FAIR <br />HOUSING <br />COUNCIL <br />r=1 OF OREGON <br />September 21, 2022 <br />Eugene Hearings Officer <br />101 West 10th Avenue, <br />Eugene, OR 97401 <br />RE: Zone Change request to revise zoning from split zoned R-1/AG (Low Density <br />Residential/Agricultural) to R-1 (Low Density Residential) (Z 22-8) <br />Dear Hearings Officer: <br />This letter is submitted jointly by Housing Land Advocates (HLA) and the Fair Housing Council <br />of Oregon (FHCO). Both HLA and FHCO are non-profit organizations that advocate for land use <br />policies and practices that ensure an adequate and appropriate supply of affordable housing for <br />all Oregonians. FHCO's interests relate to a jurisdiction's obligation to affirmatively further fair <br />housing. Please include these comments in the record for the above-referenced proposed <br />amendment. <br />As you know, all amendments to the City's Comprehensive Plan and Zoning map must comply <br />with the Statewide Planning Goals. ORS 197.175(2)(a). When a decision is made affecting the <br />residential land supply, the City must refer to its Housing Needs Analysis (HNA) and Buildable <br />Land Inventory (BLI) in order to show that an adequate number of needed housing units (both <br />housing type and affordability level) will be supported by the residential land supply after <br />enactment of the proposed change. <br />The staff report for Z 22-8 does not include findings for Statewide Planning Goal 10, describing <br />the effects of the amendments on the City, despite the fact that this is a zone change affecting the <br />residential land supply. The required Goal 10 findings must demonstrate that the proposed <br />change does not leave the City with less than adequate residential land supplies in the types, <br />locations, and affordability ranges affected. See Mulford v. Town of Lakeview, 36 Or LUBA 715, <br />731 (1999) (rezoning residential land for industrial uses); Gresham v. Fairview, 3 Or LUBA 219 <br />