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Eugene Planning Commission May 2, 2018 Page 3 It is difficult to conceive how this heading could not indicate our opinion that the scope of the applicant's assessment is in dispute. On the following page, the GeoScience report states: " All test pits were located in the more gently sloping area at the top of the ridge. None of them were excavated on the steeper slopes or in the immediate vicinity of the landslide mapped by the applicant's Engineering Geologist. The easternmost test pit (TP-5) was located on Lot 13 directly in the area between the two apparent slope movements affecting the PUD. Even TP-8, which easily could have been placed at the mapped scarp on Lot 16, was placed around 100 feet from there at the far (northern) boundary of Lot 15. No test pits at all were installed on the southernmost two lots despite significant geomorphic evidence of slope movement being present. No test pits at all were installed in the area later slated for installation of the storm-water discharge for much of the eastern half of the PUD. The 10 test pits describe an area that is on the order of 2.7 acres, which represents around 20% of the entire PUD's area. Had these test pits all been located in the much steeper eastern portion of the site, they might have provided valuable information to address EC 9.6710 and EC 9.8320. However, as it is, the test pits were installed in the most gently sloping portion of the PUD and provide no information whatever regarding the issue of stability of the east-facing slope. This is clearly insufficient to satisfy both EC 9.6710 and EC 9.8320."3 It is difficult to understand how these statements by Dr. Schlieder fail to "dispute the scope of the study or provide evidence that it does not adequately address on- and off-site impacts", or how this could be more clearly and plainly stated. How does "Inadequate... Area" not dispute the scope of the applicant's study? How does the description of the lack of test pits in key areas of the proposed PUD not constitute evidence of a lack of adequacy? In summary, Ms. Gustafson-Lucker's findings regarding the consistency of the application with EC 9.8320(2) are based on two errors: 1. She failed to note that, by their own admission, the investigation conducted by Branch Engineering was "a preliminary study" rather than and "in-depth, detailed analysis. 2. She failed to consider evidence that Branch Engineering's areally limited work cannot "adequately consider both on-site and off-site impacts" as required by the SITS. 3GeoScience Technical Review, Geotechnical/Geologic Assessment and Addendum Capital Hill PUD, March 7, p. 5, V paragraph