Applicant Final Argument Testimony - 4-29-2021

Law Office of Mike Reeder C'rcqoi- Lan c, Usc La April 29, 2021 Virginia Gustafson Lucker, Eugene Hearings Official c/o Rodney Bohner, Associate Planner Planning Division City of Eugene 99 W. 10th Ave. Eugene, OR 97401 rbohner o,eugene-or.gov Re: Cottages at Delta Ridge (PDT 20-4/WG 20-1/ARB 20-3) Applicant's Final Argument Dear Ms. Gustafson Lucker: The Applicant provides this letter as its final written argument. The Applicant has previously responded to all of the issues raised by the opponents on or before April 15, 2021. On April 23rd, the Applicant received a letter dated April 22nd from Charles Woodward IV on behalf of Hope Vaccher. Ms. Vaccher claims that she is responding to an issue raised by Jeff and Linda Cook regarding the Applicant's request for an adjustment to the block standards. However, the sole issue raised by M. Vaccher in her April 22nd letter was addressed in my letter dated April 22nd on behalf of the Applicant in response to the same issue raised by the Cooks previously. For convenience I provide an excerpt of the Applicant's April 22, 2021 letter (pages 7- 9, internal footnotes omitted) to show that Ms. Vaccher's argument is without merit: `Issue #4 - Adjustment to Block Requirements The Cooks discuss the adjustment to the block requirement of EC 9.5500(10). This standard requires that, without an adjustment, a multiple-family development on 8 or more acres create 4 acre or smaller blocks bounded by public or private streets. The Applicant's Street Connectivity Study by Kelly Sandow, P.E. of Sandow Engineering, dated February 11, 2021 (Exhibit E of the initial Application), provides the justification for the requested adjustment to the block requirements on pages 10-12. Ms. Sandow states as follows on page 12: Of= cr vio"c: I'G78) J IJ 281 5 4L 1 ,+ct.. 5.:... )OP) Fre'(n;ri'egrrl :,is~ rr;n f .i_F i C,.Fr...r 'l ",101 cfcccnI ndUS0.Woni