standards for the TIA established in Administrative Rule Sections - <br />.86 -F(4.1) an (5). <br />4) Failure to properly evaluate the contribution to AM peak traffic of trip <br />generation from the 14,000 square feet of proposed commercial <br />development. Applicant has claimed only "specialty retail" will locate at <br />this development, whereas a wide range of commercial uses are possible. <br />Applicant has made the arbitrary claim that this development will add zero <br />trips to the AM peak without any factual evidence, as required in <br />Administrative Rule Section -9.8650-(6). <br />5) Failure to adequately evaluate the impacts of southbound trips from the <br />proposed development, as well as the impacts of westbound and <br />eastbound trips. Trips are merely allocated to the north and south <br />directions on Hilyard and are not allocated to the east or west. Allocated <br />trips are not evaluated in terms or their impacts on the next immediate <br />intersection. A more-rigorous trip allocation should reasonably be <br />required under Administrative Rule Section R-9.8650-F(7) and -(8). <br />6) Failure to adequately consider the spillover of traffic onto neighborhood <br />residential streets that would result from this proposed development <br />under increased traffic conditions, as required in Eugene Code 9.8650 and <br />Administrative Rule Section -9.8650-F(7) and F(8). <br />7) Failure to address the obvious conflict between increased southbound left <br />turns from Hilyard onto E 32nd and increased westbound left turns from E <br />32nd onto Hilyard that would occur under developed conditions, as noted <br />in testimony from Friends of Eugene. The TIA has noted that current <br />problems exist making left turns from 32nd onto Hilyard. This is the only <br />route identified in the TIA for southbound trips from the proposed <br />development. Therefore, this is a critical movement that must be analyzed <br />in sufficient detail to establish safety and efficacy. Applicable rules include <br />Eugene Code 9.8650 and Administrative Rule Sections -9.8650- <br />F(8.1), -F(9), and -(10). <br />Fodor & Associates - Page 2 <br />