From:Mark Biggin <br />To:GIOELLO Nick R <br />Subject:re PDF 25-01 and SDR 25-02 <br />Date:Thursday, February 19, 2026 9:19:37 AM <br />You don't often get email from markbiggin@sbcglobal.net. Learn why this is important <br />[EXTERNAL ] <br />Dear Nick Gioello, I request that the applications for the Braewood Hills 3rd addition Final PUD <br />(PDF 25-01) and Standards Review (SDR 25-02) be denied for the following reasons. <br />Re SDR 25-02 <br />1. Eugene City code EC 9.4920 (2) (b) requires a predetermined setback on Goal 5 <br />wetlands. The wetland on the property (AMA 5B) is a Category B wetland and thus requires a <br />25-foot buffer. The established boundary of the wetland can be from the jurisdictional <br />wetland boundary accepted by the Oregon Department of State Lands, if provided by the <br />property owner. Indeed, the application includes such a map accepted by Oregon Department <br />of State Lands. The map labels the wetland as Wetland 2B and shows clearly that the wetland <br />is wider than the conservation setback on the developer’s site map and thus the setback does <br />not meet the 25-foot setback requirement. Obviously the developer’s setback must be <br />widened. <br />2. Eugene City code EC 94920 (3) code indicates that if a wetland and stream exist <br />together, the /WR conservation area is the total footprint of the /WR conservation areas <br />combined. <br />a. The proper /WR conservation area has not been determined, as the /WR conservation <br />area for the wetlands was not calculated or mapped at all. Nor was the total footprint <br />combined. The City should insist that a 25-foot setback for the wetland be combined with the <br />40-foot setback for the Category C stream. In some places, this revised setback will be more <br />than that in the current the site plan. <br />b. All wetlands within 50 feet of property lines need to be identified and noted since all <br />wetlands are a natural resource and the City has designated the whole site as a Goal 5 <br />resource. <br />c. The site plan should also properly identify all trees by species and dimension on the site <br />plan as they, too, are a natural resource. <br />d. Critical root zones for trees to be preserved within the /WR conservation area must be <br />shown and information provided on how they will not be negatively impacted. As the <br />applicant has not provided the proper conservation zone to include wetland AMA 5B/Wetland