RECEIVED <br />Electronically <br />01-07-2020 <br />City of Eugene <br />ZVR 20-1 (Conte) Additional application material #4 planning Division <br />This document adds further evidence that demonstrates that- purely as a zoning issue-the subject site <br />and existing structure cannot be converted from an "Office" use to the "Drug Treatment Clinic- Non- <br />residential" because the required parking would be prohibited on the portion of the site that is zoned <br />S-DW Downtown Westside Special Area Zone. <br />The use of the existing 19,255 (more or less) structure for the "Drug Treatment Clinic - Non-residential" <br />use would fall under the "Hospital, Clinic or other Medical Health Treatment Facility (including mental <br />health) in excess of 10,000 square feet of floor area" category in Eugene Code Table 9.6410 Required <br />Off-Street Motor Vehicle Parking. The "Minimum Number of Required Off-Street Parking Spaces" for this <br />use is "1 per each 200 square feet of floor area or 1.35 per bed," which results in a requirement for 96 <br />parking spaces (more or less). EC 9.6410(3)(a) provides that "[a] parking reduction of up to * * * * * 25 <br />percent of the minimum requirement in all other zones is allowed as a right of development." The <br />resulting requirement is 72 parking spaces (more or less). <br />Based on the following aerial image with a rough superimposition of the tax, the area of the site that is <br />not covered by the existing structure appears to be entirely covered with the parking area that serves <br />tenants and clients of the existing structure. The existing parking area comprises approximately 59 <br />parking spaces, far short of the minimum required for the "Drug Treatment Clinic - Non-residential" use. <br />Even more critically, at appears that only 25 parking spaces are on the area that is currently zoned C-2 <br />Community Commercial. The other parking spaces are on the area, to the west of the original lot 400, <br />that is zoned S-DW. <br />As explained below, LUBA has found in multiple decisions that an accessory use is inherently an integral <br />element of the principal use and cannot be allowed on any area of a site unless the zoning of that area <br />permits the principal use. <br />The S-DW zone does not permit the "Drug Treatment Clinic - Non-residential" use. The S-DW zone also <br />permits a "Parking Area" only as an "Accessory Use," never as a stand-alone, principal use. Thus, in the <br />ZVR 20-1 (Conte) Additional Application Material #4 Page 1 January 7, 2010 <br />