Mr. James Spickerman <br />September 3, 1994 <br />Page 2 <br />(f) Proposed buildings, road, and other uses are designed and sited to assure <br />preservation of significant on -site vegetation, topographic features, and other <br />unique and worthwhile natural features, and to prevent erosion or flood hazard. <br />Section 9.589 Parking Area Landscaping and Screening Standards, sub - section (2) (i) states: <br />"New developments with existing significant vegetation on site are encouraged to <br />preserve and integrate the vegetation into the design of the development." <br />As is the case for a majority of the Goodpasture Island PUD, the existing elevation is such that we <br />are required to raise it to 1' above the flood plain elevation for all structures. The proposed grading <br />plan is based on meeting that criteria together with the provisions of the "Americans With <br />Disabilities Act" with respect to providing access to the living units. As such we will be <br />undertaking significant grading of the site which will impact the existing vegetation. In an effort to <br />determine how these somewhat conflicting requirements for access, flood control and vegetation may <br />be reconciled we further looked to the code and have focused on the provision for minimizing the <br />removal of significant vegetation. <br />Currently three types of vegetation exist on the site. First are the typical grasses and weeds that <br />comprise most vacant parcels of land. Second, the bulk of the site is covered in Blackberries (Rubus <br />'Himalaya). Third are trees of two varieties. The primary tree on the site are Cottonwoods (Populus <br />trichocarpa). In addition there are three 24" caliper Maple Trees (Acer macrophyllum) located in the <br />southwest corner of the site. No Heritage Trees are located on this site. We believe the Blackberry <br />bushes and the Cottonwood trees do not meet the code criteria for being declared significant and <br />request that we be allowed to remove these trees as a part of our grading efforts on the site. <br />Justification for this request is as follows: <br />Blackberries (Rubus 'Himalaya) are described on page 203 of the 1979 edition of Sunset New <br />Western Garden Book as: <br />"Seldom sold but has escaped and grows wild wherever adapted. Can be a <br />prodigious, spreading pest." <br />The City of Portland considers them to be a noxious weed (due to their invasive nature) and their <br />removal from the proposed building site should be encouraged, not restricted. Blackberries could <br />possibly be considered a significant plant if the intent of the zoning had been as a wildlife preserve <br />or agricultural tract. <br />Cottonwood trees (Populus trichocarpa) are typically found in low areas or along streams, and appear <br />to be most at home (or significant) in natural settings. They are soft - wooded, short lived, drop a <br />large amount of cottony seed masses and break up easily in wind and ice storms (not an uncommon <br />occurrence in Eugene). They are described in the 1979 edition of Sunset New Western Garden Book <br />which warns: <br />"Do not plant near water or sewer lines, septic tanks or their leach lines. Roots are <br />invasive - not for city streets, lawns or small gardens." <br />Serious conflicts with development are anticipated if the Cottonwood trees are required to be <br />preserved. These include: <br />1. Extreme difficulty removing and reworking soil in order to achieve flood <br />control and subsurface structural integrity to support multi - family <br />development. (Refer to Geotechnical Resources Incorporated Foundation <br />Investigation Report dated August 24, 1992.) <br />2. Extreme difficulty in achieving a realistic density of development to make the <br />project economically feasible. <br />3. Safety hazards to future residents. <br />