Virginia Gustafson Lucker, Hearings Official <br />October 17, 2018 <br />Page 8 <br />environmental permits. The University will develop a specific restoration design plan as a <br />component of this permitting. <br />Nothing in the City’s S-RP zone rules or related policies requires riparian restoration to <br />precede other activities in the University’s Plan. Imposing that type of timing requirement <br />would undermine the University’s comprehensive planning efforts and be contrary to RP Study <br />Policy A.3, which calls for a “a high degree of flexibility for development proposals.” <br />E. Parking Issues <br />Opponents’ arguments: <br />Opponents make several arguments related to a parking <br />structure proposed in the Plan. The subject structure will be located on an existing surface <br />parking lot near the intersection of Riverfront Parkway and Millrace Drive. This parking <br />structure will be designed in part to serve the University’s future Knight Campus for <br />Accelerating Scientific Impact, which is located outside of the S-RP zone. <br />Opponents argue both that the University proposes too much and too little parking in the <br />S-RP zone. First, Mr. Malone argues that parking in the S-RP zone may only serve uses located <br />in the S-RP zone, and therefore the University’s proposed parking structure near Riverfront <br />Parkway may not provide parking for the Knight Campus. See Oct. 3 Malone letter. Mr. <br />Malone’s client Allen Hancock appears to argue that parking facilities must be located within <br />400 feet of the specific uses they are designed to serve under EC 9.3715(1). See Oct. 3 Hancock <br />letter at “Issue 1.” <br />Mr. Malone also argues that the proposed parking structure near Riverfront Parkway may <br />block visual access to the riparian area along the Willamette River from Riverfront Parkway in <br />violation of EC 9.3715(1)(c). See Sept. 12 Malone letter at 2. <br />University’s response: <br /> First, it is important to stress that the development standards in <br />EC 9.3715 are generally not applicable criteria to a master site plan. Parking compliance for <br />specific facilities will be determined through future construction-related permitting decisions. <br />Second, the 400-foot proximity standard in EC 9.3715(1) is simply a default; the rule <br />explicitly allows the City to approve a different parking standard through the master site plan <br />CUP process. The City and the University have cooperatively planned University-related <br />parking on a campus-wide basis for many years. The 1988 master site plan contemplated a <br />string of parking lots adjacent to the railroad tracks in the S-RP zone, and the plan did not limit <br />the use of these lots to S-RP zone facilities. Some of those parking lots were developed, <br />including the surface lot at the location of the parking garage proposed in the University’s <br />4 <br />current Plan. Compare 1988 master site plan parking diagram with 2018 Plan application <br />narrative Figure 2.1 and Plan Exhibit A Sheet L02. <br />4 This diagram is available at page 3893 of the Cziko File pdf. <br /> <br />