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Open Record 3 final rebuttal by applicant (10-17-18)
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Open Record 3 final rebuttal by applicant (10-17-18)
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Last modified
10/17/2018 3:35:50 PM
Creation date
10/17/2018 3:35:48 PM
Metadata
Fields
Template:
PDD_Planning_Development
File Type
CU
File Year
18
File Sequence Number
1
Application Name
U of O North Campus
Document Type
Public Testimony
Document_Date
10/17/2018
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Yes
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Virginia Gustafson Lucker, Hearings Official <br />October 17, 2018 <br />Page 6 <br />C. Issues Related to Proposed Recreation Fields <br /> Opponents arguments: <br />Many opponents assume that the recreation fields proposed in <br />the Plan will be made of artificial turf, and those opponents make a variety of arguments against <br />this facility design. For example, Sean Malone argues that artificial turf violates Metro Plan <br />policies D.5 and E.2. See Sept. 12 Malone letter. Allen Hancock argues that only natural grass <br />recreation fields are consistent with the standards for S-RP zone development in the Greenway <br />under EC 9.3725(2)(c). Opponents also suggest that artificial turf fields are inconsistent with the <br />purpose of the S-RP zone as stated in EC 9.3700. See e.g., undated letter from Mari Galloway. <br />Universitys response <br />: The Plan does not include any specific facility design for the <br />recreation fields, and the fields will be subject to additional future permitting depending on their <br />design. For example, if the University proposes lighting for the fields, this design will be subject <br />to the Citys outdoor lighting permit standards in EC 9.6725. <br />Regardless of the materials used on the fields, this development will require compliance <br />with stormwater site development standards in EC 9.6790-9.6797. The Citys stormwater <br />standards are designed to prevent water pollution associated with runoff, including any pesticide <br />runoff from natural grass. See EC 9.6790. The University is committed to environmental <br />stewardship, and the university will carefully study field surfaces and their impacts on the <br />environment before proposing any construction project for recreation fields north of the railroad <br />tracks. <br />Metro Plan policies D.5 and E.2 both concern compatibility of uses with the natural <br />environment, including the Willamette River. As described in Part I above, the RP Study is a <br />refinement plan to the Metro Plan and all University uses in the S-RP zone are permitted uses <br />under the RP Study. University uses such as recreation fields are therefore, by definition, <br />compatible with Metro Plan policies, including policies D.5 and E.2. This issue was resolved in <br />the Urquhart and Stotter cases because those decisions upheld the RP Study and the S-RP zoning <br />rules as consistent with Goal 5, Goal 15 and the Metro Plan. Mr. Malones argument that <br />artificial turf fields are inconsistent with the Metro Plan is therefore incorrect. <br />Moreover, EC 9.3700 specifically states that the purpose of the S-RP zone is to provide <br />for activities and uses that complement the research and educational functions of the <br />\[University\]. Physical education and recreation are part of the Universitys educational <br />function. Recreation fields are therefore consistent with the purpose of the S-RP zone. <br />Furthermore, as noted above, the proposed fields are also explicitly within the scope of permitted <br />uses in the S-RP zone because they are University uses. <br />EC 9.3725(2)(c) requires the maximum possible landscaped area, open space, or <br />vegetation between the activity and the river (emphasis added). Recreation fields satisfy this <br />criterion because the fields are open space. Moreover, the fields themselves are the relevant <br />activity under EC 9.3725(2)(c), and the Plan calls for a minimum 200 foot setback between the <br /> <br />
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