<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 /> 6 <br /> <br />have changed the term “Low Density Residential” to “Residential” in eight instances. In response, the <br />applicant has updated the text of the proposed Code Amendments (Exhibit A) and Plan Amendments <br />(Exhibit B) to eliminate this change and revert to the “Low Density Residential” term (see applicant’s <br />First Open Record Submission dated January 27, 2026). <br /> <br />That said, we understand that FNA is concerned about upzoning from R-1 to higher-density zones, and <br />that this change, if enacted, would affect the FSAS land use designation. The applicant contends that a <br />terminology change does not affect the underlying designation or its purpose. The Metro Plan includes <br />numerous land use designation categories. “Low Density Residential” is a division of the “Residential” <br />category. As previously noted, regardless of the terminology change, the proposal does not change the <br />base zone designation of Low Density Residential. The R-1 Low Density Residential zone implements <br />the comprehensive plan (Metro Plan) by providing for low-density residential uses. The FSAS “Land <br />Use Diagram Text” for the “Low Density Residential” plan area states that “[t]his area is to remain in low <br />density residential use * * * .” This text is unchanged by the proposal. <br /> <br />The City’s Zone Change Approval Criteria at EC 9.8865 require consistency with applicable provisions <br />of the Metro Plan and with applicable adopted refinement plans, among other criteria. Based on that <br />fact, a proposed zone change from R-1 Low-Density Residential to R-2 Medium-Density Residential or <br />R-3 Limited High-Density Residential within the boundaries of the FSAS would appear to require a <br />concurrent Plan Amendment to change the FSAS plan designation to “High Density Residential” or to <br />change the “Land Use Diagram Text” for the “Low Density Residential” plan area in the FSAS to allow <br />residential uses other than low density. We note that the FSAS Land Use Diagram does not include a <br />“Medium Density Residential” plan area, only “High Density Residential” and “Limited Institutional” <br />(formerly “Limited High Density Residential/Limited Institutional”). <br /> <br />This is to state that the applicant recognizes FNA’s concerns regarding the potential for upzoning, has <br />crafted the proposal so as not to enable upzoning without addressing the FSAS text, and has gone <br />further to revert all changes to the Low Density Residential title and text to their original enactment. <br /> <br />C. Transportation <br /> <br />The Highway Capacity Manual (HCM) explicitly addresses designing for infrequent events and unusual <br />surges. For example, page 3-11 of the HCM includes the following sentence: “Selection of an analysis <br />hour usually implies that a small portion of the demand during a year will not be adequately served.” <br /> <br />FNA cites text from HCM Chapter 15, which addresses limitations of the methodology. Chapter 15 <br />focuses on the analysis methodology for two-lane rural highways; the cited methodology was not <br />developed for a facility like Agate Street and would be inappropriate to apply. The HCM contains <br />distinct analysis methodologies for the many types of intersections and transportation facilities. The <br />TPR analysis applied the appropriate methodologies from the HCM to evaluate the signalized <br />intersections (Chapter 19), two-way stop-controlled intersections (Chapter 20), and all-way stop- <br />controlled intersections (Chapter 21) along Agate Street. <br /> <br />FNA also cites text from HCM Chapter 17, which warns that serious problems can occur when “peak