clearly indicated and labeled with accurate spatial representations. <br />Expand Scope to include AM Peak and School Safety <br />The scope of the TIA also needs to be expanded to consider the AM peak traffic <br />period. Analysis and traffic counts for the morning peak periods are required by <br />Administrative Order No. 58- 02- 02-F, Section R-9.8650-F(5.1). This is also <br />necessary because the area includes a number of schools that generate <br />considerable morning traffic that coincides with the morning rush hour in the <br />7:30am to 8:30am period. These schools include four public elementary schools <br />and a middle school: Charlemagne, Ridgeline Montessori, Camas Ridge, and <br />Edgewood elementary schools, and Spencer Butte middle school. In addition to <br />the morning traffic generated by these schools in the form of automobile trips, <br />there is also traffic generated by children with and without parents travelling by <br />bike and on foot. Alder and E 32nd are part of the city's "safe routes to schools" <br />and should receive special attention in the TIA to assure that pedestrian and bike <br />safety are maintained, if not improved. No consideration is given to this in the <br />TIA. Pedestrian and bike safety are specifically mentioned in Eugene Code <br />9.8670 Applicability. Traffic Impact Analysis Review is required when one <br />of the conditions in subsections (1) - (4) of this section exist <br />(2) The increased traffic resulting from the development will <br />contribute to traffic problems in the area based on current accident <br />rates, traffic volumes or speeds that warrant action under the city's <br />traffic calming program, and identified locations where pedestrian <br />and/or bicyclist safety is a concern by the city that is documented. <br />While we have indicated that the scope of the TIA needs to be expanded to <br />include a larger impact area, AM peak traffic flows, and school safety (as noted <br />above), the following comments regarding mitigation are based solely on the <br />existing TIA and Code criteria under EC 9.8650 and EC 9.8680(1) and (2). <br />Specifically, the purpose statement of EC 9.8650, which is referenced specifically <br />under "Approval Criteria" in 9.8680(1), states: <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 />Fodor & Associates - Page 6 <br />