Wednesday, June 6th' 2018 DELIVERED VIA EMAIL <br />Eugene Mayor, City Council and City Manager <br />City Manager's Office <br />125 East 8th Avenue <br />Eugene, OR 97401 <br />Re: SDU Prohibition in S-JW and S-C <br />Dear Mayor, City Councilors and City Manager: <br />WE CAN, the Walkable Eugene Citizen's Advisory Network, strongly urges City Council to vote "No" on the <br />Ordinance regarding secondary dwellings as amended at the May 23rd Council Work Session to exclude the <br />Jefferson Westside Special Area Zone (S-JW) and Chambers Special Area Zone (S-C) from compliance with SB <br />1051. <br />WE CAN has already submitted comment regarding our concerns about the overall interpretation of SB 1051 the <br />City has taken. The explicit prohibition of Secondary Dwellings in the S-JW and potentially S-C area not only <br />compounds the existing non-compliance with SB 1051, but also decreases clarity in the overall code and brings <br />to the forefront underlying issues with the S-JW code. <br />Violation of S13-1051 <br />WE CAN is already on record indicating that we believe that SB 1051 allows each lot that contains a detached <br />single family home to build a Secondary Dwelling Unit if they so desire. Staff has interpreted SB 1051 to mean <br />that each zone that allows detached single-family homes should also permit SDUs. Under either interpretation, <br />the proposal to exclude SDUs from the S-JW is in clear violation of SB-1051. <br />The S-JW is clearly an area zoned for detached single-family housing. The S-JW includes as a "purpose" <br />"encouraging the preservation of existing small lots and small, relatively lower-cost, single-dwelling, detached <br />homes, as well as by encouraging new, smaller and relatively lower-cost, detached, single-dwellings and <br />duplexes."' Of all the dwelling types defined in the Eugene code, including triplexes, rowhouses, fourplexes, and <br />multiple family dwellings, the lot size and design requirements in the S-JW prohibit any new dwellings of types <br />other than detached one-family dwellings and duplexes.' As duplexes are also a permitted type in Eugene's R-1 <br />zone, a claim that the inclusion of duplexes as a housing type in the 5-JW zone means that it is not an "area <br />zoned for detached single family dwellings" would be tantamount to claiming that no area in Eugene is zoned <br />for detached single family dwellings, a statement that is untrue on its face. Forbidding SDUs outright in this <br />zone is clearly in violation of the interpretation of SB-1051 that states that SDUs shall be permitted in areas <br />zoned for detached single-family dwellings. <br />t Eugene Code 9.3600 (10) <br />There are approximately 106 residential lots in the S-JW that are over 9,000 square feet, and would thus theoretically <br />allow more than two dwellings on the lot. However, dwellings per lot in the S-JW for lots over 9,000 square feet are <br />calculated by dividing the lot size by 4,500 and then rounding down. This means that only two dwellings are allowed on lots <br />between 9,000 and 13,500 square feet, and three on the 5 existing residential lots over 13,500 square feet. The code allows <br />for on additional dwelling to be established on a lot that is between 9,000 square feet and 12,499, and two additional units <br />on lots over 13,500, but only if no residential building on the lot has more than two dwellings in the same building, among <br />other restrictions. This prohibits prohibiting triplexes, fourplexes, and other attached multiple-family housing. <br />