Attachment D <br />Staff Response to Public Comments <br /> <br />To address key issues raised in public testimony in response to the Lombard Apartments <br />applications, staff has prepared the following responses. This is not a comprehensive list of <br />every comment received. However, staff has thoroughly reviewed all submitted testimony and <br />provides a response with the intent of addressing the common themes and primary concerns <br />raised by neighbors. The key issues identified in the testimony are in bold, followed by staff <br />approval criteria. It is also noted that the Eugene Hearings Official (not City staff) will make the <br />decision on this application. <br /> <br />Traffic Impacts <br />Comments provided in public testimony received to-date raise a number of concerns related to <br />traffic impacts to River Road, west of the site, and on Lombard and Fir, located south of the <br />site. <br /> <br />Need for Traffic Impact Analysis Review <br />Testimony raised the question why a Traffic Impact Analysis (TIA) was not required. The <br />purpose of Traffic Impact Analysis Review is to ensure that developments which will generate a <br />significant amount of traffic, cause an increase in traffic that will contribute to traffic problems <br />in the area, or result in levels of service of the roadway system in the vicinity of the <br />development that do not meet adopted level of service standards provide the facilities <br />necessary to accommodate the traffic impact of the proposed development. <br /> <br />A common trigger for requiring a Traffic Impact Analysis relies on trip generation. <br />1 <br />Developments which generate 100 or more vehicle trips during any peak hour as determined <br />by the Institute <br />development will generate 50 trips during the AM peak hour, 69 trips during the PM peak hour, <br />and 49 trips during the weekend peak hour. The City of Eugene Engineering staff reviewed and <br />concurred Based on the estimated trip generation, <br />a TIA is not required. <br /> <br />Furthermore, due the decision, <br />which was applied for under needed housing approval criteria, a TIA is not required <br />because the applicant is proposing needed housing. Needed housing applications are entitled <br />to clear and object approval criteria, and the Hearings Official found that because the TIA <br />approval criteria are not clear and objective, they cannot be applied to needed house <br />applications. <br /> <br />1 counted in 15-minute increments between the hours 7-9 <br />AM. The four 15-minute increments that see the highest traffic counts compose the 60- <br />between 4-6 PM. <br /> <br /> <br />