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closely as possible to 30 curb feet on center with consideration for driveways and credits <br /> or waiver granted by the City Manager, Urban Forester, or Public Works." <br /> Finding: The rules identify the desired spacing of trees to be on an average of 30 <br /> curb feet. The rules establish location standards in R- 7.280 -C.1 for the placement of trees <br /> to prevent conflicts with driveways and other structures. Depending on factors such as lot <br /> • size, driveway size, block size, and the location of public improvement, the location <br /> standards may not allow an average of a 30 curb foot spacing to be achieved. In those <br /> cases the maximum number of trees allowed by the location standards shall be the number <br /> required. Credit for preserving existing trees and waiver of the requirement to plant trees <br /> have been provided in the revision to R- 7.2$0 -C.1 in response to comment 1. <br /> Comment 6: The requirement of R- 7.280 -D.3.3 that trees be 100% free from <br /> insects, disease, etc. is not practical, and the section should be clarified to require the trees <br /> be "reasonably free" <br /> Finding: I concur with this recommendation and Section R- 7.280 -D.3.3 has been <br /> revised accordingly. <br /> Comment 7: The. requirement in R- 7.280 -D.3.4 that tree structural . scaffold <br /> branches be at least 6" apart where they attach to the main trunk should be revised to <br /> require that the scaffold branches shall be well proportioned where they attach to the main <br /> trunk. <br /> Finding: I concur in part with this recommendation, and Section R-7.280-D.3.4 <br /> has been revised to provide that the structural scaffold branches shall be well proportioned <br /> where they attach to the main trunk with an average spacing of at least six inches. <br /> Comment 8: The 2" caliper requirement for Arterial and Collector streets in R- <br /> 7.280-C.4.2 needs to be modified so that when the CitY takes possession of those trees, <br /> the trees are 2" in caliper. <br /> Finding: I concur with this recommendation, and Section R- 7.280 -D.4.2 has been <br /> revised accordingly. <br /> Comment 9: There is no need to waste City resources /funds on extending <br /> administration time periods as required by R- 7.280 -E.1. If a tree has been replaced due <br /> to vandalism or other conditions and that tree meets City criteria, i.e., 1.5 or 2" caliper <br /> by the end of the original establishment period, then acceptance should be granted. <br /> Finding: The purpose of a 3 year establishment period is to assure initial pruning <br /> and 3 years of wateririg are provided to a young tree before it is expected to survive on <br /> its own in Eugene's summer climate. Requiring the establishment period to be extended <br /> Administrative Order - 3 <br />