development, and the existing zoning is consistent with that designation. <br />The Response Committee and several neighbors also argue that the density is actually much <br />greater than indicated and allowed because of site constraints and the areas the applicant has <br />proposed for open space and preservation. They argue that the applicant should not be permitted <br />to count the individual and common preservation areas in calculating the proposed density. They <br />argue that "in an effort to camouflage the incontrovertible massive neighborhood impact of the <br />proposed PUD, the Applicant has grossly understated actual density by 59%." (Response <br />Committee March 7, 2018 Written Hearing Testimony, page 102.) They also argue that <br />proposed Lots 18 and 19 should not be included in the net density calculations because they <br />"neither physically abut the development sites of the other 32 lots nor are they physically visible <br />from the other 32 lots." By excluding these two lots and subtracting the common and private <br />preservation areas, the Response Committee concludes that the density would be 5.25 units per <br />acre, in violation of the maximum allowed. <br />The Response Committee cites no legal justification for their desired recalculation of the <br />proposed density. The common and private preservation areas are part of the proposed PUD and <br />appropriately considered in determining net density. And all lots, whether or not visible from <br />other parts of the PUD, not only may, but must be considered in the density calculations. <br />The applicant and city have correctly calculated the proposed density and the proposed 2.6-2.9 <br />dwellings per acre is well within the density allowed under the Metro Plan. <br />The Planning Staff have identified the three following policies within the Metro Plan Residential <br />Land Use and Housing Element as approval criteria for the proposed PUD: <br />Policy A.10: Promote higher residential density inside the UGB that utilizes existing <br />infrastructure, improvements the efficient ofpublic services and facilities, and conserves <br />rural resource lands outside the UGB. <br />Policy A.13: Increase overall residential density in the metropolitan area by creating <br />more opportunities for effectively designed in-fill, redevelopment, and mixed use while <br />considering impacts of increased residential density on historic, existing and future <br />neighborhoods. <br />Policy A.17. Provide opportunities for a .full range of choice in housing type, density, <br />size, cost and location. <br />The Staff Report described how the proposed PUD generally furthers these three policies. The <br />Response Committee and numerous neighbors provide extensive discussion as to how the <br />proposed development fails to satisfies these Metro Plan policies. However, none of these <br />policies constitute a mandatory approval criterion for the proposed development. By their terms, <br />they are directives to the City to guide the City in implementing the Metro Plan. And, in fact, for <br />many of the reasons the Response Committee and neighbors cite, the City has not designated this <br />property for `higher density' residential development. Consistent with the Metro Plan <br />designation, the City has zoned the subject property, as well as the surrounding residential <br />Hearings Official Decision (PDT 17-1) 14 <br />