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.Finding: The. City's annual budget process fulfills the state requirement of reporting on SDC revenues " <br />and expenditures by system. The Capital Improvement Plan (CIP) process is .used to identify projects to <br />be funded by SDCs and to balance that against anticipated revenues, ,SDC funds are expended in <br /><' conformance with the City's SDC Methodology. Information on revenues and expenditures of SDC funds <br />`' ~is available and was incorporated into presentations given by City staff. The City does conduct <br />corriparisons of its rates against those of other communities; however that information is only intended to <br />provide a way of assessing whether the City's rates are appreciably different from othercommanities. <br />Further evaluation is typically necessary to.determine the cause of the difference. <br />Comment 9: VVhy is the "D" level of service used as the basis for transportation calculations? <br />Einding~ Level of Service "D° is established as the minimal level of service in the City's adopted <br />transportation plans (e.g. Transplan), as well as. being the national standard that urban arterial and <br />collector streets are typically designed tq meet. Transportation SDCs are based on new development - <br />c®ntributing their fair share to maintaining the planned and funded level of service,for City infrastructure, <br />Comment 10: 1Nhy is there such a negligible difference between the cost per trip ($723.69) and the cost per <br />single family dwelling (SFD) .($730.93)? Adopt a more realistic figure for calculation of the cost per trip; ®ther <br />than one trip per peak hour.. Remove the cap on development impact in the Transportation system <br />calculations. ° <br />Finding: In response to the first two comments„according to the Institute of Traffic Engineers' Trip <br />Generation Manual ,(utilized in developing the City's Methodology), a single family dwelling has a trip rate <br />of 1.01 trips per p.m. peak hour. Therefore, the~Transportation SDC for a single family dwelling is nearly <br />equivalent to the cost fora single trip. <br />In response to'the second comment, the current SDC Methodology contains a table oftrip rates by <br />development type. 'The rates are capped so that no development will exceed ten trips per thousand <br />gross square feet. Modification of the cap is apo~icy-issue that cannot be addressed in the context of <br />6 <br />' this administrative rule process, as noted in the opening paragraph ofthis document. _ <br />.:Comment 11: The comment period should be extended, either because not all affected parties Mad <br />sufficient time to respond, or because the scope of the changes is significant enough that additional public <br />debate is needed. The public comment has been dominated by realtors and developers with a financial <br />interest in lower SDCs. <br />Finding.: The proposed changes are an attempt to update the SDC Methodology and rates. so that they- <br />are consistent with current conditions (e.g. current City construction costs) without modifying the policy <br />framework established:by the Eugene City. Council Because policy issues were not being reviewed or <br />addressed, the standard rate setting provisions of Eugene Code were used. The process met State and <br />-.City required notification timelines,. Staff also provided information, made presentations, and met with <br />groups upon request to provide additional information. <br />Comment 12: The City's method of determining average costs for construction are based on projects which <br />differ greatly.. It is not valid'to use`this as the basis of an inflation index. The City should employ an intlati®n <br />index which cannot be biased by project variables. <br />gj The City used City representative projects that included SDC-eligible components in orderto <br />determine average costs. These costs were then utilized to establish the currentsystem value. In <br />addition, as noted in the Respohse under Comment 1, the City subsequently utilized a lower adjustment <br />factor for those components of the system for which current construction cost information was . <br />unavailable. <br />Comment 13 Add reserve capacity reimbursement components to all (SDC) systems. <br />Finding: -This is a policy issuethat cannot be addressed in the context ofthis administrative rule . <br />process, as noted in the opening paragraph ofthis document. It should be noted that the Local and <br />Regional Wastewater SDCs do include a reimbursement component. <br />Exhibit B to Administrative Order No. 58-97-02-F-2 Page 3 <br />