LUBA RET. EX 076/077 RE-J - Laserfiche WebLink

photos at LUBA Rec 682 and 683. A couple cases even appear to be captured in the photographs submitted by the applicant on August 31, 2015. The three video files included in my August 31, 2015 testimony also show substantial presence of legally-parked cars. Further, as the August 25, 2015 letter from Lauren Regan attests, residents do park (legally) on the pavement that's located on their own private property. (See Attachment I included with my August 31, 2015 testimony.) Thus, Mr. Dixon's anecdotal testimony doesn't change the fact that parked cars do obstruct two- way traffic on Oakleigh Lane at different places and times, and there is nothing in the record that ensures this practice won't continue in the future. ONE-TIME SNAPSHOTS AREN'T EVIDENCE OAKLEIGH LANE WOULD REMAIN UNOBSTRUCTED My argument is not based on a claim that at every moment of every day parked cars obstruct Oakleigh Lane. The applicant's ten snapshots depict a common scenario during the middle of a weekday when the working families along Oakleigh Lane have driven their cars to their jobs. This "evidence" might be germane to safety issues if residents could time house fires and heart attacks on the right days of the week and at the right time. The real world doesn't work that way, and the Eugene-Springfield Fire Department certainly doesn't base their safety standards and practices for emergency access on just responding during certain hours of the day or when conditions on the street are ideal. The applicant's snapshots capture a few minutes of a single day - just one moment in time, and they're no more a basis for findings about Oakleigh Lane than Mr. Dixon's anecdotal observations. The record already contains snapshots that show a different scenario with cars parked on the roadway. For example, see the four pictures at LUBA Rec 682 and 683. In addition, the two videos that I submitted on August 31, 2015, show Oakleigh Lane around noon on Sunday, August 30, 2015, when one of the residents on Oakleigh Lane was hosting a "fantasy football" party. See the following video files: • 2015August30PedestriansBicyclistAndVehicleSharingTheOakleighLanePavement.mp4 • 2015August30TruckLeavingOakleighLaneResidence.mp4 My argument concerns events, such as a weekend party, that are not at all unlikely. What would happen, for example, if an Oakleigh Meadows Co-housing (OMC) resident had a heart attack at 7:30 a.m. on a weekday morning at a time when a number of cars remained parked along the 250-foot long choke point' and some of the other OMC residents were leaving the compound to drive down Oakleigh Lane and off to their jobs? When the emergency vehicle - The "choke point" is the 250-foot segment of Oakleigh Lane that has a 20-foot right of way and only approximately 14' to 16' feet of pavement in the public right-of-way. Note that only the third, fourth, fifth and sixth submitted photos submitted by the applicant appear to show the "choke point." The • other photographs show stretches of Oakleigh Lane closer to River Road that have wider right-of-way. Trautman Appeal Testimony PDT 13-1 Page 3 September 4, 2015 275 266