process. I agree with Gepper that the City provided the necessary procedures to allow opponents, <br />including Young, to participate.-' Young filed testimony in opposition to the proposal. I do not see <br />that Young's substantial rights were prejudiced. Furthermore, an opponent may not raise procedural <br />arguments on behalf of people who have not participated in the decision making process. <br />Young's arguments do not provide a basis to deny the application. <br />Zone Change Approval Criteria <br />Eugene Code (EC) 9.8865 provides the criteria for approval of a zone change: <br />Zone Change Approval Criteria. Approval of a zone change application, including the <br />designation of an overlay zone, shall not be approved unless it meets all of the following <br />criteria: <br />1) The proposed change is consistent with applicable provisions of the Metro <br />Plan. The written text of the Metro Plan shall take precedence over the <br />Metro Plan diagram where apparent conflicts or inconsistencies exist. <br />2) The proposed zone change is consistent with applicable adopted refinement <br />plans. In the event of inconsistencies between these plans and the Metro <br />Plan, the Metro Plan controls. <br />3) The uses and density that will be allowed by the proposed zoning in the <br />location of the proposed change can be served through the orderly extension <br />of key urban facilities and services. <br />4) The proposed zone change is consistent with the applicable siting <br />requirements set out for the specific zone * * * <br />5) In cases where the NR zone is applied based on EC 9.2510(3), the property <br />owner shall enter into a contractual arrangement with the city to ensure the <br />area is maintained as a natural resource area for a minimum of 50 years." <br />EC 9.8865(l) <br />EC 9.8865(1) requires that the proposed zone change be consistent with applicable <br />provisions of the Metro Plan. The most applicable provision of the Metro Plan is the plan <br />designation for the subject property, which is Government & Education. PL implements the <br />Government & Education designation. The existing overlay is not inconsistent with the Metro <br />Plan, but it also not required by the Metro Plan. <br />2 1 adopt and incorporate Gepper's April 14, 2020 memorandum in this decision. <br />Hearings Official Decision (Z 20-2) Page 3160