Attachment A <br />runoff and treatment, limitations on new impervious surfaces, floodplain regulations, and <br />provisions related to construction impacts. Some testimony also raises the question of whether <br />the proposed amendments should include additional restrictions on base zone development <br />standards such as restrictions on building height within the Willamette River Greenway <br />Boundary. <br />Given the project goal of creating clear and objective standards for proposed housing in the <br />Greenway to ensure compliance with State law, these topics are all generally outside the <br />intended (or at least initial) scope of review for these proposed land use code changes. This <br />effort has understandably been a challenge in and of itself, given the difficult nature of <br />attempting to craft clear and objective standards that are sufficient to comply with the highly <br />subjective requirements of Goal 15. Consequently, the staff team is consistently looking to <br />ensure that proposed changes, additions, or amendments to other existing development <br />standards are only included to the extent that they: <br />• Demonstrate the necessity for meeting the requirements of Goal 15; <br />• Ensure the standards are clear and objective as required under State law; and, <br />• Avoid causing "unreasonable cost and delay" under new standards applied to needed <br />housing development. <br />Staff remains open and responsive to considering possible additional changes to the draft code <br />that can meet these stated goals, but further expanding the scope of the project to address <br />other existing development standards would certainly take more time and resources at this <br />stage. Several topics, such as introducing new limitations on impervious surfaces and building <br />height, are likely better suited for other City-wide legislative updates. <br />Regarding concerns around stormwater impacts, the City's Comprehensive Stormwater <br />Management Plan (CSWMP), Stormwater Management Manual (SWMM), and related <br />development standards already located in the Eugene Code address stormwater treatment and <br />runoff requirements for new development. Current development standards are not only <br />intended to mitigate the negative external impacts of stormwater through treatment and <br />detention, but also to encourage the use of pervious surfaces. Staff has concerns that an <br />outright prohibition on new impervious surface may have unintended consequences for parking <br />lots, driveways, and other hardscape areas other than new buildings, in which pervious surfaces <br />may not be the most effective tool for handling stormwater impacts. Such a prohibition would <br />only exist within the arbitrary boundaries of the Willamette River Greenway and may also <br />create new difficulties in addressing the challenging requirements for this project as noted <br />above, particularly for properties within the Greenway boundary located relatively far away <br />from the river. An update to the stormwater regulations is expected to begin over the next year <br />and it would likely be more appropriate to address this type of regulation on a City-wide basis. <br />Another example would be related to possible new building height limitations. As it stands, the <br />proposed Willamette River Greenway Code Amendments do not change allowed building <br />heights, which are regulated by the base zoning of a particular property. Consideration for <br />changing building heights may be better suited for evaluation as part of future corridor <br />Page 9 of 43 <br />