Testimony by two, independent, licensed traffic engineers <br />discredits comments from Gillespie and Dahl. <br />In response to the memo from Scott Gillespie and the comments from Mark Dahl, I engaged <br />Massoud Saberian, PE, PTOE, to provide his expert opinion on the comments by Gillespie and <br />Dahl and to address whether these comments would impact the conclusions by Haregu <br />Nemariam, PE, NEA, presented in her extensive analysis and report that I provided as Exhibit <br />D2 of my April 12, 2017 testimony. <br />Exhibit Al provides a condensed vita for Mr. Saberian. Exhibit A2 provides his detailed <br />review and conclusions after reviewing the Gillespie and Dahl documents and the full <br />Nemariam Report. Saberian's assessment provides substantial and reliable expert testimony in <br />support of his conclusions: <br />"Based on the review of the Nemariam Report and the two documents cited above, it is <br />my professional opinion that neither document provides relevant, substantial evidence <br />that would contradict the conclusions in the Nemarian Report. <br />"It is also my independent, professional opinion that the Nemarian Report provides <br />reliable, substantial evidence and expert analysis that supports the conclusions in the <br />report." <br />Mr. Saberian specifically stated: <br />"Mr. Gillespie's memo provides no specific evidence or analysis that would contradict <br />[Nemariam's] conclusions." Page 4 of Saberian Report. <br />Mr. Saberian specifically identified the following conclusion by Haregu Nemariam as remaining <br />uncontradicted by Gillespie's memo: <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." Page 10 of Nemariam Report. <br />Regarding Dahl's comments, Mr. Saberian pointed out that not a single "bullet point" that Dahl <br />presented as "evidence" was relevant to determining whether Oakleigh Lane can provide safe <br />and unimpeded access for emergency response. Mr. Saberian concluded: <br />"In conclusion, there is nothing in Mr. Dahl's comments that would warrant any <br />revision to the Nemariam Report's analysis or conclusions. <br />Additional errors and deficiencies in staff comments <br />The false and misleading conclusory statements in the April 12, 2017 memo from Erik Berg- <br />Johansen are covered in detail in my "Motion to Reject or Strike City Staff Testimony re PDT <br />13-1," which is incorporated herein by reference. <br />Gillespie's memo made the following assertions regarding Lane County standards <br />without providing any supporting evidence or explanation: <br />Conte Appeal Responsive Testimony PDT 13-1 Page 2 April 19, 2017 <br />