Applicant's Final Written Argument <br />Lombard Apartments <br />July 23, 2018 <br />approval standards; citing Rogue Valleg Assoc. of Realtors, 35 Or LUBA at 158)). <br />The proposed use is compatible with the city park use along the river. <br />Page 6 of 12 <br />EC 9.8815(6): When site review approval is required, the proposed development will <br />be consistent with the applicable site review criteria. <br />This Willamette Greenway Permit application is being reviewed concurrently with a <br />Needed Housing track Site Review Permit application which must meet the criteria for a <br />Needed Housing Site Review application. Therefore, this provision is redundant and violates <br />the commands of ORS 197.307(4). <br />EC 9.8815(7): The proposal complies with all applicable standards explicitly addressed <br />in the application. An approved adjustment to a standard pursuant to provisions <br />beginning at EC 9.8015 of this land use code constitutes compliance with the standard. <br />This standard is redundant. This proposal complies with all applicable standards. <br />In summary, the Application meets the criteria for approval for a Willamette Greenway <br />Permit. However, even if it could be argued that the Application does not meet the criteria, <br />no Willamette Greenway permit is required since all the criteria are either subjective, <br />ambiguous or not applicable. Requiring the Applicant to pay the fee, go through the process <br />and defend an application violates the commands of ORS 197.307(4). <br />b. The Needed Housing Statute & Senate Bill 1051 (2017 <br />This application is an application for "needed housing" as defined by ORS 197.303. <br />This application is a prime example of the need for the "clear and objective" standards <br />imposed upon local governments by the state legislature under ORS 197.303-.307 (the <br />"Needed Housing Statute") as amended by Senate Bill 1051 (2017). <br />Even though this site has been designated Medium Density Residential and zoned R- <br />2, medium density residential for decades, there is significant neighborhood opposition to this <br />development. Even though the site is located between a key transit corridor (River Road) and <br />City parkland, the opponents (or at least a significant number of them) claim that this site <br />should either be parkland or low density residential. <br />The need for more housing in Oregon generally, and Eugene specifically, is acute - <br />that fact is well known and need not be discussed in detail here. Without expanding the urban <br />growth boundary for residential land, the City of Eugene has made the ultimate policy choice <br />to grow up and not out. This necessarily means that the City Council has opted for increased <br />residential density within the UGB. This ultimate policy choice was made in light of other <br />policy considerations - policy considerations that while important must give way in limited <br />circumstances to housing. The state legislature has reacted to the state's housing crisis by <br />r.u 7 Pip-) <br />