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i <br /> as on of the conditions of restoration. <br /> <br /> ~rr <br /> Findin At times, betterment is the only option available to a utility, or that matter <br /> the City, in restoring the public way. Betterment is also required by State law, as in the <br /> requi ement for ADA accessibility installation or upgrades in certain locations ORS 447.310. <br /> Furt rmore, betterment could be construed to include, as an example, new concrete in a <br /> side alk that contained old cracked concrete originally. In other situations, it may not be <br /> possi le to obtain surface restoration coverings that match the original or existing covering, <br /> and a upgrade may be required to prevent the installation ofsub-standard surfacing. The <br /> issue f betterment has not been used by the City to penalize those who work in the public <br /> way. No changes were made to the rule or Manual as a result of this comment. <br /> Comment 8. The drawings required by the City of Eugene in Section 2.H.5 of the <br /> Man al exceed those required by the other cities in which we operate. We work in over 100 <br /> franc ised cities and our drawings provided to the City of Eugene have been based on the <br /> stand ds required by the majority of those cities we serve. We find the requirement of the <br /> City f Eugene to be somewhat excessive and requiring a significant amount of extra time <br /> to be dded to our construction processes. We are in the process of looking at providing a <br /> syste that will meet the City of Eugene's but we cannot provide all the information at this <br /> time. <br /> Findin .Section 2.H.5 referenced by Northwest Natural, does not apply to utilities <br /> or th 'r operations. This section covers temporary surfacing permits, which are applied for <br /> by pr vate parties to perform temporary street improvements for access to private property. <br /> Secti n 2.D.2 of the Manual addresses the plan and drawing requirements for utility work <br /> in the public way. The only change made to this section was addition of a requirement that <br /> plans identify the tree species if the work zone falls within the critical root zone of a street <br /> tree. Identification is necessary so staff can evaluate the proposed impacts and the tree's <br /> abilit ,based on species, to recover from the potential impact. The level of accuracy and <br /> detai required on utility plans does not exceed the requirement of other projects that take <br /> place in the public way. It is essential that plans contain sufficient accurate information for <br /> staff valuation of the impact on and potential conflicts with existing facilities. Plans that <br /> do no contain accurate or complete information will continue to be returned to the pxovider <br /> for c rrection and resubmittal. No changes were made to the rule or Manual as a result of <br /> this c mment. <br /> Comment 9. Critical root zones referenced in Section 2-D-2 of the Manual. It is <br /> being required that we note the "size, location, species of each tree" within the work area. <br /> We o ce again feel the City is requesting information that is not reasonable. We do not <br /> empl y urban foresters or arborists as Field Engineering Technicians and we do not have <br /> perso nel that can always identify the "species" of the trees in a proposed work area. We <br /> sugg st a simplification or change in this requirement. <br /> ~rr Administrati e Order - 5 r:\adminord\rules\OOrowrl2ao.wpd(09/13/00) <br /> <br />