Broadway Alley and Lincoln Street Property Page 7 of 7 <br />Adjustment Review Application SB 1537: Written Statement <br />March 27, 2026 <br /> <br />Schirmer Consulting, LLC · PO Box 10424, Eugene, OR 97440 · (541) 234-5108 <br />Landscape Architecture + Land Use Planning <br /> <br />(g) The application states how at least one of the following criteria apply: <br />(B) The adjustments will enable development of housing that reduces the sale or rental prices per <br />residential unit; <br />This is true for this project. <br /> <br />(3) . . . . . . <br /> <br />(4) A local government shall grant an adjustment to the following development standards: <br />(g) For manufactured dwelling parks, middle housing as defined in ORS 197A.420 (1)(c)(D), Multi- <br />family housing and mixed-use residential housing: <br /> <br />(A) Requirements for bicycle parking that establish: <br />(i) The minimum number of spaces for use by the residents of the project, provided the <br />application includes at least one-half space per residential unit. <br />There are 20 dwelling units proposed and 16 bicycle spaces proposed. One-half space per <br />unit would be 10 bicycle parking spaces minimum. 16 bicycle parking spaces meet this <br />minimum. <br /> <br />III. Justification for the Ministerial Review Process. <br />The statute allows the City to follow a ministerial process where appropriate: <br />Oregon Laws 2024, Ch. 110, Sec. 45(6): <br />(6) A city shall apply the procedures in this section, and only the procedures in this section, to a limited land use <br />decision, even if the city has not incorporated limited land use decisions into land use regulations, as <br />required by ORS 197.646 (3), except that a limited land use decision that is made under land use standards <br />that do not require interpretation or the exercise of policy or legal judgment may be made by city staff using <br />a ministerial process. <br /> <br />The language above affords the City discretion to use a ministerial review process to review adjustment <br />requests that “do not require interpretation or the exercise of policy or legal judgment.” The applicant <br />believes this is such a situation: <br />· The minimum bicycle parking requirement is numerical; the allowed adjustment is numerical; the <br />requested adjustment is within the numerical parameters allowed by the statute. <br />· The requested adjustment is less than allowed by the statute. <br /> <br />Section 38 – Eligible Development and Design Standards: Required Eligible Adjustment Amount states <br />‘Must be eligible for full adjustment’ so this adjustment does not require interpretation by staff or the exercise <br />of policy or legal judgement. <br /> <br />The applicant requests a ministerial process for review of this request. This application is being submitted in <br />response to plan review check comments on building height. <br /> <br />Thank you! <br /> <br />Sincerely, <br />Schirmer Consulting, LLC <br /> <br /> <br /> <br />Carol Schirmer <br />Principal