Questions and Responses regarding Scott Gillespie Testimony - Submitted by Paul Conte <br />24. RE: "The narrow character for the existing roadways is consistent with the intent of the current City <br />design standards for queuing streets." <br />Please answer the question under #18. <br />Comment: Gillespie provided no explanation or support for his conclusory statement; accordingly, <br />his statement is neither reliable nor probative. <br />25. RE: "This situation happens all throughout the City of Eugene and other communities on Oregon. <br />City design standards evolve and it is not implied that older streets designed under older standard <br />are inadequate or inherently unsafe." <br />Are you implying that "older streets designed under older standard are" necessarily adequate and <br />safe? <br />Comment: Gillespie provided no explanation for the relevance or implications ofthis statement. The <br />fact that older streets may not be inadequate or unsafe provides no evidence that Capital Drive is <br />adequate and safe. This statement is not probative. <br />26. RE: "The roadways are merely suffering from functional obsolescence. Functional obsolescence does <br />not imply that older streets are unsafe, perform poorly or do not have the capacity to serve growth. <br />Functional obsolescence simply means there is a reduction in the usefulness or desirability of a <br />roadway because of an outdated design feature, usually one that cannot be easily changed." <br />What does 'functional obsolescence" comprise? Does 'functional" encompass "safe"? <br />Is a street that is 'functionally obsolescent" necessarily safe? <br />If a street is unsafe because of an "outdated" design feature, does that allow an exception to EC <br />9.8320(5) and (6), which require safe access to the PUD? <br />Comment: Gillespie provided no explanation for the relevance or implications of his statements. The <br />fact that older streets may not be inadequate or unsafe provides no evidence that Capital Drive is <br />adequate and safe. This statement is not probative. <br />27. RE: "...there is no appreciable difference between an 18 foot wide road and a 20 foot wide road." <br />Please explain this conclusion when two 10-foot-wide fire trucks are unable to physically pass one <br />another on an 18-foot-wide road and can physically pass one another on a 20-foot-wide road. <br />Please cite to accepted professional standards and/or practices upon which this conclusion is based. <br />Comment: Gillespie declined to explain his statement, which is, on the face of it, false. His statement <br />is erroneous and unreliable. <br />28. RE: "The utilization of on street parking is sparse and the portions that are being used support traffic <br />calming in the area." <br />Please identify documentation in the City's records for Capital Drive that street parking is "being <br />used" to "support" traffic calming in the area. <br />Comment: Gillespie provided no facts to back up his statement, appears to be made up out of thin <br />air. His statement is unsupported and unreliable. <br />29. RE: "The roadway has historically performed well and there is no engineering evidence to the <br />contrary." <br />Please explain this as requested for question #23. <br />March 8, 2018 P a g e (8 <br />