minimum paving width of at least 20 feet. Oakleigh Lane isn't just slightly shy of that functional <br />requirement, it's six feet too narrow along the final 250 feet approaching the proposed PUD. <br />Additional conclusions by Nemariam's assessment support these points (and more): <br />"As shown on the photos near the fire hydrant, the available roadway width of less than <br />20-foot will not provide enough room for firefighters to efficiently set up and use their <br />equipment." Page 8. <br />"This 1,000-foot long dead-end street lacks connectivity to other city streets to efficiently <br />and safely accommodate access to proposed PUD site by emergency fire and medical <br />services vehicles." Page 10. <br />"The safe and unimpeded ability of emergency response vehicles to traverse this <br />extensive length of substandard roadway cannot be ensured without improvements <br />identified elsewhere in this report." Ibid. <br />"The 250-foot segment of Oakleigh Lane has a pavement width within the public right- <br />of-way of only 14 feet, more-or-less. This narrow pavement width cannot provide safe <br />and unimpeded two-way travel for emergency vehicles attempting to reach the <br />proposed PUD site and/or transit from the PUD site to a hospital." Page 11. <br />"The 250-foot segment has a right-of-way of 20 feet and a pavement width, exclusive of <br />shoulders, of approximately 14 feet. Due to the limited right-of-way it would be <br />impossible to provide the required 26 feet road width at the fire hydrant unless <br />additional areas were dedicated or an easement provided." Ibid. <br />"Oakleigh Lane, in the configuration approved by the EPC, cannot safely accommodate <br />emergency response vehicles because of the potential for parked vehicles to obstruct the <br />travel lane." Page 14. <br />The commissioners must take into account that it is physically impossible for two emergency <br />vehicles to move past one another within the limited width of 14-foot paving. A 10-foot-wide <br />fire truck couldn't even get past a 6-foot-wide car in this width. The commissioners also cannot <br />continue to ignore that the City allows LEGAL PARKING, and residents often do LEGALLY <br />PARK, on both sides of the narrowest segment, restricting the available paving width to even <br />less than 14 feet.' <br />In conclusion, there is simply no evidence or rational justification for a finding that <br />Oakleigh Lane could provide unimpeded emergency response to the proposed PUD with <br />Oakleigh Lane's current configuration (even with no paving width less than 14, as the prior <br />In his report, Weishar also made the ridiculous suggestion that "[t]he problem with excessive parking <br />on both sides of the Oakleigh Lane pavement is that it could require a fire truck to have to back down <br />the street." (Emphasis added) LUBA II Rec 365. <br />Needless to say, if the conditions on Oakleigh Lane require a fire truck to have to "back down the <br />street," then Oakleigh Lane cannot be considered to provide "unimpeded" emergency response. <br />Weishar has thus inadvertently confirmed in his "expert" testimony that the proposed PUD <br />doesn't satisfy the requirements of EC 9.8320(6) for unimpeded emergency response. <br />Conte Appeal Testimony PDT 13-1 Page 9 April 12, 2017 <br />