Public Hearing for an 11-home development at 5920 SW 48th Ave is scheduled for Wednesday, March 8, 2017.

By signing below, I offer my opposition to the following elements of LU 16-159330 LDS ENM, a proposed 11-home subdivision by Everett Custom Homes at 5920 SW 48th Ave. Portland, OR 97221

1. The current proposal does NOT meet the Land Division Clearing and Grading and Land Division Tree Preservation approval criteria.

Due to its location in a landslide hazard area, its slopes and topography, the environmental overlay zone and mapped wetlands on the site, and the site’s location at one of the headwaters of a tributary in the Fanno Creek watershed, the city code does not require a minimum number of lots for this development. As such, 11 homes is an egregious amount of homes to propose on the site in question. The applicant claims it is not practicable to meet the Portland City Code approval criteria for tree preservation (33.630.200) or the clearing and grading standards (33.635.100), instead prioritizing their desire to maximize the lots and homes. The applicant has not provided alternative plans that would minimize disruption to the natural resources and functional values of the site, or in the surrounding area, as required per the approval criteria in the city code

2. The proposed street connection of SW Pendleton forces an unnecessary and unacceptable amount of disruption for nominal upside.

The requirement for “street connectivity” per the city’s connectivity requirement (33.654.11.10.B.1 and 33.654.130.B) is being prioritized over all other approval criteria, and will require:

• re-grading of 100% of the developable portion of the site
• construction of a wide paved/ impervious new public street (to accommodate the applicant’s desire for maximum lots)
• alteration of 75% of the site’s natural drainage patterns
• high and visible (6’) retaining walls built on 10-15’’ of imported fill
• removal of almost all significant and preservable remaining trees on the site (including a 45’ Western Red Cedar in the right of way)
• minimum lot sizes (as small as 4,200 square feet)
• maximization of lot coverage (resulting in large home footprints, and minimal green space, which is out of character with the neighborhood)
• building out to near maximum lot density allowed on the site

This is an extraordinary amount of disruption for an entirely non-critical street connection, and, as such, it is entirely avoidable with alternative plans which are being proposed by the Hayhurst Neighborhood Association. The alternative plans satisfy all three parties - the applicant, the city, and the neighborhood. Instead, the applicant and city did not provide in the record alternative plans that investigated options for fewer lots or home sites, for no through street connection, or for smaller home footprints, or investigate alternatives with less of an impact on the site than as proposed.

I am calling on BDS and the City of Portland to honor the concerns and will of the neighborhood, by amending proposal LU16-159330 LDS ENM so that:

• LU 16-159330 LDS ENM is denied as currently proposed.
• The applicant is required to provide alternative plans and analyses as part of any new application, with all approval criteria balanced and met as part of any approval or approval with conditions.
• The requirement for a through street connection between the two segments of SW Pendleton be removed or modified, such that any connection allow only for right of way linkages for passage by pedestrians and bicycles, and for emergency vehicle access or turnaround (if necessary). If a connection cannot be designed to meet the requirements of NOT requiring regrading of the site, NOT changing the natural drainage of the site, NOT removing any of the remaining significant trees outside the EC zone, and NOT removing the significant Western Red Cedar located in the existing Pendleton right-of-way, it should NOT be required.