roadways, and the congestion, and the ten blind curves that must be experienced in order to be <br />understood. <br />Similarly, it is not simply the traffic counts (as the Hearings Official acknowledges, expert <br />opinions may differ), but rather the related issue is the congestion produced on the existing, old, <br />non-standard roadways,"which is mostly without sidewalks. There is congestion for all the <br />different users of the pri mary travelway: pedestrians, bicyclists, personal vehicles, service and <br />delivery trucks, and emergency responders. There are people walking dogs, or pushing baby <br />carriages; children walking to and from school; people walking on the wrong side of the road - <br />and becoming a hazard since they are not visible to drivers coming around blind curves. <br />Some Eugene Public Works staff dismiss evidence of impacts of roadway restrictions and <br />elevations from valley floor to the proposed site. Instead they rely on "queuing" traffic, or <br />passive traffic calming, or "self-regulating conditions," which Hearings Official accepts (DHO, <br />pp. 49-50). The Hearings Official quotes (apparently without irony) the statement of a City <br />engineer (Gillespie) who stated: "From an Engineering operations and safety perspective, there is <br />no difference between an 18-foot-wide road and a 20-foot-wide road" (DHO, p. 58). But <br />Hearings Official concludes: "the review does not provide engineering evidence that the street <br />system is not functioning adequately" (DHO, p. 59). <br />However, residents, and anyone who can subtract, should know the difference. Spring Boulevard <br />and Capital Drive are from 18 to 19 feet wide. Residents and visitors alike face the frequent <br />situation on Spring Boulevard and Capital Drive where two vehicles are approaching blind <br />curves from opposite directions. Additionally, there may be an adult or child, walking or biking. <br />It's a death-defying moment, especially if the vehicle going up hill attempts to pass that walker <br />or biker without knowing that the downhill vehicle, approaching out of view, is exceeding the 15 <br />mph posted limit, or even at that limit. Or consider how, on an 18-foot roadway, a walker or <br />biker could easily be hit by extended 1 foot mirrors on a 10-foot-wide oversized vehicle which is <br />passing a five- or six-foot vehicle. <br />It is not just the numerical data, such as volume of traffic or number of peak hour trips, that is <br />important here; rather, it is the actual encounters of vehicle traffic with other users of the <br />roadway - motorized or not - where there are no sidewalks, where one lane may be blocked by <br />parked cars, delivery vehicles, or service vehicles. Service vehicles, especially landscapers and <br />construction workers, must continue to park along Spring Boulevard. and Capital Drive where <br />there is no space to pull off- regardless of whether the roads are posted for no parking - because <br />they have no alternative for conducting their business at those locations. <br />Crucially, the Hearings Official ignores discussion and evidence from Eugene Springfield Fire <br />that describe significant, dangerous conditions existing in the area and leading to the <br />development site. In a Response letter from the Fire Marshal's Office (March 27, 2017), Deputy <br />Fire Marshal Mark Dahl detailed a number of concerns, such as: "significant delays" including <br />"opposing traffic," "collisions," "construction vehicles related to residential housing," (Item 2, p. <br />2); inability to turn around and "need to back up long distances (greater than 150 ft)" (Item 4, p. <br />2). He concluded: "Given the severely restricted access to the area, in all likelihood the truck <br />company would not be able to physically drive to the scene" (p. 4) of an emergency above the <br />31 <br />