opportunities, water quality and ecological restoration of the river during'the last 10 years. Several <br />citizen groups have formed to advocate for the cleanup of the river and to create more miles of trails and <br />access points along the river. Adding 7 large multi-storyimpervious buildings and multiple tons of gravel <br />fill to the Greenway, is in essence eradicating any benefits that may be gained from the habitat <br />improvement and tree planting that has been undertaken by local volunteers. The proposed area is <br />heavily used and revered by residents. This is truly one of those Greenway areas that should not be <br />allowed to become another'sacrifice zone to high-priced condominiums. <br />The greenway also lives on in Goal 15 of our 19 statewide land use planning goals. Under this goal, local <br />governments are responsible for reviewing new or intensified development within the greenway <br />boundary- an erratic line officially depicted in Eugene's planning archives only on faded maps from the <br />Nixon era. The shortcomings of the Willamette Greenway are often unappreciated by those who know <br />the greenway as simply a core legacy of Oregon's progressive land use planning. But this wonderful idea, <br />once pursued with enthusiasm and vision, has atrophied. A continuous riverside corridor seems an <br />extremely remote possibility. Approving additional. development such as this PUD within the Greenway <br />solidifies the near- impossible vision of an ecologically intact river corridor that provides both direct and <br />intrinsic benefits to Oregonians, as well as sane land use development. This Greenway permit must be <br />denied in order to ensure continued sustainable growth for city residents, downstream neighbors and <br />generations to.come. <br />The Metro Plan goal requires Eugene, Springfield, and Lane County to adopt Greenway boundaries, to <br />specify uses permitted within those boundaries, and indicate areas of potential acquisition along the <br />Greenway. This PUD area should be one of those acquisition--the adjacent land to the east and south are <br />already in public ownership--the City should consider denying this permit and offering to further expand <br />opportunities for public access and enjoyment of this river area. <br />The PUD record fails to provide substantial evidence that EC. 9.8800 can be satisfied. Intensification of <br />uses, changes in use, or developments require special consideration before being permitted within the <br />boundaries of the Willamette River Greenway. Special consideration is required to implement Oregon <br />Statewide Planning Goal 15, Willamette River Greenway which is designed to protect, conserve, enhance, <br />and maintain the natural, scenic, historical, agricultural, economic, and recreational qualities of lands <br />along the Willamette River. The goal itself defines "change of use" and "intensification": "Change of Use <br />means making a different use of the land or water than that which existed on December 6, 1975. It <br />includes a change which requires construction, alterations of the land, water or other areas outside of <br />existing buildings or structures and which substantially alters or affects the land or water." Gunderson, <br />LLCv. City of Portland, 243 Or. App. 612, 628,.259 P.3d 1007, 1016 (2011) appeal allowed, 351 Or. 586, <br />274 P.3d 857 (2012) and affd, 352 Or. 648, 290 P.3d 803 (2012). The PUD will gravely intensify and <br />change the current use from open meadow used as park, habitat, and drainage area, to dense condo <br />development containing mostly impervious surfaces; gravel, and non-native vegetation (which may also <br />increase the amount of chemicals, fertilizers and other toxic run-off). Although the developers stated that <br />they were going to construct'green housing,' the current plans are not even LEED certified raising further <br />concerns regarding impacts to the Greenway from building materials and run-off. <br />The PUD application also fails to provide substantial evidence demonstrating that the EC 9.8815 ' <br />Willamette Greenway Permit Approval Criteria and Standards can be met. Willamette Greenway permit <br />approval may be granted only if the proposal conforms to all the criteria in subsections (1) through (4), <br />and the applicable standards of subsection (5). We take each relevant standard in turn. <br />(1) To the greatest possible degree, the intensification, change of use, or development will provide the <br />maximum possible landscaped area, open space, or vegetation between the activity and the river. <br />9 <br />805 <br />