Open Record 3 final rebuttal by applicant (10-17-18)

Virginia Gustafson Lucker, Hearings Official October 17, 2018 Page 9 In 1997, the City granted the University an adjustment to lower otherwise-required parking by 50% campus-wide. The University submits annual reports to the City to demonstrate compliance with this standard. Consistent with this campus-wide decision, in February 2018, the City granted the University an adjustment for a 25% reduction in parking associated with the Knight Campus. These 1997 and 2018 parking decisions are included in the Universitys October 3, 2018 first open record period submission. The Universitys October 10 package also includes a specific request to the Hearings Official to determine that the Citys and Universitys campus-wide parking approach applies to the Universitys Plan for the S-RP zone, in lieu of the 400 foot default in EC 9.3715. As in other City zones, the S-RP zone contains parking standards for developments in the S-RP zone. However, nothing in the S-RP zone rules or related policies preclude the University from developing parking structures in the S-RP zone to serve University uses physically located in other zones. To the contrary, as described above, all University uses are permitted uses in the S-RP zone. Moreover, the 400-foot parking proximity standard and arbitrary zoning separation between University uses and parking, as advocated by Mr. Malone and his client Mr. Hancock, would result in unneeded parking lots. This would be contrary to the campus-wide parking plan that is designed to conserve land and encourage alternative transportation. Mr. Malones and Mr. Hancocks advocacy for these parking standards also contradicts their espoused interest in environmental conservation in the S-RP zone. Finally, the photographs and diagrams included in the Universitys October 3 package demonstrate that the proposed parking structure near Riverfront Parkway and Millrace Drive will not impede visual access to the Willamette River riparian area from main entry points along Franklin Boulevard. F. Bicycle Paths Opponents arguments: The University proposes two different alignment options for a new bike path through the S-RP zone. Mr. Hancock argues that one of these designs does not provide a continuous, two way bike path as required by EC 9.3720(1). Mr. Hancock argues that the Plan is also inconsistent with the Citys Transportation System Plan, because the Universitys Plan could impede City development of a bicycle and pedestrian crossing over the railroad tracks in the S-RP zone to connect Alder Street with the existing bike path along the river. See Sept. 12 Hancock letter. Universitys response: Both of the Universitys two proposed bike path alignment options comply with EC 9.3720. The northern alignment proposes a new bridge crossing over the mouth of the Millrace Slough. The alignment extends under the south abutment of the