Eugene Planning Commission <br />May 2, 2018 <br />Page 2 <br />LEC 9.8320 (2) PUD consistent with applicable adopted refinement plan (South Hills Study) <br />The HO's decision states on page 21 (emphasis added in red): <br />For purposes of compliance with the South Hills Study, the applicant has recognized the existence <br />of conditions #1 and #S listed above and, accordingly, has provided an in-depth, detailed analysis <br />that includes an "adequate review of both on-site and off-site impact" of the proposed PUD as <br />required by the South Hills Study. While critical of the applicant's methods and analysis, Dr. <br />Gunnar [sic] does not dispute the scope of the study or provide evidence that it does not adequately <br />consider both on-and off-site impacts. <br />La. "In-depth, detailed analysis" <br />The applicant's geotechnical study does not, as the HO's decision states, rise to the level of an "in- <br />depth, detailed analysis", a fact that was readily admitted by the applicant's geotechnical engineer: <br />"I feel it should be stated that the report was intended to be a preliminary investigation for <br />planning purposes with a concentration on the proposed road layout..."' <br />A "preliminary investigation with concentration on the proposed road layout" is afar cry from an <br />in-depth, detailed analysis of the entire parcel for determination of the suitability of the property for <br />the proposed use and an assessment of potential on- and off-site impacts. The applicant's more <br />detailed investigation was conducted over less than 20% of the total area of the PUD and completely <br />ignored significant on- and off-site indications of slope instability, including the landslide scarps <br />mapped by their own engineering geologist. It does not constitute an "adequate review of both <br />on-site and off-site impacts", as required by the South Hills study. <br />Lb. "Dr. Schlieder does not dispute the scope of the study or provide evidence..." <br />The fact that the HO states that GeoScience testimony "does not dispute the scope of the study or <br />provides evidence that it does not adequately consider both on-and off site impacts" demonstrates <br />that the HO failed to read or comprehend the materials submitted by GeoScience at the hearing and <br />during the open record period. Had Ms. Gustafson-Lucker read the GeoScience report, on page 4 <br />she would have seen, in bold-face, underlined, capital letters the heading: <br />"INADEQUATE AND BIASED ASSESSMENT AREA "Z <br />'Branch Engineering letter dated March 20, 2018, second paragraph) <br />2GeoScience Technical Review, GeotechnicaUGeologic Assessment and Addendum Capital Hill PUD, <br />March 7, p. 4 <br />