<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 /> 3 <br /> <br />internal plans and policies (East Campus Area Plan, Campus Plan) to meet the need for new housing. <br />Additionally, these plans show that all remaining viable development sites for residence halls are within <br />the Limited Institutional area. The plans emphasize the importance of reserving the remaining land <br />within the central academic core for future academic instructional uses. <br /> <br />University academic instructional uses are typically more intensive than residence halls because they <br />serve a broader population and support a wider range of daily activities. Academic instructional facilities <br />accommodate large volumes of students, faculty, staff, and visitors moving through classrooms, labs, <br />lecture halls, offices, and shared learning environments. Their schedules may span from early morning <br />to late evening, with high turnover and peak-hour surges tied to class periods. Conversely, residence <br />halls function primarily as living spaces for a defined population, have predictable patterns of use, and <br />significantly lower hourly occupancy turnover. The operational demand, circulation loads, and service <br />needs of academic instructional uses, therefore, create a much higher level of use intensity than in <br />student housing and residence halls. Examples of existing academic instruction uses within or near the <br />East Campus Area include William W. Knight Law Center, Straub Hall, and Erb Memorial Union. <br /> <br />The Limited Institutional plan area within the larger East Campus Area is well-suited for residence halls <br />because it is proximate to academic buildings, support services, athletic and recreational facilities, and <br />open spaces; served by public transit and pedestrian infrastructure; and close to commercial activity <br />along Franklin Boulevard, 19th Street, and Agate Street. <br /> <br />Clear and Objective Standards for Housing <br />Oregon Revised Statutes (ORS) 197A.400 provides that local governments may only adopt and apply <br />only clear and objective standards, conditions, and procedures regulating the development of housing, <br />including needed housing. ORS 197A.018 defines “needed housing” as including “housing for college <br />or university students, if relevant to the region.” In their January 27, 2026, Memorandum, City planning <br />staff notes that “residence halls are housing and therefore are subject to clear and objective standards, <br />as required by state law.” More explicitly, ORS 197A.400(1)(b) states that the adopted standards, <br />conditions, and procedures “[m]ay not have the effect, either themselves or cumulatively, of <br />discouraging needed housing through unreasonable cost and delay” (emphasis added). <br /> <br />FNA proposes new code amendments that would require Conditional Use Permit approval for <br />residence halls in the LI area and Site Review approval for all new developments in the LI area. FNA <br />asserts compliance with EC 9.8424(1) as justification for Conditional Use Permit approval and “a <br />regulatory process that requires assessment and mitigation of impacts on the surrounding <br />neighborhood” as justification for Site Review approval. <br /> <br />Cumulatively, FNA’s proposal would subject residence halls to two new land use approval processes <br />(Conditional Use Permit and Site Review) and all other developments to one new land use approval <br />process (Site Review). Conditional Use Permit applications are reviewed under Type III procedures, <br />with the Hearings Official rendering a decision. Site Review applications are reviewed under Type II <br />procedures, with the Planning Director rendering a decision. Both types of applications are appealable, <br />with the Planning Commission serving as the review authority for Conditional Use Permit applications <br />and a Hearings Official serving as the review authority for Site Review applications. In accordance with