Eugene Hearing Official <br />August 14, 2024 <br />Page 15 <br /> <br />Public Works now wants the west stub of Randy Lane, currently proposed as a private street, to <br />be developed to public street standards, even if connectivity need not be made because the fuller <br />improvements will provide a valuable public amenity – better access to the city-owned, <br />undeveloped Videra Creek park adjacent to the southeast. This is another late-breaking change <br />in the Public Works review comments as compared with the original Staff Report. See July 31 <br />Staff Memo at 4. As discussed in section 2 above, the change to public street standards for the <br />west stub of Randy Lane triggers changes to other nuts and bolts in the plans, particularly <br />stormwater, and Public Works wants these needed changes to be reflected in specific, changed <br />conditions. <br /> <br />There is a lot to unpack here. <br /> <br />Even without connectivity now, Public Works wants the west Randy Lane stub, shown on the <br />plans as a private street like the other two private streets on the plans, to be dedicated to the City <br />and developed to full public street standards. The proposed new condition at the bottom of page <br />4 begins is: <br /> <br />“Prior to final PUD approval, the applicant shall submit an updated site plan <br />depicting that portion of Randy Lane now shown as a proposed private street on <br />Sheet L2.0 of the applicant’s site plans, as a public street instead. The revised site <br />plan shall show that portion of Randy Land will be designed and constructed to <br />City standards as a public street in accordance with EC 9.6505(3)(a) and the Local <br />Street Design Standards of the Design Standards and Guidelines for Eugene <br />Streets, Sidewalks, Bikeway and Accessways, as well as the City’s Public <br />Improvement Design Standards (PIDS) Manual.” <br /> <br />Without connectivity being required, there is no lawful basis for elevating the west Randy Lane <br />road improvements to public road standards. Several reasons support this. <br /> <br />First, conditioning to build the Randy Lane stub to public road standards is not needed for <br />compliance with any standard. The reference in the proposed condition is to EC 9.6505(3)(a). <br />That code section sets specifications for “public improvements,” not private improvements. EC <br />9.6505 begins: <br /> <br />“Improvements – Specifications. <br />All public improvements shall be designed and constructed in accordance with <br />adopted plans and policies, the procedures specified in Chapter 7 of this code, and <br />standards and specifications adopted pursuant to Chapter 7 of this code. <br />Additionally, all developments shall make and be served by the following <br />infrastructure improvements.” <br /> <br />The City must make this decision under clear and objective standards that are set out in its code. <br /> <br />“227.173 Basis for decision on permit application or expedited land division; <br />statement of reasons for approval or denial. (1) Approval or denial of a