Planning Commission

AGENDA Meeting Location: Sloat Room—Atrium Building Phone: 541‐682‐5481 99 W. 10th Avenue www.eugene‐or.gov/pc Eugene, OR 97401 The Eugene Planning Commission welcomes your interest in these agenda items. Feel free to come and go as you please at any of the meetings. This meeting location is wheelchair‐accessible. For the hearing impaired, FM assistive‐listening devices are available, or an interpreter can be provided with 48 hour notice prior to the meeting. Spanish‐language interpretation will also be provided with 48 hour notice. To arrange for these services, contact the Planning Division at 541‐682‐5675. TUESDAY APRIL 16, 2019 – REGULAR MEETING (5:30 p.m. to 7:30 p.m.) A. PUBLIC COMMENT The Planning Commission reserves 10 minutes at the beginning of this meeting for public comment. The public may comment on any matter, except for items scheduled for public hearing or public hearing items for which the record has already closed. Generally, the time limit for public comment is three minutes; however, the Planning Commission reserves the option to reduce the time allowed each speaker based on the number of people requesting to speak. B. WORK SESSION: Clear & Objective Update (Batch 2 Draft Amendments) Staff: Jenessa Dragovich, 541‐682‐8385, JDragovich@eugene‐or.gov D. ITEMS FROM COMMISSION AND STAFF 1. Other Items from Staff 2. Other Items from Commission 3. Learning: How are we doing? Commissioners: Steven Baker; John Barofsky; Tiffany Edwards (Vice Chair); Lisa Fragala; Chris Ramey; William Randall; Kristen Taylor (Chair)  AGENDA ITEM SUMMARY April 16, 2019 To: Eugene Planning Commission From: Jenessa Dragovich, City of Eugene Planning Division Subject: Clear & Objective Update: Draft Code Language – Batch 2 Items ISSUE STATEMENT Staff requests that the Planning Commission review and provide feedback on the draft land use code language for implementing Batch 2 recommendations of the Clear & Objective Housing: Approval Criteria Update. BACKGROUND Eugene’s existing clear and objective approval criteria are being reevaluated and updated. Proposed updates must meet the following goals: • accommodate housing on lands available within our current urban growth boundary (UGB) • provide a clear and objective path to land use approval for all housing as required by State law • guide future housing development in a way that reflects our community’s values The project will identify land use approval criteria and procedures to be updated, added, or removed to improve efficiency in complying with State requirements for clear and objective regulations, while still effectively addressing development impacts. In July 2015, as part of the City Council’s direction on the UGB, Council directed staff to begin an update to the City’s procedures and approval criteria for needed housing applications (the Clear & Objective Housing: Approval Criteria Update), and to bring proposed updates back for their consideration within one year of UGB acknowledgement. The UGB was acknowledged by the State in January 2018. Our target is to request City Council action on a staff proposal for updated approval criteria in May 2019. If so directed, staff will then move forward with the formal adoption process. The Clear & Objective project is being completed in four phases and is currently in Phase 3, Draft Code Writing. During Phase 2, draft recommendations for addressing key issues identified during Phase 1 as within the scope of the project were split in to two batches. Batch 1 includes all maintenance issues and less complex issues. Batch 2 includes the more complex issues. Recommendations for both batches have been advanced to the code writing stage by City Council. The following dates are key project check-ins with Planning Commission and City Council: May 8, 2018 Project overview and introduction with Planning Commission May 30, 2018 Project overview and introduction with City Council June 25, 2018 Planning Commission approval of the Public Involvement Plan September 11, 2018 Summary of Key Issues Report provided via email November 19, 2018 Planning Commission review of Batch 1 recommendations November 26, 2018 Planning Commission summary of feedback on Batch 1 items November 26, 2018 City Council advanced Batch 1 recommendations to draft code writing December 10, 2018 Planning Commission review of Batch 2 recommendations December 11, 2018 Planning Commission review of Batch 2 recommendations January 23, 2019 City Council advanced Batch 2 recommendations to draft code writing February 4, 2019 Planning Commission review of Batch 1 draft code amendments DRAFT CODE LANGUAGE The Clear & Objective Update was designed to provide incremental review of proposed code changes, with public involvement and review by Planning Commission and City Council provided during each phase of the project. Stakeholders helped identify significant issues in Phase 1, helped generate possible concepts in Phase 2, and currently, (Phase 3) can weigh in on draft amendments. Planning Commission and City Council check-ins have occurred at key project milestones. The draft code writing phase is based on the Draft Preferred Concept Report (provided with the November 19, 2018 agenda packet), which was the outcome of Phase 2. The report presented staff recommendations on how to address the 37 key issues identified during Phase 1 of the project (and described in the Summary of Key Issues Report). The recommendations from the Draft Preferred Concept Report were derived using input from the working groups, research into the issues and possible concepts, consultation with internal staff who work with the land use application review process daily, and a concept evaluation rubric for the 19 significant issues. Planning Commission reviewed and provided feedback on all recommendations over the course of four work sessions in November and December. Recommendations, as modified by Planning Commission, were advanced to draft code writing by City Council in two batches. Based on these recommendations, draft code language was crafted using the help of consultants (for tree preservation and transition standards), researching other examples and best practices, and with internal review from city staff that work with the land use code on a daily basis. Attachment A contains draft land use code language for implementing Batch 2 recommendations. Note that one item, COS-01 (Clear & Objective Compatibility) was moved from Batch 1 to Batch 2 for draft code language. The topics included in Batch 2 are: • Clear & Objective Compatibility (COS-01)  • 30-Foot Buffer Requirement for PUDs (COS-02) • 20 Percent Slope Grading Prohibition (COS-03) • One Acre Accessible Open Space for PUDs (COS-04) • Limitation Over 900 Feet for PUDs (COS-05) • Ridgeline Setback for PUDs (COS-06) • 40 Percent Open Space Requirement for PUDs (COS-07) • Tree Preservation Consideration (COS-11) • Geotechnical Requirement (COS-13) • Street Standards Modifications (COS-19) A copy of the draft land use code language was provided to interested parties on March 29, 2019, and also forwarded to the Planning Commission. Feedback was requested from interested parties over the following two-week period. Staff also held two different office hours to provide time for interested parties to drop in to ask questions and go over the draft code. Four attendees representing the development community came to the two sessions, and their feedback and questions were primarily in response to the draft