The appellant argues that the City should have required the applicant to obtain approval of <br />a Traffic Impact Analysis (TIA) permit as part of the application. The City has a somewhat unusual <br />TIA provision. Rather than being required to demonstrate compliance with applicable approval <br />criteria under some development standard, the City has a stand-alone TIA provision that requires <br />an additional permit for any developments even otherwise permitted outright developments <br />that trigger applicability under the TIA provisions. Eugene Code (EC) 9.8670 sets out when TIA <br />review is required: <br />Applicability. <br />Traffic Impact Analysis Review is required when one of the <br />following conditions exist: <br /> The development will generate 100 or more vehicle trips during any peak <br />hour as determined by using the most recent edition of the Institute of <br />involving a land division, the peak hour trips shall be based on the likely <br />development that will occur on all lots resulting from the land division. <br />2 <br /> <br /> The states that a TIA is not required because the development <br />would not generate more than 100 peak hour vehicle trips: <br />trips during any peak hour will be below the <br />100 trip threshold that would trigger a Traffic Impact Analysis (TIA). Lacking <br />a TIA, there is nothing further in the approval criteria for this application that <br />Director Decision 2-3. <br />The Planning Director only considered the number of vehicle trips that would be generated <br /> <br />by the development proposed in the current site review application the 106 apartments in <br />3 <br />determining that the TIA provisions were not triggered. The appellant argues that the Planning <br />Director also should have considered developments on other lots that were created when the <br />4 <br />subject property was created. According to the appellant, the City must add in the vehicle trips <br />from other development and determine whether a TIA is required. <br /> <br />2 <br /> <br />The other triggers for a TIA are not at issue in this appeal. <br />3 <br /> <br />There is no dispute that the traffic expected to be generated by the 106 apartments would not, by itself, generate 100 <br />or more peak hour vehicle trips and trigger the TIA provisions. <br />4 <br /> <br />Although the appellant does not argue that considering other development would necessarily require a TIA, merely <br />that the other development must be analyzed together with the current application, the result of such an analysis would <br />almost certainly trigger the TIA provisions. <br /> <br />Hearings Official Decision (SR 17-2) 3 <br /> <br />