Mr. Fred Wilson <br />March 17, 2017 <br />Page 6 <br />and Applicant Engineers. The applicant's traffic engineer walked through all the fine points of <br />the information requirements stated in the TIA Rule, and explained, in much greater detail, why <br />information that was not gathered for submission was not needed for the TIA. See Sandow <br />Engineering's Technical Memorandum, February 28, 2017. <br />As we mentioned at the hearing, with the aid of the small, medium and large "bucket" metaphor, <br />this entire proceeding is about highly technical engineering information. The persons with large <br />buckets of relevant technical information can be counted on just a couple of fingers, and they do <br />not include the Hearing Official. Unlike the vast majority of land use decisions that hit the <br />public hearing docket, this is the kind of inquiry in which the Hearing Official should be most <br />deferential to the professional opinions of the City staff. <br />Opponents had a long list of information critiques of the scope of work. Without getting too <br />deep into the weeds, we would make the following several points about why the scope of work <br />approved by the City and executed faithfully by Sandow Engineering was adequate: <br />Intersections studied: Study area intersections are determined based upon 3 <br />criteria; direct access, contiguous to the development, and development adds 50 new <br />trips. The site driveways, Hilyard/32"a, Hilyard/31 St, and Hilyard/3 0 th ~ meet the above for <br />warranting an analysis. All other intersections within the neighborhood do not meet the <br />criteria for warranting an evaluation, therefore, they are not required to be included. <br />Sandow Engineering's engineers and the City of Eugene's engineers used their technical <br />expertise and professional industry standards to define how the study area meets the <br />requirements. The arbitrary assertion that other intersections need to be studied based on <br />proximity are well beyond the requirements of the code and in misalignment with the <br />professional expertise and judgement of the engineers. <br />Time periods studied: The site driveways are the only direct access to the <br />development; therefore, they were analyzed for the AM and PM peak hours. Hilyard/ <br />32"d is the only contiguous (along the development frontage) intersection to the <br />development; therefore, was analyzed for the AM and PM peak hours. Hilyard/3I" and <br />Hilyard/300' had 50 trips added during the PM only, therefore they were included in the <br />PM analysis. All other intersections within the neighborhood do not meet the criteria for <br />warranting an evaluation. <br />Intersection Performance and Mitigation: Sandow Engineering provided <br />intersection LOS analysis for the PM and the AM conditions as required, contrary to <br />assertion of Appellant's statements made up to and including the March 15th submittals. <br />The LOS analysis as provided by the Applicant's engineer and approved by the City's <br />engineer demonstrates that the mitigation, as described in the TIA and conditioned by the <br />City, is sufficient to mitigate the impact of the development to City of Eugene's <br />standards, and no other mitigation is necessary to meet the standards. <br />