Hearings Official Decision (PDT 24-1; ST 24-3) 19 <br />existing grades on site. Sheet EXH-1 of the applicant’s site plan shows that a future street <br />connection to the north could not meet current adopted street design standards, more <br />specifically Section 2.05(J)(4) of the City of Eugene’s Public Improvement Design <br />Standards (PIDS), as the proposed street grade would exceed 20 percent.” <br />However, in its July 31, 2024 Revised Referral Comments, Public Works staff revised its <br />analysis and recommendation. While adhering to its analysis that the existing grades precluded <br />compliance with the current street design standards for connections in the direction to the north <br />and northeast, the Public Works staff determined both that the applicant had not established a <br />valid basis for an exception to the connectivity requirement for Randy Lane and also that, in <br />accordance with EC 9.6815(2)(a), Randy Lane be required to be a public street. Each of those <br />issues is addressed in relation to the applicable approval criteria as follows: <br />EC 9.6815(2)(a): All streets shall be public unless the developer demonstrates that a <br />public street or alley is not necessary for compliance with this land use code or the <br />street connectivity standards of subparagraphs (b) through (f). <br />EC 9.6815(2)(b) The proposed development shall include street connections in the <br />direction of all existing or planned streets within ¼ mile of the development site. The <br />proposed development shall also include street connections to any streets that abut, <br />are adjacent to, or terminate at the development site. <br />In its revised analysis and recommendation, Public Works staff explained its recommendation <br />that EC 9.6815(2)(a) requires Randy Lane be developed as a public street: <br />“Randy Lane is an east/west public street that terminates at one end of this development <br />site and resumes at the another; this development site constitutes the missing segment of <br />Randy Lane. * * * * * <br />“Additionally, the missing segment needed to connect Randy Lane’s east and west <br />termini is not entirely located on land above 901 feet, and the portion that is above 900 <br />feet could be built; EC 9.8325(8) does not govern every scenario in which the street could <br />be completed in the future.” <br />The Public Works analysis also includes detailed findings demonstrating the public interest in <br />establishing Randy Lane as a public street and the constitutional nexus between the impact of the <br />requirement to dedicate the public right-of-way and that public interest. Those findings, at pages <br />3-5 of the July 30, 2024 REVISED Public Works Referral Response are incorporated and <br />adopted by this reference. <br />The applicant asserts that this is a “discretionary demand’ prohibited under the clear and <br />objective criteria. Specifically, the applicant argues the City is not authorized to require its <br />extension of Randy Lane, from its existing terminus as a public street at its intersection with <br />Blacktail Drive, along the property’s southern boundary, to its proposed termination at or near <br />the proposed 901 foot line of the property, as a public street. The applicant asserts that the “City <br />Planning Commission Agenda Page 51 of 159