comments, many of them false, misleading and/or irrelevant, which generally undermined <br />opponents' testimony. For example, Haney stated: <br />"The Roadway was improved to an approximate continuous width of 20 feet." <br />As Berg-Johansen knew by this time, the roadway is improved to only 14 feet, more-or-less <br />within the 20-foot right-of-way of the 250-foot segment. But Berg-Johansen took no step to <br />correct this error in Berg-Johansen's subsequent memo to commissioners. <br />Gillespie also falsely claimed: <br />"Oakleigh Lane is a local rural road in Lane County jurisdiction and not located <br />within the City of Eugene." <br />As a Public Works Department employee who deals with city streets, Gillespie would <br />presumably know this was false, as the attached "city limits," map shows. (Exhibit C) This map <br />is readily available on the City's website. <br />Having not received the desired specific statements and "examples" from PWD <br />regarding a queuing street and 14-foot wide paving, Berg-Johansen then took it upon himself to <br />misrepresent the facts regarding the City standards for a "queuing street" and provide an April <br />12, 2017 memo (Exhibit D) to the Planning Commission with false and misleading conclusions: <br />"The concept [queuing street] creates a safe and efficient environment by utilizing <br />intermittent on-street parking (or other lane reductions) to achieve a built in traffic <br />calming effect. This concept is applied City-wide for new local street construction." - <br />Erik Berg-Johansen memo, page 1. (Emphasis added.) <br />First note that Mr. Berg-Johansen did not receive any "examples where a 14' queing [sic] street <br />was allowed through a Land Use Decision," despite his explicit request to Ed Haney. So, Mr. <br />Berg-Johansen just made up the "fact" that "[t]This concept is applied City-wide for new local <br />street construction." <br />Further, Berg-Johansen knew that the City's adopted street standards require a 21 foot <br />wide street for a "queuing street" because I had explained that to him in a phone call several <br />days earlier. Furthermore, Berg-Johansen knew that City Council had adopted standards in the <br />Design Standards and Guidelines for Eugene Streets, Bikeways and Accessways that clearly and <br />unambiguously established that 21' is the minimum paving width for a "queuing street." Here <br />is Table 2 in the "adopted" standards: <br />Conte Motion to Reject/Strike PDT 13-1 April 19, 2017 Page 3 <br />