Public Comments submitted 4-30-18 to 6-11-18

The Metro Plan policies surrounding residential lands are clear that the intent is to increase residential densities within the UGB.12 In particular, Metro Plan Policy A.16 states (emphasis added): A.16 Allow for the development of zoning districts which allow overlap of the established Metro Plan density ranges to promote housing choice and result in either maintaining or increasing housing density in those districts. Under no circumstances, shall housing densities be allowed below existing Metro Plan density ranges. In their analysis of the S-JW's compliance with the Metro Plan, staff skipped directly from policy A.15 to A.1713, ignoring the fact that the S-JW clearly allows, and in fact enforces, housing densities below existing Metro Plan density ranges. Passing additional ordinances and code amendments in order to ensure that the density in the area remains below that which is required by the Metro Plan is in clear violation of the Metro Plan, and brings into question the validity of the entirety of the S-JW code. Diminishes Neighborhood Character Prohibiting SDUs and other medium-density housing types in the S-JW is inconsistent with the historical character of the neighborhood. The areas covered by the S-JW have a long history of permitting a diversity of housing types and densities. Two cottage clusters in the area covered by the S-JW, at densities of 18 and 31 units per net acre, were built in 1939 and 1920-1940, respectively. SDU-type cottages were developed in the neighborhood as early as 1900. Fourplexes also have a long history in the neighborhood as a housing type-the dozen buildings housing fourplexes within the neighborhood were built between 1910 and 2007, including in 1925, 1935, and 1937. The historical character of the neighborhood is clearly a mix of housing types and densities within a single neighborhood. Paul Conte proposed the amendment introduced by Councilor Semple in his testimony re: City File # CA 18-1, submitted April 28`h, 2018. In this, he claimed that allowing SDUs on the smaller lots would "push the number of dwellings on smaller lots beyond the limits of compatibility." The concepts of "compatibility" and "character" are subjective concepts. However, the argument seems to be that potential SDUs would damage the character of the neighborhood by potentially permitting densities and housing types consistent with the Metro Plan designation of the neighborhood and the historical development patterns. LUBA has rejected the concept that maintaining the "character" of the neighborhood means disallowing housing types other than detached single-family or maintaining a low-density level of development. In particular, in Jefferson Westside Neighbors vs. City of Eugene, Or LUBA 045 (2008), LUBA stated (emphasis added): "Under petitioners' apparent view of EC 9.9680(1)(a), the city must determine if the potential residential use of Parcel 1 will be consistent with the predominant residential dwelling type in the neighborhood, 12 Eugene-Springfield Metropolitan Area General Plan, 2004 Update Policies "A.10 Promote higher residential density inside the UGB that utilizes existing infrastructure, improves the efficiency of public services and facilities, and conserves rural resource lands outside the UGB." A.13 Increase overall residential density in the metropolitan area by creating more opportunities for effectively designed in- fill, redevelopment, and mixed use while considering impacts of increased residential density on historic, existing and future neighborhoods. A. 14 Review local zoning and development regulations periodically to remove barriers to higher density housing and to make provision for a full range of housing options. 13 Exhibit B of Council Ordinance Number 20449, Adopted December 14, 2009. Draft Findings for CA 09-03, RA 09-02, Z 09- 04 Special Area Zone - Jefferson Westside