tree preservation standards. We heard concerns about the amount of cost preparing a tree preservation and removal plan would incur, especially for large sites; the impact the critical root zone, as currently measured, has on limiting the developability of a lot; and preference to add a minimum percentage of trees to be preserved, with the project arborist or landscape architect responsible for determining how to achieve the requirement. Support was also expressed for the removal of the 20 percent slope grading prohibition and the 30-foot buffer requirement. Written comments received as of the date of this Agenda Item Summary are provided in Attachment B. Any additional comments will be forwarded to the Planning Commission in advance of the April 16, 2019 meeting. PLANNING COMMISSION ROLE The Planning Commission is requested to review and provide feedback on the draft land use code language for Batch 2. Given the length, complexity, and interest in tree preservation standards, staff recommends dedicating the second work session to the proposed tree preservation section. Several of the remaining amendments are more straightforward and may not require as much discussion. For this work session, we will review the draft amendments in the following order: • Clear & Objective Compatibility (COS-01) o EC 9.5860 (page 1 of Attachment A) o EC 9.8100(1), 9.8325(1) (page 14) o EC 9.8445 (1) (page 17) • Geotechnical Requirement (COS-13) o EC 9.6710 (page 3) o EC 9.8030(37) (page 13) • Street Standards Modification (COS-19) o EC 9.6810 (page 4)  o EC 9.6815 (page 5) o EC 9.6820 (page 7) • 30-Foot Buffer Requirement for PUDs (COS-02) o EC 9.8325(3) (page 15) • 20 Percent Slope Grading Prohibition (COS-03) o EC 9.8325(5) (page 15) o EC 9.8520(5) (page 17) • One Acre Accessible Open Space for PUDs (COS-04) o EC 9.8325(8) (page 15) • Limitation Over 900 Feet for PUDs (COS-05) o EC 9.8325(12)(a) (page 16) o EC 9.8325(c) (page 17) o EC 9.6885(2) (page 8) • Ridgeline Setback for PUDs (COS-06) o EC 9.8325(12)(b) (page 16) • 40 Percent Open Space Requirement for PUDs (COS-07) o EC 9.8325 (page 17) • Tree Preservation Consideration (COS-11) o EC 9.6885(2) (page 8) NEXT STEPS Staff anticipates bringing proposed draft code language for both batches to City Council for a work session on May 20, 2019. At that time, Council may choose to initiate the formal adoption process. The formal adoption process will include opportunity for additional public comment and will include a Planning Commission public hearing and recommendation to City Council, followed by City Council public hearing and action. The project website is updated regularly with information about where we are in the process as well as available resources. ATTACHMENTS A. Draft Land Use Code Language for Batch 2 Issues B. Public comments received as of April 9, 2019 FOR MORE INFORMATION Staff Contact: Jenessa Dragovich, Senior Planner Telephone: 541-682-8385 Email: JDragovich@eugene-or.gov  Attachment A Clear & Objective Proposed Amendments - Batch 2 March 29, 2019 - DRAFT For background information on the proposed amendments, refer to the Preferred Concepts Report available on the project website at: www.eugene-or.gov/3947/Clear-Objective Proposed Batch 2 text in bold italic Proposed Batch 2 deletions in [bracketed strike-out] Proposed Batch 1 text in blue bold italic Proposed Batch 1 deletions in [blue bracketed strike-out] Special Development Standards for Certain Uses 9.5860 Transition Standards for Housing/Clear and Objective Applications. (1) Applicability of Transition Standards. The transition standards at EC 9.5860(2) shall apply to land use applications proposing housing to be reviewed with clear and objective approval criteria under EC 9.8100 Conditional Use Permit Approval Criteria – Housing/Clear and Objective, EC 9.8325 Tentative Planned Unit Development Approval Criteria – Housing/Clear and Objective, or EC 9.8445 Site Review Approval Criteria – Housing/Clear and Objective. The transition standards at EC 9.5860(2) apply to all new buildings and any building additions that increase the square footage of livable floor area by 20 percent or more for any of the following: (a) Multiple-family development on property abutting or directly across a public alley from land zoned R-1 or R-1.5, except where the multiple- family development consists of: 1. a single tri-plex on one lot. 2. a single four-plex on one lot. 3. structures that are less than 30 feet in height. (b) Assisted care, boarding and rooming house, campus living organization, university or college dormitory, or single room occupancy (SRO), proposed on property abutting or directly across a public alley from land zoned R-1 or R-1.5. In cases where the standards in subsection (2) apply to building additions, they shall be applicable between the addition and any property line abutting or directly across a public alley from land zoned R-1 or R-1.5. (2) Standards. The following standards apply to new buildings and building additions identified in subsection (1) and must be applied along the portion of any property line that abuts or is directly across a public alley from land zoned R-1 or R-1.5: (a) Height and Setback Options. The proposed development must comply with one of the following four options: 1. Option 1. The maximum building height of a new building or building addition shall be limited to 35 feet. In addition, at least one of the following options must be provided along the entire portion 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 1 of 18  of any property line that abuts or is directly across a public alley from land zoned R-1 or R-1.5: a. A 6-foot high, 100 percent sight-obscuring wooden fence or masonry wall. b. Landscaping with a minimum plant bed width of 7 feet meeting EC 9.6210(3) High Screen Landscape Standard (L-3). Driveways off an alley may intersect the required screening within 30 degrees of perpendicular, as measured from the centerline of the driveway to the centerline of the alley right-of-way, and are limited to a maximum width of 15 feet for one-way access or 28 feet for two-way access. 2. Option 2. The minimum interior yard setback shall be 10 feet from the portion of any property line that abuts or is directly across a public alley from land zoned R-1 or R-1.5. In addition: a. At a point that is 25 feet above grade, the interior yard setback shall slope at the rate of 10 inches vertically for every 12 inches horizontally away from that property line until a point 50 feet away from the property line. b. For new buildings or building additions within 30 feet of R-1 or R-1.5 zoned property, trees growing to a mature height of 20 to 30 feet shall be planted at a minimum interval of 15 feet, parallel to the property line, between buildings and any property line that abuts or is directly across a public alley from land zoned R-1 or R-1.5. In addition, at least one of the following shall be provided along the portion of any property line that abuts or is directly across a public alley from land zoned R-1 or R-1.5: (1) A 6-foot high, 100 percent sight-obscuring wooden fence or masonry wall. (2) Landscaping with a minimum plant bed width of 7 feet meeting EC 9.6210(3) High Screen Landscape Standard (L-3). Driveways off an alley may intersect the required screening within 30 degrees of perpendicular, as measured from the centerline of the driveway to the centerline of the alley right- of-way, and are limited to a maximum width of 15 feet for one- way access or 28 feet for two-way access. 