will cause adverse impacts to existing businesses, decrease employment growth, and <br />are not needed to achieve neighborhood goals. <br />Currently, commercial standards for exterior walls and windows only apply to new <br />commercial buildings with 25,000 square feet or more of floor area. The RRSC code <br />amendments related to exterior walls and windows will apply to all new buildings and all <br />building additions on properties zoned C-2. <br />The staff report for the Eugene Planning Commission's November 14, 2023 meeting included <br />Rowell Brokaw's evaluation of draft code standards to require a minimum of 80% of the street <br />facing ground floor building fagade to be built within the maximum front yard setback and new <br />Building Articulation standards. Rowell Brokaw stated, "The 80 percent frontage requirement <br />precludes street -facing courtyard spaces that have proven successful in other commercial <br />districts and would meet the overall goals of activated, pedestrian -oriented commercial <br />development ... It is our experience that Building Articulation standards ... add complexity to <br />development but do not prevent bad design. They often work against the stated goal of the <br />code to promote cohesive architecture that is visually appealing. We recommend eliminating <br />this section." The proposed RRSC code amendments do not address these concerns. <br />III. The RRSC Code Amendments are Not Consistent with the 1987 River Road - <br />Santa Clara Urban Facilities Plan or the Proposed RRSC Neighborhood <br />Plan <br />The adopted and acknowledged 1987 refinement plan contains policies to enhance the <br />compatibility of adjacent land uses through "appropriate buffering mechanisms, such as <br />landscape standards" and to "Minimize impacts of new commercial development intended to <br />consolidate and improve existing strip commercial areas along River Road by requiring <br />development standards."' In 2001, Eugene's Land Use Code was updated to include new <br />standards for landscaping and commercial development on a city-wide basis. Subsequent code <br />amendments have further addressed policies to enhance new commercial development. <br />The proposed RRSC neighborhood plan does not contain any policies that specifically support <br />the proposed RRSC code amendments. <br />The proposed RRSC neighborhood plan does not provide any basis for prohibiting certain uses <br />in C-2. The proposed RRSC code amendments to C-2 conflict with the proposed RRSC <br />neighborhood plan policies supporting economic development, small locally owned businesses, <br />and living wage employment opportunities. There is no clear nexus between the proposed <br />RRSC neighborhood plan and the proposed RRSC code amendments to C-2 standards. The <br />proposed RRSC code amendments will impact all C-2 zoned property in RRSC and result in a <br />substantial number of new non -conforming situations and significant financial costs to <br />businesses. <br />11987 River Road -Santa Clara Urban Facilities Plan, policies 1.0 and 5.0, page 2-18. <br />RRSC Code Amendments Page 4 of 5X019 BISHOW <br />Bishow Testimony March 4, 2024 dM CONSULTING <br />21 <br />