Page 4 <br />June 22, 2016 <br />parking between the front fagade and Valley River Drive, and the Applicant did not seek an <br />adjustment for this non-compliant component of the proposal, the Application does not comply <br />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 Application only addressed the main <br />entrance on the east side "per guidance provided by the City of Eugene staff." The elevations <br />submitted by the Applicant as part of the supplemental submittal do not satisfy EC 9.2173(6)(d) <br />because there are not 30 feet of weather protection features along all entrances. <br />6. EC 9.6792 - Stormwater Quality. <br />The Applicant failed to demonstrate compliance with two aspects of the stormwater quality <br />standards set forth in EC 9.6792. First, EC 9.6792(3)(a) requires the Applicant to submit a site <br />development plan that demonstrates certain infiltration rates, bedrock, groundwater elevations <br />and ground surface slopes conditions exist on the site and EC 9.6792(3)(d)(1) requires the <br />Applicant to submit a report that demonstrates at least one of these conditions exists to ensure the <br />stormwater runoff can be adequately accommodated on-site. The Applicant admitted that <br />"Geotechnical work has not yet been completed," the preliminary information they provided <br />confirms that "these conditions will be verified with the geotechnical report to be submitted with <br />the building permit" and the Applicant failed to provide additional information as part of its <br />supplemental submission. These site development standards cannot be deferred to the building <br />permit phase when there is no opportunity for public review and comment. <br />Second, EC 9.6792(3)(d)(2) requires an applicant proposing to use the public off-site stormwater <br />quality facilities, which the Applicant is proposing in this case, to "submit a report that <br />demonstrates there is insufficient land area to construct an approved infiltration or filtration <br />facility by setting forth the required size of the smallest infiltration or filtration facility needed <br />for the development's impervious surface area and a site plan demonstrating that an approved <br />infiltration or filtration facility cannot be located on the development site without reducing the <br />size of the proposed development which is otherwise consistent with all other applicable lot and <br />development standards." Once again, the Applicant failed to submit a report or other evidence <br />supporting its claim that there is insufficient area on site to address the stormwater. <br />7. EC 9.4934 - Water Resources Conservation Overlay Zone. <br />The Applicant failed to demonstrate that its proposal to remove the 32-inch Black Cottonwood <br />tree located within the Water Resources Overlay complies with EC 9.4930(2)(k). EC <br />