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• Eugene Public Works Maintenance Memorandum dated February 26, 2018 (Submitted as Attachment V, Neighborhood Response Document): "Fire apparatus are often approximately 10-feet in width from mirror to mirror." • Referral Comments 4J School District, November 16 2017: 4J School District "discontinued bus service to Capital, Madrona and Cresta De Ruta due to unsafe passing and operating conditions for our school buses." Buses were described as 40 feet in length and 10 feet in width, mirror-to-minor. • Photographic evidence that two vehicles of that size cannot pass each other on an 18 foot wide street (Neighborhood Response to PDT 17-1, pp. 168-169), despite the assertion by Scott Gillespie, PE (December 8 2017, Attachment F Staff Report) that "From an Engineering operations and safety perspective, there is no appreciable difference between an 18 foot wide road and a 20 foot wide road. 2. The Hearings Official erred in finding that "it appears that, while the streets are narrow and not constructed to current city standards, the street system does function adequately. Based on. the above analysis, public facilities and services are either presently available, or can be available, and can be extended to serve the proposed development, in compliance with EC 9.8320(7)." p. 59. On page 58 the Hearings Official says, "However, they also note that through vigilance and caution, they and their neighbors are able to navigate and drive safely through this neighborhood. " The Hearings Official is basing her conclusion that the below standard street system does function adequately on the notable vigilance and caution of the current neighbors. This in no way shows that the system is adequate to serve the proposed development. It is a situation that would be undermined by the addition of over 31-35 new homes and the increased probability of less than vigilant and cautious drivers. 3. The Hearings Official improperly relied on demonstrably erroneous and unreliable evidence by Scott Gillespie, Eugene Public Works. One of several examples is that she erred in accepting his assertion that "From an Engineering operations and safety perspective, there is no appreciable difference between an 18-foot-wide road and a 20-foot-wide road." This was accepted at face value with no evidence to back it up. An 18ft wide road clearly does not provide as much room for cars, pedestrians, and bikes as a 20ft wide road. Less room provides for a higher likelihood of conflict. The Hearings Official explicitly or implicitly relied upon the false claim that Capital Drive could function as a "queuing" street. 4. The Hearings Official erred in citing the evidence that on street parking on Capital Drive acts as a traffic calming device. "The utilization of on street parking is sparse and the portions that are being used support traffic calming in the area. " (p.58) The Hearings Official has already accepted that the no parking on Capital (which is actually under appeal) is necessary for emergency access, so the presence of parking cannot be cited as a traffic calming measure if it will not exist. 5. The Hearings Official Erred in disregarding the many enforcement issues on Capital Drive and surrounding streets. Regarding the Traffic Study provided by the Response Committee, the Hearings Official states (p. 58): "However, that review primarily emphasizes how the current 26