1 <br />possible. Schill letter, P. 3. Again, the need is motivated by the construction of the Knight <br />Campus, not a need arising out of the S-RP zone. <br /> <br />The provisions that govern the S-RP zone strongly suggest that the proposed <br />transportation facilities within the S-RP zone are intended to serve the uses within the S-RP <br />zone. For example, EC 9.3715 provides that <br />consistent with the purpose and intent of the S-RP Riverfront Park Special Area Zone as well as <br />its unique location adjacent to the Willamette River and Millrace, the following development <br />standards shall apply.This implies that Riverfront Park Special Area Zone is intended to serve <br />those uses within the zone. Clearly, a parking structure proposed for the S-RP zone is intended <br />to serve uses within S-RP zone, not those within a separate zone (i.e., the Walnut State Special <br />Area Zone). <br /> <br />Moreover, the Walnut Station Special Area Zone contains its own specific parking <br />requirements, see EC 9.3970(4), including the location of -street motor vehicle <br />parking,-site parking,.ifically, for s within structured parking with <br />two or more levels, the maximum number of parking spaces is 1 parking space per every 250 <br />square feet of gross floor area.This standard conflicts with the parking standards for the <br />Riverfront Park Special Area Zone, see EC 9.3715(1)(a)(1)-(5), which lends more support to the <br />notion that a parking garage located within the S-RP zone cannot serve the Knight Campus. <br /> <br /> It is also notable that there is no evidence in the record to suggest that the proposed <br />parking structures would be within 400 ft of the Knight Campus, which would plainly violate EC <br />9.3715(1), which requires parking garages be located within 400 feet of structures to be served. <br />Indeed, the site plans indicate that such parking structures would not be within 400 feet of the <br />Knight Campus, even assuming that the parking structures in the S-RP zone could support the <br />Knight Campus development, which is in a separate zone. <br /> <br /> For the foregoing reasons, the request must be denied. <br /> <br />Sincerely, <br /> <br />Sean T. Malone <br />Attorney for George Evans, Allen Hancock, and the UO Riverfront Restoration <br />and Education Group <br /> <br />Cc: <br /> <br />1 <br /> The Schill letter is contained in the record and recently submitted by Allen Hancock on <br />September 28, 2018. <br />2 <br /> <br /> <br />