3. Option 3. A minimum 30-foot setback shall be provided between a new building or building addition and the portion of any property line that abuts or is directly across a public alley from land zoned R-1 or R-1.5. The 30-foot setback area may be used for open space, vehicle use area, bicycle and pedestrian circulation, or landscape screening and must contain trees growing to a mature height of at least 20 feet, spaced at a minimum interval of 25 feet, parallel to and within five feet of the property line, in the setback area. 4. Option 4. A new building or building addition shall be set back at least 50 feet or a setback equal to the height of the tallest building on the development site, whichever is less, from the portion of any property line that abuts or is directly across a public alley from land zoned R-1 or R-1.5. The 50-foot setback area may be used for 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 2 of 18  open space, vehicle use area, bicycle and pedestrian circulation, or landscape screening. (b) Allowed intrusions into setbacks. In lieu of the permitted setback intrusions provided at EC 9.6745(3) the following intrusions are allowed within the interior yard setback area described in subparagraphs (a)2 through 4: 1. Eaves and chimneys may intrude a maximum of 2 feet into the vertical plane of the interior yard sloped setback area. No other intrusions are allowed into the vertical plane of the setback. 2. Dormers may intrude into the sloped portion of the interior yard sloped setback area provided each dormer is no more than 10 feet wide and the total width of all dormers on a given wall does not exceed 30 percent of the linear length of the building wall. 3. Architectural screens or arbors serving an upper floor balcony may protrude a maximum of 6 feet into the sloped portion of the interior yard sloped setback area. (c) Balconies, decks and other outdoor spaces located above the ground floor shall be setback at least 20 feet from any property line that abuts land zoned R-1 or R-1.5. (d) Tree Exception. An exception to the tree planting required by subsections (a)(2) and (3) is allowed if the applicant provides a signed and notarized letter from the abutting property owner stating that the abutting property owner does not desire the trees required by this section. This exception does not apply to trees required by other applicable standards. Future development proposals subject to the standards in this section will need to obtain a separate exception from the tree planting requirements of this section. This change implements COS-01 (Clear & Objective Compatibility). The new code section applies to higher-instensity development abutting lower-intensity development (e.g. multi-family development next to single family development in the R-1 Low-Density Residential zone). The proposed code language provides four options for providing a transition buffers when required. General Standards for All Development 9.6710 Geological and Geotechnical Analysis. (6) [Needed] Clear and Objective Housing. Unless exempt under 9.6710(3)[(a)-(f)], in lieu of compliance with subsections (2), (4), and (5) of this section, applications proposing [needed]housing to be reviewed with clear and objective approval criteria shall include a certification from an Oregon licensed Engineering Geologist or an Oregon licensed Civil Engineer with geological experience, prepared within five years of the date of application, that includes the following information[stating]: (a) Identification of any portion of the proposed development site that is located in an area of moderate or high landslide susceptibility as shown on the city’s adopted Eugene Landslide Hazard Map. 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 3 of 18  (ab) A statement t[T]hat the proposed development [activity]will not be impacted by existing or potential stability problems or any of the following site conditions: slopes 20 percent or greater, springs or seeps, depth of soil bedrock, soil types, variations in soil types, open drainage ways, fill, or a combination of these conditions. (bc) If proposed development [activity]will be located in an area identified as moderately or highly susceptible to landslides pursuant to (a), or will be impacted by existing or potential stability problems or any of the site conditions listed in (ab), the certification must also include: 1. A review of the suitability of the proposed lot layout, street locations, and proposed locations for utilities, driveways, parking areas, and buildings given the landslide hazards, stability problems, and/or site conditions identified in the certification; 2. Any recommended modifications to the proposed lot layout, street locations, and proposed locations for utilities, driveways, parking areas, and buildings that in the engineer’s opinion, would mitigate the landslide hazards, stability problems, and/or site conditions identified in the certification; 3. Methods for safely addressing the landslide hazards and/or site conditions identified in (b) and (c)[.]; and, 4. Recommendations, if any, for additional geotechnical analysis for future buildings or improvements on the development site. 5. Recommendations, if any, for additional geotechnical analysis for future buildings or improvements on proposed lots or parcels. If [a statement]certification is submitted under (6)(bc), the application shall include the applicant’s statement that it will develop in accordance with the Engineer’s [statement]certification. This change implements COS-13 (Geotechnical Requirement). The revised code language adds additional risk factors to be considered and clarifies what the professional certification must address. These changes also relate to COS-03 (20 Percent Slope Grading Prohibition) and the recommendation to remove the prohibition on grading and rely on the geotechnical review. The proposed change includes adding 20 percent or greater slopes as an indicator of potential stability problems and specifically and requires review and recommendations of the proposed lot layout and street locations. 9.6810 Block Length. (1) Except as provided in subsections (2) and (3) of this section, b[B]lock length for local streets shall not exceed 600 feet.[,] (12)Applications not proposing housing to be reviewed with clear and objective approval criteria, [unless an exception is] may be exempt from the block length requirements in subsection (1)[granted] based on one or more of the following: (2a) Physical conditions preclude a block length 600 feet or less. Such conditions may include, but are not limited to, topography or the existence of natural resource areas such as wetlands, ponds, streams, channels, rivers, lakes or 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 4 of 18  upland wildlife habitat area, or a resource on the National Wetland Inventory or under protection by state or federal law. (3b) Buildings or other existing development on adjacent lands, including previously subdivided but vacant lots or parcels, physically preclude a block length 600 feet or less, considering the potential for redevelopment. (4c) An existing public street or streets terminating at the boundary of the development site have a block length exceeding 600 feet, or are situated such that the extension of the street(s) into the development site would create a block length exceeding 600 feet. In such cases, the block length shall be as close to 600 