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2017 Remand – Applicant Final Rebuttal 5-3-17
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2017 Remand – Applicant Final Rebuttal 5-3-17
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Last modified
5/8/2017 4:00:24 PM
Creation date
5/5/2017 8:47:03 AM
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Template:
PDD_Planning_Development
File Type
PDT
File Year
13
File Sequence Number
1
Application Name
OAKLEIGH COHOUSING
Document Type
Public Comments
Document_Date
5/3/2017
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Yes
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Eugene Planning Commission <br />May 3, 2017 <br />Page 9of10 <br />obstruction." Ms. Nemariam does not dispute that drivers can safely drive <br />around temporary obstructions caused by parked cars. <br />April 26, 2017 Letter from Access Engineering to Planning Commission, p. 2-3 (Emphasis <br />added). <br />In fact, following a site visit, the Fire Marshal's office confirmed that "Oakleigh <br />Lane in and of itself does not exhibit si ni 'cant risk to emergency response actions" <br />and that the PUD will provide "actual safety improvements" by providing for an <br />emergency vehicle turnaround on the subject property. Again, substantial evidence in <br />the record demonstrates that the PUD will not pose an impediment to emergency <br />response. <br />Conclusion <br />In 2013, opponents argued that the PUD posed "safety risks" to Oakleigh Lane, <br />undeterred by the fact that there was no evidence of any safety risk. Hearings Official <br />Fred Wilson saw through these arguments stating: <br />[T]he strong assertion that an increase in ADT will result in traffic accidents or <br />actual danger to pedestrians and bicyclists is not supported by substantial <br />evidence in the record. Assertion is not evidence, and neither is an <br />explanation of inductive reasoning. * * * <br />This record contains uncontroverted evidence that the proposed development <br />will come nowhere close to producing the 100 peak hour trips necessary to <br />trigger a TIA. That standard does not discuss or contain a requirement to <br />provide a TIA simply because ADT will rise by a certain percentage, or a certain <br />number of pass-by trips will be generated. To interpret EC 9.8320(5)(c) or EC <br />9.6870(1) otherwise would be to add language and concepts to the provision <br />that do not exist. That would violate ORS 174.010. The Hearings Official has <br />not been directed to any evidence in the record that shows accident rates for <br />Oakleigh Lane or at the intersection with River Road are a problem. Nor have <br />other documented 'problems' with traffic volumes or speeds been submitted by <br />any party... Finally, LOS at the intersection of Oakleigh Lane and River Road <br />appears to be adequate and there is no evidence in the record showing that the <br />proposal will reduce the LOS to an unacceptable or failing service level. <br />Therefore, there is no evidentiary basis for requiring a TIA or assuming that the <br />increase in ADT will necessarily lead to unsafe conditions along the lane. <br />Hearings Official Decision, p. 29. <br />Despite nearly four years and two open-record periods, the opponents are still trying <br />to get this City to believe that there is a traffic safety issue based on little more than <br />their assertion of an issue; and to require improvements to existing infrastructure that <br />
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