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triggers the need to address the TPR, the applicant is required demonstrate consistency with the specific provisions within OAR 660-012-0060, which ultimately ensures compliance with Goal 12. To do this, an applicant submits a transportation study prepared by a professional transportation engineer to assess the expected transportation system impacts associated with a proposed amendment or zone change on the long-term viability of the transportation system. In this case, the applicant triggered the requirement to perform a TPR because they are proposing an amendment to the Metro Plan diagram, which changes the number of theoretical trips that could be generated from the site. Therefore, the City must assess whether the transportation system can handle the theoretical change in development potential. A TIA, on the other hand, applies at the time of development. The stated purpose of a TIA is to ensure that developments which will generate a significant amount of traffic, cause an increase in traffic that will contribute to traffic problems in the area, or result in levels of service of the roadway system in the vicinity of the development that do not meet adopted level of service standards provide the facilities necessary to accommodate the traffic impact of the proposed development. A common trigger for requiring a TIA relies on trip generation. Developments which generate 100 or more vehicle trips during any peak hour' as determined by the Institute of Transportation Engineer's (ITE) Trip Generation manual generally trigger a TIA. As it relates to this property, a TIA may be triggered in the future based on the number of trips generated by future development. Accuracy of Applicant's TPR Analysis Neighbors and some commissioners expressed concerns regarding the accuracy of the applicant's TPR analysis. Primary among the concerns is that the TPR analysis does not accurately reflect current conditions. Additionally, concerns have been raised that the reasonable worst-case scenario analysis provided appears to "game the system" in favor of the applicant. One specific concern is that TPR traffic counts may be lower due to current COVID-19 restrictions. However, while business and employment closures and public health restrictions may have certainly decreased traffic, the applicant's intersection traffic counts occurred in August 2019. Given this fact, staff believe the applicant's traffic counts accurately reflect current "normal" conditions. Another concern was related to the accuracy of the applicant's "reasonable worst-case scenario." The Transportation Planning Rule (TPR) requires a determination of whether the amendment would involve a "significant effect" to the City's transportation system, and if so, to provide mitigation measures to address that impact. This determination relies on identifying "before" and "after" reasonable worst-case land use assumptions and comparing theoretical trip generation numbers. The TPR does not include a specific methodology for a reasonable worst-case analysis, which is generally dependent on local zoning, land use regulations, and traffic engineering expertise. ' To determine the AM "peak hour," vehicles are counted in 15-minute increments between the hours 7-9 AM. The four 15-minute increments that see the highest traffic counts compose the 60-minute "peak hour" that is used for analysis. The same is done for PM peak hour, but the time of measurement is between 4-6 PM.