feet as practicable. (5d) As part of a Type II or Type III process, the developer demonstrates that a strict application of the 600-foot requirement would result in a street network that is no more beneficial to vehicular, pedestrian or bicycle traffic than the proposed street network and that the proposed street network will accommodate necessary emergency access. (23) Applications proposing housing to be reviewed with clear and objective approval criteria, must comply with the block length requirements in subsection (1) unless existing slopes would result in a street grade that exceeds the grade allowed under current adopted street design standards when measured from proposed streets to the existing grade of the subdivision boundary or abutting property under separate ownership. (4) Block length may be adjusted in accordance with EC 9.8030(37) for applications proposing housing to be reviewed with clear and objective approval criteria. This change relates to COS-19 (Street Modifications). The proposed changes and new language clarify the available exceptions to block length, street connectivity, and cul-de-sac or emergency turnarounds for Clear & Objective applications. An option to seek a discretional adjustment is also proposed. 9.6815 Connectivity for Streets. (2) Street Connectivity Standards. (a) All streets and alleys shall be public unless the developer demonstrates that a public street or alley is not necessary for compliance with this land use code or the street connectivity standards of subparagraphs (b) through (f) of this subsection. (b) The proposed development shall include street connections in the direction of all existing or planned streets within 1/4 mile of the development site. The proposed development shall also include street connections to any streets that abut, are adjacent to, or terminate at the development site. (c) The proposed development shall include streets that extend to undeveloped or partially developed land that is adjacent to the development site or that is separated from the development site by a drainage channel, transmission easement, survey gap, or similar property condition. The streets shall be in locations that will enable adjoining properties to connect to the proposed development’s street system. 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 5 of 18  (d) Secondary access for fire and emergency medical vehicles consistent with EC 9.6870 is required. (e) Except for applications proposing [needed] housing to be reviewed with clear and objective approval criteria, all applicants shall show that the proposed street alignment shall minimize excavation and embankment and avoid impacts to natural resources, including water-related features. (f) In cases where a required street connection would result in the extension of an existing street that is not improved to city standards and the street has an inadequate driving surface, the developer shall construct a temporary barrier at the entrance to the unimproved street section with provision for bicycle, pedestrian, and emergency vehicle access. The barrier shall be removed by the city at the time the existing street is improved to city standards or to an acceptable standard adopted by the public works director. In making a determination of an inadequate driving surface, the public works director shall consider the street rating according to Eugene’s Paving Management System and the anticipated traffic volume. (g) Except for applications proposing housing to be reviewed with clear and objective approval criteria, [I]in the context of a Type II or Type III land use decision, the city shall grant an exception to the standards in subsections (2)(b), (c) or (d) if the applicant demonstrates that any proposed exceptions are consistent with either subsection 1. or 2. below: 1. The applicant has provided to the city, at his or her expense, a local street connection study that demonstrates: a. That the proposed street system meets the intent of street connectivity provisions of this land use code as expressed in EC 9.6815(1); and b. How undeveloped or partially developed properties within a quarter mile can be adequately served by alternative street layouts. 2. The applicant demonstrates that a connection cannot be made because of the existence of one or more of the following conditions: a. Physical conditions preclude development of the connecting street. Such conditions may include, but are not limited to, topography or likely impact to natural resource areas such as wetlands, ponds, streams, channels, rivers, lakes or upland wildlife habitat area, or a resource on the National Wetland Inventory or under protection by state or federal law. b. Buildings or other existing development on adjacent lands, including previously subdivided but vacant lots or parcels, physically preclude a connection now or in the future, considering the potential for redevelopment. (h) For applications proposing housing to be reviewed with clear and objective approval criteria, exceptions to street connectivity standards may be granted if one of the following conditions exists: 1. Existing buildings on land abutting the development site and under separate ownership obstruct the extension of the planned street; 2. Existing slopes would result in a street grade exceeding current adopted street design standards when measured from proposed streets to the existing grade of the subdivision boundary or 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 6 of 18  abutting property under separate ownership; 3. Provision of an intersecting street would require dedication of 25 percent or more of the total development site area. 4. Abutting residential land cannot be further divided under current development standards. (i) Street connectivity standards may be adjusted in accordance with EC 9.8030(37) for applications proposing housing to be reviewed with clear and objective approval criteria. This change relates to COS-19 (Street Modifications). The proposed changes and new language clarify the available exceptions to block length, street connectivity, and cul-de-sac or emergency turnarounds for Clear & Objective applications. An option to seek a discretional adjustment is also proposed. 9.6820 Cul-de-Sacs or Emergency Vehicle Turnarounds. (1) Except for streets that are less than 150 feet long and streets that will be extended in the future, all streets that terminate shall be designed as a cul-de-sac bulb or an emergency vehicle turnaround. (2) If a street will be extended in the future, a temporary easement shall be provided and an emergency vehicle turnaround shall be constructed. (3) There shall be no cul-de-sacs more than 400 feet long from the centerline of the intersecting street to the radius point of the cul-de-sac bulb. (4) Public accessways to provide safe circulation for pedestrians, bicyclists and emergency vehicles shall be required from a cul-de-sac or emergency vehicle turnaround longer than 150' in length when measured from the centerline of the intersecting street to the radius point of the cul-de-sac or to the center point of the emergency vehicle turnaround. (5) As part of a Type II or Type III process, an exception may be granted to the requirements of (1), (3) and (4) of this section. For applications proposing housing to be reviewed with clear and objective approval criteria, exceptions may only be granted as provided in subparagraph (c). For all other applications, exceptions may be granted because of