<br /> <br />University of Oregon February 10, 2026 <br />RA 25-01, CA 25-02, Z 25-03 <br />Final Open Record Submission <br /> <br /> 8 <br /> <br />flexible guide for specific decision-making * * * “. Additionally, the plan notes that a “review of the <br />[FSAS] plan should be conducted in about ten years to determine if a major update is appropriate.” The <br />proposed Refinement Plan Amendments are supported by the stated need to update the plan “in about <br />ten years” and because they do not affect consistency with the remaining portions of the refinement <br />plan that pertain to sections other than “The University of Oregon Lands.” <br /> <br />A tenant in FNA’s arguments is the assertion that the applicant and the City have failed to “propose <br />development requirements/conditions that would implement the Refinement Plan policies and mitigate <br />the impact from high-intensity uses * * * .” The proposed amendments do not introduce any new <br />policies to the refinement plan or code. The amendments update the refinement plan text to be <br />consistent with the East Campus Area Plan. The majority of text amendments occur in “Section E. The <br />University of Oregon Lands,” which pertains to University-owned property. FNA may be equating <br />residence halls with “high-intensity uses.” However, as discussed in Section A., academic instructional <br />uses are more intensive than residence halls, so it is appropriate to allow residence halls in the Limited <br />Institutional plan area. Finally, the policy language addressing mitigation of off-site impacts only applies <br />to new development in the Low Density Residential zone (see FSAS, University of Oregon Lands, <br />Policy 5 (renumbered from 6)). <br /> <br />We restate City staff’s findings, that the approval criterion at EC 9.8424(1)(c) appears to require <br />consistency with the “goals” listed in the FSAS, and that the goals do not appear to serve as mandatory <br />approval criteria for the proposed Refinement Plan Amendments under EC 9.8424(1)(c) or for the <br />proposed Code Amendments under EC 9.8065(2) (see Eugene Planning staff memorandum dated <br />January 27, 2026). <br /> <br />In response, the applicant submits findings demonstrating consistency with the applicable approval <br />criteria, as shown in [Exhibit C Proposed Findings]. These findings are based on the staff’s proposed <br />findings from January 4, 2026. The applicant has supplemented staff’s findings to address the issues <br />raised by opponents in this proceeding. <br /> <br />E. Code Amendments <br /> <br />In testimony submitted on February 2, 2026, FNA proposes new Code Amendments that would apply <br />Site Review to the LI area and add special development standards to all developments in the LI area. <br />For reasons stated previously, the applicant does not accept these proposed changes. However, the <br />applicant is willing to modify the proposed Code Amendments to be consistent with the acceptable <br />changes FNA has proposed to the Refinement Plan text amendments, as contained in EC 9.9570 <br />Fairmount/U of O Special Area Study Policies. These proposed changes primarily revert to the original <br />language in the current Refinement Plan and are reflected in [Exhibit A Code Amendments]. <br /> <br />F. Refinement Plan Amendments <br /> <br />In testimony submitted on January 27, 2026, FNA proposes changes to the Refinement Plan <br />Amendments. In total, FNA proposes 22 text changes to the applicant’s proposed Refinement Plan <br />Amendments, which were submitted to the City on July 23, 2026. The applicant has reviewed these