insignificant changes in trip generation and parking needs may be necessary to show that a proposed <br />modification is insignificant, they do not.demonstrate conclusively that such is the case. <br />A few other conclusions made by the planning staff merit comment, as future applications may be based in part <br />on assertions that if a proposed modification better meets design criteria, or is an insignificant change, or that <br />if a modification is consistent with conditions imposed on a prior approval those modifications are necessarily <br />insignificant. It may be that the -changes -will include feature that will make the development more consistent <br />with existing design standards, but that is not relevant to the question of whether the proposed modification -is <br />"insignificant. "A waiver or change to a particular design standard may make a development more consistent <br />with existing development, while consistency with new design standards may change the 'feel" of the approved <br />development insignificant ways. Similarly, as this application shows, a proposed modification may he <br />consistent with prior approvals for the property, yet still result in more than insignificant changes in the <br />physical appearance of the development, the use of the site and impact on the surroundingproperties." (See <br />attached decisio71.) <br />Asa specific example, the comments from Public Works Department erroneously concludes that the proposed <br />development will have "minimal ofd site traffic impacts." <br />A reasonable person would expect that the increase in traffic arising iirom the addition of more than 1-1/2 times <br />the current number of residents' cars all at the very end of a dead-end street would have more than the <br />"least amount" of feasible impact, particularly when it would be feasible to develop the site with fewer <br />dwellings and thus reduce the additional traffic so as to be commensurate with the current per-acreage or per <br />frontage traffic levels. Put another way, a reasonable person would also find this amount of increased traffic <br />very significant and of great importance to existing residents. <br />-'he same applies to impacts on environmental quality. No reasonable-person would consider the amount of <br />rtermeable and vegetated ground area that will be lost to be the "least amount" that is feasible on this site, and <br />such a large loss would certainly be considered very significant, following the interpretation in MDA 05-2. <br />As the findings in MDA 05-2 make clear, standards that require "minimal" or "insignificant" impacts present <br />bigh bars, but they are the law; and proposed PUD developments are required to clear that bar. <br />The application in this case does not come close to meeting the criterion at EC 9.8320(12) and must be denied <br />or modified. <br />Paul Conte <br />1461 W. 10th Ave. <br />Eugene, OR 97402 <br />Paul Conte <br />54],.344.2552 <br />969 <br />