Relying on some undefined, "creative" street design comes nowhere close to <br />demonstrating that the necessary right-of-way and street improvements can ever be <br />accomplished sufficiently to satisfy the approval criterion. <br />Other than this "hand-wave," there is no evidence in the record to demonstrate that <br />Oakleigh Lane can ever be improved to safely handle the traffic that would result from <br />approval of the PUD. <br />REVIEW OF APPLICATION MATERIALS <br />The following sections describe (and correct, as necessary) all the relevant statements in <br />the application related to the approval criteria identified at the beginning of this <br />testimony. <br />Metro Plan Policies <br />The application does not address Metro Plan Policies A.12 or A.B. The application <br />addresses TransPlan TSI Pedestrian Policy #1 under findings for Metro Plan Policy F.26, <br />which is similarly worded; however, these findings do not address pedestrian safety on <br />Oakleigh Lane at all. The application addresses TransPlan Finance Policy #4 under <br />findings for Metro Plan Policy G.36, which is similarly worded; however, these findings <br />do not address paying the PUD's capacity impact on the transportation system at all. <br />EC 9.9610(2)(b) <br />The application states that the "City of Eugene Street Classification Map identifies <br />streets similar to Oakleigh Lane as a local street." This broad indirect reference is <br />adequate for the purposes of demonstrating that Oakleigh Lane is not an "arterial"; <br />however, as explained previously, Oakleigh Lane is specifically an "access lane," <br />according to City specifications and County records. <br />EC 9.8320(5)(a) <br />The application states: "Oakleigh Lane can be described as having a 'country lane' <br />feeling, which neighbors have explicitly expressed an interest in preserving. The <br />application asserts that "[a]dequate access to the site is provided through the adjacent <br />public street network, Oakleigh Lane, and street connections are provided to all existing <br />streets that abut the property." Oakleigh Lane is the only street that is adjacent to <br />and/or abuts the property, and all vehicle traffic must enter and leave the development <br />by travelling the entire length of Oakleigh Lane. <br />The application does not propose, or request approval of, any modification or <br />adjustments to the requirements of under EC 9.8320(5)(a), based on EC 9.8320(11). <br />The application requests an exception to the standards in EC 9.6815(2)(b), (c) and (d), <br />based on the proposed exceptions being consistent with EC 9.6815(2)(g)1.a and b. The <br />letter from Access Engineering, dated August 6, 2013, was submitted as the "Local <br />October 9, 2013 Conte testimony re PUD 13-1 9 1 P a g e <br />