Eugene Planning Commission <br />July 9, 2019 <br />Page 4 <br /> <br />The weakness of Neighbors’ argument can be found in their response to the increased <br />number of test pits that were dug. They argue that there is no standard that says a certain number <br />of test pits is adequate(one can also say inadequate). By the same token, there is no standard <br />that says a certain “percentage”of the site must be “covered” by test pitsin order to be adequate. <br />There is no standard other than a professional’s expert opinion that the number or location of test <br />pits doneadequately maps the relevant geologic conditions. No standard involves a certain <br />percentage of site coverage; no standard involves a certain number of test pits. Applicants’ <br />engineers have rightly asked, “How much would be enough for the neighbors?” <br />The fact of the matter is that the test pits focus on the areasof the subject propertywhere <br />construction is likely to take place –the roads and the likely building locations for homes. As <br />the Site Exploration Map submitted on remand shows, the test pits are spread out and located <br />approximately where 19 of the 34 building sites are located. Six more of those lots, not <br />including the barn site, have existing structures on them. And two more are unbuilt sites (Lots 1 <br />and 2) on a part of the property that is not within any hazard area as shown by the DOGAMI <br />maps. This means that test pits, existing construction and lots where slopes are not an issue are <br />present for 27 of the 34 lotsfor development in the areas where development is likely to occur. <br />That is 79% of the developable sitelocations. And that does noteveninclude test pits thatare at <br />the same elevation laterally from adjacent lots. <br />Neighbors suggest that more test pits should be dug in areas that will not be developed. <br />Why would one want to disturb existing vegetation, which adds to soil stability,to dig test pits in <br />areas where no construction will occur? It makes little sense to do so, and one suspects that <br />Neighbors would not ever concede that a sufficient “percentage”of the site has been studied. <br />Data are endless, but more data does not always have more utility to making a decision. <br />This is not to say that the eastern lots of the proposal do not warrant appropriate attention. <br />They have been given that attention through these studiesand will get more attentionassite <br />specific geotechnical studies are conducted andindividual dwellings are constructed.The <br />geotechnical analysisin the recordshows that, with properly engineered foundations using <br />construction techniques imposed by conditions of approval, that it is safe to build on the <br />property.As Branch Engineering has explained, it is likely thatseveral if not most ofthe lots on <br />the eastern edgewill require a pier style foundation or more extensive foundation workthan <br />normal, but that roads and dwellings can be built safely on the subject property.That conclusion <br />for the eastern slope of the property is much like the pier foundation house to the west of the <br />subject property, located in an area mapped by DOGAMI as “high hazard.”Such foundations <br />are safe despite the slopes. <br />The Planning Commission should conclude that the geotechnical analysis contained in <br />the record provides sufficient evidence to reach conclusions regardingpublic safety,the on-site <br />and off-site impacts and, in particular, adequately addresses the areas where construction activity <br />will occur. <br />4 <br />