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Eugene Planning Commission May 2, 2018 Page 7 7. Stormwater from approximately half of the PUD property will be discharged to two "level spreaders" located on a 50% slope near the center of the east side of the PUD, approximately 100 feet from the Ribbon Trail. The design discharge for this system is the equivalent of 29 garden hoses running at full capacity. This will nearly inevitably result in soil erosion in the vicinity of the Ribbon Trail. It may also result in increased pore pressures in the slide deposit mapped by DOGAMI and GeoScience downslope from there." The applicant's geotechnical engineer agrees that this is "not the best idea in my opinion"." In their findings, both City staff and the HO relied entirely on statements by the applicant's geotechnical consultant regarding the suitability of the site, without ever checking whether the work and evidence presented actually supports these statements. The main reason the work conducted to date fails to do so is the fact that the verification conducted via subsurface exploration is limited to the area least likely to "unearth" evidence of more substantial issues than 2.5 feet of slide debris. The applicant admits to having "mapped to the best of their ability" "areas of gross land instability on the east side", but neither the actual extent and configuration of these features, nor their import for the design of the PUD are discussed. Given that 80% of the proposed PUD area was NOT ASSESSED during the applicant's investigation, including all of the steep eastern portions of the PUD, the applicant cannot demonstrate that the PUD as currently designed will not be a risk to public health and safety, or prevent soil erosion. The HO is relying on "future work" by the applicant to address the question. However, EC 9.8320(6) requires that this determination be made at the Tentative PUD application stage, not at the PEPI or building permit stages. Rather than requiring the applicant to provide further evidence of the innocuousness of the proposal, the HO would rather ask for evidence from the opposition that the proposal does not adequately address the issue. Where presented (such as the percentage of area assessed, the errors made, the inappropriate stormwater design), the HO dismisses such evidence (e.g. remote sensing mapping of geomorphic features, verified by lateral offsets and distress in the pavement of Floral Hill Drive), or ignores it (the level spreader design). 11GeoScience Technical Review, Geotechnical/Geologic Assessment and Addendum Capital Hill PUD, March 7, pp 8&9. 12 Branch Engineering Rebuttal, 3/20/18 p.2, 4th paragraph.