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Eugene Hearing Official November 23, 2015 Page 8 city designed the LUCU to offer two separate sets of approval criteria applicable to land use applications involving needed housing. The first track (needed housing track) is intended to contain only clear and objective criteria. The second is an optional, alternative track (alternative track) that includes criteria that are not intended to be clear and objective. Petitioners advance three general types of challenges. [41 Or LUBA at 383] The first kind of error related to standards that were not clear and objective. First, petitioners contend that some of the criteria under the needed housing track contain terms or standards that are not in fact clear and objective. These criteria are identified in Table 1.1 of Home Builders' petition for review, which challenges over 100 LUCU provisions, organized in 31 categories. [M..] The second kind of error is clear and objective standards that are so stringent as to prevent development, forcing an applicant into the discretionary track. Second, petitioners argue that some of the city's needed housing standards, even assuming they are clear and objective, are written in a manner that effectively prohibits and renders impossible the development of needed housing under clear and objective standards. Petitioners offer three examples or types of such standards, and argue that these types of standards violate the needed housing statutes because they essentially force the needed housing developer into seeking approval under the alternative track. Petitioners submit that forcing a needed housing applicant to pursue approval under the alternative track is inconsistent with the intent of the needed housing statutes. [Id. at 383-384] The third kind of error is clear and objective standards that discourage housing through unreasonable cost and delay. Third, petitioners argue that a number of LUCU provisions, even if clear and objective, nonetheless violate ORS 197.307(6) because they "discourage needed housing through unreasonable cost or delay." These LUCU provisions do so by either (1) reducing the area of development sites that can be developed; (2) requiring additional amenities in connection with development; or (3) adding additional requirements for filing complete applications for development. [Id at 384] In the balance of this argument, we explain how all three types of error are reflected in the city position. LUBA's most recent application of the Needed Housing Statute was in Gr•ol p B, LLC v. City of Corvallis, _ Or LUBA _ (LUBA No. 2015-019, Aug. 25, 2015). There LUBA reversed the city's denial of an apartment on land it found to be in the BLI. There LUBA held