Hutchinson <br />Cox Attorneys <br />September 11, 2015 <br />VIA HAND DELIVERY and EMAIL <br />Attorney <br />ZACK P. MITTGE <br />zmittge(eugenelaw.com <br />Legal Assistant <br />GAIL C. CROSS <br />gcross@eugenelaw.com <br />RECEIVED <br />Eugene Planning Commission <br />c/ o Senior Planner Gabriel Flock S E P 11 2015 <br />99 West 10"' Avenue <br />Eugene, Oregon 97401 BUILDICITY NG O P EUGF-E <br />N SVCS <br />Gabriel.flocl C@d.eugene.or.us <br />Re: Oakleigh Meadow Co-Housing/Final Rebuttal (PDT 13-001) <br />Our Client: Oakleigh Meadow Co-Housing <br />Our File no: C1343D <br />Dear Commissioners: <br />. In accordance with the open record sequence specified at the Planning <br />Commission meeting on August 17, 2015, please find- enclosed ,the applicant's final <br />rebuttal. Please include this letter in the record of the City's proceedings on this <br />matter, and provide us with notice of any further actions with regard to this Tentative <br />Planned Unit Development. <br />Introduction <br />The applicant is proposing a unique and beautiful development on Oakleigh <br />Lane. Once approved, the Oakleigh Meadow Co-Housing development will provide <br />an unprecedented development within the City of Eugene, an"intergenerational <br />residential community" developed by the private householder/ members. <br />- The Co-Housing Development will provide a shared community of skills and <br />resources amongst its members while reducing environmentali impacts through <br />efficient resource implementation and economic use of building space. The proposal <br />before you is literally award-winning, and will preserve over 5070 as open space <br />(including 2070 of the property adjoining the undeveloped parkland to the east), and <br />utilizes a unique "green wall" design of espaliered trees on an 8 foot wall along the <br />western property boundary to eliminate impacts on properties to the west. <br />Significantly, on remand the opponents do not challenge the OMC PUD itself. <br />Instead, they urge that the existing road - Oakleigh Lane - is unsafe, or does not <br />conform to current City standards,. and that the PUD should be denied as a result. <br />There are several problems with this position. In particular, the opponents <br />misrepresent the content of Public Works findings, misunderstand the legal <br />requirements applicable to existing streets, and fail to establish the existence of safety <br />400 WOOLWORTH BLDG • 940 Willamette Street • MAIL: PO Box 10886 • Eugene, Oregon 97440 • PHONE: 541686-9160 • FAX: 541343-8693 <br />wmvmceugenelaw.com <br />304 <br />• <br />424 <br />