2017 Remand - Public Comment (2)

Dahl's comments at least don't dissemble. But as Mr. Saberiari s analysis explained, Dahl didn't present any relevant facts, nor did he provide any explanation of how the five facts he did state would support a conclusion that Oakleigh Lane could provide safe and unimpeded access for emergency response. Dahl's comments do, however, provide an opportunity to clarify several points: 1. As Dahl observes, for safety, the code requires "installation of 20ft wide fire department access road" on the PUD site. This on-site road must be kept clear at all times. It would be unreasonable (in fact, idiotic) to then force emergency responders to navigate a 14-foot roadway, potentially obstructed by legally parked cars, inorder to get from River Road and onto the 20-foot wide fire apparatus access road that's only on the site. 2. Sprinklers may mitigate the harm from delays in first response by fire apparatus, but sprinklers provide no safety benefit for emergency medical response. According to the 2013 Standards of Coverage Eugene Springfield Fire, about two-thirds of the Eugene Springfield Fire (EFS) emergency responses are for medical emergencies. These emergency responses cannot afford to be impeded, no matter what sprinkler system is in place. (See Figure 3.7 in Exhibit C.) 3. EFS standard practices, as explained in the attached excerpts, frequently call for an immediate response by multiple emergency vehicles. This practice helps ensure that all equipment and personnel are quickly deployed to cover incidents about which all the details may not be known in the first critical minutes. (See page 88 of Exhibit C.) Accommodating multiple emergency vehicles, such as those shown in Exhibit D, on the 14-foot roadway segment of Oakleigh Lane would significantly increase the risk of potential impediments to emergency response, particularly for emergency medical incidents where victims must be rushed from the site, back across the 14-foot roadway segment, in order to get to the hospital. Finally, any testimony from the Fire Marshal that claims Oakleigh Lane can provide safe and unimpeded emergency response - despite the EFC and other standards - must actually describe how this would be possible given the documented, grossly substandard conditions on Oakleigh Lane. During the Hearings Official evidentiary hearing, there was no testimony at all from the Fire Marshal regarding EC 9.8320(6). In these remand proceedings, there wasn't much more of an effort to actually evaluate the potential risks presented by Oakleigh Lane. As documented by the timestamps on the e-mails in Exhibit E of my "Motion to Reject or Strike City Staff Testimony re PDT 13-1," Dahl appears to have written his comments within just a seven-hour period, probably less. And this lame effort was only done in response to a request by Berg-Johansen to provide comments that would help undermine opponents' case. Such a slapdash effort produced nothing more than a document with no relevant data or analysis. The fact remains that the record contains no actual evaluation of Oakleigh Lane by the Fire Marshal. Conte Appeal Responsive Testimony PDT 13-1 Page 4 April 19, 2017