Page 3 <br />June 8, 2016 <br />basis for failing to comply with this requirement. At a minimum, the Applicant must seek and <br />obtain approval for an adjustment. Second, the Applicant failed to address the frontage along <br />Delta Highway/I-105. <br />3. EC 9.2170(10) - Underground Utilities. <br />The Applicant failed to demonstrate compliance with the underground utility requirements set <br />forth in EC 9.2170(10). EC 9.2170(10) provides: "All utilities on the development site shall be <br />placed underground." The Applicant admits that the "daylight stormwater facilities" are not <br />underground. This aspect of the proposal does not comply with EC 9.2170(10) and the <br />Applicant did not seek an adjustment. <br />4. EC 9.2173(4)(a) - Off-Street Parking. <br />The Applicant failed to demonstrate compliance with the off-street parking requirements set <br />forth in EC 9.2173(4)(a). EC 9.2173(4)(a) provides: "No off-street parking shall be located <br />between the front facade of any new building(s) and the primary adjacent street." The Applicant <br />asserts that Delta Highway/I-105 is the "primary adjacent street" for purposes of this criterion <br />but does not explain why. Valley River Drive is the primary adjacent street, not Delta <br />Highway/I-105, because it provides the sole access to the site. Delta Highway/1-105 cannot be <br />the primary adjacent street since it provides no access and is at a different elevation. Since there <br />is off-street parking between the front facade and Valley River Drive, and the Applicant did not <br />seek an adjustment for this non-compliant component of the proposal, the Application does not <br />comply with this criterion. <br />5. EC 9.2173(6)(d) - On-Street Pedestrian Circulation. <br />The Applicant failed to demonstrate compliance with the on-street pedestrian circulation <br />requirements set forth in EC 9.2173(6)(d). EC 9.2173(6)(d) applies to all customer entrances: <br />"Internal pedestrian walkways provided in conformance with subsection (a) above shall provide <br />weather protection features such as awnings or arcades within 30 feet of all customer entrances." <br />(Emphasis added). Similarly, the requirements set forth in EC 9.2173(6)(a) also expressly apply <br />to "all customer entrances." <br />Notwithstanding this clear and unambiguous language, the Applicant only addressed the main <br />entrance on the east side "per guidance provided by the City of Eugene staff." Regardless of this <br />guidance, the Applicant is required to provide weather protection features for all customer <br />entrances. <br />6. EC 9.6780 - Visual Clearance Area. <br />The Applicant failed to demonstrate compliance with the visual clearance area standards set forth <br />in EC 9.6780. EC 9.6780 provides: "Development sites shall have triangular vision clearance <br />areas on all street corners to provide for unobstructed vision consistent with American <br />Association of State Highway and Transportation Officials (AASHTO) standards." The <br />Applicant states that the existing access "is assumed to comply with the vision clearance <br />