<br /> <br /> <br /> <br />November 1, 2024 <br /> <br /> <br />Eugene Planning Commission <br />c/o Jeff Gepper, Senior Planner <br />Eugene Planning Division <br />99 W. 10th Avenue <br />Eugene, OR 97401 <br /> <br />Sent via email: JGepper@eugene-or.gov <br /> <br />RE: CA 24-3 Stormwater Code Amendments <br /> <br /> <br />Mr. Gepper: <br /> <br />In my role as ExecuƟve Officer of the Western Oregon Builders AssociaƟon (Ņa HBA of Lane County), I <br />wanted to reach out in advance of and submit for inclusion in the public tesƟmony porƟon of next <br />week’s Planning Commission meeƟng the following thoughts. <br /> <br />The primary objecƟon I want to convey on behalf of our members is the applicaƟon of stormwater code <br />amendments in projects that predate said amendments. We believe previously approved developments <br />with final recorded plat should not be subject to the amended stormwater standards as those prior <br />approvals represent a legally binding agreement of which the City is a party. As such, development <br />should proceed based on the originally approved standards. To do otherwise would cast doubt on the <br />integrity of future negoƟaƟons and agreements with the City. <br /> <br />Of added concern would be the applicaƟon of amended codes in cases of one-off or ghost lot buildouts <br />in subdivisions that are essenƟally completed under prior standards. Applying the new standards may <br />require an applicant to abandon a proposed project altogether for economic reasons, leaving a derelict <br />lot in an otherwise completed development. <br /> <br />In keeping with the Governor and Legislature’s iniƟaƟve to cut red tape and remove barriers to boost <br />housing in Oregon, our firm belief is that previously approved developments be honored and exempted <br />from updated stormwater standards. Doing so will also decrease the likelihood that local decisions could <br />be subject to scruƟny by the Governor’s new Housing Accountability and ProducƟon Office that would <br />further delay our mutual objecƟve of providing much needed housing. <br />