HomeMy WebLinkAboutItem 7: MUPTE for 16th and Hilyard Apartments
ECC
UGENE ITY OUNCIL
AIS
GENDA TEM UMMARY
Action: Resolution 4938 Approving a Multiple-Unit Property Tax Exemption for
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Residential Property Located at 693 East 16 Avenue, Eugene, Oregon (Corey
Development, LLC)
Meeting Date: April 14, 2008 Agenda Item Number: 7
Department: Planning and Development Staff Contact: Richie Weinman
www.eugene-or.gov Contact Telephone Number: 682-5533
ISSUE STATEMENT
The City Council is asked to approve a resolution granting a Multi-Unit Property Tax Exemption
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(MUPTE) for the 16 and Hilyard Apartments.
BACKGROUND
The council has a 30-year history of supporting tax exemptions under this program in order to encourage
new housing in the core area. In April 2004, the council amended the MUPTE program regulations and
boundary.
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The proposed project will be built at 693 East 16 Avenue, which is zoned R-3, high-density residential.
Currently, the property is occupied by a two-story single family home built in 1905 and a one-story
duplex constructed in 1947. Neither is considered a historical resource and both are in a deteriorated
condition. The applicant followed the required procedures and properly informed the City of their intent
to remove the existing structures.
In 2007, the same applicant applied for a MUPTE for the new construction of a three-story building with
ten two-bedroom units at the same location. The application was not approved by the City Council.
This revised proposal is for a new concept featuring a two-story building with two one-bedroom units
and five two-bedroom units.
Citizen Comments
A display advertisement was published in the Register-Guard on February 25. No comments were
received during a 30-day period. The applicant met with the West University Neighbors and received an
endorsement. A letter of support is provided as Attachment E.
Design Features
Consistent with the council’s stated interests in the adopted MUPTE Standards and Guidelines, this
application proposes infill housing that increases density in the core area and provides new housing
using higher grade materials. The minimum density for this site is three units which this development
exceeds by four units. The proposed housing involves a two-story building with seven total units.
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Other design and sustainability features:
• Recycling of building materials from demolition of the buildings currently on the site, as well as job
site waste from the new project.
• Infill density is above the minimum while still maintaining neighborhood character.
• Project located close to downtown, university, bike paths, and mass transit, minimizing the necessity
to use automobiles.
• Landscaping utilizes native species and drought resistant plants; topsoil will be preserved and reused
on-site.
• Energy efficient windows are provided in each primary living space to maximize natural light and
ventilation.
• Individually controlled zone heat sources for each room will allow for room-by-room control.
• Construction materials include engineered lumber (where practical); oriented strand board sub-
flooring and sheathing; thermal mass flooring.
• Use of exterior air infiltration barrier.
• Use of energy efficient appliances and water heater.
• Use of stormwater filtration and pretreatment prior to entering public stormwater system.
• Use of water efficient plumbing fixtures.
• Use of bathroom fans with timers.
• Use of outdoor lights that are “night sky” friendly.
• Low VOC paints and carpets will be specified.
• On-site recycling provided.
• Covered parking area is open on one side for natural ventilation; entry ways to structure are on
opposite side of the building to reduce infiltration.
Responsiveness to adjacent historic structures: There are no adjacent historic structures.
Use of higher quality materials that contribute to longevity: Materials to be used in the proposed
development which will contribute to longevity include: light colored “cool” asphalt roofing products
with a 40-year life; composite or fiber cement style (hardi-plank type) siding.
Prominent entry facing the public street: The proposed development includes a prominent entry facing
Hilyard Street which will showcase stone pillars and expanded front porch areas.
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Number of units by which minimum density is exceeded or which incorporate three or more bedrooms
to encourage families: The proposed development will exceed minimum density standards by four
units. None of the units in the proposed development incorporate three or more bedrooms.
Number of available ADA accessible units. Twenty five percent of the units will be adaptable.
