counters be collected for all study intersections. <br />We see that a "video analysis" was used for the Hilyard and 30t" intersection. Is <br />this a completely objective, verifiable, and accurate basis for characterizing this <br />intersection? If so, we would like the actual video and original traffic counts <br />to be entered into the record as part of the TIA so that we may <br />independently verify its accuracy. <br />Minimum standards for the TIA are established in Administrative Order No. 58- <br />02- 02-F. Section R-9.8650-F(4.1) requires actual traffic counts on an hourly and <br />daily basis for all streets and intersections in the study area. No daily figures are <br />provided in the TIA and we see no evidence that actual traffic counts have been <br />collected. Section R-9.8650-F(5) requires traffic counts for morning peak <br />periods as well as evening peaks. <br />We recognize that the TIA scope is established partly by the discretion of the C <br />Traffic Engineer and that, while there is a minimum scope required, there is no <br />maximum scope. The current TIA appears to represent the absolute minimum <br />analysis. Given the large scale of this project and the heavy congestion currently <br />experienced in this area, the additional traffic generated will have significant <br />impacts on surrounding streets and intersections. We believe that the scope of <br />the TIA is therefore inadequate and needs to be expanded to include a larger <br />area in order to adequately reflect the actual traffic impact area. The purpose <br />statement for the Traffic Impact Analysis Review in Eugene Code 9.8650 (cited <br />below) clearly states that significant amounts of traffic and traffic problems <br />are included in the scope of a TIA. This purpose statement is also directly referred <br />to in the Approval Criteria in 9.8680(1) and is therefore a requirement. <br />9.8650 Purpose of Traffic Impact Analysis Review. The purpose of Traffic <br />Impact Analysis Review is to ensure that developments which will <br />generate a significant amount of traffic, cause an increase in traffic that <br />will contribute to traffic problems in the area, or result in levels of service <br />of the roadway system in the vicinity of the development that do not <br />meet adopted level of service standards provide the facilities necessary to <br />accommodate the traffic impact of the proposed development. <br />The scope of the study area also needs to be expanded to comply with the <br />Fodor & Associates - Page 4 <br />