Eugene Planning Commission <br />May 2, 2018 <br />Page 12 <br />For EC 9.8320(6) (The PUD will not be a significant risk to public health and safety, including but <br />not limited to soil erosion, slope failure, stormwater or flood hazard, or an impediment to emergency <br />response.) the errors are: <br />3. Given that 80% of the proposed PUD area was NOT ASSESSED during the applicant's <br />subsurface exploration, including all of the steep eastern portions of the PUD, the applicant cannot <br />demonstrate that the PUD as currently designed will not be a risk to public health and safety, or <br />prevent soil erosion. The HO is relying on "future work" by the applicant to address the question. <br />However, EC 9.8320(6) requires that this determination be made at the Tentative PUD application <br />stage, not at the PEPI or building permit stages. <br />4. Despite the HO's assurances to the contrary, the applicant's report does not contain "numerous <br />specific recommendations to minimize the potential for slope failure" and one of their <br />recommendations appears to actually increase the potential by allowing overly steep fill slopes with <br />inadequate drainage. <br />5. The HO erred in accepting Branch Engineering's explanation of the tree deformation on the site <br />as having resulted from "soil creep" only. She ignored evidence presented by GeoScience of tree <br />deformation inconsistent with "soil creep" present on the site in the areas with evidence of slides. <br />6. In finding that the deformation exhibited by the pavement of Floral Hill Drive is anthropogenic, <br />the HO erred by failing to consider the totality of facts in evidence and simply accepting statements <br />and "opinions" by the applicant's consultant. <br />7. The PUD design includes at least one feature (the "level spreader" stormwater discharge) which <br />will significantly increase the risk of off-site impact from slope movements and soil erosion. <br />In this case, the applicant has failed to provide sufficient evidence to support the statements <br />made in their reports and testimony regarding compliance with two provisions of the Eugene <br />Code (EC 9.8320(2) and 9.8320(6)). GeoScience has presented evidence of active landslides <br />located both on- and off-site to the east of the PUD. This evidence consists of LiDAR <br />geomorphic mapping, which has been corroborated by evidence in the field of both deformed <br />trees on the site itself, and deformed pavement in a road that crosses several of these landslide <br />features below the PUD. For these reasons, from a geotechnical viewpoint only, it would be <br />a mistake to accept this PUD, the current design of which fails to consider these issueswo^ <br />Respectfully submitted, <br />GeoScience, Inc. <br />Gunnar Schlieder, Ph.D., CEG <br />Expires 12/31/18 <br />