or mechanisms to ensure continued protection, or otherwise specifically address the areas of <br />likely conflict, such as installing non-native grass lawns within the /WR conservation area, the <br />need for steps and hand rails to access the area outside of the keystone block wall, etc. <br />The proposed lot configuration clusters the smallest developable areas adjacent to, and <br />encroaching into, the /WR conservation area. This necessitates a crossing that disrupts the <br />resource and vegetation and both increases the demand for use of the /WR conservation area <br />and the likelihood of disruption via activities associated with residential use (including <br />activities that are permitted outright, permitted subject to SDR approval, or are prohibited). <br />• The proposed crossing and development west of the crossing, and associated impacts to natural <br />resources, are not necessary to achieve any R-1 zone density requirement (there is no <br />minimum) or the proposed density on the subject site. <br />• The proposed PUD incorporates lot configurations, conservation boundaries, and visual cues <br />that encourage confusion regarding the extent of the regulated /WR conservation area and <br />permitted activities. The fence within the tract suggests lower need for enhancement and <br />maintenance. The conservation tract under separate ownership creates the impression that a <br />different level of protection is afforded for property outside the tract. Based on enforcement <br />history for much larger lots in the Mirror Pond Subdivision to the north with protection <br />measures applying to a portion of the lot, it does not appear implementation of required use <br />restrictions and protection measures for much smaller lots is feasible, whereas inclusion of the <br />/WR conservation area within a separate open space tract managed by the homeowners <br />association could provide a more feasible alternative for protection. <br />The removal of the proposed berm is an unnecessary disruption within the /WR conservation <br />area and is not necessary to accommodate vegetation enhancements and has not otherwise been <br />demonstrated to enhance the riparian resource within the /WR conservation area. <br />• The applicant does not substantiate that the crossing is situated to reduce impacts to vegetation <br />within the channel. <br />The applicant does not demonstrate that the proposed crossing is engineered to reduce impacts; <br />the proposed gabion design is less durable relative to other options and is more likely to <br />necessitate repairs that will disrupt the channel and associated vegetation than known <br />alternative culvert crossing designs. The applicant does not otherwise establish that the <br />proposed culvert maintains the 100-year storm event capacity without significant impacts on <br />the natural drainage course and upstream and downstream capacity and that the extensive <br />gabion system with a closed-bottom culvert protects the Goal 5 resources and avoids <br />unnecessary disruption to the greatest extent feasible. <br />The applicant's proposal to modify PUD lot requirements will facilitate unnecessary disruption <br />of natural resources. <br />The applicant responds that staff either improperly conflates approval standards, or imports additional <br />restrictions where none exist. For example, the applicant asserts that conditions of approval can be <br />imposed to require that CC&Rs clearly address permitted activities within the /WR conservation area, <br />and the city can enforce those regulations against individual property owners. Further, the applicant <br />argues that staff s concerns regarding the inclusion of conservation areas in up to 33 percent of a lot <br />Alder Woods PUD (PDT 07-5 & SDR 08-2) <br />Page 18 <br />Laurel Ridge Record (Z 15-5) Page 1146 <br />