June 20, 2025 <br />Page 3 of 7 <br /> <br />(2) The final configuration of property lines shall not reduce an existing lot below the minimum lot <br />standards established in this land use.code or otherwise violate standards of this land use code, building <br />codes, fire codes, and Chapter 7. <br />Each of the four properties is zoned AG Agricultural with an urbanizable lands (UL) overlay. <br />The AG zone specifies a minimum lot size of 20 acres. EC 9.2020. However, as each of the four lots <br />involved is substantially smaller than the 20-acre minimum, none of them will be “reduce[d]” below the <br />minimum parcel size by the property line adjustments, and the same may be approved consistently with the <br />provisions of ORS 92.192. <br />ORS 92.192(3)(b)? authorizes property line adjustments outside of the corporate limits of a city where <br />the properties involved are “smaller than the minimum lot or parcel size for the applicable zone before and after <br />the property line adjustment.” This statutory provision is applicable to the property line adjustments at issue in <br />this application. As depicted in the enclosed site plans, each of the four lots involved are smaller than the 20- <br />acre minimum parcel size for the agricultural zone and will still be smaller than the minimum parcel size after <br />the property line adjustments. Accordingly, the property line adjustments may be approved consistently with <br />EC 9.2020 and ORS 92.192. <br />ORS 92.192(4) imposes additional requirements for property zoned “exclusive farm use, forest use or <br />mixed farm and forest use.” However, these standards are not applicable to the urbanizable lands at issue. While <br />the properties are designated “agricultural” by the City, this designation is not equivalent to an “Exclusive Farm <br />Use” designation, which is a county zoning designation that is required to limit uses to certain farm uses and to <br />prohibit or substantially limit nonfarm uses.2 See ORS 215.203(1)* & 215.213. The City’s agricultural zone is <br />not an EFU zone because it limits farm uses that are permitted outright by the statute and permits residential <br />and other uses which are either not allowed or strictly limited by the statute. Compare ORS 215.213 and EC <br />9.2010. Likewise, the “agricultural” zone would not be considered a forest or mixed farm and forest zone, <br />because it does not permit forest operations. As such, the limitations’ in ORS 92.192(4) are not applicable. <br />The proposed reconfiguration of the units of land would also not violate standards of the land use code, <br />building codes, fire codes, and Chapter 7. Consistent with EC 9.4620, the proposed property line adjustment <br />would not increase the number of developable lots, nor would it increase the development potential of the lots, <br /> <br />? Although the statute references “county” approval for property line adjustments “entirely outside the corporate limits of <br />a city,” the City of Eugene has the responsibility for administering property line adjustments within the urbanizing area <br />pursuant to an intergovernmental agreement with Lane County. <br />3 Lane County zones property EFU by imposing its Exclusive farm Use Zone (E-RCP) for lands outside of the urban <br />growth boundary. <br />4 “Zoning ordinances may be adopted to zone designated areas of land within the county as exclusive farm use zones. Land <br />within such zones shall be used exclusively for farm use except as otherwise provided in ORS 215.213, 215.283, or <br />215.284.” <br />5 Even if ORS 92.192(4) were applicable, and it is not, the proposed property line adjustments would not violate the <br />limitations found therein. The City agricultural zone doesn’t include a minimum parcel size for the creation of a dwelling, <br />so ORS 92.192 subsection (4)(a)-(c) are not applicable, and none of the properties were created by a Measure 37/49 waiver <br />so subsection (4)(d) is not applicable.