of construction. Owners of property with private preservation areas may build 200 sq. <br />foot out buildingsÄas many as they want to per lot. Those out buildings and the storm <br />water system will require access and maintenance, which will require the removal of <br />vegetation. <br /> <br />The Staff report praises the preservation area in Tract A that extends north to south and <br />east to west between lots 13 and 14. They also state that trees eliminated in the <br />preservation areas and in other areas will be replaced with trees of 1.5 inches in caliper or <br />five feet in height. The project's tree replacement plan is woefully insufficient. The <br />Application proposes to replace each felled tree (each "discretionary tree") with a new <br />one. However, the new trees will be so small (1 inch caliper for deciduous trees and 5 <br />feet tall for coniferous trees) that they will not reach the height of the removed trees for <br />generations, if at all. The Applicant might have understood this if the Eugene Planning <br />Staff had not given a waiver for the code requirement that they have a certified arborist <br />consulted in the creation of the tree preservation plan. In terms of visual impact, forest <br />health (see the foresterÈs report attached to the Joint Response Committee document), <br />small trees serve as an inadequate replacement for larger trees in terms of screening, <br />visual impact, slope stability, and forest health. A small tree cannot withstand windthrow <br />or protect surrounding trees from windthrow. It is obvious that the proposed project will <br />not "integrate" into the surrounding neighborhood for 50 to 100 years. Furthermore, <br />Planning Staff conditions weaken tree protection. The application originally stated that <br />removal of trees in preservation areas "must be documented by a certified <br />and approval <br />arborist. Documentation must be provided to the City for review prior to <br />tree removal activity." The proposed change suggested by the Eugene Planning Staff has <br />no <br />deleted the "required approval" phrase. Therefore, removal of preservation trees <br />longer requires city approval....only city "review." <br />Knowingly or unknowingly, the <br />Eugene Planning StaffÈs recommendations have weakened tree preservation. <br /> <br />Also in the proposed changes to Note #8 on sheet L3.0, Eugene Planning Staff indicates <br />that "Any trees that must be replaced within private preservation areas are the <br />responsibility of that lot owner." The March 3, 2017 version of the Application called for <br />each lot owner to manage their individual lot preservation area; however, more recent <br />versions have the HOA shouldering the responsibility for this maintenance (Page 26 of <br />the 8/22/17 Application). This confusion emanates from the absence of draft CC&Rs and <br />so many revisions to the Application. If the City Planners can't get it straight, how is the <br />community expected to do so. The Eugene Planning Staff also states that the city will not <br />enforce CC&Rs, a statement that undercuts the seriousness and adequacy of the tree <br />preservation plan. In addition to adding that trees removed in Tract A for installation of <br />the storm water drainage system will need to be replaced at a rate of 2 new for everyone 1 <br />removed, this proposed condition eliminates the previous time frame for replacement of <br />these trees in this portion of Tract A. The original applications stated that trees would be <br />replaced in the "fall of the year after completion of the work as accepted by city." Now <br />there is no time frame for replacement trees. This proposed new paragraph also uses the <br />final phrase "planted in the same general area." This language is too vague to provide <br />adequate preservation of trees. Once again, the Eugene Planning Staff has weakened the <br />tree preservation plan with their proposed changes. <br /> <br />