findings, and I agree with staff's conclusions. Therefore, I adopt and incorporate the findings in <br />the staff report in this decision, except as further discussed. <br />VRI.raised eleven challenges to the applicant's compliance with the applicable approval <br />criteria, and the applicant referenced those eleven challenges so I will address them in that order <br />as well. <br />1. Setbacks <br />The site review requirements of Eugene Code (EC) 9.8440(5)(k) require that the <br />application comply with certain applicable development standards, including setback <br />requirements. EC 9.2170(4)(b) provides: <br />"The maximum front yard setbacks stated in Table 9.2170 Commercial Zone <br />General Building Height and Setback Standards, shall apply only to new <br />buildings and any building addition that increases the length of the building <br />facade facing a street, internal accessway, private drive, or shopping street as <br />defined in EC 9.2175(3) by at least 100%. For purposes of this subsection, front <br />yard setback may be measured from a public street or from the edge of the <br />sidewalk furthest from the curb of an internal accessway, private drive, or <br />shopping street. In addition, all new buildings and the portion of the <br />development site specifically affected by the new building are subject to the <br />requirements of this subsection. (See Figure 9.2170(4)(b) Maximum Front Yard <br />Setbacks, Building Orientation, and Entrances.) <br />"2. In C-2 and C-3, a minimum of 25% of all street facing facades <br />must be within the specified maximum front yard setback, or, <br />orientation to an internal accessway, private drive, or shopping <br />street as defined in EC 9.2175(3) is permitted in compliance with <br />EC 9.2173(4)(a)." <br />The maximum front yard setback from Table 9.2170 for the subject property is 25 <br />feet. VRI argues that both Valley River Way and Delta Highway are front yards for <br />purposes of EC 9.2170. The proposed building would be substantially more than 25 feet <br />from both Valley River Way and Delta Highway, and would not meet the requirement <br />for 25% of all street facing facades to be within the front yard setback. The applicant <br />originally took the position that only Delta Highway was a front yard and that the <br />requirement was satisfied because the facade would be located within the setback from <br />an internal sidewalk accessway. The applicant now argues that only Valley River Way is <br />Hearings Official Decision (WG 16-1/SR 16-1/ARB 16-3) 3 <br />