Revised Final Order required). In contrast, a requirement for a minimum paving width of at <br />least 20 feet is the only defensible finding that is supported by the evidence, both from existing <br />standards and from the unavoidable recognition that it takes at least 20 feet width for two <br />emergency vehicles to pass by one another.' <br />It is also inarguable that the traffic generated by 29 new dwellings across this 250-foot <br />stretch will significantly increase the risk to anyone using the pavement to walk, travel in a <br />wheelchair, ride a bike or play. Currently the estimated Average Daily Trips (ADT) generated <br />by the seven existing single-family homes that abut this 250-foot segment is 67. The estimated <br />ADT along this segment if the PUD's 29 new dwellings were approved would be 235. That <br />would more than triple the exposure of non-motorized users to motorized traffic. Oakleigh Lane <br />may already be unsafe to some degree, but that is not the criterion that applies. What is clear is that <br />such a large increase in vehicular traffic would significantly exacerbate the risks on this narrow <br />paving and right-of-way segment that must be shared by all modes of travel (as well as kids <br />playing). The Nemariam analysis confirmed this problem and stated that at least one sidewalk <br />was necessary for the safety of non-motorized travel: <br />"In addition, sidewalks should be provided, so that pedestrian and wheelchairs users <br />will not be forced to be on the travel lane." Page 5. <br />We turn now back to the evidence in the record. It is unfortunate that during the initial <br />application process (i.e., up to the evidentiary hearing before the Hearings Official) the City <br />Public Works Department (PWD) staff never actually evaluated the application's conformance <br />to EC 9.8320(6) with respect to "significant risks" or "impediment to emergency response." The <br />PWD report did speak indirectly to these issues in comments under EC 9.8320(11)(b) ("The PUD <br />complies with EC 9.6500 through EC 9.6510 Public Improvement Standards"): <br />"EC 9.6505 Improvements - Specification (3) Streets and Alleys and (4) Sidewalks <br />"Until such time that property owners elect to improve Oakleigh Lane to full <br />City standards; including sidewalks, the existing paved surface in Oakleigh <br />Street will continue to adequately provide for motorized and foot traffic, as well <br />as for emergency vehicles and delivery services, provided the paved surface is <br />not blocked by parked vehicles. Since the existing paved surface provides safe <br />asp sage for two-way vehicular traffic, bicycles, pedestrians and emergency <br />vehicles, and since there is nothing to suggest that the impacts of the proposed <br />development will result in unsafe conditions in Oakleigh Lane, it is appropriate <br />An argument might be made, as was made when the City Council reduced the minimum width on <br />Crest Drive to 18 feet (two 9-foot travel lanes), that a slightly lesser width than 20 feet could be safe, as <br />long as there was an adjacent sidewalk and "mountable curb" - within the public right-of-way - so that <br />an emergency vehicle could use a small portion of the sidewalk, if necessary. But the configuration of <br />Oakleigh Lane - which has a paving width of only 14 feet, no sidewalks, and cars legally parking on <br />the paving - in no way would come close to this type of ad hoc accommodation. In any case, it must be <br />the City Council that adopts reductions in paving width for specific cases, not the staff or Planning <br />Commission. <br />Conte Appeal Testimony PDT 13-1 Page 10 April 12, 2017 <br />