additional area shown in white in the site plan, which we assume is paved. The <br />result is a reduced buffering around parking and around interior of site around <br />buildings, which seems undesirable for aesthetics, buffering from adjacent single- <br />family homes, and pedestrian movement. <br />Applicant is seeking a variance for the requirement to provide parking islands of <br />20 feet in width to separate parking areas (EC 9.5500(12)(b)(3)). First, we believe <br />that the parking area calculations need to include all paved surfaces. The revised <br />site plan only includes "blue" areas in calculating parking area. "White" areas <br />shown around parking stalls should also be included as parking area, unless <br />another designation and function is applied in the site plan. As depicted, the <br />parking area appears to be a single parking court, or at most, two courts, which <br />exceeds the 9,000 sq.ft. maximum. With the area calculations corrected to include <br />all paved parking surfaces, we believe that site plan does not provide adequate <br />buffering or grouping of traffic courts to be a suitable alternative to the code <br />requirements. <br />Traffic Impact Analysis <br />Traffic generation by a project of this scale (108 residential units and 14,000 sq.ft <br />of retails space) is the single greatest concern of the neighborhood. The area <br />already experiences significant congestion which currently exceeds city standards <br />in numerous locations. Residents of the area could experience a significant loss of <br />mobility due to this project if the scale of the development is not reduced or <br />mitigation measures increased. For one example, existing residents seeking to <br />access Hilyard Street from the west side via E 33rd or E 31St already experience <br />significant difficulty and delay. Hilyard is a critical north-south connection for <br />much of South Eugene and there is no other alternative route other than the <br />highly congested Willamette Street. Increased congestion here will cause spillover <br />and ripple effects in a much larger area. <br />In reviewing the TIA, it is impossible to determine the factual source of the data <br />for existing traffic, upon which the analysis is based. Data for multiple <br />intersections are reported in the TIA, but the original source of the traffic counts <br />is not provided. We do not believe that theoretical model data, nor any historic <br />counts more than six months old should be used for representing traffic in this <br />area. We are requesting actual, recent traffic counts using physical traffic <br />Fodor & Associates - Page 3 <br />