Responsiveness to neighborhood character and safety in respect to height, mass, architectural detail,
landscaping and open space: The proposed development is a two-story building, to be built on a
concrete slab foundation with minimum ceiling heights. It will be built in the Craftsman style,
reminiscent of the historic homes built in Eugene in the early 1900s. Roof pitch is set to balance the
façade and enhance the period style architectural details. Height and mass has been minimized to the
fullest extent possible. The height of the north-facing wall to the fascia board is 17 feet, and a hip roof
eliminates the towering effect of a gable end. Additional investment will be put into porches, rail
details, stone columns and trim details. Front porches provide gathering spaces and, given their
proximity to the street and sidewalks, there will be less likelihood of vandalism. Tenants will be able to
interact between themselves and the community via the open porches and balconies. Each space is
provided with outdoor gathering space directly adjacent to the street. Trees, shrubs, and lawn area will
further integrate the development with the neighborhood. The parking area will consist of seven spaces
(exceeding the minimum required by the Code for this 12-bedroom complex) which will be shielded
from public view.
Impact and Need for Tax Exemptions to Encourage Housing
The City and other local taxing districts forgo revenue when property is exempted from taxes. This
project proposes new construction on a property that has been underdeveloped, based on the zoning.
The land continues to be taxed during the exemption period. The improvements will bring substantial
revenue, after ten years, beyond what is currently being collected.
The total current property taxes on the property total $4,037. The tax on the land is estimated at $960
and will continue to be taxed during the exemption period. Therefore, $3,077 that is currently being
paid in taxes on the existing improvements will come off the tax rolls for ten years ($30,770). However,
after ten years an estimated $9,069 will be annually paid taxes on the new improvements. The lost
revenue from the taxes on the current improvements will be made up 3.39 years after the ten-year
exemption ends.
Timing
This application was submitted on February 20, 2008. The council has 90 days to review the Directors
Report and Recommendation. If the council hasn’t acted in 180 days the application is considered
approved. City Council consideration is currently in the first 90-day time period.
RELATED CITY POLICIES
MUPTE is enabled by State statute. The City of Eugene has participated in the MUPTE program since
1978. Since that time, all 15 requests have been approved by the City Council. Encouraging housing in
the core area is consistent with numerous adopted planning and policy documents. Examples include:
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Growth Management Policies
Policy 1 Support the existing Eugene Urban Growth Boundary by taking actions to increase density
and use on existing vacant land and under-used land within the boundary more efficiently.
Policy 2 Encourage in-fill, mixed-use, redevelopment, and higher density development.
Policy 3 Encourage a mix of business and residential uses downtown using incentives and zoning.
West University Refinement Plan
V.9 The City will encourage residential uses in all parts of the plan area.
V.11 The City and the neighborhood shall study ways to encourage a variety or mix of structure
types providing both owner and rental opportunities and appealing to a diverse population.
COUNCIL OPTIONS
The council may approve the exemption, deny the exemption, or may delay approval in order to request
additional information from the developer to determine that a satisfactory public benefit has been met.
CITY MANAGER’S RECOMMENDATION
The City Manager recommends approving the resolution to grant the exemption.
SUGGESTED MOTION
Move to adopt Resolution 4938 approving a multiple-unit property tax exemption for residential
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property located at 693 East 16 Avenue, Eugene, Oregon (Corey Developtment, LLC).
ATTACHMENTS
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A. Resolution approving a property tax exemption for 16 and Hilyard Apartments
B. Report from the Planning and Development Director
C. History of granted MUPTEs
D. Images of current property
E. Letter of support from West University Neighborhood
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F. Resolution denying a property tax exemption for 16 and Hilyard Apartnments
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Note: A copy of the MUPTE application for 693 E. 16 Avenue will be placed in the Council Office for
review. This includes images of the proposed development.
FOR MORE INFORMATION
Staff Contact: Richie Weinman
Telephone: 682-5533
Staff E-Mail: richie.d.weinman@ci.eugene.or.us
L:\CMO\2008 Council Agendas\M080414\S0804147.doc
ATTACHMENT A
RESOLUTION NO. ______
A RESOLUTION APPROVING A MULTIPLE-UNIT PROPERTY TAX
EXEMPTION FOR RESIDENTIAL PROPERTY LOCATED AT 693 EAST
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16 AVENUE, EUGENE, OREGON (COREY DEVELOPTMENT, LLC).
The City Council of the City of Eugene finds that:
A.
Our Property Holdings One, LLC, is the owner of real property located at 693
East 16th Avenue, Eugene, Oregon, 97401, more particularly described on the attached Exhibit
A. On April 18, 2007, the City of Eugene received an application submitted by Corey
Development, LLC pursuant to the City’s Multiple-Unit Property Tax Exemption Program
(Sections 2.945 and 2.947 of the Eugene Code, 1971) with respect to residential units to be
constructed on the property.
