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Exhibit B It is reasonable to provide clarification as to what constitutes attachment to avoid someone from claiming that a 2" by 4" board is sufficient to "attach" the accessory dwelling to the primary dwelling, and only be subject to the standards that apply to "attached secondary dwellings." Typically, attached accessory dwellings have less external impacts, because they are a part of the primary dwelling, and therefore have a lessor set of standards than detached accessory dwellings. 9.2741 Special Use Limitations for Table 9.2740. (2) Secondary Dwellings. Secondary dwellings are only permitted in R-1 and are subject to the standards beginning at EC 9.2750, except that new secondary dwellings are prohibited on alley access lots. 9.2751 Special Development Standards for Table 9.2750. (18) Alley Access Lots in R-1. (a) General Standards. 2. Use Regulations. Alley access lots have the same land use regulations as the base zone except that there is no allowance for a secondary dwelling. Findings: The prohibition on siting an accessory dwelling on an R-1 lot if the lot does not have street frontage and can be accessed only from an alley is a regulation relating to siting. It relates to the location of buildings, specifically those that are proposed for location on an alley; it relates to the ground that may be occupied by an accessory dwelling. ORS 197.312(5)(b) specifically makes the allowance of accessory dwellings subject to local regulations. Although this regulation does make an accessory dwelling a prohibited use on some lots, it is reasonable because it is necessary to addresses the impacts of a potential doubling of the number of vehicular trips on city alleys that are not typically improved to a level to support such traffic. It also helps ensure that the increased densities on these inherently small lots do not create "livability" issues that arise when residential neighborhoods become overcrowded with unregulated infill. Development on alley access lots can be more impactful to surrounding properties because they are generally small lots surrounded by homes on three sides. The existing alleys are within the older neighborhoods where there is a traditional grid pattern of blocks and streets along with older homes that limits the location and overall size of alley access lots. The regulation is an effective way to limit traffic on the city's alleys, many of which are unimproved, and to address livability concerns associated with overcrowding. 9.2751 Special Development Standards for Table 9.2750. (17) Secondary Dwellings in R-1. (a) General Standards for Attached Secondary Dwellings. Except as M