Hathaway Koback <br />Connors uP <br />June 22, 2016 <br />VIA EMAIL <br />Fred Wilson <br />City Hearings Officer <br />c/o Erik Berg-Johanson <br />Eugene Planning Department <br />Atrium Building <br />99 West 10" Avenue <br />Eugene, OR 97401 <br />Re: Eugene Towneplace Suites (WG 16-1/SR 16-1/ARB 16-3) <br />Rebuttal Letter <br />Dear Mr. Wilson: <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 />m i keco n n ors Ah kcl l o. com <br />As you know, this office represents Rockbridge Capital, the owners and operators of the Valley <br />River Inn located at 1000 Valley River Way, Eugene, OR 97401 ("Valley River Inn"). At the <br />June 8 public hearing for Valley Hospitality, LLC's (the "Applicant") above-referenced <br />application for the proposed 101-room hotel (the "Application"), you established a post-hearing <br />process that allowed the parties to submit rebuttal evidence and argument pursuant to ORS <br />197.763(6)(c). This letter constitutes Valley River Inn's rebuttal to the supplemental evidence <br />submitted by the Applicant on June 15. As explained below, the Applicant's supplemental <br />submissions failed to adequately address the issues raised by Valley River Inn and therefore the <br />Application must be denied. <br />A. Procedural Issues. <br />Before addressing the substantive merits of the supplemental evidence submitted by the <br />Applicant, there are two procedural issues Valley River Inn needs to raise. First, the Applicant's <br />Exhibit C2, the arborist's supplemental report, cannot be considered because it was submitted <br />after the deadline established at the hearing. The deadline for submitting supplemental evidence <br />was 5 p.m. on June 15, 2016. As noted by the City staff, the Applicant submitted Exhibit C2 <br />after this deadline. Therefore, Exhibit C2 should be rejected and the Applicant cannot rely on it <br />for purposes of justifying the Application. <br />Second, Valley River Inn wants to clearly state that it will object to any new evidence included <br />in the Applicant's closing argument. Valley River Inn raised a number of specific questions and <br />concerns about the Application and its compliance with various criteria. Rather than respond to <br />