East Campus University of Oregon (CA 25-02, RA 25-01, Z 25-03) <br />Findings Page 14 of 36February 2026 <br /> <br /> <br />example, expresses concern over “significant traffic, traffic safety, and parking issues related to <br />significant campus development that has occurred over the past 15 years.” This letter also <br />alleges that “Agate Street is currently failing.” FNA Transportation Committee Chairperson Tom <br />Jordan similarly alleges that the Kittelson analysis “misrepresents Agate Street’s conditions.” <br />The Council finds that these arguments conflate traffic associated with the broad range of <br />University and other local uses generally, with the more narrow range of traffic (primarily <br />student housing-related) that would be generated by the proposed amendments. The Kittelson <br />TPR Analysis concludes that current conditions on Agate Street are within acceptable levels of <br />service under City rules, and that the expected traffic increases from the proposed <br />amendments will not cause Agate Street or other local streets to fail or otherwise fall below the <br />performance standards set by the City. The Kittelson TPR Analysis therefore concludes that <br />projected traffic is within the acceptable range set forth in the state TPR. <br />Kittelson’s January 27 memo explains that its traffic counts were collected on a typical weekday <br />when the University was in normal session, during both peak and off-peak times and that <br />Kittelson’s analysis focuses on the busiest 15 minutes within the peak hour. The Council finds <br />that FNA’s assertions to the contrary are not supported by evidence in the record. <br />The Council accepts the Kittelson TPR Analysis as substantial evidence and chooses to rely on <br />that evidence given Kittelson’s expertise in traffic engineering and Kittelson’s further <br />explanation of the consistency of its methodology with the state TPR in Kittelson’s January 27 <br />technical memorandum. The Council finds that FNA’s assertions regarding Agate Street’s <br />conditions are not supported by reliable facts in the record and therefore the opponents’ <br />testimony does not undermine the Kittelson analysis. <br />2. Other methodological arguments <br />FNA’s final argument letter from February 2 disputes that the Kittelson analysis is consistent <br />with the methodology prescribed by the Highway Capacity Manual (HCM). Specifically, FNA <br />asserts that Kittelson’s analysis of Agate Street intersections is inconsistent with Chapter 15.1 of <br />the HCM with regard to “Cross-street congestion blocking through traffic [between <br />intersections].” FNA did not enter the HCM into the record or otherwise provide evidence that <br />would explain the context of the HCM provisions that they cite. <br />The University responds in its February 10 rebuttal that Chapter 15 of the HCM applies only to <br />two-lane rural highways and therefore is not relevant to the analysis of Agate Street in the <br />Kittelson TPR Analysis. <br />As described above, the Council chooses to rely on the Kittelson TPR Analysis. That document <br />explains how Kittelson performed its study in accordance with the HCM. Kittelson’s January 27 <br />memo reiterates that it performed the study in accordance with the HCM and that the HCM is <br />“recognized and accepted as the best practice throughout the United States.” FNA does not <br />offer any explanation for its qualifications to interpret and apply the HCM, and the University’s <br />rebuttal indicates that FNA is misinterpreting the HCM. The record reflects that City Staff also <br />support Kittelson’s TPR Analysis. The Council therefore rejects FNA’s arguments regarding the <br />methodology of Kittelson’s TPR Analysis.