the City's adopted standards supported Oakleigh Lane functioning as a "queuing street" and <br />that a paving width of only 14 feet was "safe" and would not impede emergency response. <br />Thus, it would be irresponsible for commissioners to avoid grappling with the true facts <br />based on a misplaced belief that LUBA's prior findings provide some sort of "safe harbor" for <br />the commissioners' earlier findings. <br />THE RECORD CONTAINS A PREPONDERANCE OF EVIDENCE THAT THE PUD WOULD BE A <br />SIGNIFICANT RISK TO PUBLIC SAFETY, INCLUDING FROM IMPEDIMENTS TO EMERGENCY RESPONSE <br />VIA OAKLEIGH LANE; AND THERE IS NO RELIABLE EVIDENCE TO THE CONTRARY. <br />Prior testimony by Simon Trautman provided extensive documentation on the Eugene Fire <br />Code standards for fire apparatus access roads (Exhibit F, pages 8-149), as well as relevant <br />standards from Oregon Department of Transportation (ODOT; Ibid., pages 14-15) and the U. S. <br />Occupational Safety and Health Administration (OSHA; Ibid., page 15), which are included <br />herein by reference and which commissioners should read closely. <br />Further confirmation of what's required for minimizing risk and providing unimpeded <br />emergency response can be found in the publication Best Practices - Emergency Access in Healthy <br />Streets by the County of Los Angeles Department of Public Health publication. See Exhibit G. <br />Here is a relevant excerpt: <br />"There are two notable examples where states have chosen not to adopt the IFC <br />[International Fire Code]10. Neither Oregon nor Washington requires local jurisdictions <br />to adhere to the IFC. They permit cities to design streets with clearances of less than 20 <br />feet. Oregon uses Neighborhood Street Design Guidelines." The Oregon Office of the <br />State Fire Marshal, the Oregon Fire Chiefs' Association and the Oregon Fire Marshals' <br />Association endorse these guidelines. They include street cross sections of 20 feet <br />without on-street parking 24 feet with parking on one side, and 28 feet with parking on <br />both sides. The guidelines also provide for periodic breaks in parking with driveways <br />and no parking areas, so that 20 feet is available at intermittent locations along the <br />streets." (Emphasis added.) Page 29. <br />The relevant contents of the record can be summarized as follows with regards to Oakleigh <br />Lane, which is a local cul-de-sac street that must provide for two-way traffic: <br />a) Oakleigh Lane is the only means for all vehicular access to and from the proposed PUD. <br />b) Oakleigh Lane is roughly three times the recommended length for cul-de-sacs. <br />9 Exhibit F to this testimony does not include the attachments to Trautman's testimony. Those can be <br />found at LUBA II Rec. 146-312. <br />10 Actually, State of Oregon has adopted the IFC, but allows jurisdictions to adopt street designs that <br />supplant the IFC standards. <br />11 This is the ODOT document cited in this and previously submitted testimony. Note that the operative <br />term in this passage is "clearances less than 20 feet." The passage goes on to state that the street cross <br />sections must be at least 20 feet without parking and greater street width with parking on one or both <br />sides. <br />Conte Appeal Testimony PDT 13-1 Page 15 April 12, 2017 <br />