Eugene Hearing Official <br />July 31, 2024 <br />Page 10 <br /> <br />the Hearing Official based on the testimony. That option can be implemented with a condition <br />of approval. <br /> <br />Finally, opposition evidence relied on competing storm water analysis by Goebel Engineering, <br />which did the original engineering for the entire 80- acre Braewood Third Addition at the turn of <br />the millennium. The KPFF memo identifies the key assumptions in the Goebel study that make <br />it inappropriate to rely upon for this decision. Most importantly, the standards have changed <br />dramatically since 2003. In addition, the 2003 analysis examined a much bigger watershed than <br />the 12+ acres studied here by KPFF. The 2003 Analysis is not a reliable basis for questioning <br />the study supporting this application. <br /> <br />4. Lot size of proposed Lot 39. (Woodward Letter pages 7-8) <br /> <br />The Woodward challenge here is simple: To qualify for an exception to the maximum lot size of <br />13,500 sq ft, the applicant needs to show the “feasibility” of a conceptual buildout plan, and that <br />is not possible due to the 901’ elevation prohibition on any development. <br /> <br />The response has been extensively briefed elsewhere, including at the start of this letter. The City <br />may not impose the 901’ development prohibition under the new umbrella of the Middle <br />Housing Statute. <br /> <br />Sincerely, <br /> <br />Bill Kloos <br /> <br />Bill Kloos <br /> <br />Exhibits: <br /> <br />A – Johnson Eug Middle Housing Defense Brief 12.10.2022.pdf <br />B – KPFF Memo and Graphics 0 7.31.2024.pdf <br />C – Amended Site Plan Sheet L2.0 7.30.24.pdf <br />D --Metro Ackn DLCD Staff Rpt 7.29.1982.pdf <br /> <br /> <br /> <br /> <br /> <br /> <br />