ATTN: Nick Gioello, Associate Planner <br />City of Eugene, Planning and Development, Planning Division <br />99 West 10th Ave, Suite 290 <br />Eugene, OR 97401 <br />From: Albert LePage, M.Ed.Science, B.S.Biology, Member, Society for Conservation Biology <br />1944 Cleveland St <br />Eugene, OR 97405 <br />Date: February 14, 2026 <br />Comments Re: PDF 25-01 (Final PUD – “Braewood Hills 3rd Addition”) and SDR 25-02 (/WR <br />Water Resources Overlay – Randy Lane Extension) <br />Hello Mr. Gioello: <br />I am writing to provide comments on the Final Planned Unit Development application PDF 25 -01 for <br />Braewood Hills 3rd Addition and the associated Standards Review application SDR 25 -02 for work within <br />the /WR Water Resources Overlay to extend Randy Lane through the southern portion of the property. I <br />respectfully request that the City deny the applications as currently submitted because the record does <br />not demonstrate compliance with the applicable approval criteria in EC 9.8365, 9.8470, and 9.4980, and <br />because the information provided is incomplete, inconsistent, and in several instances speculative or <br />unsupported by data. [1][2][3] <br />1. EC 9.8365 – Final PUD does not conform to tentative approval and conditions <br />EC 9.8365 requires a finding that the final PUD plan “conforms with the approved tentative PUD plan and all <br />conditions attached thereto.”[1] <br />The January 21, 2026 supplemental materials describe multiple conditions of approval (COA 5, 6, 7, 15, 16, 26) <br />that were previously found not satisfied, and assert that new easement documents and a revised stormwater <br />report now resolve these issues. However, several of these responses still do not show clear, objective <br />conformance with the tentative approval: [6] <br />COA 7 – Public wastewater easement: The City’s prior comment notes that the final plans “do not show <br />a 14-foot PUE or Public Wastewater Easement to encumber the proposed public wastewater system,” yet <br />the applicant’s response is simply that the final plans show a PUE over the entire width of the private <br />roads and that this “satisfies this requirement,” with no revised plan sheet or measurement confirming <br />that the easement width, alignment, and rights match the condition of approval. This is a conclusory <br />statement, not evidence of compliance.[6] <br />COA 26 – Stormwater compliance with EC 9.6796: The stormwater report asserts that “no errors were <br />found in the stormwater system design” and that “the facilities and conveyance components have enough <br />capacity to handle the required storm events and should be approved as designed,” but this is the <br />engineer’s own self-evaluation rather than a demonstration that each applicable criterion in EC 9.6796 <br />and related stormwater standards is actually met. The report does not provide a clear checklist <br />cross-walk to the City’s adopted stormwater manual and code provisions, leaving gaps in the evidence <br />needed for a final PUD finding under EC 9.8365. [2] [6] <br />Joint Access and Maintenance (COA 5, 6, 15, 16): The various agreements (JAM and multiple “Private <br />Utility and Joint Access Easements”) are lengthy, complex, and impose numerous cross-easement and <br />cost-sharing obligations on future owners that are not transparent in the PUD plan itself. There is no <br />demonstration in the record that these private easement schemes preserve the same functional <br />circulation, emergency access, and utility access that were evaluated at tentative PUD, nor that they are <br />consistent with the City’s street and access standards. [6]