<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 /> 5 <br /> <br />1051 (2017) requires local governments to remove discretionary, subjective criteria from housing <br />development review unless they also offer a clear and objective parallel path. The City has <br />implemented these regulations by adopting clear and objective criteria and approval processes. <br />Implementing FNA’s suggested changes would require significant undoing of adopted community <br />policies, standards, conditions, and procedures, which is not supported by the proposal. <br /> <br />Special Development Standards <br />FNA suggests that special development standards should apply to all development in the LI plan area <br />and proposes amending the code to implement these standards, including minimum landscape <br />standards; stepped building height setbacks on the south and east edges; additional setbacks and <br />stepped building height setbacks adjacent to LDR property; and traffic circulation and mitigation plans. <br />FNA does not quantify these measures or suggest how they could be applied as clear and objective <br />standards and approval criteria. Many of these standards already exist in code and apply to <br />developments in the PL zone and the /EC overlay zone. <br /> <br />EC 9.2685 requires a minimum front yard setback of 10 feet. The applicant proposed to amend /EC <br />9.4420(2) to limit building height to 85 feet and to 45 feet within 75 feet of Low Density Residential <br />property. The Landscape Standards at EC 9.6200 through EC 9.6255 apply to all developments. <br />Additionally, the Multiple-Unit Standards at EC 9.5500 apply to all multiple-unit development and <br />include building setbacks, building orientation and entrances, building mass and façade, building <br />articulation, landscaping, and open space requirements. Regarding stepped building heights, the <br />applicant found that stepbacks can “reduce building efficiency, reduce potential housing capacity on a <br />site, and require additional vehicle circulation (elevator and stairs) per unit built, which raises per-unit <br />costs” (see applicant’s Final Open Record Submission to Planning Commission dated November 11, <br />2025). Regarding traffic impact and mitigation, developments in the PL zone are subject to a Traffic <br />Impact Analysis review if any of the conditions in EC 9.8670 are met, which, depending on the analysis <br />results, may result in requirements for improvements or mitigation imposed on the development. <br /> <br />In summary, the applicant finds the introduction of another set of special development standards <br />redundant and unnecessary, necessitating code and refinement plan amendments that are outside the <br />scope of the proposal and unsupported by the findings. <br /> <br />B. Terminology <br /> <br />The initial proposal included changes to two titles and labels (terminology) in the FSAS and on the <br />plan’s Lane Use Diagram (Map 6: Generalized Future Land Use Patterns) to improve clarity and ease <br />of reference. The term “Limited High Density Residential/Limited Institutional” was changed to “Limited <br />Institutional,” and “Low Density Residential” was changed to “Residential.” In addition, the initial <br />proposal amended the “Land Use Diagram Text” of Subsection II (“Land Use”) of the FSAS under these <br />two titles to update the text to be consistent with the East Campus Area Plan. <br /> <br />In prior testimony, FNA expressed concerns about the implications of the proposed change from “Low <br />Density Residential” to “Residential.” To address these concerns, the applicant agreed to retain the <br />existing “Low Density Residential” terminology in the Code and Refinement Plan. The proposal would