B.
On June 25, 2007, the City Council denied applicant’s request for the property tax
exemption.
C.
On January 7, 2008, David Corey submitted a revised application for Corey
Development, LLC and requested that the Council reconsider its June 25, 2007 decision based on
the redesigned project. The revised application proposes a smaller apartment complex than the
complex proposed in the original application, and includes an updated income analysis for the
property illustrating that construction of this project is not viable without the property tax
exemption.
D.
A display ad soliciting recommendations or comments from the public was
published in the Register-Guard on February 25, 2008, and advised that written comments would
be accepted for a period of 30 days from the date of publication. Recommendations or
comments were also solicited from the Planning Commission, and other interested City
departments, agencies, and neighborhood groups. No comments were received in response to the
ad.
E.
The Report and Recommendation attached as Exhibit B recommends that the
application be approved and the exemption granted. In making the recommendation, the
Director found that the applicant submitted all materials, documents and fees required by the
application and the City as set forth in Section 2.945 of the Eugene Code, 1971, and is in
compliance with the policies set forth in the Standards and Guidelines adopted by Administrative
Order No. 53-04-03-F.
F.
The project consists of the development of two residential one-bedroom units, and
five residential two-bedroom units, which are not designed for, nor will be used as, transient
accommodations.
Resolution – Page 1
08 Corey-Hilyard Apts Reapplication MUPTE Res. (00182259)
NOW, THEREFORE,
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF EUGENE, a
Municipal Corporation of the State of Oregon, as follows:
Section 1.
Based upon the above findings which are adopted, and the City Council’s
review of the Report and Recommendation of the Director of the Planning and Development
Department attached as Exhibit B, the City Council approves the application of Corey
Development, LLC for an ad valorem property tax exemption under the City’s Multiple-Unit
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Property Tax Exemption Program for the residential units to be constructed at 693 East 16
Street, Eugene, Oregon, and more particularly described on the attached Exhibit A, subject to the
following conditions:
1.
The project shall consist of two residential one-bedroom units, and five
residential two-bedroom units, which are not designed for, nor will be used as, transient
accommodations.
2.
The project shall be completed on or before January 1, 2012.
3.
The project shall include all of the public benefit design elements as
required in the Standards and Guidelines and described in Section 4.2 of the Report and
Recommendation attached as Exhibit B.
4.
The project shall be in conformance with all local plans and planning
regulations, including special or district-wide plans developed and adopted pursuant to
ORS Chapters 195, 196, 197, 215 and 227.
Section 2.
The residential units to be constructed upon the property described in
Section 1 above are declared exempt from local ad valorem property taxation beginning July 1 of
the year following certification of completion and continuing for a continuous period of ten years
unless earlier terminated in accordance with the provisions of Section 2.947 of the Eugene Code,
1971.
Section 3.
The City Manager, or the Manager’s designee, is requested to forward a
copy of this Resolution to the applicants, and to the other affected taxing districts, within ten
days, and to cause a copy of this Resolution to be filed with the Lane County Assessor on or
before April 1, 2009.
Section 4.
This Resolution shall become effective immediately upon its adoption.
The foregoing Resolution adopted and effective the ____ day of April, 2008.
___________________________________
City Recorder
Resolution – Page 2
08 Corey-Hilyard Apts Reapplication MUPTE Res. (00182259)
ATTACHMENT B
REPORT AND RECOMMENDATION
of the
Director of the Planning & Development Department
Corey Development, LLC
Multiple-Unit Property Tax Exemption
The Director of the Planning & Development Department of the City of Eugene
finds that:
1.
Our Property Holdings One, LLC, is the owner of real property located at 693
East 16th Avenue, Eugene, Oregon, 97401, more particularly described on the attached Exhibit
A. On April 18, 2007, the City of Eugene received an application submitted by Corey
Development, LLC pursuant to the City’s Multiple-Unit Property Tax Exemption Program
(Sections 2.945 and 2.947 of the Eugene Code, 1971) with respect to residential units to be
constructed on the property.
2.
On June 25, 2007, the City Council denied applicant’s request for the property tax
exemption.
