Hearings Official Ken Helm <br />November 10, 2015 <br />Page 2 <br />as overlay zones with sufficient buildable land to satisfy that need." (Emphasis <br />added.) <br />Thus, in reading the needed housing statutes, before you even arrive at subsection (4) for the <br />clear and objective requirement, you first must read through three subsections that discuss the <br />purpose of the needed housing requirement. And the purpose of the needed housing <br />requirement is tied to the price or rent level of the available housing (e.g., "particular" prices <br />and rents). <br />The applicant wishes to read away the entire purpose of the needed housing statute. The <br />applicant is required to show that its development is needed housing "as defined by state <br />statute." Without a reference to the price range or rent level of the proposed housing, the <br />applicant cannot meet this first criterion for its needed housing application. The burden of <br />meeting the applicable criteria belongs to the applicant. This record fails to provide evidence <br />that this application meets the criterion under EC 9.8325(1). <br />Last, to the extent that the applicant cites a housing inventory for its theory that the proposed <br />development is one for needed housing, such argument does not comport with ORS 197.304. <br />This statute requires the Hearings Official to apply the needed housing statutes and the needed <br />housing requirements separately from any housing inventory prepared with the City of <br />Springfield. The housing inventory cited by applicant is a combined inventory for both Eugene <br />and Springfield. However, ORS 197.304(1) requires that we look only to Eugene in <br />implementing ORS 197.307. ORS 197.304(1) ("Notwithstanding an intergovernmental <br />agreement pursuant to ORS 190.003 to 190.130 or acknowledged comprehensive plan <br />provisions to the contrary, a city within Lane County that has a population of 50,000 or more <br />within its boundaries shall meet its obligation under ORS 197.295 to 197.314 separately from <br />any other city within Lane County.") (Emphasis added.). With ORS 197.304, the Hearings <br />Official cannot look to the joint Eugene-Springfield housing inventory for purposes of the <br />applicant's requirement to show compliance with needed housing "as defined by state statute." <br />Because applicant has not cited to a needed housing inventory developed "separately from any <br />other city within Lane County," the applicant fails to satisfy its evidentiary burden under EC <br />9.8325(1). <br />EC 9.8325(5) <br />"There shall be no proposed grading on portions of the development site that meet or exceed <br />20% slope." <br />Applicant's site map shows portions of the development site that meet or exceed 20% slope. <br />However, not all portions of the development site that meet or exceed 20% slope are identified <br />on the site map. Using the five-foot contour intervals on the site map, it is readily apparent <br />