FODOR & ASSOCIATES LLC <br />Community <br />Planning Consulting <br />To: Erik Berg-Johansen, Associate Planner <br />City of Eugene Planning Division <br />99 West 10th Avenue <br />Eugene, OR 97401 <br />Sent via email attachment to: erik.berg@ci.eugene.or.us <br />Submitted: January 10, 2017 <br />Comments in Response to Supplemental Material for <br />Traffic Impact Analysis, TIA 16- 007, Part 2 <br />The Applicant has submitted new material into the record date December 26, <br />2016 relating to Traffic Impact Analysis, TIA 16- 007. We are submitting these <br />additional comments on behalf of Friends of Eugene in response to the new <br />material. Note that our comments here on the issue of AM peak traffic are in <br />addition to our prior comments submitted into the record on January 6, 2017. <br />Those prior comments related to the AM peak traffic issue are included herein by <br />reference. <br />Threshold for Analysis of AM Peak <br />The Applicant has indicated that the proposed development would generate less <br />than 100 trips during the AM peak hour, and therefore is not required to analyze <br />the morning peak period traffic impacts. This is not the case. The Eugene Code <br />does not state that the 100-trip criteria must be met in the AM peak for the AM <br />peak traffic to be included in the analysis. <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 />(1) The development will generate 100 or more vehicle trips during <br />any peak hour as determined by using the most recent edition of the <br />Institute of Transportation Engineer's Trip Generation. <br />394 East 32nd Avenue • Eugene, OR 97405 <br />541/345-8246 • email: info(a)fodorandassociates.com <br />