Hathaway Koback <br />Connors up <br />520 SW Yamhill St. <br />Suite 235 <br />Portland, OR 97204 <br />E. Michael Connors <br />503-205-8400 main <br />503-205-8401 direct <br />mikeconnors(cDhkclla.com <br />September 6, 2016 <br />VIA HAND DELIVERY <br />City of Eugene Planning Commission <br />Kristen Taylor, Chair <br />John Barofsky, Vice-Chair <br />Steve Baker <br />John Jaworski <br />Jeffrey Mills <br />Bree Nicolello <br />William Randall <br />99 W. 10°i Avenue <br />Eugene, OR 97401 <br />Re: Eugene Towneplace Suites (WG 16-1/SR 16-1/ARB 16-3) <br />Valley River Inn - Response to Appeal <br />Dear Commissioners: <br />Received in Public Hearing <br />City of Eugene Planning & Development <br />SEP 06 2016 <br />File W G No- <br />Exhibit 2 <br />This office represents Rockbridge Capital, the owners and operators of the Valley River Inn <br />located at 1000 Valley River Way, Eugene, OR 97401 ("Valley River Inn"). We are submitting <br />the following response to Valley Hospitality, LLC's (the "Applicant") appeal of the Hearings <br />Official's decision, dated August 5, 2016, denying the application for the proposed 101-room <br />hotel (the "Application"). For the reasons provided below, Valley River Inn respectfully <br />requests that the Planning Commission dismiss or deny the appeal and affirm the Hearings <br />Official's decision. <br />Background <br />As Valley River Inn explained in the initial hearing process and the Applicant readily admits, <br />this particular site is extremely challenging due to its access, size, configuration and proximity to <br />the Willamette River. As a result of these site constraints, a 101-room hotel is simply not <br />appropriate on this site. This problem is reflected by the fact that the Applicant is requesting <br />numerous adjustments to the approval standards and failed to demonstrate compliance with <br />several applicable approval criteria. <br />Valley River Inn raised its concerns and addressed those approval criteria the Applicant did not <br />adequately address at the first public hearing before the Hearings Official on June 8, 2016. <br />Rather than take these concerns seriously, the Applicant elected to play procedural games and <br />