the existence of one or more of the following conditions: (a) Physical conditions preclude development of the connecting street. Such conditions may include, but are not limited to, topography or likely impact to natural resource areas such as wetlands, ponds, streams, channels, rivers, lakes or upland wildlife habitat areas, or a resource on the National Wetland Inventory or under protection by state or federal law. (b) Buildings or other existing development on the subject property or adjacent lands, including previously subdivided but vacant lots or parcels, physically preclude a connection now or in the future, considering the potential for redevelopment. (c) For applications proposing housing to be reviewed with clear and objective approval criteria, an exception to the requirements of subsections (1) through (4) may be granted if the applicant provides certification from an Oregon licensed civil engineer stating that a cul-de- sac cannot be constructed to meet current standards according to the 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 7 of 18  adopted Design Standards and Guidelines for Eugene Streets, Sidewalk, Bikeways and Accessways; This change relates to COS-19 (Street Modifications). The proposed changes and new language clarify the available exceptions to block length, street connectivity, and cul-de-sac or emergency turnarounds for Clear & Objective applications. An option to seek a discretional adjustment is also proposed. 9.6885 Tree Preservation and Removal Standards. (2) Tree Preservation and Removal Standards. (a) Definitions. For the purposes of this subsection (2), the following definitions apply: 1. Significant Tree. A living, standing tree having a trunk with a minimum cumulative diameter breast height of 8 inches, or, when there are multiple trunks, having a minimum cumulative diameter breast height of 8 inches, considering the 2 largest trunks measured at 4.5 feet above mean ground level at the base of the trunk or trunks. Invasive species listed in Table 9.6885(2)(d)4. are not significant trees. 2. Significant Tree Cluster. A group of five or more significant trees where each tree in the group shares overlapping branches with at least one other tree in the group. 3. South Hills Area: All properties located within the City’s adopted Urban Growth Boundary, above an elevation of 500 feet, and: a. South of 18th Avenue, b. South of Franklin Boulevard and East of the intersection of 18th Avenue and Agate Street, or c. If 18th Avenue were extended from the intersection of 18th Avenue and Willow Creek Road directly west to the Urban Growth Boundary, the area south of that extension of 18th Avenue. 4. Tree Preservation and Removal Plan. A written report and site plan prepared by a certified arborist or landscape architect that includes all significant trees on the development site and their critical root zones (CRZ). This plan shall specify trees to be preserved, trees to be removed, and trees to be mitigated according to 9.6885(2)(d)5. This plan shall include proposed lot or parcel boundaries. For development sites within the South Hills Area, this plan shall delineate areas between 500 and 700 feet elevation, between 700 and 900 feet elevation, and areas above 900 feet elevation. (b) Exemptions. A proposed development shall be exempt from the requirements of EC 9.6885(2) if either of the following apply: 1. The development site is 13,500 square feet or less and not located in the South Hills Area. 2. The development site is in the R-1.5 Rowhouse zone. (c) Tree Preservation and Removal Plan. An applicant must submit a Tree Preservation and Removal Plan, prepared by a certified arborist or landscape architect, that includes all of the following: 1. Locations of all significant trees on the development site. For each tree to be preserved, include the critical root zone (CRZ), protective 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 8 of 18  fencing location, and a percentage calculation of impacts to the CRZ. For a tree to be counted as a preservation tree, CRZ impacts of more than 30 percent are not allowed. 2. The location of all public and private utility easements, driveways, and areas of grading or excavation on the development site. 3. All proposed development on the site and proposed lot or parcel boundaries. 4. Identification of trees to be preserved, removed, or mitigated according to 9.6885(2)(d)3. 5. For development sites within the South Hills Area, delineate areas between 500 and 700 feet elevation, between 700 and 900 feet elevation, and areas above 900 feet elevation. 6. All significant trees shall be physically identified, numbered, and tagged in the field. Tag identification numbers shall be shown on the plan and must correspond with the tag identification numbers in the field. 7. A table with the identification number, Diameter Breast Height (d.b.h.), genus, species, location factor, size factor, key species factor, and tree rating score for all significant trees on the development site. The table shall be organized by Location/Zone category according to Table 9.6885(2)(d)3. a. Location Factor. Each significant tree shall be assigned a numeric location factor according to Table 9.6885(2)(c)7.a. If more than one listed location applies, then the highest rating must be used. Table 9.6885(2)(c)7.a. Tree Location Factor Tree Location Rating Front yard setback of proposed lot or parcel 1 Interior yard setback of proposed lot or parcel 2 Significant tree cluster 3 Front yard setback of development site (for land divisions, this means 4 prior to the proposed land division) Interior yard setback of development site (for land divisions, this means 5 prior to the proposed land division) In an area with slope greater than 25 percent 5 b. Size Factor. Trees shall be assigned a numeric size factor based on genus, species, and Diameter Breast Height (d.b.h.) in accordance with Table 9.6885(2)(c)7.b. 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 9 of 18  Table 9.6885(2)(c)7.b. Tree Size Factor 8-11" d.b.h. 12-15" d.b.h. 16-19" d.b.h. 20-23" d.b.h. 24-30" d.b.h. 31-42" d.b.h. >43" d.b.h. Genus and Species Common Name Populus trichocarpa Black Cottonwood 0 0 0 1 2 3 4 Pseudotsuga menziesii Douglas Fir 0 0 0 1 2 3 4 Calocedrus decurrens Incense Cedar 0 1 1 2 2 3 4 Thuja plicata Western Red Cedar 0 1 1 2 2 3 4 Abies Grandis Grand Fir 1 1 2 2 3 4 5 Acer macrophyllum Bigleaf Maple 1 1 2 2 3 4 5 Alnus rhombifolia White Alder 1 1 2 2 3 4 5 Alnus rubra Red Alder 1 1 2 2 3 4 5 Fraxinus latifolia Oreogn Ash 1 1 2 2 3 4 5 Pinus ponderosa Ponderosa Pine 1 1 2 2 3 4 5 Pinus contorta Lodgepole Pine 1 1 2 2 3 4 5 Salix lucida ssp. Lasiandra Pacific Willow 1 1 2 2 3 4 5 Salix scouleriana Scouler’s Willow 1 1 2 2 3 4 5 Tsuga heterophylla Western Hemlock 1 1 2 2 3 4 5 Acer circinatum Vine Maple 1 2 3 4 5 5 5 Cornus nuttallii Pacific Dogwood 1 2 3 4 5 5 5 Quercus garryana Oregon White Oak 1 2 3 4 5 5 5 Quercus kelloggii California Black Oak 1 2 3 4 5 5 5 Arbutus menziesii Madrone 2 3 4 5 5 5 5 Taxus brevifolia Pacific Yew 2 3 4 5 5 5 5 Other Significant Tree Other Significant Tree 0 0 1 1 2 3 4 c. Key Species Factor. Significant trees listed by species name in Table 9.6885(2)(c)7.b. shall be assigned a key species factor of 3. Trees that fall within the category of “Other Significant Tree” shall not be assigned a key species factor. d. Tree Rating Score. Each significant tree shall be assigned a tree rating score that is the sum of location factor, size factor, and key species factor. Example: Location Factor (Significant tree cluster) +3 Size Factor (Arbutus menziesii, 15” d.b.h.) +3 Key Species Factor (Arbutus menziesii) +3 Tree Rating Score 9 (d) Tree Preservation Requirement. 