Some of our residents have been speaking up about problems with this DevNW development on Floral Hill Drive since it was first proposed in 2024. There were NO letters in support of the development. Seven letters AGAINST the development were received by the City of Eugene. Were you one of the people that spoke up AGAINST the development? Let us know!

from Rebecca Kassan, July 2025

July 3, 2025
To: Eugene City Council 
From: Rebecca Lynn Kassan

Re: Letter Regarding Floral Hill Terrace 

Comments on Application FHT ST 26-2, proposed 40-unit complex Community Land Trust subdivision (Laurel Hill Valley neighborhood)

Dear Commissioners,

I am writing regarding Application FHT ST 26-2, the proposed 40-unit Floral Hill Terrace development. I understand this project is being developed by DevNW, a nonprofit affordable housing organization, as a Community Land Trust subdivision of multiplex middle housing for homeownership. I recognize the value of affordable homeownership opportunities in our region. My comments below are limited to specific, objective safety and environmental standards that I believe this application must satisfy regardless of the applicant or housing type. I am concerned about the impact this housing development will have on the safety and livability of this community. I am asking the city to confirm and document compliance with each before final approval.

1. Fire Access and Evacuation — Oregon Fire Code Standards

This parcel sits within a valley with elevated fire risk. We are in a very vulnerable fire zone according to the 2026 Wildfire Protection Plan. The neighborhood is served by only two access roads, both narrow, regardless of what is built on this parcel. The actual width of both access roads is less than 20 feet with turns tighter than a 28-foot inside radius

These are life-safety minimums under the Oregon Fire Code that apply to any development, of any type, at any level of affordability:

• Minimum unobstructed width of 20 feet (OFC §503.2.1), exclusive of shoulders
• Minimum vertical clearance of 13 feet 6 inches
• Minimum turning radius of 28 feet inside / 48 feet outside (OFC Appendix D) for fire apparatus to navigate the route
• The fire code official has authority to require more than one approved access route where a development’s size, or the length of a dead-end access road, creates unacceptable delay for emergency responders.

I request that the city take seriously a Eugene-Springfield Fire Marshal written determination confirming whether the existing two access roads meet OFC §503.2.1 and Appendix D standards for a development of this size, and whether a secondary/emergency-only access point should be a condition of approval. I would like to confirm compliance with an existing, objective, life-safety standard about the project’s design or merits, and applies equally to any 40-unit development on this site, rather than a discretionary judgement.

2. The Traffic Study’s Methodology Does Not Support Its Conclusion

I understand a traffic count or flow test has been conducted for this application, and that it was performed during a period with little to no traffic, with the applicant treating that result as demonstrating the road network’s adequacy. I wonder whether the evidence in the record actually supports the conclusion being drawn from it. I know from experience it is dangerous to drive, walk, and ride a bike due to the limited road clearance. Cars and pedestrians need to yield to oncoming traffic with no sidewalk and very little shoulder. A dog that was on a leash walking in front of my house was killed by a speeding car 2 years ago. 

Professional traffic impact analyses in Oregon are expected to follow established, objective methodology, generally requiring:

• Counts taken during the weekday AM peak (typically 7–9 a.m.) and PM peak (typically 4–6 p.m.) periods — not an arbitrary or low-traffic window — because the purpose of a traffic study is to capture worst-case, representative conditions, not best-case ones.
• Trip generation rates drawn from the current ITE (Institute of Transportation Engineers) Trip Generation Manual, applied by a licensed Oregon Professional Engineer, whose stamp should appear on the report.
• Level of Service (LOS) analysis against the region’s adopted performance standards (Eugene-Springfield’s Regional Transportation Plan sets LOS D as the standard outside the Central Area Transportation Study zone).
• Counts that are current (typically within the last 1–3 years) and reflect normal seasonal and weekday conditions, not an atypical day.

I request the actual traffic study document from the city’s public land use application file for FHT ST 26-2 to see the following:

• What date and time the counts were taken, and whether they cover AM and PM peak periods
• Whether the report is signed and stamped by an Oregon-licensed Professional Engineer
• What trip generation methodology was used, and whether it’s from the current ITE manual
• Whether the stated conclusion (“adequate access”) is actually supported by the data collected, or is an unsupported leap from a single low-traffic observation

I request that the city review the traffic study that follows standard professional methodology — AM and PM peak-hour counts, prepared by a licensed engineer, using current ITE trip generation rates — before relying on the existing study to find that the road network can adequately serve this development. 

3. Stormwater Runoff and Downstream Flooding — Eugene’s Headwaters Area Standards

This parcel sits in a valley below a mountain slope that already produces winter runoff flooding. Converting several acres of absorbent, vegetated land into roofs, driveways, and roads reduces the site’s ability to absorb that runoff, meaning more water moving faster into the same downstream yards and drainage ways that already flood today. This is a hydrology and engineering question, not a question about the applicant or housing type.

According to the City of Eugene Property Explorer, this parcel sits above the 500 ft threshold, which would trigger:

• Eugene’s Headwaters Area stormwater standard (on-site infiltration/detention requirement) 
• The EC 9.9590 5-units/acre density cap concerns
• The need to address setback zones and protective overlay for flooding

Eugene Code 9.6790–9.6797 (implemented via Ordinance 20369 and the city’s Stormwater Management Manual) sets specific, objective, dimensional standards:

• Flow control: new or replaced impervious surface must control the volume, duration, and peak rate of runoff leaving the site, so that post-development peak flows do not exceed pre-development conditions.
• “Headwaters Area” standards: land above 500 feet in elevation within city limits is subject to a requirement that new or replaced impervious surface include on-site infiltration or on-site detention specifically designed to control stormwater volumes and flow rates. 
• Stormwater quality/quantity treatment is required for any project adding 1,000+ square feet of new impervious surface — a 40-unit subdivision with roads and driveways will trigger this many times over.

