Page 3 <br />June 22, 2016 <br />both sides of the accessway." EC 9.2175(3)(a). The parking area does not qualify under this <br />definition because it does not have 8-foot sidewalks on both sides. The Applicant relies on its <br />adjustment for purposes of satisfying EC 9.2170(4)(b)(4), but EC 9.2170(4)(b)(4) is not subject <br />to an adjustment because adjustments to the setback requirements are limited to "the minimum <br />and maximum front yard setbacks."' EC 9.2170(4)(e). <br />2. EC 9.2170(5) - Landscaping. <br />The Applicant tailed to demonstrate compliance with the street tree requirements set forth in EC <br />9.2170(5)(d). EC 9.2170(5)(d) imposes requirements for street frontage trees. The Applicant's <br />sole basis for not complying with this requirement is its unsubstantiated claim that "the <br />developable portion of the site does not have street frontage that would allow for installation of <br />street trees." Even if that is true, at a minimum the Applicant must seek and obtain approval for <br />an adjustment. The Applicant did not request an adjustment as part of its supplemental <br />submission. <br />Nor did the Applicant address these street requirements along Delta Highway/I-105. EC <br />9.2170(5)(d) provides that "Street tree requirements are specified in EC 7.280. EC 7.280 <br />provides that "Existing large-scale street trees on or adjacent to a development site shall be <br />retained unless approved for removal by the city pursuant to section 6.300 to 6.330 of this code <br />during site development * * and "Any street tree removed by permit through demolition or <br />construction within the street right-of-way shall be replaced within the street right-of-way at a <br />location approved by the city with a tree of similar value." The Applicant failed to demonstrate <br />that the proposed development complies with these criteria. <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. The Applicant did not request an adjustment as part of its supplemental <br />submission and therefore cannot comply with EC 9.2170(10). <br />4. EC 9.2173(4)(x) - 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 once again failed to explain why in its supplemental submission. Valley River Drive is the <br />primary adjacent street, not Delta Highway/I-105, because it provides the sole access to the site. <br />Delta Highway/I-105 provides no access and is at a different elevation. Since there is off-street <br />' EC 9.8020 provides that "Adjustment review is available only where this land use code <br />provides that a specific standard may be adjusted." The Eugene Code does not provide for an <br />adjustment to this particular standard. <br />