3.
On January 7, 2008, David Corey submitted a revised application for Corey
Development, LLC and requested that the Council reconsider its June 25, 2007, decision based
on the redesigned project. The revised application proposes a smaller apartment complex than
the complex proposed in the original application, and includes an updated income analysis for
the property illustrating that construction of this project is not viable without the property tax
exemption.
4.
I have reviewed the application and specifically find that the project to be
constructed will result in an eligible structure for the property tax exemption as defined in the
Standards and Guidelines, will be located within the downtown core area, the construction will
be completed on or before January 1, 2012, and:
4.1 The applicant has submitted all materials, documents and fees required by
the City;
4.2 Design elements that benefit the general public have been included in the
project. The design elements consist of:
4.2.1 Sustainability features. Sustainability features of this project
include:
•Recycling of building materials from demolition of the buildings
currently on the site, as well as job site waste from the new project.
•Infill density is maximized to extent allowed, while maintaining
neighborhood character.
Exhibit B to Resolution No. ____ -- Report and Recommendation – Page 1
08 Corey-Hilyard Apts Reapplication MUPTE R R (00182257)
•Project located close to downtown, university, bike paths, and
mass transit, minimizing the necessity to use automobiles.
•Landscaping utilizes native species and drought resistant plants;
topsoil will be preserved and reused on site.
•Energy efficient windows are provided in each primary living
space to maximize natural light and ventilation.
•Individually controlled zone heat sources for each room will allow
for room-by-room control.
•Construction materials include: Engineered lumber is specified
where practical; oriented strand board sub-flooring and sheathing; thermal
mass flooring.
•Use of exterior air infiltration barrier.
•Use of energy efficient appliances and water heater.
•Use of stormwater filtration and pretreatment prior to entering
public stormwater system.
•Use of water efficient plumbing fixtures.
•Use of bathroom fans with timers.
•Use of outdoor lights that are “night sky” friendly.
•Low VOC paints and carpets will be specified.
•On site recycling provided.
•Covered parking area is open on one side for natural ventilation;
entry ways to structure are on opposite side of the building to reduce
infiltration.
4.2.2 Responsiveness to adjacent historic structures. There are no
adjacent historic structures.
4.2.3 Use of higher quality materials that contribute to longevity.
Materials to be used in the proposed development which will contribute to
longevity include, light colored “cool” asphalt roofing products with a 40-year
life; composite or fiber cement style (hardi-plank type) siding.
4.2.4 Prominent entry facing the public street. The proposed
development includes a prominent entry facing Hilyard Street which will
showcase stone pillars and expanded front porch areas.
4.2.5 Number of units by which minimum density is exceeded or which
incorporate three or more bedrooms to encourage families. The proposed
development will exceed minimum density standards by ____ units. None of the
units in the proposed development incorporate three or more bedrooms.
4.2.6 Number of available ADA accessible units. Twenty five percent
of the units will be adaptable.
4.2.7 Responsiveness to neighborhood character and safety in respect to
height, mass, architectural detail, landscaping and open space. The proposed
Exhibit B to Resolution No. ____ -- Report and Recommendation – Page 2
08 Corey-Hilyard Apts Reapplication MUPTE R R (00182257)
development is a two-story building, to be built on a concrete slab foundation
with minimum ceiling heights and will be built in the Craftsman style,
reminiscent of the historic homes built in Eugene in the early 1900s. Roof pitch is
set to balance the façade and enhance the period style architectural details. Height
and mass has been minimized to the fullest extent possible. The height of the
north-facing wall to the fascia board is 17 feet, and a hip roof eliminates the
towering effect of a gable end. Additional investment will be put into porches,
rail details, stone columns and trim details. Front porches provide gathering
spaces and, given their proximity to the street and sidewalks, there will be less
likelihood of vandalism. Tenants will be able to interact between themselves and
the community via the open porches and balconies. Each space is provided with
outdoor gathering space directly adjacent to the street. Trees, shrubs, and lawn
area will further integrate the development with the neighborhood. The parking
area will consist of seven spaces (exceeding the minimum required by the Code
for this 12-bedroom complex) which will be shielded from public view.
4.2.8 Number of units designed for home ownership. None of the units
are designed for individual ownership.
