<br /> <br /> <br />CA 24-3 Code Amendments Page 3 of 3 <br />Bishow Testimony October 25, 2024 <br />There is an insufficient factual basis to justify the proposed new stormwater standards applying to <br />commercial and industrial projects subject to city approved land use decisions that already demonstrated <br />compliance with city stormwater standards. For example, developments required to comply with an <br />approved PUD should not be required to modify the PUD or submit a new Tentative PUD application. <br /> <br />The Code Amendments are NOT Consistent with Statewide Goal 10 <br /> <br />Draft EC 9.6792(3)(b)2 refers to the applicant demonstrating the development site has “insufficient land <br />area to construct an infiltration or extended filtration facility” and “The proposed development is <br />otherwise consistent with all other applicable lot and development standards.” The term “insufficient lot <br />area” is ambiguous. The requirement that the project is consistent with all other standards does not <br />appear to include city approved modifications or variances. <br /> <br />What about exempting residential developments that achieve at least 80% of the maximum allowed <br />density and commercial and industrial developments that achieve a specific FAR? What about adding to <br />EC 9.6792(3)(b)2b, “or as modified through a PUD, Adjustment Review or other land use decision”? <br /> <br />The Code Amendments are NOT Consistent with Envision Eugene <br /> <br />The Envision Eugene Comprehensive Plan states, “New land use plans and changes to the City’s land use <br />code and land use plans must be consistent with the policies in the Envision Eugene Comprehensive <br />Plan.” (page I-3) <br /> <br />The proposed code amendments are not consistent with the Envision Eugene Comprehensive Plan <br />policies below on page ED-4. <br />Policy 3.5 Business retention and expansion. Facilitate the retention and growth of existing <br />businesses in the community. <br />Policy 3.6 Responsible economic development. Support economic development initiatives that <br />reflect long-term priorities, improve community resilience to climate change and natural hazards, <br />improve energy efficiency or reduce greenhouse gas emissions, and enhance opportunities to <br />borrow, rent, or otherwise make better use of underutilized public and private assets. <br /> <br />The proposed code amendments could substantially increase the cost of commercial and industrial <br />developments and do not support business retention and expansion. The proposed code amendments <br />conflict with energy related policies to shift away from the use of fossil fuel and create more climate <br />friendly developments. For example, as existing fuel stations and parking areas transition towards use of <br />electric vehicles, it is likely existing paved areas will be replaced as new infrastructure is installed for <br />charging stations and underground fuel tanks are removed. As land prices increase, surface parking lots <br />may increasingly be redeveloped into parking garages and more climate friendly developments. Do the <br />draft stormwater standards adequately balance other community policies? <br /> <br />Sincerely, <br /> <br />Teresa Bishow <br />Teresa Bishow, AICP <br />