With all that said, we touch on the highpoints here. <br />The core of the City Attorney's pitch is a labeling exercise. Whereas the goalpost statute refers <br />to "standards and criteria," the City Attorney uses the term "development standard" to refer to <br />new or amended standards and criteria that the City wants to apply in the future despite the <br />statute. "Development standards" in the City's parlance are really just "standards and criteria" <br />with different labels. <br />The four substantive areas of concern to the City are: Multi-Family Standards adopted in 2002; <br />Goal 5 standards adopted in 2005; Stormwater Standards adopted in 2006; and TIA standards <br />adopted in 2002. <br />Multi-Family Standards in EC 9.5500: The Applicant's counsel explained at the <br />hearing that it was the prospect of the impending Multi-Family standards in 2002 that prompted <br />the filing of this application. The reason is that this project can't comply with the standards. For <br />example: <br />Street Frontage. EC 9.5500(4)(b) sets building frontage requirements on Willamette <br />Street that can't be met: <br />"On development sites that will result in 100 feet or more of public or <br />private street frontage, at least 60 percent of the site frontage abutting the <br />street (including required yards) shall be occupied by a building(s) or <br />enhanced pedestrian space with no more than 20 percent of the 60 percent <br />in enhanced pedestrian space, placed within 10 feet of the minimum front <br />yard setback line." <br />Block Requirements. EC 9.5500(10)(a) would require creating city blocks throughout <br />this site, with attendant impacts trees, topography and neighbors' buffering. <br />"Block Structure. Multiple-family developments 8 or more acres in size <br />shall be developed as a series of complete blocks bounded by public or <br />private streets. Natural areas, waterways, high voltage power lines, and <br />other similar substantial physical features may form up to 2 sides of a <br />block. The maximum block size within a multiple-family development <br />shall be no greater than 4 acres in size. (See Figure 9.5500(10) Multiple- <br />Family Block Requirements.)" <br />Vehicle Parking; Parking Courts. EC 9.5500(12)(b) sets design standards for "parking <br />courts" that would radically change the site design and push development closer to the <br />neighbors. <br />"Parking Courts. <br />1. Maximum Size of Parking Courts. Individual parking courts shall <br />be no more than 9,000 square feet in size and shall be physically and <br />visually separated by a landscape area a minimum of 20 feet in width. No <br />APPLICANT'S FINAL ARGUMENT - Page 4 <br />Cathedral Park (CU 02-4) Record July 2016 <br />