than 10 acres. At just over 4.5 acres, the subject site falls into forecast for sites under 10 acres. <br />The ELSS identified 404 acres of developable industrial lands less than 10 acres in size. Based on <br />forecasted land need, the ELSS forecast calculated a surplus of 121 acres. Due to this identified <br />surplus and in combination with deficiencies with other employment land types, the City <br />pursued strategies to increase the supply of employment land capacity and efficiency such as <br />consolidating small sites into larger sites and rezoning some areas zoned industrial to a new E-2 <br />Mixed Use Zone (Envision Eugene Implementation: Employment and Industrial Zone Changes <br />and Code Amendments; City Files CA 13-4 and Z 13-8). These efficiency measures resulted in a <br />deficiency of 26 small-industrial acres. The City addressed this deficiency by including some <br />smaller industrial sites in the Clear Lake UGB expansion area. <br />As discussed above, the ELSS does not identify the subject property in the inventory of available <br />or developable industrial employment lands. In terms of potential loss of over four acres of <br />designated industrial employment lands, the ELSS supports the proposed amendment following <br />on the heels of the ELSS measures to increase capacity and efficiency of employment lands <br />broadly within the urban growth boundary. First, the proposed amendment and zone change <br />would permit a mixture of commercial and industrial uses with an emphasis on employment <br />use flexibility while avoiding creating a non-conforming situation regarding current industrial <br />development. Further, by allowing for more employment use types than in the industrial plan <br />designation and zoning, the proposed mixed-use designation and zoning allows for greater <br />employment capacity and reduces the need to expand the UGB for employment lands. <br />Additional findings addressing the relevant policies of the Metro Plan and Envision Eugene, <br />consistent with OAR 660-009-0010(4)(a), are provided below under EC 9.7735(2) and (3) and <br />are incorporated herein by reference. <br />Further contextual analysis demonstrating how the proposed amendment supports Statewide <br />Planning Goal 9 generally is included in the applicant's narrative. <br />Given these facts, the requested Metro Plan Amendment will not adversely impact the ability to <br />provide opportunities for a variety of economic activities. <br />Based on these findings, the proposal is consistent with Statewide Planning Goal 9. <br />Goal 10: Housing - To provide for the housing needs of citizens of the state. <br />Goal 10 requires that communities plan for and maintain an inventory of buildable residential <br />land for needed housing units. The Administrative Rule for Statewide Planning Goal 10 (OAR <br />660 Division 8) states that "the mix and density of needed housing is determined in the housing <br />needs projection. The Envision Eugene Residential Lands Supply Study (RLS), which includes <br />Eugene's Housing Needs Assessment (HNA), determined that Eugene meets the demand for <br />low, medium, and high-density residential land. Further, the Buildable Land Inventory (BLI) <br />recognized the subject site as developed and designated for industrial development. <br />Findings <br />MA-20-2 / RA 20-2 / Z-20-8 <br />