<br />July 2025 Findings & Decision of the Planning Director Page 5 of 10 <br />Headwaters Trail Electric Upgrade (SDR 25-1) <br />The applicant has demonstrated in their written materials that the proposal that the new <br />underground lines are serving existing development and are not serving undeveloped area. The <br />new underground utilities have also been designed to mitigate, to the greatest extent possible, <br />impacts to the protected resources in the area. Overall, the underground of infrastructure will <br />help to mitigate the need for future vegetation and soil impacts by requiring less maintenance <br />that overhead utility infrastructure. Again, the applicant states in their site plans that all <br />impacted areas will be backfilled with 24 inches of materials. A report by Joe Bettis of <br />Turnstone Environmental Consulting dated May 12, 2025 concluded that there are no rare <br />species in this area of proposed work. Finally, the applicant once again agrees that work will be <br />limited to June 30 through September 30 to avoid soil compaction and other adverse impacts. <br />Based on these findings and the applicant’s materials, their proposal complies with the <br />requirements set out in EC 9.4930(3)(e)1-5. Findings demonstrating compliance with EC <br />9.4980(2) through (5) are provided below. <br />EC 9.4980 /WR Water Resources Conservation Overlay Zone – Development Standards. <br />(2) Vegetation Removal. Vegetation removal within the /WR conservation area and within <br />areas removed from the /WR conservation area shall comply with the following standards: <br />(a) Vegetation removal shall be limited to: <br />1. Plant species that are non-native and invasive; <br />2. Dead or dried native plants or grasses only when they constitute an imminent fire <br />hazard; <br />3. Living native or non-native vegetation, when its removal is necessary to facilitate <br />or encourage the growth of other native species (e.g., native wet prairie plant <br />species) consistent with adopted plans or policies; or <br />4. The minimum area of native vegetation removal necessary to accommodate uses <br />approved in accordance with EC 9.4930(3)(a) through EC 9.4930(3)(k), and uses <br />approved through an adjustment approved in accordance with EC 9.8030(21). <br />The applicant notes that this area has recently had significant vegetation removal by the City of <br />Eugene Parks and Open Space work teams to help eliminate invasive blackberries. The applicant <br />acknowledges that they will conduct the minimum amount of vegetation re moval needed to <br />conduct the work for replacement of the existing poles and the new underground utility. The <br />applicant’s site plans include an area of impact an anticipated removal necessary to conduct the <br />work. Based on the applicant’s site plans and written statement, they will comply with this <br />requirement. Based on the available information, this standard is met. <br />(b) Clearing of more than 500 square feet of vegetation must comply with Erosion <br />Prevention regulations for sensitive areas in EC 6.645. <br />Approximately 1,500 square feet of disturbance area is proposed. The written narrative states, <br />“Erosion and sediment control measures are provided in the attached erosion control plan. <br />Erosion control for this project will be regulated according to the City of Eugene Commercial