Testimony submitted June 28, 2016, p.6). The Storm Drainage System: The Public Works Referral Response notes that a private storm drainage system is shown to provide drainage for the private street and paved surfaces, but the applicant has not demonstrated that the proposed dwelling units will be served by a storm drainage system. Public Works staff does not concur that this criterion has been met and recommends that the plans be revised to demonstrate how the structures are served with [a] storm drainage 8