i <br />Metro Plan} and the 187 Westside Neighborhood 'Ian ~wNP}.13 <br />Therefore' the two wNP policies cited in the first and second assignments of error <br />are comprehensive plan policies and the decision in Baker applies to these <br />policies, <br />Conse uently, in addition to failing to meet two mandatory approval criteria q <br />enumerated in Eugene Code has explained in the first and second assignments of <br />error}, the proposed zone change also conflicts with the requirement laid down <br />by Baker. The evidence and arguments from the first and second assignments ~of <br />error are incorporated herein as the basis for this assignment of error. <br />while the substantive arguments are the same here asunder the First and Second <br />Assignments of Error, the legal foundation is based on statutory requirements <br />and not local Land use code. ~ ~ ~ , <br />coNCLUSYoN <br />For the foregoing reasons, the approval of this zone change must be modif led to <br />add a condition limiting the uses identified above ar the zone change must be <br />denied. <br />Respectfully submitted this 16th day of August 2411. , <br />. FoR JEFFERSON wESTSIDE NEIGHBORS <br />Paul Came <br />JWN Chair ~ ~ , <br />' ~ Contact inf ormation <br />141 '.14th Ave., Eugene, oR 97442 <br />Chair~jwneugene.org <br />541.344,2552 <br /> <br />, <br />~3 LUBA made a comparable statement in reference to another one of Eugene's refinement plans, <br />"The City of Eugene's comprehensive plan is made up of a number of documents, Two of those , <br />documents are the Metro Plan and the west University Refinement Plan." Home Builders <br />Association of Lane County v. City of Eugene LUBA Nos. 2005-148 and 200$-149, pg. ~.8-19, <br />Appeal Statement Z 11-3 18 August 1d, 2411 <br />PC Agenda -Page 27 <br />