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 10 of 18  1. Except as provided in EC 9.6885(2)(d)5, significant trees must be protected and preserved in accordance with the requirements of Table 9.6855(2)(d)3. 2. The overall tree rating score referenced in Table 9.6885(2)(d)3. is the sum of the tree rating scores for all significant trees located within the development site or, if the development site is located in more than one of the Location or Zone categories listed in Table 9.6885(2)(d)3., the overall tree rating score is the sum of the tree rating scores for all significant trees located within each Location or Zone category. 3. If a development site is located in more than one Location or Zone categories listed in Table 9.6885(2)(d)3., the Tree Preservation and Removal plan must address each Location or Zone category separately. Table 9.6885(2)(d)3. Tree Preservation Requirements Location Zone Minimum Preservation Outside the South Hills Area All zones except R-1 At least 25 percent of the Low-Density overall tree rating score Residential R-1 Low-Density At least 35 percent of the Residential overall tree rating score Within the South Hills Area, All zones At least 35 percent of the located above 500 feet and overall tree rating score below 700 feet elevation Within the South Hills Area, All zones At least 40 percent of the located at or above 700 feet overall tree rating score and below 900 feet elevation Within the South Hills Area, All zones At least 50 percent of the located at or above 900 feet overall tree rating score elevation 4. Tree Preservation Exceptions. a. Trees that are not significant can be removed. b. Trees not counted toward meeting the minimum preservation requirements in Table 9.6885(2)(d)3. can be removed. c. Invasive species listed in the following table can be removed: Table 9.6885(2)(d)4. Invasive Species Genus and Species Common Name 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 11 of 18  Acer plantanoides Norway Maple Aesculus hippocastanum Horeschestnut Ailanthus altissima Tree-Of-Heaven Betula pendula European Birch Betula pubesc European Birch Buddleia alternifolia Fountain Butterfly Bush Buddleia davidii Fountain Butterfly Bush Crataegus monogyna English Hawthorn Ilex aquifolium English Holly Juniperus virginiana Eastern Redcedar Ligustrum vulgare Common Privet Populus alba White Poplar Prunus avium Sweet Cherry Prunus cerasifera Thundercloud Plum Prunus domestica Plum Prunus laurocerasus English Laurel Prunus lusitanica Portugal Laurel Prunus mahaleb Mahaleb Cherry Pyrus communis Pear Robinia pseudoacacia Black locust Sorbus aucuparia Eropean mountain-ash 5. Mitigation. a. An applicant may elect to mitigate significant trees on the development site as provided below: b. An applicant may mitigate significant trees with a collective tree rating score of up to 50% of the overall tree rating score applicable to the development site or portion of the development site, as provided in EC 9.8865(2)(d)2-3 and Table 9.6885(2)(d)3. c. Each tree to be mitigated must be replaced with two trees selected from the named species listed in Table 9.6885(2)(c)7.b. At the time of planting, deciduous trees used for mitigation must have a minimum diameter of 2 inches as measured by American Association of Nurserymen Standards and evergreen trees used for mitigation must be a minimum of 6 feet in height. d. Mitigation is not available for trees located on portions of the development site at or above 900 feet in elevation. 6. Protection Standards. The following notes must be included on the final plan set submitted for approval by the City and shall apply at the time of development: a. “Protective fencing for trees identified to be preserved shall be installed by the applicant and inspected by the City prior to beginning any development activities. All protective tree fencing must remain in place until completion of all construction activities; any relocation, removal, or modification of the protective fencing shall only occur under the direction of a certified arborist and a written explanation of the reason for the relocation, removal, or modification of the protective fencing from the certified arborist must be provided to the City.” b. “At the time of building permit, a site plan in compliance with the approved tree preservation and removal plan is required.” 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 12 of 18  c. “No excavation, grading, material storage, staging, vehicle parking or other construction activity shall take place within protective tree fencing areas.” d. “The removal of trees not designated as ‘to be preserved’ is not required; removal may occur at the applicant or future owners’ discretion.” e. “In the event a tree designated to be preserved must be removed because it is dead, diseased, or hazardous, documentation by a certified arborist must be provided to the City prior to tree removal. The tree(s) must be replaced with trees selected from the named species listed in Table 9.6885(2)(c)7.b., and two replacement trees must be planted for every one tree removed. At the time of planting, replacement deciduous trees must have a minimum diameter of 2 inches as measured by American Association of Nurserymen Standards, and replacement evergreen trees must be a minimum of 6 feet in height.” [No permit for a development activity subject to this section shall be approved until the applicant submits plans or information, including a written report by a certified arborist or licensed landscape architect, that demonstrates compliance with the following standards: (a) The materials submitted shall reflect that consideration has been given to preservation in accordance with the following priority:] [1. Significant trees located adjacent to or within waterways or wetlands designated by the city for protection, and areas having slopes greater than 25%; 2. Significant trees within a stand of trees; and 3. Individual significant trees.] (be) Street Tree Removal. If the proposal includes removal of any street tree(s), removal of those street trees has been approved, or approved with conditions according to the process at EC 6.305 Tree Felling Prohibition. This change implements COS-11 (Tree Preservation Consideration). The new language establishes a clear and objective tree rating system and then sets minimum preservation requirements, mitigation allowances, and exemptions. The changes also relate to COS-05 (Limitation Over 900 Feet for PUDs) by imposing a higher preservation requirement in areas above 900 foot elevation. Application Requirements and Criteria 9.8030 Adjustment Review - Approval Criteria. The planning director shall approve, conditionally approve, or deny an adjustment review application. Approval or conditional approval shall be based on compliance with the following applicable criteria. (37) Street Standards Adjustment. Where this land use code provides that street 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 13 of 18  standards may be adjusted, the standards may be adjusted upon a demonstration by the applicant that the requested adjustment is consistent with the following: (a) The applicant has submitted a report prepared by an Orgon licensed civil engineer that demonstrates it is not technically or financially feasible to construct the street in accordance with adopted plans and policies, and adopted “Design Standards and Guidelines for Eugene Streets, Sidewalks, Bikeways, and Accessways.” (b) The adjustment is necessary due to at least one of the following conditions: 1. Existing on-site or off-site geologic or topographic conditions, or existing wetlands designated for protection by the City of Eugene; or 2. Existing development on lands abutting the development site. This change relates to COS-19 (Street Modifications). The proposed new language provides discretionary approval criteria for a new adjustment review option for Clear & Objective applications. If the clear and objective exception to the standards cannot be met, applicants have the option to apply for a discretionary adjustment to the standards. 