Questions and Responses regarding Scott Gillespie Testimony - Submitted by Paul Conte <br />What were the values of those estimates? <br />Comment: Gillespie provided no explanation; accordingly, his conclusory statement is neither <br />reliable nor probative. <br />14. RE: "The engineer analyzed intersections for safety and operations." <br />What were the probative results that the applicant's engineer claimed? <br />Comment: Gillespie provided no description of the results; accordingly, his statement isn't <br />probative. <br />15. RE: "The applicant's engineer demonstrated that no crash reducing measures are necessary, <br />recorded traffic speeds are within acceptable percentages for the posted and statutory speed, <br />Capital Drive & Spring Blvd have adequate capacity to serve the development site and no <br />measureable congestion from an engineering standpoint will result from the proposed <br />development." <br />What were the specific data and analysis submitted by the applicant's engineer that you are relying <br />upon for the following conclusions: <br />a) no crash reducing measures are necessary <br />b) recorded traffic speeds are within acceptable percentages for the posted and statutory speed <br />c) Capital Drive & Spring Blvd have adequate capacity to serve the development site <br />d) no measureable congestion from an engineering standpoint will result from the proposed <br />development." <br />Comment: Gillespie provided no explanations; accordingly, his conclusory statements are neither <br />reliable nor probative. <br />16. RE: "City Engineering staff has confirmed the new pavements have the capacity to serve the existing <br />neighborhood and the proposed development site" <br />What measure of "capacity" are you referring to e.g., volume, Gross Vehicle Weight, other? <br />Comment: Gillespie provided no explanation; accordingly, his conclusory statement is neither <br />reliable nor probative. <br />17. RE: "The City of Eugene would not have knowingly reconstructed an unsafe condition." <br />Are you claiming that this is reliable and probative evidence upon which the Hearings Official should <br />base his conclusions, or is this just speculation? On what concrete evidence do you base this <br />statement? <br />Comment: Gillespie provided no explanation; accordingly, his conclusory statements are neither <br />reliable nor probative. <br />18. RE: "The narrow roadway and topography create a self-regulating condition and appropriate for the <br />topography, speeds and volumes in the surround neighborhoods." <br />What is the meaning of "self-regulating" in standard, professional lexicon? <br />Comment: Gillespie provided no explanation; accordingly, his conclusory statement is neither <br />reliable nor probative. <br />March 8, 2018 Page 16 <br />