Eugene Planning Commission <br />July 9, 2019 <br />Page 2 <br /> <br />transparent so you can see the underlying development, if any, on the included aerial photo. <br />Page 3 shows the subject property (indicated by the green check mark) with the relatively flat <br />portions of the site as clear, and the majority of the likelybuilding sites falling within the yellow <br />(moderate) zone. Some dwelling sites on the east may intrude into the orange (high) hazard <br />zone. <br />Attachment 1, pages 4, 5 and 6 show different areas in west Eugene where development <br />has safely occurred on areas of moderate, high and very high risk of landslides. Some areas, as <br />shown on page 6,the Timberline Drive Area, include multi-family housing as well as single <br />family residentsin a very highrisklandslide area. <br />If one examines the SLIDO mapfor the Eugene Area,Attachment 1, page 2,one realizes <br />that almost the entire City of Eugene’s residential land inventory is encumbered by site <br />conditions similar to the conditionspresent here. <br />The Capital Hill PUD proposal, the geotechnical analysis and the conditions of approval <br />proposed are consistent with development that has occurred throughout the City.See, <br />Attachment 2, Schirmer Satre Groupletter (discussing nature of project design and geotechnical <br />analysis for projects in South Hills).Neighbors asked you before to enhance one of the Hearings <br />Official’sconditions –one that required a subjective off-site impacts determination for building <br />site geotechnical studies. That led to a remand because it was an improper condition of approval. <br />Now they ask you to applya more stringent interpretation of the City’s geotechnical standards <br />and to require more analysis of the property than has beenapplied in the past. <br />The Planning Commission should resist Neighbor’s requests to deviate from the City’s <br />past practices. Doing so not only shifts the goal posts for the Applicants, it will shift the goal <br />posts for much of the City’s residential buildable lands inventory. That is a policy choice you <br />should not make. <br />Also, as discussed further below, Neighbors’ geotechnical consultant misread the <br />stormwater analysis and is absolutely wrong in his assertions, as are the Neighbors and their <br />attorney by repeating those assertions. The evidence in the record supports the conclusion that, <br />as properly conditioned, the PUD will not be a significant risk to public health and safety due to <br />soil erosion or slope failure, and that both on-site and off-site impacts have been adequately <br />reviewed and mitigated. <br />Proposed Condition of Approval 10 with its requirement for site-specific (PEPI and <br />dwelling) geotechnical studies and the requirement for proposed development consistent with the <br />site-specificstudy and Branch Engineering’s general recommendations for development, and the <br />construction of the proposed stormwater system will ensure that the development does not <br />includeany of the potential slide triggers. The proposed development will not remove the <br />resisting force at the toe of any potential slide area; it will notlead todevelopment of <br />infrastructure or dwellings designed to increase the driving force at the top of any slide area by <br />the placing of soil; and it will notadd water to the slide area (in fact, the stormwater management <br />2 <br />