9.8100 Conditional Use Permit Approval Criteria- [Needed] Housing/Clear and Objective. The hearings official shall approve, conditionally approve, or deny the conditional use permit application. Unless the applicant elects to use the [general] discretionary criteria contained in EC 9.8090 Conditional Use Permit Approval Criteria – General/Discretionary, where the applicant proposes [needed housing, as defined by the State statutes] housing, the hearings official shall approve or approve with conditions a conditional use based on compliance with the following criteria: (1) [The applicant has demonstrated that the proposed housing is needed housing as defined by State statutes.] The proposal complies with EC 9.5860 Transition Standards. This change implements COS-01 (Clear & Objective Compatibility). The replacement text points to proposed new transistion standards. For ease of use and code efficiency (as the standards with apply to three application types), the new transition standards are proposed to be located under EC 9.5000 Special Development Standards for Certain Uses. Applicability is clear as the approval criteria for each of the three application types will include a criterion requiring compliance with the transition standards. In addition, the transition standards start with an applicability statement that identifies the three applications subject to the standards. 9.8325 Tentative Planned Unit Development Approval Criteria – [Needed] Housing/Clear and Objective. Unless the applicant elects to use the discretionary criteria contained in EC 9.8320 Tentative Planned Unit Development Approval Criteria- General/Discretionary, for housing applications entitled to clear and objective review pursuant to state statute, Tthe hearings official shall approve, conditionally approve, or deny the PUD application [with findings and conclusions. Unless the applicant elects to use the general criteria contained in EC 9.8320 Tentative Planned Unit Development Approval Criteria –General, where the applicant proposes needed housing, 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 14 of 18  as defined by the State statutes, the hearings official shall approve or approve with conditions, a PUD] based on compliance with the following criteria: (1) The applicant has demonstrated that the proposed housing is needed housing as defined by state statutes.] The proposal complies with EC 9.5860 Transition Standards. This change implements COS-01 (Clear & Objective Compatibility). The replacement text points to proposed new transistion standards. For ease of use and code efficiency (as the standards with apply to three application types), the new transition standards are proposed to be located under EC 9.5000 Special Development Standards for Certain Uses. Applicability is clear as the approval criteria for each of the three application types will include a criterion requiring compliance with the transition standards. In addition, the transition standards start with an applicability statement that identifies the three applications subject to the standards. (3) [The PUD provides a buffer area between the proposed development and surrounding properties by providing at least a 30 foot wide landscape area along the perimeter of the PUD according to EC 9.6210(7).] *Renumber remaining subsections.* The removal of subsection (3) from the Tentative PUD approval criteria implements COS-02 (30-Foot Buffer Requirement for PUDs). The 30-foot buffer criterion is being replaced by the proposed new transition standards under EC 9.5000 Special Development Standards for Certain Uses. See related issue COS-01 and proposed language at EC 9.5860. (5) [There shall be no proposed grading on portions of the development site that meet or exceed 20% slope.] *Renumber remaining subsections.* The removal of subsection (5) from the Tentative PUD approval criteria implements COS-03 (20 Percent Slope Grading Prohibition). Slope stability in the context of road layout and lot locations will be addressed under the revised geotechnical requirement (see related issue COS-13 and revisions at EC 9.6710). (97) [All proposed dwellings within the PUD are within 1/4 mile radius (measured from any point along the perimeter of the development site) of an accessible recreation area or open space that is at least 1 acre in size and will be available to residents.] PUDs proposed on development sites that are two acres or larger must comply with either subsection (a) or subsection (b) below: (a) The PUD is located within a 1/2-mile of a public park, public recreation facility, or public school (measured from any point along the perimeter of the development site to any point along a property line of a public park, public recreation facility, or public school); or (b) Except as provided in EC 9.8325(8)(b)1, the PUD shall provide common open space within the development site equal to a minimum of 10 percent of the development site or 14,500 square feet, whichever is greater. 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 15 of 18  1. If the PUD includes lot areas smaller than the minimum lot area allowed in the base zone, then common open space must be provided according to the following formula: (𝑳𝒐𝒕 𝑨𝒓𝒆𝒂 𝑻𝒐𝒕𝒂𝒍) 𝟏 [𝟏 − ( )] × (𝑷𝑼𝑫𝑨𝒓𝒆𝒂) (𝑵𝒖𝒎𝒃𝒆𝒓 𝒐𝒇 𝑳𝒐𝒕𝒔 × 𝑴𝒊𝒏 𝑳𝒐𝒕 𝑺𝒊𝒛𝒆) 𝟐 2. Common open space shall be provided in one separate tract of land, except that developments providing more than 29,000 square feet of common open space may include up to three common open space tracts provided no tract is less than 14,500 square feet.. 3. Ownership of the common open space tract(s) must be dedicated to all lot or parcel owners within the development site. 4. Each common open space tract must include a portion with minimum dimensions of 70 feet by 70 feet. 5. Common open space tracts must have a minimum of 20 feet of lot frontage along an existing or proposed public way or private street. 6. Common open space tracts do not have to meet lot standards. The above changes to the Tentative PUD approval criteria implement COS-04 (One Acre Assessible Open Space for PUDs). The first change revises the required distance from existing public open space from ¼ mile to ½ mile radius. The remaining revisions are to implement a scalable on-site open space requirement so that more common open space is required for PUDs proposing to reduce lot area below the minimum base zone standard. (1210) For any PUD located within or partially within the boundaries of the South Hills Study, the following additional approval criteria apply: (a) [No development shall occur on land above an elevation of 900 feet except that one dwelling may be built on any lot in existence as of August 1, 2001.] Development on any portion of the development site located above 900 feet elevation is limited by the following: 1. The sum of all building area, measured using building footprints, shall not exceed 5,000 square feet on proposed new lots or parcels. 