Hathaway Koback <br />Connors LLP <br />Receiad in P" t c bearing <br />City of Eugene PLrning, & Development <br />JUN 08 2016 <br />File W& 16-/ <br />Exhibit -7~. 1 <br />June 8, 2016 <br />VIA HAND DELIVERY <br />City Hearings Officer <br />Eugene Planning Department <br />Atrium Building <br />99 West 10th Avenue <br />Eugene, OR 97401 <br />Re: Eugene Towneplace Suites (WG 16-1/SR 16-1/ARB 16-3) <br />Dear Hearings Officer: <br />520 SW Yamhill St. <br />Suite 235 <br />Portland, OR 97204 <br />E. Michael Connors <br />503-205-8400 main <br />503-205-8401 direct <br />mikeconnors(@hkc1lp.com <br />This office represents Rockbridge Capital, the owners and operators of the Valley River Inn <br />located at 1000 Valley River Way, Eugene, OR 97401. We are submitting the following <br />comments with respect to the above-referenced Valley Hospitality, LLC's (the "Applicant") <br />application for the proposed 101-room hotel (the "Application"). <br />As the Applicant readily admits, this particular site is extremely challenging due to its access, <br />size, configuration and proximity to the Willamette River. As a result of these site constraints, a <br />101-room hotel is simply not appropriate on this site. This problem is reflected by the fact that <br />the Applicant is requesting several adjustments to the approval standards and failed to <br />demonstrate compliance with several other applicable approval criteria as noted in this letter. <br />Therefore, the Application should be denied for the reasons provided herein. <br />1. EC 9.2170(4)(b) - Setbacks. <br />The Applicant failed to demonstrate compliance with the setback requirements set forth in <br />Eugene Code ("EC") 9.2170(4)(b) in several respects. EC 9.2170(4)(b) imposes front yard <br />setback requirements and restrictions. Both EC 9.2170(4)(b) and the definition of "Front Yard <br />Setback" make it clear that there can be more than one front yard setback if the building has <br />frontage on more than one street. In this case, there are two frontages - Valley River Drive and <br />Delta Highway/I-105. <br />Notwithstanding the fact that the subject property clearly has frontage along Valley River Drive, <br />the Applicant only addressed this requirement with respect to the east facade facing Delta <br />Highway/I-105. The Applicant claims that it is not required to demonstrate compliance with <br />respect to the north facade facing Valley River Drive "per guidance from the City of Eugene <br />