established. As explained under Il.a, above, the study area established by the City must be "adjacent" to <br />the UGB, including "land in the vicinity of the UGB that has a reasonable potential to satisfy the <br />identified need deficiency." ORS 197.298(1)(b); OAR 660-024-0060(4). <br />Specifically, Eugene's study area for industrial land includes all land west of Interstate 5,12 south of the <br />McKenzie River, and within % mile of Eugene's current UGB or within the Eugene-Springfield <br />Metropolitan Area General Plan boundary (which extends beyond % mile in some areas). The study area <br />includes some additional land to allow for analysis of exception areas or non-resource areas that abut <br />the current UGB and extend beyond the boundary described above. Through a separate study (the UGB <br />Expansion Analysis for School Land), a 54-acre portion of this study area has already been identified for <br />an expansion to site a new <br />City of Eugene Urban Growth Boundary Study <br />school facility and will, Industrial Land Evaluation <br />therefore, not be considered Study Area <br />in this UGB Expansion Analysis <br />for Employment Land. The <br />industrial land study area <br />includes about 18,734 acres, <br />more than enough land to <br />ensure consideration of all <br />land with a reasonable <br />potential to satisfy the need. <br />The location of the study area <br />is shown on the "Study Area" <br />map. <br />IL <br />i <br />_ "J- <br />A _ <br />v„. <br />Land Inside UGB Major Streets <br />Industrial Expansion Study Area ( Water Bodies <br />{ School Expansion <br />12 The acknowledged regional comprehensive plan (the Metro Plan) provides that "[t]he division of responsibility <br />for metropolitan planning between the two cities is the Interstate 5 Highway." ORS 197.304 requires Eugene and <br />Springfield to establish separate UGBs "consistent with the jurisdictional area of responsibility specified in the <br />acknowledged comprehensive plan." <br />Appendix B to Findings May 2017 Page 10 <br />