Conclusion <br />If commissioners abide by the legal requirement that the applicant must meet their burden of <br />proof based on substantial and reliable evidence, the findings with respect to EC 9.8320(6) should <br />not be difficult. <br />There is simply NO evidence in the record that a reasonable person would rely on as proof that <br />Oakleigh Lane, as the only access to residents of the proposed PUD, is adequate for safe and <br />unimpeded access by emergency response. <br />For the reasons stated above and in other testimony, the Planning Commission must <br />either deny the application or impose adequate conditions of approval as described in my <br />April 12, 2017 testimony. <br />it <br />Submitted on the 191h day of April, 2019 by <br />Paul'Conte <br />EXHIBITS <br />Al. Vita for Massoud Saberian <br />A2. Analysis of staff comments by Massoud Saberian <br />B. City Limits Map excerpt <br />C. 2013 Standards of Coverage Eugene Springfield Fire excerpts <br />D. Typical fire equipment dimensions <br />E. Lane Code Chapter 15 excerpts <br />Conte Appeal Responsive Testimony PDT 13-1 Page 5 April 19, 2017 <br />