incorporate and rely on staff "findings" when those findings don't adequately <br />evaluate the impacts and fully address issues raised in testimony that are "arguably <br />relevant" to the criteria. Blanket, conclusory "findings" are not sufficient, especially <br />when they completely inconsistent with other findings in the same Staff Report. <br />EC 9.8320(5)(c) - This criterion requires consistency with the provisions of the Traffic <br />Impact Analysis Review of EC 9.8650 through 9.8680 "where applicable." Because <br />the development would not increase peak-hour trips above the threshold that <br />requires a Traffic Impact Analysis, this criterion was not applicable. <br />There staff comments for this criterion provide no evidence or analysis and merely <br />includes the conclusory statement that "[r]eferral comments from Public Works staff <br />indicate no concerns related to traffic safety issues <br />EC 9.6805 - It is under this section in the Public Works Referral Comments (pages <br />2-4) that the following "constitutional findings for exaction" are found: <br />"It is in the public's interest to have Oakleigh Lane consist of 45 feet of right-of <br />way through the development site's entry drive aisle and to consist of 33 feet <br />beyond the drive aisle to the terminus of the street in order to ensure safety for <br />pedestrians, bicyclists and motorists traveling on Oakleigh Lane (a low-volume <br />street), to ensure the efficient provision of emergency services and to guarantee <br />that the proposed development and adjacent properties are accessible via <br />Oakleigh Lane. <br />Improving Oakleigh Lane to these standards will allow for two-way vehicular <br />and bicycle traffic, will provide separation between vehicular traffic and <br />pedestrians and will also provide for emergency response and access to adjacent <br />lots. Because 45 feet of right-of-way is the minimum amount of right-of-way <br />necessary to construct Oakleigh Lane in this manner as a low-volume street, and <br />because 33 feet of right-of-way is the minimum amount of right-of-way <br />necessary to construct the turnaround at this location, the public interest in safe <br />vehicular, pedestrian and bicycle travel and emergency response and access will <br />be at risk if the 22.5 foot and 13 foot strips of right-of-way are not dedicated. <br />Without the additional right-of-way, Oakleigh Lane cannot be improved to the <br />City's minimum street design standards and the 168 new vehicle trips per day <br />generated by the proposed development, along with the additional pedestrian <br />and bicycle traffic generated by the proposed development, will not be assured <br />of safe access via Oakleigh Lane." <br />October 9, 2013 Conte testimony re PUD 13-1 19 1 P a g e <br />