The City's staff report is in error regarding the designation of Oakleigh Lane as a low volume residential <br />' road based on the City's perception that there are 25 residential lots on Oakleigh Lane. Currently, <br />Oakleigh Lane has 23 residential tax lots and 20 existing residential units (Figure 3). Excerpt is presented <br />below (from Page 12, 4th paragraph). <br />' Pursuant to EC 9.6850 Dedication of Public Ways, as a condition of any development, the City may <br />require dedication of public ways for bicycle and/or pedestrian use as well as for streets and alleys, <br />' provided the City makes findings to demonstrate consistency with constitutional requirements. The <br />public ways for streets to be dedicated to the public by the applicant shall conform to the adopted <br />right-of-way map and EC Table 9.6870. EC 9.6870 Street Width confirms that the required right-of- <br />way width for Oakleigh Lane is 45 feet, based on the street functioning as a Low-Volume Residential <br />Street. Public Works staff confirms that there are currently 25 residential tax lots along Oakleigh Lane, <br />and with the addition of 29 dwelling units proposed by the subject development, the Average Daily <br />' Traffic (ADT) would be greater than 500 trips per day, which is within the expected 250-750 ADT range <br />for low-volume streets. <br />' By definition, a road that serves less than 25 residential lots is considered an access lane according to <br />Eugene Arterial & Collector Street Plan (ACSP, November, 1999) adopted by the City as Resolution No. <br />4608 and Ordnance No. 20181 (excerpt presented in Appendix B). The ACSP defines the access lane as <br />' having less than 250 ADT. If the Institute of Transportation Engineer (ITE) Trip Generation Manual <br />models the number of ADT per day for single family detached dwellings as 10 ADT, then Oakleigh lane <br />currently has 200 ADT at the intersection of Oakleigh and RR. Page 15, last two paragraphs of the Staff <br />Report states that the proposed development would increase the ADT on Oakleigh by 164. The <br />anticipated ADT for the intersection of Oakleigh and RR would then be 364, which significantly exceeds <br />the Access Lane ADT maximum of 250. Appendix C presents photos of Oakleigh Lane and photos of <br />' RR area low volume residential roads. <br />To add, per Lane Code 15.010(35)(e)(v) a Local Access Road is defined as follows: <br />(v) Local Access Road. A Public Road that is not a County road, state highway, or federal road. <br />Pursuant to ORS 368, the County and its officers, employees and/or agents, is not liable for <br />failure to improve Local Access Roads and is not liable to keep Local Access Roads in repair. <br />The County shall spend County moneys on Local Access Roads only if it determines that the <br />work is an emergency or if: <br />(aa) the Director recommends the expenditure; and <br />(bb) the public use of the road justifies the expenditure proposed; and <br />' (cc) the Board enacts an order or resolution authorizing the work and designating the work to be <br />either a single project or a continuing program. <br />A portion of Oakleigh Lane remains in Lane County jurisdiction and is referred to by the County as an <br />access road. A portion of the road is in City jurisdiction. The City Public Works Department refered to <br />Oakleigh lane during a conversation with Bryn Thorns on August 25th, 2013, as a local access road and <br />even Steven Ochs, city planner referred to Oakleigh Lane as a local access road during a conversation <br />with Bryn Thorns on about August 26th, 2013. This suggests that the road should be classified as an <br />access road and should have a limit of 250 ADT. In addition, the lane is longer than 400 feet which is the <br />1 <br />Page 7 of 20 <br />