To that end, the Oakleigh Lane neighbors and I engaged an independent, licensed <br />Traffic Engineer, Haregu Nemariam,4 who is based in Portland, to conduct a deep and through <br />evaluation of the 250-foot long, narrow segment of Oakleigh Lane. The project's stated objective <br />was to conduct: <br />"[An] assessment to determine the adequacy of the approximately 250-foot segment of <br />Oakleigh Lane to consistently, reliably and safely function as a 'Queuing Street' so the <br />configuration of the street and physical elements such as moving and parked vehicles <br />(including fire trucks), fire hydrant, fences, etc. would not impede access to emergency <br />vehicles responding to emergencies on a proposed PUD site." (See Exhibit E.) <br />The assessment included a site visit by the traffic engineer to Oakleigh Lane and resulted in a <br />detailed, fourteen-page analysis with extensive exhibits in support of the conclusions. The <br />overarching conclusion of this assessment was unequivocal and based on verifiable facts: <br />"Oakleigh Lane as approved in the City's "Final Order" would not have the minimal <br />configuration necessary to function reliably as a "queuing street" along the 250-foot <br />segment analyzed." Page 14. <br />In addition, the analysis concluded: <br />"For Oakleigh Lane to function as queuing street it should be improved to include a <br />21-foot minimum paving width that is signed and marked to provide a 14-foot wide <br />travel lane and a 7-foot parking lane. In addition, sidewalks should be provided, so that <br />pedestrian and wheelchairs users will not be forced to be on the travel lane. The 20-foot <br />wide right-of-way width is not adequate to allow the improvements noted above." <br />Page 5. <br />Any legitimate, evidence-based assessment has to start with a review of the relevant (and true) <br />facts, which is what the Nemariam analysis and report did (and which Weishar's conclusory <br />letter did not). <br />Oakleigh Lane is very long and narrow, lacks any connectivity other than to River Road at one <br />end, and dead-ends at the proposed PUD site. The final 250-foot segment that provides access <br />to the entry of the proposed PUD is extremely constricted, having only approximately 14 feet of <br />paving within a 20-foot right-of-way. The City and County allow LEGAL PARKING on both <br />sides of the street, including in the right-of-way and on the paving, and there are no sidewalks <br />on either side. <br />As a general assessment, it is impossible to ensure that emergency response vehicles will <br />have unimpeded access across the final 250-foot segment to reach dwellings and residents on the <br />proposed PUD. To start with every standard that has been submitted to the record requires at least 20 <br />foot wide paving because any less would mean two ten foot wide emergency vehicles could not move past <br />each other. It's no coincidence that the City's adopted street standards, the Eugene Land Use <br />Code, the Eugene Fire Code and the ODOT recommendations for "narrow" local streets all have <br />4 Exhibit D provides some information about Nemariam Engineers & Associates, LLC, and the <br />company's principal, Haregu Nemariam, who conducted the assessment and wrote the report. <br />Conte Appeal Testimony PDT 13-1 Page 8 April 12, 2017 <br />