<br />GIOELLO Nick R <br />From:Paul Conte <paul.t.conte@gmail.com> <br />Sent:Friday, March 30, 2018 3:04 PM <br />To:GIOELLO Nick R <br />Subject:Responsive testimony for PDT 17-1 Capital Hill Tentative PUD <br />March 30, 2018 <br />Dear Mrs. Gustafson-Lucker, <br />This testimony directly responds to testimony submitted during the first open-record period, <br />specifically the following statement by Mr. Damien Gilbert, Branch Engineering, on page 2 of his <br />March 21, 2018, "Technical Memorandum." <br />"The off-site roadway exceeds theCity standard for clear lane width of 14-feet on a local <br />street or access lane, provided the one area identified in my traffic safety study and <br />recommended for a safety improvement is followed. This is the area where approximately <br />four cars park on the downhill side of the street at approximately 2625 Capital Drive. This <br />was recommended with or without the subject development application. As you witnessed in <br />the hearing, the neighbors agree that the on-street parking is not an ideal condition. While <br />there is still no recent known accident history on this off-site roadway, the traffic study <br />recommends a safety improvement for that area." (Underline added.) <br />As I explain below the assertion that "the City standard for clear lane width \[is\] 14-feet on a local <br />street" is false. Coming from a licensed traffic engineer, this statement can only be understood as a <br />deliberate attempt to mislead the Hearings Official. The Hearings Official must not rely on this <br />deceptive statement because it is demonstrably not true. <br />The record contains the City's adopted street standards, as well as Eugene Fire Code. The most <br />relevant standard for determining unimpeded access for emergency response vehicles(EC <br />9.8320(6)) is stated in the fire code, which requires a twenty-foot-wide clear fire apparatus access <br />road from the fire station to the development site. <br />City code has a minimum paving width of 20 feet, which Mr. Gilbert deliberately left out of his <br />"expert" testimony. City code allows a 14-foot, two-way travel lane only on a street that has <br />twenty-one-foot-wide paving, and which has an adjacent seven-foot-wide, paved lane that provides <br />designated "pass-by" areas at least every 150 feet. <br />There is absolutely no place in any local standard that approves a two-way travel lane as narrow as <br />14 feet on a street that has less than 21 feet of paving. Capital Lane does not meet city standards <br />and cannot meet them without improvements, including widening the pavement and providing at <br />least one adequate sidewalk. <br />As a final comment, Mr. Gilbert gets up on his "high horse" to impugn Mr. Massoud Saberian's <br />analysis, and yet Mr. Gilbert himself has stooped toa bald-faced attempt to fool the Hearings <br />Official with what is basically a lie. This deceit would jeopardizs people's safety and potentially <br />their lives, and should not be tolerated from a licensed traffic engineer. <br />Paul Conte <br />1 <br /> <br />