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<br />4. Existing average daily traffic volumes are based on City of Eugene data that was <br />collected in 2002~ seven years ago. There is no explanation in the TIA why it was <br />used and how the validity of the data was verified for accuracy in 2007 (outside of the <br />PM Peak Hour, no new counts were taken). <br /> <br />5. As stated in the TIA, PM peak hour counts were taken in January and February of <br />2007, between the hours of 4-6 PM on a typical weekday. There is no explanation in <br />the TIA as to how it was determined that 4-6 PM on a weekday represented the worst <br />case traffic volume. There is also no explanation in the TIA how counts taken in <br />January and February represented the average or peak month for traffic congestion. <br />Traffic volumes vary throughout the year and to compensate for this a seasonal <br />adjustment factor is commonly applied. None was applied in this case. <br /> <br />In conclusion~ the TIA for the Santa Clara School Site Redevelopment PAPA is <br />inadequate for the City to make a finding of no significant impact and be consistent \Vith <br />the requirement of the TPR. It is recommended that the City either deny this application <br />based on the applicant not providing an adequate TIA or, with the consent of the <br />applicant table the application pending the preparation of a new TIA. If the decision of <br />the Planning Commission is to table the application, we would be available to work with <br />city staff and the applicant to develop a TIA scope and review draft materials which will <br />help ensure that traffic issues are adequately analyzed, and the requirement of the TPR <br />are met. <br /> <br />Please enter this letter into the record for the planning commission and upcoming city council <br />hearings. <br /> <br /> <br />c. Erik Havig, Region 2 Planning & Development Manager <br />Jane Lee, Area 5 Manager <br />Michael Spaeth, District 5 Manager <br />Marguerite Nabeta, DLCD Field Representative <br /> <br />3 <br />