MICHAEL J. GELARDI <br />Direct: (541) 431-1438 <br />mgelardi@hershnerhunter.com <br />October 17, 2018 <br />Virginia Gustafson Lucker, Hearings Official <br />c/o Nick Gioello <br />Planning and Development Department <br />City of Eugene <br />th <br />99 West 10 Avenue <br />Eugene, OR 97401 <br />RE: File CU 18-01 and WG 18-12: University of Oregon final rebuttal <br />Dear Ms. Gustafson Lucker: <br />Our law firm represents the University of Oregon in connection with land use permitting <br />for the University’s “North Campus” master site plan (the “Plan”). This letter is the University’s <br />final rebuttal to the evidence and argument entered into the record in this proceeding. <br />Part I of this letter provides background and context to the University’s conditional use <br />permit (“CUP”) and Willamette Greenway permit application to the City of Eugene (“City”) for <br />approval of the University’s Plan. Part II summarizes the evidence and arguments presented by <br />opponents of the Plan that relate to the applicable permit approval criteria, and responds to each <br />of the opponents’ relevant claims. <br />I. Background and Context of the University’s Plan <br />The Plan addresses the University’s proposed uses in the Riverfront Park Special Area <br />Zone (the “S-RP” zone) for the next 30 years. The S-RP zone is a unique local zone that is the <br />product of two key planning decisions made by the City and the University during 1985 and <br />1986. The first decision is the Riverfront Park Study (“RP Study”), which is a refinement plan to <br />the Eugene-Springfield Metropolitan Area General Plan (the “Metro Plan”). The second <br />decision is an intergovernmental agreement between the City and the State of Oregon, acting <br />1 <br />through the State Board of Education (the “IGA”). The history of the RP Study, the IGA, and <br />the University’s prior 1988 master site plan for the S-RP zone are briefly summarized below. <br />1 <br /> The RP Study and the IGA are included in the record in a large file submitted by opponent Paul Cziko on <br />approximately September 12, 2018 (the “Cziko File”). The RP Study is located at pdf page 4974 of the Cziko File, <br />and the IGA is at page 5046 of this pdf. <br />01691923.DOCX <br /> <br />