PDF Page 51 <br />Opponents and staff might argue that more than one or two dwellings is OK. But why is that, if <br />the object is to meet SHS and PUD protection objectives? Where does one draw the line on <br />how many houses? Each additional house is another ding on the objectives. Put differently, <br />starting with the Staff Report recommendation for.fewer dwellings, how low does the applicant <br />need to go in terms of a dwelling count irf order to earn favorable consideration from the staff? <br />And what would be the justification for that number, which could be reduced to findings that <br />are reasoned and based on the evidence. An unhappy opponent could appeal the approval <br />with two dwellings and make an. empirical case for shorting the SHIS and PUD objectives. <br />What makes sense is to posit the 5 du/ac cap as being the acknowledged ultimate policy choice <br />about how far to mitigate the adverse impacts of housing on the South Hills Goal 5 visual <br />resources, At that point, the inquiry in the PUD review shifts to how best to arrange that <br />proposed density on the site. <br />(c) Previous PUD approvals under the South Hills Study. <br />The city's track record of PUD approvals in the South Hills supports the approach discussed <br />above - honoring the density cap as the city's ultimate policy choice for the number of units <br />allowed. The Hearing Official has demonstrated a willingness to posit the proposed <br />development first, and then make tree preservation, for example, a secondary consideration. <br />One example is the Friendly Place PUD, PDT 08-6 (Oct. 10, 2008), a copy which appears in the <br />applicant's Prehearing Exhibits as Exhibit 3-1.2. There the Hearings Officer approved removing <br />all 16 significant trees from the site. She explained that while the tree preservation standards <br />are designed to protect trees, tree removal must occur to facilitate development. The <br />commercial zoning of the property and the proposed density of the development made it <br />difficult to locate development such that trees would have a reasonable chance of survival, See <br />Decision at S. <br />Summary <br />In summary, the correct approach is to treat the 5 du/ac density cap as a presumed allowed <br />density, based that density being part of the acknowledged Goal 5 program. The question then <br />becomes what approaches to organizing the use on the site are an acceptable fit under the , <br />other standards. This respects the Goal 5 program. And it avoids the slippery slope into <br />whether one or two dwelling units on the entire site is a better plan. <br />2. South Hills PUDs as an exercise in making trade-offs among conflicting values. <br />The approval standards for a South Hills PUD appear in both the SHS and the PUD sections of <br />the code. They amount to a long list of values that are intended to be preserved or enhanced. <br />These include: road connectivity, natural features, habitat, stormwater mitigation, view shed, <br />buffering, trees, stability of development, wetlands, riparian areas, significant vegetation, <br />compatibility with surroundings, solar, life/safety access, block length, views, and many more.. <br />LaurelRidge Applicant Final Argument - Page 17 <br />100 <br />Laurel Ridge Record (Z 15-5) Page 855 <br />