2. Driveways shall not exceed 16 feet in width. The removal of existing subsection (a) from the Tentative PUD approval criterion implements COS-05 (Limitation Over 900 Feet for PUDs). The change replaces the former limitation of one dwelling with the new density limit under (b)(4) below. The proposed new language adds new limitations to reduce the development impacts above 900 feet elevation. The added limitations are to further protect the area above 900 feet elevation from an intensive level of development, consistent with the South Hills Study. 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 16 of 18  (b) Development on any portion of the development site located above 900 feet elevation shall be setback at least 300 feet from the ridgeline unless there is a determination by the city manager that the area is not needed as a connection to the city’s ridgeline trail system. For purposes of this section, the ridgeline [trail] shall be considered as the line indicated as being the urban growth boundary within the South Hills Study plan area. This revision implements COS-06 (Ridgeline Setback for PUDs). The change clarifies that the setback will now only apply to portions of the development site located above 900 feet elevation. (c) [Development shall cluster buildings in an arrangement that results in at least 40% of the development site being retained in 3 or fewer contiguous common open space areas. For purposes of this section, the term contiguous open space means open space that is uninterrupted by buildings, structures, streets, or other improvements.] *Renumber remaining subsections.* The removal of subsection (c) implements COS-07 (40% Open Space Requirement for PUDs). The intent is to instead rely on other existing regulations for lot coverage and on-site open space provision. (dc) Residential density is limited as follows: 1. In the area west of Friendly Street, the maximum level of new development per gross acre shall be 8 units per acre. 2. In the area east of Friendly Street, the maximum level of new development per gross acre shall be limited to 5 units per acre. 3. Housing developed as Controlled Income and Rent Housing shall be exempt from the density limitations in subsections 1 and 2 above, but are subject to the other applicable development standards and review procedures. 4. For any portion of the development site located above 900 feet elevation, the maximum density for shall be 2.5 units per gross acre, or one dwelling per legal lot in existence as of August 1, 2001, whichever is greater. The addition of subsection 4. implements COS-05 (Limitation Over 900 Feet for PUDs). The change adds a new density restriction for any portion of the development site located above 900 feet elevation. 9.8520 Subdivision, Tentative Plan Approval Criteria - Needed Housing. (5) [There shall be no proposed grading on portions of the development site that meet 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 17 of 18  or exceed 20% slope.] *Renumber remaining subsections.* The removal of subsection (5) from the tentative subdivision approval critiera implements COS-03 (20 Percent Slope Grading Prohibition). Slope stability in the context of road layout and lot locations will be addressed under the revised geotechnical requirement (see related issue COS-13 and revisions at EC 9.6710). 9.8445 Site Review Approval Criteria- [Needed] Housing/Clear and Objective. Unless the applicant elects to use the discretionary criteria contained in EC 9.8440 Site Review Approval Criteria- General/Discretionary, for housing applications entitled to clear and objective review pursuant to state statute, [T]the planning director shall approve, conditionally approve, or deny the site review application. [Unless the applicant elects to use the general criteria contained in EC 9.8440 Site Review Approval Criteria – General, where the applicant proposes needed housing, as defined by the State statutes, the planning director shall approve, or approve with conditions, a site review] based on compliance with the following criteria: (1) [The applicant has demonstrated that the proposed housing is needed housing as defined by state statutes.] The proposal complies with EC 9.5860 Transition Standards. This change implements COS-01 (Clear & Objective Compatibility). The replacement text points to proposed new transistion standards. For ease of use and code efficiency (as the standards with apply to three application types), the new transition standards are proposed to be located under EC 9.5000 Special Development Standards for Certain Uses. Applicability is clear as the approval criteria for each of the three application types will include a criterion requiring compliance with the transition standards. In addition, the transition standards start with an applicability statement that identifies the three applications subject to the standards. 04/09/19 Clear & Objective Proposed Amendments - Batch 2 Page 18 of 18  Attachment B DRAGOVICH Jenessa L From: DRAGOVICH Jenessa L Sent: Monday, April 08, 2019 10:11 AM To: 'Ron-Janet Bevirt' Subject: RE: REMINDER: Clear & Objective Office Hours 4-7pm TONIGHT Hi Ron, We did miss you Thursday! Thanks for the email. The definition of Diameter Breast Height does provide direction by clarifying that “breast height” is measured at 4.5 feet above the mean ground level at the base of the trunk. EC 9.0500 Definitions. Diameter Breast Height (d.b.h.). The diameter of the trunk or trunks of a tree measured at 4.5 feet above mean ground level at the base of the trunk or trunks. Let me know if anything else comes up for you as you go through the draft amendments. ੗ Jenessa From: Ron‐Janet Bevirt <beznys@gmail.com> Sent: Thursday, April 04, 2019 3:43 PM To: DRAGOVICH Jenessa L <JDragovich@eugene‐or.gov> Subject: Re: REMINDER: Clear & Objective Office Hours 4‐7pm TONIGHT Hi Jenessa, I would have come today, if only to be sociable, but I have other projects on‐going. The only thought I had re clear and objective was re "breast height" since that is not a specific number. I realize that definition may have some "historical" or other reason for existing, but it could be a point of dissension. Best, Ron On Thu, Apr 4, 2019 at 8:50 AM DRAGOVICH Jenessa L <JDragovich@eugene‐or.gov> wrote: Good Morning! Reminder that we’ll be holding open Office Hours tonight to go over the Batch 2 draft amendments. Bring your questions and/or curiosity and we’ll help unpack the draft code language. OFFICE HOURS Thursday, April 4th 4:00‐7:00 p.m. Room 2021 (2nd floor) 1 If tonight doesn’t work, there will be another session on Monday… Monday, April 8th 11:00‐1:00 p.m. Saul Conference Room (3rd floor) Office Hours will be in the Atrium building located at 99 West 10th Avenue If you have questions but can’t make it to one of these sessions, call or email me! Best, Jenessa Dragovich | Senior Planner Eugene Planning Division | Land Use Planning 99 West 10 Avenue | Eugene Oregon 97401 th Phone 541.682.8385 | Fax 541.682.5572 Visit the Planning Website Messages to and from this e-mail address may be available to the public under Oregon Public Records Law.  Please consider the environment before printing this message 2