Item B: Ordinance Concerning Goal 5 Natural Resources Study

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. PeaceHealth October 3,2005 Mayor Kitty Piercy and City Council c/o Neil Bjorklund Senior Planner City of Eugene eugenenr@ci.eugene.or.us RECEIVED OCT - 3 2005 Re: Eugene GoalS Natural Resource Project CITY OF EUGENE PLANNING DEPARTMENT Dear Mayor Piercy and Councilors, On behalf of PeaceHealth, please allow me this opportunity to express reservations about the ordinance to address the City's obligations under Statewide Planning GoalS. While PeaceHealth supports the conservation and enhancement of natural resources, including those inventoried on PeaceHealth's property between Goodpasture Island Road and the Willamette River, the ordinance as proposed represents a one-size-fits-all approach. As such, adoption of the new standards under the Water Resources Conservation Overlay Zone will represent new and additional limitations to future development on the Goodpasture properties. These limitations greatly exceed current encumbrances to portions of the property under local and state Willamette River Greenway provisions. The Greenway boundary was established on the subject property in the course of the City's development of the East Bank Trail through the site. It bears noting that PeaceHealth dedicated the easement for the East Bank Trail through the site (unlike other property owners along the trail route), and allowed the City to provide a construction staging area on the site, all at no cost to the public. Yet, under the proposed ordinance, the East Bank Trail would be allowed within the overlay area subject to Standards Review under proposed EC 9.4930(3)(b), but virtually no other development. There's little doubt that outstanding riverside development can occur on the Goodpasture site that respects and enhances the site's riparian ecology, while still realizing high quality urban design and development that provides lasting community benefit. But the ordinance as proposed removes any potential for creative design within the Greenway, and instead prohibits virtually all development within the overlay zone. We encourage the Council to incorporate into the ordinance the ability to use the Standards Review process to make development proposals within the overlay area which can achieve the overarching objectives of the ordinance, if not the letter. For example, property owners should be given an opportunity to present design alternatives that could result in the equivalent buffer area as would be covered under the conservation setbacks in proposed EC 9.4920, but perhaps not so uniformly applied along the length of a given /iia:y~yr~#d~