LAW OFFICE OF BILL KLOOS PC <br />OREGON LAND USE LAW <br />375 W. 4TH AVENUE, SUITE 204 <br />EUGENE, OR 97401 <br />TEL: 541.343.8596 <br />WEB: WWW.LANDUSEOREGON.COM <br />April 6, 2018 <br />Eugene Hearing Official <br />c/o Eugene Planning and Development <br />99 W. 10`x' Ave. <br />Eugene, OR 97401 <br />Re: Capital Hill PUD; Applicant's Final Argument <br />Dear Hearings Official: <br />BILL KLOOS <br />BILLKLOOS @LANDU SEOREGON. COM <br />Please accept this letter as the applicant's final argument. No new evidence is intended to be <br />included here. <br />We organize this letter using the positive Staff Report as an outline. We reference our March 5 <br />Spreadsheet of Standards which addresses and critiques standards in summary fashion. <br />We ask that the HO keep a few Big Picture points in mind when working her way through the <br />details of this final argument. <br />This is a proposal to infill on R-1 land that is surrounded by land developed with similar <br />uses and at similar densities. This is where the City, as a matter of policy, has determined <br />that development should happen. <br />The density proposed here is well below what is allowed by the plan and the zone, and it <br />is at about the density the City assumes in its Buildable Land Inventory will be put on <br />land in this part of town. <br />South Hills PUDs trigger a raft of discretionary standards, which offer opponents a long <br />list of things to complain about and a long list of avenues opponents can take to argue we <br />just didn't get it quite right. No South Hills PUD applicant for a PUD can get it right on <br />all issues in the eyes of all neighbors. Getting a proposal together that attracts a positive <br />staff report is a major accomplishment. <br />We have a recommendation for approval from staff, subject to conditions. The applicant <br />can live with all the conditions. <br />With those points as an introduction, we offer the following argument. <br />DESCRIPTION OF PLANNED UNIT DEVELOPMENT REQUEST <br />This development proposal is accurately described in the Staff Report at page 4. <br />APP C - Final Argument 4.6.2018 <br />