HANSEN Alissa H <br />From: <br />SELSER Lindsay R <br />Sent: <br />Thursday, May 24, 2018 12:34 PM <br />To: <br />HANSEN Alissa H; HOSTICK Robin A <br />Cc: <br />BRAUD Denny <br />Subject: <br />FW: Adding ADUs to R-2, R-3 and R-4 is not required, has no benefit and would <br />complicate application procedures <br />FYI <br />From: Paul Conte <paul.t.conte@gmail.com> <br />Sent: Thursday, May 24, 2018 9:07 AM <br />To: *Eugene Mayor, City Council, and City Manager <mayorcouncilandcitymanager@ci.eugene.or.us> <br />Subject: Adding ADUs to R-2, R-3 and R-4 is not required, has no benefit and would complicate application procedures <br />Mayor and Councilors, <br />I was glad to see that Emily Jerome unequivocally confirmed that SB 1051 does not require explicit addition <br />of ADUs as an allowed use in R-2, R-3 and R-4 (or S-JW and S-C). <br />The only remaining reason that staff now has for adding the ADU residential subcategory to R-2, R-3 and R-4 <br />is their claim that this would add "clarity." But Alissa Hansen's jumbled "justification" turned reality on its <br />head, as I'll explain. <br />First, what appears to motivate staff now is still their holding on to the incorrect, "gut" belief that they <br />need to put "ADU" explicitly into the R-2, R-3 and R-4 code to demonstrate to the State that Eugene Code <br />complies with SB 1051. That's not a requirement, of course. But, at a very superficial level, a DLCD staff <br />might look at R-2, see it allows "ADU" and be satisfied. However, any serious challenge to R-2 would look at <br />R-2's allowance for multiple dwellings of a variety of types and conclude, as the DLCD staff and City <br />Attorney already have, that R-2 is in compliance. So, despite staff's "feelings," there is no actual legal or <br />political value to adding ADUs to R-2, R-3 and R-4. <br />Turning now to Alissa's justification that adding ADUs to R-2, R-3 and R-4 would improve "clarity," she made <br />two points: <br />a) Staff keeps track of SDUs (ADUs) and wouldn't be able to do that if an applicant proposed a second <br />dwelling on an R-2/3/4 lot. But staff has never tracked SDUs/ADUs in R-2/3/4, and Alissa didn't point to any <br />requirement or benefit in adding that administrative overhead going forward. Adding ADUs to R-2/3/4 <br />would increase the burden on staff (and applicants). <br />b) Staff wouldn't be able to determine which type of dwelling was being applied for in R-2/3/4 unless the <br />applicant identified whether it was an "SDU (ADU)" or a "second dwelling." She made it seem like this would <br />be a problem, and that staff couldn't be burdened with having to examine the specifics of an (e.g.) R- <br />2 dwelling application to determine whether or not it was for an ADU. The problem with this argument is <br />that it relies on there being some new reason or benefit that would justify a staff person make the <br />determination whether a dwelling application in (e.g.) R-2 was an "ADU." Currently, staff looks to see <br />whether an R-2/3/4 proposal is for single-family, duplex, or multiple-dwelling. Adding another subtype <br />of single-family, i.e., ADU, to R-2/3/4 just complicates the procedures for both the applicant and staff. <br />