My yard, and those around me get flooded every winter. My neighbor to the South accused me of dumping buckets of water in his yard. I investigated with the city and the houses along my street were built at the same time in the 60s with huge 3 foot diameter drainage pipes underground to divert water to the south toward his house and those further downhill. All of our yards get 3-5 inches of water every winter. I worry the hardscape created this housing development will cause more runoff and be a flood risk to all of our houses down hill. 

I request that the city require the applicant to submit a full hydrology/stormwater study — not just a standard stormwater quality plan — that specifically models pre- and post-development peak flow rates to the downstream properties already experiencing flooding, and that flow control facilities be sized to keep post-development peak flows at or below existing conditions, consistent with the stated purpose of EC 9.6790.

4. Wildlife Habitat and Mapped Natural Resources — Statewide Goal 5

This parcel may contain habitat and natural resource values that are subject to specific, mapped protections under Oregon’s Statewide Planning Goal 5, independent of what type of housing is proposed:

• The /WR Water Resources Conservation Overlay Zone, which applies development setbacks and standards to protect significant riparian areas, wetlands, and water-related wildlife habitat on specific mapped properties.
• Eugene’s Significant Goal 5 Wetlands inventory, which identifies parcels meeting the state’s mandated criteria for locally significant wetlands under OAR 141-086-350.

Although we have Hendricks park to the West, the acreage in the center of this community serves as a habitat and refuge for many birds and mammals. There are wild turkeys and quail that have consistent breeding areas in this field. Bats, foxes, and deer are prolific in the field. I ask the city to weigh the land’s general open-space value against the housing proposal. 

I want to be direct about the limits of this letter. Under Oregon’s needed housing statute (ORS 197.307) and the state’s middle housing law (HB 2001), the city is legally required to apply only clear, objective, non-discretionary standards to housing applications like this one — it cannot deny or condition approval based on subjective judgments about unit count, neighborhood character, or general preference for open space over housing. I am not asking the commission to deny this application on those grounds, and I’d expect that public comment on this project be evaluated on the specific, measurable, code-based standards above, which apply regardless of the applicant’s mission or the housing type proposed.

Conclusion

I ask the commission to confirm, on the record, that Application FHT ST 26-2 meets the Oregon Fire Code’s access standards, that the traffic/access study relied upon actually meets standard professional methodology and supports its conclusions, that the project meets Eugene’s stormwater flow-control and Headwaters Area requirements, and that any applicable Goal 5 habitat protections are addressed — before final approval. If any of these have not been documented with adequate evidence, I ask that the corresponding study be corrected or supplemented before the application proceeds.

Sincerely, 

Rebecca Kassan
XXXX Floral Hill Dr.
Eugene Oregon

from Mary Gent, Spring 2025

This email is in response to the public comment period for the Affordable Housing Project RFP which runs through 4/30/25. 

In a rather cursory review of the proposed documents it appears 4 entities are requesting 1.98M from $709,879 available housing trust dollars. The Floral Hill CLT requesting 600K, 85% of the total available funds.

As a 30 year resident at XXXX Floral Hill Dr I will present some general observations and concerns with the Floral Hill Project:

• size and scope of a very dense housing project serving 100-160 residents on 4 acres of land with shared common space. Who will provide onsite management of a housing development of this size and density? Disputes will occur with a need for some type of home owner association to set guidelines and resolve disputes. This should be addressed in the proposal. Density disputes must not fall on Laurel Hill Valley Neighborhood Association to resolve. Nor Public Safety resources.
• Fiscal sustainability – the project cost is 19.2M with 9.3M coming from the sale of units. 8.8M is identified as coming from public sources. What are these public sources and how reliable are they in our current city, county, state and federal fiscal crisis. It is unacceptable with looming budget problems and a federal administration striking all equity grants that the citizens (property owners) be asked to dig deeper. Fiscal sustainability over time must be addressed.
• Traffic flow and public safety – the project acknowledges 36 units will have a minimum of 36 cars, likely 72 cars. Without access to public transportation. Floral Hill Rd is a narrow winding street, without sidewalks. Heavily used by cyclists, dog walkers, runners, elderly residents. With access and egress to a public forested trail used by children, dogs, adults. The problem will be compounded if mailboxes and garbage cans are on the street side of Floral Hill. Public safety concerns must be addressed and mitigated. I have lost one dog to a speeding car who could not bother to slow down nor stop after hitting our rescue dog.
• fire mitigation – given the density of housing without green space between units the risk of fire spread is quite high. We know from the Colorado Thompson Fire east of Boulder, houses themselves are ignition points. Dense housing results in fire spread. With a dense and dry urban forest at the footsteps of the project. What construction materials will be used to address fire mitigation? Cement based siding? How will fire response be addressed in urban density  housing next to an urban forest? Look no further than Eaton or Palisades Fire for insights.

My recommendation is the project be reduced in size to serve 50-80 residents on 4 acres of land. It is simply unfair to target minority populations in this proposal and then offer very dense housing. It is a set up. With no effort to address disputes living under such close quarters. Frankly it strikes me as another well intentioned white proposal for disenfranchised minorities.

Respectfully submitted,

Mary Gent

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