To: Hearings Official Ken Helm <br />From: Ross Williamson <br />Re: PDT 15-001, Post-Hearing Submission <br />Date: November 10, 2015 <br />Following are comments directed at four PUD criteria. I also offer a comment on the <br />adjustment application. <br />EC 9.8325(1) <br />"The applicant has demonstrated that the proposed housing is needed housing as defined by <br />State statutes." <br />I understand this PUD application is neither the time nor place to make arguments about the <br />City's housing inventory and whether it complies with the needed housing statute. The <br />argument I raise is whether the applicant meets the first criterion for a PUD approval under the <br />needed housing track. That criterion is in obligation upon the applicant, one that the applicant <br />has the burden of satisfying. Whether or not the City's housing inventory is acknowledged is <br />not at issue. In fact, the criterion makes no mention of the City's housing inventory. The issue <br />is whether the applicant has demonstrated that the proposing housing "is needed housing as <br />defined by State statutes." EC 9.8325(1). <br />Applicant does not identify the price range or rent level for the proposed houses. Were <br />applicant to identify those characteristics of the proposed development, applicant would then <br />need to show that those categories of single family dwellings are identified by the City of <br />Eugene as "needed." Applicant does not meet either requirement. <br />ORS 197.303 defines "needed housing" as "housing types determined to meet the need shown <br />for housing within an urban growth boundary at particular price ranges and rent levels...." ORS <br />197.303(1) (emphasis added). <br />ORS 197.307(4) then provides that criteria applied to needed housing applications must be <br />clear and objective. However, for providing context for the definition of "needed housing", the <br />first three subsections of ORS 197.307 also provide clear guidance. <br />ORS 197.307 provides, in part: <br />"(1) The availability of affordable, decent, safe and sanitary housing <br />opportunities for persons of lower, middle and fixed income, including housing <br />for farmworkers, is a matter of statewide concern. <br />"(2) Many persons of lower, middle and fixed income depend on government <br />assisted housing as a source of affordable, decent, safe and sanitary housing. <br />"(3) When a need has been shown for housing within an urban growth boundary <br />at particular price ranges and rent levels, needed housing shall be permitted in <br />one or more zoning districts or in zones described by some comprehensive plans <br />