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as one of the conditions of restoration. <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 />requirement for ADA accessibility installation or upgrades in certain locations ORS 447.310. <br />Furthermore, betterment could be construed to include, as an example, new concrete in a <br />sidewalk that contained old cracked concrete originally. In other situations, it may not be <br />possible to obtain surface restoration coverings that match the original or existing covering, <br />and an upgrade may be required to prevent the installation of sub-standard surfacing. The <br />issue of 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 />Manual exceed those required by the other cities in which we operate. We work in over 100 <br />franchised cities and our drawings provided to the City of Eugene have been based on the <br />standards required by the majority of those cities we serve. We find the requirement of the <br />City of Eugene to be somewhat excessive and requiring a significant amount of extra time <br />to be added to our construction processes. We are in the process of looking at providing a <br />system that will meet the City of Eugene's but we cannot provide all the information at this <br />time. <br />Finding. Section 2.H.5 referenced by Northwest Natural, does not apply to utilities <br />or their operations. This section covers temporary surfacing permits, which are applied for <br />by private parties to perform temporary street improvements for access to private property. <br />Section 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 />ability, based on species, to recover from the potential impact. The level of accuracy and <br />.detail 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 evaluation of the impact on and potential conflicts with existing facilities. Plans that <br />do not contain accurate or complete information will continue to be returned to the pxovider <br />for correction and resubmittal. No changes were made to the rule or Manual as a result of <br />this comment. <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 once again feel the City is requesting information that is not reasonable. We do not <br />employ urban foresters or arborists as Field Engineering Technicians and we do not have <br />;personnel that can always identify the "species" of the. trees in a proposed work area. We <br />suggest a simplification or change in this requirement. <br />.Administrative Order - 5 r:~aam~~o~a~~uies~ooroW~i2ao.Wpa~o9n3ioo~ <br />