locations. Based on an erroneous assumption of available paving width, Weishar's conclusions <br />have no merit and cannot reasonably be relied upon by the Planning Commission as valid <br />"expert testimony." <br />Weishar also attempts to turn the City's street classification system on its head in the <br />following incorrect and misleading statement: <br />"As a low-volume residential street, Oakleigh Lane can safely accommodate between <br />250 and 750 average daily trips. Combining traffic from Oakleigh Meadow with the 11 <br />existing single-family homes on Oakleigh Lane, which are equivalent to 210 daily trips, <br />the total would be 378 daily trips, well within the range for a low-volume residential <br />street." <br />Pause for a moment and reread that first sentence which presents his "expert testimony" that <br />Oakleigh Lane can accommodate the anticipated traffic volume. <br />Weishar's is claiming that - because Oakleigh Lane would be classified as a low-volume <br />residential street - Oakleigh Lane ipso facto (by that very fact) can safely accommodate any <br />traffic volume within the range that defines the low-volume residential category of streets. The <br />truth is that a street is classified based on the projected traffic volume, which says nothing at all <br />about that streets' adequacy to safely accommodate the projected volume. According to <br />Weishar's inane (and deceptive) logic, Oakleigh Lane could be a dirt, four-wheel-drive track <br />over which 378 daily trips (and occasional emergency vehicle responses) are projected to travel, <br />and commissioners would have to accept that Oakleigh Lane could safely accommodate the <br />traffic because of its classification. This is pure nonsense, and commissioners should not again <br />allow themselves to be bamboozled because Weishar has concocted a contorted justification for <br />his client's proposal. <br />Towards the end of his report, Weishar makes the untrue and scurrilous accusation that <br />"In addition, there is some speculation that neighbors could intentionally obstruct potentially as <br />much as six feet of the improved street surface, leaving an improved travel surface of 13 feet <br />along a 250-foot portion of the street." This vicious slander calls to mind shades of a Trump <br />"tweet" attack with utter disregard for the truth. Commissioners must reject this accusation and <br />consider how such tactics, as well as Weishar's misrepresentation of code provisions described <br />above, call into question whether or not Weishar's opinions are of the caliber that an <br />independent, unbiased professional would make. <br />THE DEFICIENCIES IN OAKLEIGH LANE <br />Commissioners cannot legitimately rely on the "queuing street" claim any longer. Nor can <br />commissioners in good faith rely on Weishar's conclusory statements that are based on no <br />evidence or actual analysis other than the false information he included in his letter. <br />Hopefully, a majority of commissioners will carefully look at the actual facts, including <br />the risks and impediments present with Oakleigh Lane's current configuration, and will make <br />an honest evaluation of whether the evidence - as required by law - convincingly proves that <br />Oakleigh Lane would provide safe and unimpeded access were a 29-unit PUD to be approved <br />and occupied at the end of the road. <br />Conte Appeal Testimony PDT 13-1 Page 7 April 12, 2017 <br />