LAW OFFICE OF BILL KLOOS PC <br />OREGON LAND USE LAW <br />375 W. 4TH AVENUE, SUITE 204 <br />EUGENE. OR 97401 <br />TEL: 541.343.8596 <br />WEB: WWW.LANDUSEOREGON.COM <br />December 16, 2015 <br />Eugene Planning Commission <br />c/o Eugene Planning and Development <br />Atrium Building <br />99 West 10th Ave. <br />Eugene, OR 97401 <br />-Received <br />DEC 18 2015 <br />City of Eugene <br />Planning Division <br />BILL KLOOS <br />BILLKLOOS a;LANDUSEOREGON.COM <br />Re: Chamotee Trails PUD (PDT 15-1/ARA 15-13)-- <br />Applicant's Appeal of Hearings Official Denial to Planning Commission <br />Dear Commissioners: <br />The major case the applicant is relying upon for its argument under the Needed Housing Statute <br />is the recent opinion of LUBA in the Group B, LLC matter in the City of Corvallis. The legal <br />issue is identical, notwithstanding the Hearings Official's attempt to distinguish it. <br />That LUBA opinion has now been affirmed by the Court of Appeals. The full citation is: <br />Group B, LLC v. Citv of Cot-vallis, _ Or LUBA _ (August 25, 2015), aff'd without opinion <br />275 Or App 577 (Dec. 16, 2015). <br />The Court's decision does not add anything to the LUBA decision. It just says that LUBA got it <br />right. <br />Sincerely. <br />ogee gym" <br />Bill Kloos <br />