TECHNICAL MEMORANDUM <br /> <br /> <br /> <br /> March 21, 2018 <br />DATE: <br /> <br /> Capital Hill PUD <br />PROJECT: <br /> <br /> Eugene Hearings Official <br />TO: <br /> <br /> Bill Kloos, PC <br />CC: <br /> <br /> <br /> Damien Gilbert, P.E. <br />FROM: <br /> Principal, Branch Engineering, Inc <br /> <br /> Capital Hill PUD (PDT 17-1) <br />RE: <br /> <br /> <br /> <br />In response to testimony provided in the record and at the hearing, I offer the following clarifications <br /> <br />The most important item to point out is that a Traffic Impact Analysis was not required for this project <br /> <br />Mr. Massoud Saberian, P.E. submitted a critical and clearly biased review of the voluntary traffic safety <br />study submitted by the applicant for the subject project. In this review, he represented himself as <br />somehow more qualified than the professional engineers at the City of Eugene to review a traffic study. <br />It is unclear if Mr. Saberian ever visited the site or closely examined the traffic conditions himself his <br />report merely uses the photos provided by those in opposition to the application. These photos <br />dramatize the conditions of the roadway system and we do not know whether or not they were staged. <br />Furthermore, nothing in those photos or review comments were related to the relevant criteria or <br />demonstrated a standard was not met. <br />Mr. Saberian is a full-time supervising engineer at the City of Santa Rosa, California. The address for <br />the consulting and engineering company he listed on his review report is in Beaverton, Oregon, and is <br />a residential apartment address. The Oregon Administrative Rules (OARs) for engineers specifically <br />prohibit an engineer from representing themselves in an office when they actually work full-time from <br />another office. In particular, OAR 820-010-0720(1)(a) prohibits an engineering office from operating <br />without a fulltime Oregon licensed engineer. It is questionable how an engineer can be in responsible <br />charge of engineering work at two different engineering offices in two different states at the same <br /> <br />HEARINGEXHIBITG <br /> <br />310 5 Street, Springfield, OR 97477 | 541.746.0637 www.BranchEngineering.com <br />th <br /> <br />