<br /> <br /> Comments of Keri Green <br /> PDF-25-01/SDR 25-02 <br />____________________________________________________________________________________ <br /> <br /> 1 <br /> February 20, 2026 <br /> 2225 McLean Blvd. <br /> Eugene, Oregon 97405 <br /> <br /> <br /> <br />Mr. Nick Gioello, Associate Planner <br />City of Eugene <br /> <br />Re: Braewood Hills 3rd Addition <br />File Numbers: PDF 25-01 / SDR 25-02 <br /> <br />Dear Mr. Gioello, <br /> <br />The applicant’s proposal remains incomplete and out of compliance with Eugene’s code requirements. I <br />request this application be denied for the reasons below. <br /> <br />EC 9.4920 (2)(b) /WR Water Resources Conservation Overlay Zone <br />This code is applicable because the property contains a Goal 5 water resource site identified for <br />conservation. For Wetland 2B, the applicant has not met the required setback of 25 feet. This code must <br />be considered in tandem with EC 9.4920 (3) which requires that a total calculation be done when <br />wetlands exist along with a riparian site. The code states: “…the /WR conservation area for each of the <br />individual water features shall be calculated and mapped separately, and the total footprint of all the <br />individual /WR conservation areas combined shall be the /WR conservation area for that site.” The <br />required setback for the Category C stream is 40 feet. Therefore, the setback for Wetland 2B should be at <br />least 65 feet. <br /> <br />The City of Eugene has previously acknowledged that the subject property is Goal 5. As such, it behooves <br />the planning department to apply the land use standards required by the Goal 5 natural resources <br />conservation regulations of the State of Oregon (Oregon’s Statewide Planning Goals and Guidelines <br />OAR 660-015-0000(5). <br /> <br />For reference, here is an excerpt from the Hearings Official Decision Braewood Hills 3rd <br />Addition (PDT 24-1; ST 24-3) September 5, 2024, Page 8: <br /> <br />…the subject property is included on the City’s acknowledged Goal 5, based on its inclusion in <br />the April 12, 1978, Scenic Sites Working Paper, which is adopted as an inventory of significant <br />Goal 5 resource within the City of Eugene by Ordinance No. 20351. As the staff report explains, <br />the Scenic Sites Working Paper designates the subject site as one of the Natural Sites of Visual <br />Prominence and Prominent and Plentiful Vegetation. The City entered into the Record an undated <br />and unlabeled map that the City states is the “Figure H2” that is identified as “Metro Plan Update, <br />Natural Assets and Constraints-Working Papers Scenic Areas.” According to staff’s calculations, <br />this “Figure H-2” generally identifies the entire subject property (as well as a large swath of the <br />City’s South, Southwest and East Hills) as being within the acknowledged Goal 5 inventory. <br />Within that general area, a protected upland stream corridor on the subject property is listed on <br />the City’s adopted Goal 5 Water Resources Inventory (2005), as reflected by the /WR Water <br />Resources Conservation Overlay zone for this property. <br /> <br />EC 9.6885 Tree Preservation and Removal Standards <br />My comments in this section refer to Tree Preservation within Videra Park