Page 6 <br />June 22, 2016 <br />9. Willakenzie Area Plan Policies. <br />The Applicant failed to demonstrate compliance with the Willakenzie Area Plan Policies, <br />Commercial Area Design, Policy 10. Policy 10 provides that: "commercial area entrance <br />driveways should be provided with a minimum eight-foot-wide planting strip between the entry <br />drive and the parking areas." The Applicant admits that the proposal does not comply with this <br />criterion for the portion of the entrance driveway adjacent to the McGrath's Fish House <br />restaurant. The Applicant did not request an adjustment to this standard as part of the <br />supplemental submittal nor is an adjustment allowed.2 <br />10. EC 9.8815 - Willamette Greenway Permit. <br />The Applicant failed to demonstrate compliance with EC 9.8815(1). EC 9.8815(1) requires the <br />Applicant to demonstrate: "To the egr atest possible degree, the intensification, change of use, or <br />development will provide the maximum possible landscaped area, open space, or vegetation <br />between the activity and the river." (Emphasis added). The Applicant claimed it complies with <br />this criterion because "roughly 16,000 square feet will be improved with ornamental landscaping <br />or native plants" and "Thus, approximately 60 percent of the area of this site located within the <br />Willamette Greenway boundary will be landscaped." Revised Application Narrative, pp.60-61. <br />In our June 8 letter and testimony, we challenged the accuracy of these figures and alleged based <br />on a review of the site plan that the developed portion of the area within the Willamette <br />Greenway boundary constitutes at least 50 percent of this area. The Applicant's Exhibit E1, <br />submitted as part of is supplemental submittal, confirms our interpretation of the site plan. <br />Exhibit E1 shows that 36.6 percent of the area will be building & paving, 4.1 percent will be <br />sidewalks and 8.1 percent will be storm management and fire access areas. Therefore, a total of <br />48.8 percent of the Willamette Greenway area will be developed. <br />Regardless of whether the Applicant is developing 50 or 40 percent of the Willamette Greenway <br />area, this proposal hardly qualifies as preserving this area to the "greatest degree possible." The <br />Applicant failed to demonstrate that it is not possible to reduce the size of the hotel building or <br />remove the parking in this area since it is not necessary to satisfy the parking requirements. The <br />Applicant may desire a 101-room hotel with 111 parking spaces from a business perspective, but <br />that is not a legitimate basis for demonstrating that the maximum possible landscaped area, open <br />space, or vegetation has been provided to the "greatest degree possible." <br />Conclusion <br />As the Applicant readily admits, this particular site is extremely challenging due to its access, <br />size, configuration and proximity to the Willamette River. As a result of these site constraints, a <br />101-room hotel is simply not appropriate on this site. This problem is reflected by the fact that <br />the Applicant is requesting several adjustments to the approval standards and failed to <br />2 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 />