EC 9.5500(11)(b) and (b)(2) fall within the definition of ,is defined <br />as ed or unimproved public or private way, other than an alley, that is <br />created to provide ingress or egress for vehicular traffic to one or more tax lots or parcels, <br />riveswhen it states that \[p\]arking <br />drives are driveways The applicant argues that \[t\]he driveways do not provide <br />ingress and egress to one or more lots or parcels. They provide internal access within the <br />Subject Property.iveways clearly allow access to the lot and the site of the <br />development. Until the applicant subtracts that acreage, the net density calculation is <br />erroneous. <br />Because the net density calculation is a matter of addition and subtraction, it falls <br />squarely within the clear and objective criteria the applicant alleges are applicable. In <br />other words, the net density calculation is not a product of e-laden <br />analysis that are designed to balance or mitigate impacts of a development on (1) the <br />property to be developed or (2) the adjoining properties or community. <br />Next, the reason that the TIA provisions are applicable is that they address the <br />traffic and not the actual residential buildings. The applicant has not pointed to anything <br />in the statute that purports to render a TIA ineffective simply because it is associated with <br />a housing application. <br />The applicants argument that the Willamette River Greenway is also rendered <br />ineffective is also meritless. HB 1051 (2017) did not specifically address housing that is <br />placed within the Greenway. It is simply the standards within whatever residential zone <br />is at issue. It does not go beyond the residential zone into other overlay-type zones such <br />as the Willamette Greenway Provisions. As explained above, the same is true of the TIA, <br />which is a requirement independent of the criteria for the residentially-zoned property. <br />Attached hereto is further analysis by Greenlight Engineering in response to the <br />Sandow Engineering letter that was submitted on July 9, 2019. <br />For the foregoing reasons, the application must be denied. <br /> <br />Sincerely, <br /> <br />Sean T. Malone <br />2 <br /> <br />