GREENLIGHT ENGINEERING <br />TRAFFIC ENGINEERING/TRANSPORTATION PLANNING <br />June 11, 2018 <br />Rodney Bohner <br />City of Eugene <br />99 W. 10`" Avenue <br />Eugene, OR 97401 <br />RE: Lombard Apartments (WG 18-3/SR 18-3/ARA 18-8) <br />Mr. Bohner, <br />Received <br />JUN 12 2018 <br />City of Eugene <br />Planning Division <br />Greenlight Engineering has been asked to evaluate the transportation related impacts of the <br />proposed Lombard Apartments in Eugene, Oregon. We have completed a review of the <br />Sandow Engineering October 6, 2017 and May 19, 2018 memos and transportation related <br />materials in the written record of the land use application. We have the following comments <br />about the project. <br />EC 9.8670(2) <br />The October 6, 2017 Sandow Engineering memo provides an analysis of the City of <br />Eugene's requirements in determining the need for a traffic impact analysis per Eugene Code <br />("EC") 9.8670. <br />EC 9.8670(2) requires a TIA when "[t]he increased traffic resulting from the development <br />will contribute to traffic problems in the area based on current accident rates, traffic volumes <br />or speeds that warrant action under the city's traffic calming program, and identified <br />locations where pedestrian and/or bicyclist safety is a concern by the city that is <br />documented." <br />Sandow Engineering's response to this requirement reads "[t]here are no documented safety <br />or traffic problems in the area that the project would be contributing to. Therefore, a TIA is <br />not triggered under this criterion." <br />There is no evidence that there was any evaluation whatsoever of the development's impact <br />on current accident rates, the development's impacts on traffic volumes or speeds or any <br />evaluation of the development's impacts of volumes and speeds that would warrant action <br />under the city's traffic calming program. There is also no evidence that there was any <br />evaluation of the development's impact on pedestrian or bicyclist safety. Additionally, there <br />is no evidence that the city was contacted to determine if there are any concerns that have <br />been documented by the city. <br />The applicant should be required to provide evidence that addresses the applicable criterion. <br />13554 Rogers Road • Lake Oswego, OR 97035 <br />Phone: 503.317.4559 • www.greenlightengineering.com <br />