• street must convey all the traffic volume, as well as a large number of pedestrians and bicyclists, <br />from the proposed PUD, just as one pipe in our hypothetical example must carry all the <br />wastewater volume. <br />The PUD's proposed 29 dwellings would be at the very end of Oakleigh Lane, and every <br />one of the cars, trucks, service and emergency vehicles travelling between the site and the only <br />intersection (at River Road) would have to flow along the entire length of Oakleigh Lane, which <br />is already serving about twenty households. <br />Thus, on the face of it, it would be unreasonable to conclude - as the Hearings Official <br />(and Planning Commission) did that Oakleigh Lane requires a 45-foot right-of-way for the <br />fifty feet that's adjacent to the proposed PUD in order to be safe and adequate, and yet the entire <br />870 feet of the rest of Oakleigh Lane, into which all of the PUD traffic volume would be <br />dumped, is certain to be safe and adequate when it comprises a 250-foot long segment of right- <br />of-way that's only 20 feet wide and an additional 400 feet that has less than a 40-foot right of <br />way. This is like a twenty-inch wastewater pipe on the development site dumping its entire <br />volume into a ten-inch pipe downstream. <br />But, didn't the Public Works Report nevertheless provide expert analysis as evidence <br />that the longer section of Oakleigh Lane would be safe and adequate with its current narrow, <br />substandard right-of-way? <br />Actually there is no such finding about Oakleigh Lane's public right-of-way in the Public Works <br />Report. <br />Nor is there any analysis at all of whether the 20-foot and other narrow rights-of-way <br />between the subject site boundary and the intersection at River Road are consistent with the <br />approval criteria in EC 9.8320(5) and EC 9.8320(5)(a). <br />Instead, a careful look at the record reveals that the Hearings Official relied upon <br />portions of the Public Works Department Report that actually analyzed only the application's <br />compliance with the approval criterion EC 9.8320(11)(b) Public Improvement Standards and the <br />referenced standards in EC 9.6505(3)(b) for paving widths and other improvements: <br />"Until such time that property owners elect to improve Oakleigh Lane to full City <br />standards; including sidewalks, the existing paved surface in Oakleigh Street will <br />continue to adequately provide for motorized and foot traffic, as well as for emergency <br />vehicles and delivery services, provided the paved surface is not blocked by parked <br />vehicles." PH-30 at 14. (Emphasis added.) <br />The Public Works Department Report findings in this section do not even mention right-of-way, <br />and they do not in any way speak to the application's compliance with the right-of-way <br />requirements of EC 9.6870, which are referenced by the EC 9.8320(5)(a) approval criterion that is <br />at issue in this appeal. Nowhere else in the Public Works Department Report is there any <br />mention of Oakleigh Lane's grossly substandard right-of-way being sufficient for compliance <br />with the EC 9.8320(5) approval criterion. In other words, there is no Public Works analysis in the <br />record that concludes that a right-of-way width less than 45 feet would provide a safe and adequate <br />transportation system. <br />Trautman Appeal Testimony PDT 13-1 Page 18 July 27, 2015 <br />210 <br />