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<br />the economy. Oregon Administrative Rule 660-009-000 et seq. (Division 9) establishes the <br />applicability of Goal 9 nIles. OAR 660-009-0010(4) states: <br /> <br />for a post-acknOlvledgement plan amendment under OAR chapter 660, division 18, that <br />changes the plan designation of land in excess of two acres within an existing urban <br />growth boundary from an industrial use designation to a non-industrial use designation, <br />or an other employment use designation to any other use designation, a city or county <br />must adJ,ress all applicable planning requirements... " <br /> <br />To comply with Goal 9 the Eugene City Council adopted the Eugene Commercial Lands Study <br />(ECLS) in May 1992, updated in October 1992. The ECLS was subsequently acknowledged by <br />LCDC as contonning to the Metro Plan and Goal 9 during periodic review in 1994. <br /> <br />OAR 660-009-0010(4) does not apply in this situation because the changes proposed by this <br />application will remove less than two acres from the supply of land designated for commercial <br />use. <br /> <br />Goal10 - Housing: To provide/c)r the housing need~ of citizens of the slate. <br /> <br />Response: <br />Goal 10 requires buildable lands for residential use to be inventoried and requires plans to <br />encourage the availability of adequate numbers of needed housing units at price ranges and rent <br />levels commensurate with the financial capabilities of Oregon households. Oregon <br />Administrative Rille 660, Division 8 defines standards for compliance \",ith Goal 10. OAR 660- <br />008-0010 requires that: <br /> <br />"Sufficient buildable land shall be designated on the comprehensive plan map to satisfY <br />housing needs by type and density range as determined in the housing needs projection. <br />The local buildable lands inventory must document the amount of buildable land in each <br />residential plan designation." <br /> <br />The comprehensive plan map for the City of Eugene is the Metro Plan Diagram. Approval of the <br />applicant's proposed amendments changing approximately 7.3 acres from Low Density <br />Residential to Commercial and 1.3 acres from Commercial to Medium Density Residential on <br />the Metro Plan Diagram requires compliance with statewide planning Goal 10; Housing (OAR <br />660, Division 8). (The change will have a net effect of adding 6.0 acres to the commercial <br />designation while removing 7.3 acres of Low Density Residential and adding 1.3 acres of <br />Medium Density Residential.) The Post Acknowledgement Plan Amendment (PAPA) is <br />consistent with the parts ofthe }...tetro Plan which address the requirements of Goal 10, as 'will be <br />shown below. Using Metro area average densities of developed properties the table below shows <br />that the proposed impact of the anlendments will be insignificant when considering a comparison <br />of the total number of likely dwelling units for the plan designation and! or zoning type. <br /> <br />Santa Clara - Zone Change Application <br />Written Statement-August 2, 2007 <br /> <br />Page 33 of41 <br />