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Ir? Home Builders A S S O C I A T I O N of Lane County January 10, 1994 Mr. Jan Staszewski, Urban Forester Department of Public Works 1820 Roosevelt Eugene, OR 97402 Dear Jan: Thank you for the invitation to comment on the Tree Ordinance (No. 19927) adopted by Council on June 30, 1993. At the January meeting of our Government Affairs Committee, the subject was discussed at length and a consensus formed that it is really too early to comment on the application of the tree ordinance because there has been so little tree cutting permit activity and so little experience with the ordinance on the part of our builder and developer members. However, aside from any discussion of the way in which the ordinance is applied, it continues to be the position of the Home Builders Association that passage of the ordinance was not justified by actual past experience; that the criteria for permit issuance in the ordinance are unnecessarily restrictive; that some of the standards in the criteria for permit issuance (eg. "felling would be compatible with generally acceptable principles of . . . ecology" and "Wooded areas . . . retained for their scenic and wildlife habitat values ") are so vague as to defy consistent, predictable interpretation; and, finally, that the overall regulatory process appears as though it will be fragmented and unnecessarily burdensome (both in cost and delay), for both the city and private landowners. While more experience must precede serious discussion, a fundamental flaw in the application of the ordinance by the city to date is the disregard for economy in general. It appears that multiple permit applications and incremental removal of trees will be required as bare land is converted to residential use in stages. This incremental approach would save no more trees in the long run, but would add considerably to the cost of removal for the land owner and to the cost of enforcement for the city. Sincerely, Tim Vollmer Executive Vice President