4.2.9 Solicitation of comments from relevant neighborhood associations.
The applicant has notified West University Neighborhood Association of plans
for development and the Association has gone on record as supporting the
application as long as that the positive design features are retained.
4.3 The project was monitored through the City’s regular processes with
respect to planning, permit and building and safety requirements to insure compliance
with all local regulations;
4.4 The site is currently occupied by a single family home built in 1905 and a
duplex built in 1947. Both buildings are currently occupied by students. In June, 2006,
the applicant notified Eugene Senior Planner Ken Guzowski of his intent to demolish the
structures. The applicant plans to demolish the existing structures after donating them to
the Eugene Fire Department for practice; and
4.5 The owner has stated in the application and provided evidence that the
project would not be feasible without the tax exemption. The net operating income from
this project is estimated at $50,660 per year, and the loan payment at $53,808 per year,
which results in a negative cash flow of $3,148 per year.
5.
A display ad soliciting recommendations or comments from the public regarding
this project was published in the Register-Guard on February 25, 2008. The period for comment
expired on March 26, 2008. No comments were received in response to the ad.
Exhibit B to Resolution No. ____ -- Report and Recommendation – Page 3
08 Corey-Hilyard Apts Reapplication MUPTE R R (00182257)
Therefore,
based upon the above findings, the project is in conformance with all
applicable local plans and provisions of the Eugene Code, 1971, planning regulations, the
Metropolitan Area General Plan, and the criteria set forth in the City’s adopted Standards and
Guidelines for Multiple-Unit Housing Property Tax Exemptions. I recommend that the
application be approved.
Dated this _____ day of ___________________________, 2008.
_________________________________
Director, Planning & Development
Department, City of Eugene
Exhibit B to Resolution No. ____ -- Report and Recommendation – Page 4
08 Corey-Hilyard Apts Reapplication MUPTE R R (00182257)
ATTACHMENT C
MULTI-UNIT PROPERTY TAX EXEMPTION PROGRAM HISTORY
NAMEADDRESSNUMBER OF UNITSYEAR
APPROVED
Broadway Center Washington and Broadway 107 units 1978
12 studio; 71 One-Bedroom; 24 Two-
Bedroom; 12 Studio
Lawrence Court 8th and Lawrence 50 One-Bedroom 1980
Washington Abbey 10th and Washington 48 units 1984
9 One-Bedroom/plus loft; Five Two-
Bedroom; 34 One-Bedroom
Olive Terrace 15th Ave. & Olive St. 28 units 1989
4 Studio; 12 One-Bedroom Units; 12
Two-Bedroom Units
Joseph Shapitka 445 W. 10th Ave. 8 Two-Bedroom Units. 1990
Burnell Ambrose 17 & 35 Lawrence St. 7 One-Bedroom Units. 1995
Nozama Apartments 525 & 541 E. 19th Ave. 14 units 1995
12 Two-Bedroom Units; 2 Four-Bedroom
Units.
701 & 725 E. 14th Ave. 1357 53 units 1995
Hilyard House
& 1377 Hilyard 44 Two-Bedroom Units; 9 One-Bedroom
Units.
