of those river. features. This PUD absolutely fails to meet this standard as demonstrated throughout these <br />comments. <br />(5) The PUD fails to comply with Metro Plan D.8 because it fails to ensure public enjoyment and <br />actually hinders access to the river corridor park area. Instead, a large portion of this Greenway area (at <br />least the area adjacent to the park and on the floodplain should be acquisition by the City to be placed in <br />park status. <br />EC 9.8815 (5) states, "In areas not covered by subsection (4) of this section, the intensification, change of <br />use, or development shall conform with the following applicable standards: <br />(a) Establishment of adequate setback lines to keep structures separated from the Willamette River <br />to protect, maintain, preserve, and enhance the natural, scenic, historic, and recreational qualities of the <br />Willamette Greenway. Setback lines need not apply to water related or water dependent activities as <br />defined in the Oregon Statewide Planning Goals and Guidelines (OAR 660-15-000 et seq.). <br />As discussed above, there are no setbacks between the development and the Greenway river corridor- <br />the building is practically touching their property line. <br />(c) Protection and enhancemen tof the natural vegetative fringe along the Willamette River to the <br />maximum extent practicable. <br />As discussed above, instead of vegetation along the property boundary, there will be large condos with no- <br />screening at all. The PUD fails to comply with this standard and it should apply because the adjacent land <br />is river corridor open space and this standard is not meant to solely apply to the extremely thin strip of <br />land between the river itself and the bike path. Raptors, beavers and other wildlife need more than 10-15 <br />feet of habitat, and thus use the open space areas across the bike path extensively and thus the natural <br />vegetative fringe is imperative and must be protected on this site. <br />(g) Compatibility with recreational lands currently devoted to metropolitan recreational needs, used <br />for parks or open space and owned and controlled by a general purpose government and regulation of such <br />lands so that their use will not interfere with adjacent uses. <br />As discussed at length, maximum density condo development with no setbacks or screening adjacent to <br />recreational lands directly interferes with adjacent park and open space uses. At a minimum, the current <br />site plan is designed with the buildings facing the grassy open space park area and has no screening, <br />fencing, or boundary, and creates the illusion that the city property belongs to the OMC development. <br />In addition, the PUD fails to comply with the Lower River Road Concept Plan (2009) regarding <br />Greenway and open space criteria. In 2009, the Planning Commission approved the Lower River Road <br />Concept Plan as the refinement plan for the area. The WG and Rasor Park were top priorities within this <br />plan. "In keeping with its Greenway setting, this Concept Plan envisions that development and <br />landscaping, and especially land adjacent to the Willamette River, will reflect a deep connection to the <br />river and associated natural values of the riparian landscape. River parks will be managed as an <br />important wildlife corridor, and as a unique and treasured natural asset. Landscaping, signage, <br />pedestrian routes, and view corridors will inform travelers along River Road that they are near the river." <br />LRRCP p. 6. The plan mandates that future land use near'the river corridor region (as opposed to the <br />commercial area near River Road) must "maintain as relatively undeveloped zones to mitigate the <br />impacts of dense development nearby.... Serve as refuge and passive recreation for residents [and <br />species such as eagles, osprey, beavers and more], and provide children with a place for unstructured <br />exploration and play, and a rare place to experience nature in the urban environment." LRRCP p. 7. The <br />Plan envisioned dense development adjacent to River Road and thus the current condo development fails <br />to comply with these standards. Regarding development adjacent to Greenway Parks, the Plan also <br />requires "the natural character and ecological values of the river corridor will be visually and functionally <br />extended throughout the Willamette Greenway via conservation easements and native and naturalistic <br />landscaping." Thus the refinement plan further argues for city acquisition of at least the portion of the <br />11 <br />807 <br />