Paradice Apts 640 E. 15th Avenue 30 units 1996
6 Studio; 8 One-Bedroom Units;
16 Two-Bedroom Units.
High Street Terrace 10th Ave. & High St. 58 units 1996
20 Studio; 26 One-Bedroom Units; 12
Two-Bedroom Units
Broadway Place Broadway and Charnelton 170 units 1996
74 Studio, 72 One-Bedroom, 24 Two
Bedroom
The Tate 1375 Olive 47 units – condominiums 2004
14 one-bedroom, 27 two-bedroom, 6
three-bedroom
Patterson House 979 Patterson 27 units 2004
3 studio, 12 0ne-bedroom, 12 two-
bedroom
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Parkside Place 633 E. 14 Alleyway 21 units 2006
1 one-bedroom, 2 two-bedroom, 5 three-
bedroom, 7 four-bedroom, 6 five-bedroom
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Coho Townhouses 631 E. 14 Ave. 9 four-bedroom units 2007
NAMEADDRESSNUMBER OF UNITSYEAR
APPROVED
14 units
Patterson Place 1360,1372 Patterson 2 two-bedroom, 6 three-bedroom, 4 four-2007
bedroom, 2 five-bedroom Under
Construction
Steelhead 2007
534,535 E. 14th9 rental
Townhouses Under
Construction
Eugene Downtown 2007
990 Lincoln24 ownership
Cohousing In advanced
7 rental (tentative)
planning
PENDING REQUESTS
NAME ADDRESS NUMBER OF STATUS COUNCIL
UNITS ACTION
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16 and Hilyard Apts. 693 E. 16th 7 rental (2 one-Public comment Scheduled for
(Corey Development bedroom, 5 two-period ended April 14, 2008
LLC - David Corey) bedroom)? 3/25/08
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The Fenway 450 E. 14 6 new (4 3BR, 2 Public comment Scheduled for
(Twenty LLC - Dean 5BR) 1 existing period ended April 14, 2008
Hanson) house (6 br) 3/25/08
Additional Downtown Housing Tax Exemptions (not MUPTE)
Lincoln School 58 units Historic Exemption (15 years)
Tiffany Building 28 units Historic Exemption (15 years)
Aurora Building 54 units Low-income Exemption (20 years)
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WestTown on 8 (under construction) 102 units Low-Income Exemption (20 years)
Updated: March 31, 2008
ATTACHMENT D
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ATTACHMENT F
RESOLUTION NO. ______
A RESOLUTION DENYING A MULTIPLE-UNIT PROPERTY TAX
EXEMPTION FOR RESIDENTIAL PROPERTY LOCATED AT 693 EAST
TH
16 AVENUE, EUGENE, OREGON (COREY DEVELOPTMENT, LLC).
The City Council of the City of Eugene finds that:
A.
Our Property Holdings One, LLC, is the owner of real property located at 693
East 16th Avenue, Eugene, Oregon, 97401, more particularly described on the attached Exhibit
A. On April 18, 2007, the City of Eugene received an application submitted by Corey
Development, LLC pursuant to the City’s Multiple-Unit Property Tax Exemption Program
(Sections 2.945 and 2.947 of the Eugene Code, 1971) with respect to residential units to be
constructed on the property.
B.
On June 25, 2007, the City Council denied applicant’s request for the property tax
exemption.
C.
On January 7, 2008, David Corey submitted a revised application for Corey
Development, LLC and requested that the Council reconsider its June 25, 2007 decision based on
the redesigned project. The revised application proposes a smaller apartment complex than the
complex proposed in the original application, and includes an updated income analysis for the
property illustrating that construction of this project is not viable without the property tax
exemption.
D.
A display ad soliciting recommendations or comments from the public was
published in the Register-Guard on February 25, 2008, and advised that written comments would
be accepted for a period of 30 days from the date of publication. Recommendations or
comments were also solicited from the Planning Commission, and other interested City
departments, agencies, and neighborhood groups. No comments were received in response to the
ad.
E.
The Report and Recommendation attached as Exhibit B recommends that the
application be approved and the exemption granted. In making the recommendation, the
Director found that the applicant submitted all materials, documents and fees required by the
application and the City as set forth in Section 2.945 of the Eugene Code, 1971, and is in
compliance with the policies set forth in the Standards and Guidelines adopted by Administrative
Order No. 53-04-03-F.
F.
The project consists of the development of two residential one-bedroom units, and
five residential two-bedroom units, which are not designed for, nor will be used as, transient
accommodations.
Resolution – Page 1
08 Corey-Hilyard Reapp. MUPTE Denial Resol. (00196363)
NOW, THEREFORE,
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF EUGENE, a
Municipal Corporation of the State of Oregon, as follows:
Section 1.
Notwithstanding the above findings and the Report and Recommendation of
the Director of the Planning and Development Department attached as Exhibit B, the City
Council denies the application of Corey Development, LLC for an ad valorem property tax
exemption under the City’s Multiple-Unit Property Tax Exemption Program for the residential
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units to be constructed at 693 East 16 Street, Eugene, Oregon, and more particularly described
on the attached Exhibit A.
Section 2.
The City Manager, or the Manager’s designee, is requested to forward a
copy of this Resolution to the applicants within ten days.
Section 3.
This Resolution shall become effective immediately upon its adoption.
The foregoing Resolution adopted and effective the ____ day of April, 2008.
___________________________________
City Recorder
Resolution – Page 2
08 Corey-Hilyard Reapp. MUPTE Denial Resol. (00196363)