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HomeMy WebLinkAboutCorrespondence APPLICANT 3/26/2007 ~ .. SATRE A~S.OClATf ~, Satre Associates, P C 132 East Broadway SUite 536 Eugene, Oregon 9740 I Phone 541465 4721 Fax 5414654722 I 800 662 7094 wwwsatrepccom March 26, 2007 City ofSpnngfie1d Development Services 225 Fifth Street Spnngfield, Oregon 97477 ~~ @~ ~ \TI ~~ MAR 2 6 0 7 ~ ~ J ~o'~~l By l- ,w3--'.-:- Attn Gary Karp, Planner Re The Villages at Marco1a Meadows City Files LRP 2006-00027 and ZON 2006-00054 Dear Gary, Please accept the enclosed document for the record as the applicant's response to the list of concerns received from DLCD m theu March 12, 2007, letter addressed to the CIty of Spnngfield We appreciate DLCD's review or our applical10n and tlus opporturuty to reply Please contact us should you l.ave any questIOns or requue any addll10nal mformal1on m tlus regard Smcerely, 'R~d-M S~YlV Richard M Satre, AICP, ASLA, CSI Encl Responses to March 12 DLCD List of Concerns Planners, Landscape Archl1ects and EnVironmental Speclallsts ..... - SATRE ASSOCIATES SATRE ASSOCIATES, P.C. Planners, Landscape Architects and Environmental SpecialIsts 132 East Broadway, SUite 536, Eugene, Oregon 97401 (541) 465-4721 . Fax (541) 465-4722 . 1-800-662-7094 www satrepc com ~~@~ow~~ lli MAR 26 07_ J March 26, 2007 By THE VILLAGES AT MARCOLA MEADOWS METROPOLITAN PLAN AMENDMENT LRP 2006-00027 ZONE CHANGE ZON 2006-00054 RESPONSES TO MARCH 12, 2007 DLCD LIST OF CONCERNS Marguente Nabeta, AICP, South WIllamette Valley RegIOnal Representative of the Department of Land ConservatIOn and Development, sent a letter and an attached list of concerns dated March 12,2007 to Gary M Karp, Planner for the City of Spnngfield Development Services Department Commumty P1anrung DIVISIon, the staff planner assIgned to these applications Mr Karp forwarded Ms N abeta' s letter to us for responses Our responses are given below QUALITATIVE ANALYSIS DLCD Comments 1, and 3 Item # 1 pomts out that Goal 9 compliance may be addressed With both quantitative and qualitative analyses Item #3 acknowledges qualitative comments, but alleges that no analYSIS or reasonable conclUSIOns are proVided to Justify redesIgnatlOn In the applicant's reVIsed Goal 9 findmgs of March 17,2007, a qualitative analYSIS IS presented m tbe sectIOns titled "Site SpeCific Issues," "Competmg Sites," and "Companng Wages" on pages 6 tbrough 10 of 12 pages Additional mformation regardmg the qualities of the site affectmg ItS sUltabtlity for development under ItS current deSignation IS presented m the P1anrung ComrmsslOn Staff Report for March 27, 2007, m the "Executive Summary," and on pages 1-34 tbrough 1-37 In these two documents, there IS extensive matenal regardmg the Instory, context, conditions, and marketability of the subJect site The SUItability of the site IS analyzed m the context of changmg market forces and m companson to the progress of development m the Gateway Campus Industnal Dlstnct, locatIOn of the maJonty ofSpnngfie1d's The Villages at Marcola Meadows - Re.ponses to DLCD Concerns March 26, 2007 page I of6 shovel-ready CI land These discussIOns demonstrate the mfenonty of the subject site compared to the rest of the CI mventory, and also pomt out the pressure for Commercial development on more SUitable sites A reasonable conclusIOn IS made that redeslgnatmg the subject slte will ease commerCial development pressures on tf ~Q,' r! m"P.I't",;, wlnle sacnficmg a site that m 23 years has shown no potential fOl ~WHt~~ r"j) l CI designatIOn ni II' JU MAR 2 6 01 j , ACKNOWLEDGED INVENTORIES DLCD Comment s 2, 4 c, e, 8, 11 By Item #2 askS about "cumulative actIOns smce the 2002 [SIC] CommerCial study" and questIOns the use of figures from the 2006 Industnal-Commercwl BUildable Lands Study (CIBL) Item #4 c refers to a figure m the applicant's February 28, 2007 responses to Goal 9 denved from older mventones Items #4 d and 4 e refer to figures m the same February 28, 2007 document tbat were based on the CIBL study Items #8 and #11 further questIOn studies used m the prevIOus verSIOn of the applicatIOn The applicant's March 17, 2007 document reVised prevIOus Goal 9 responses to rely only on mventones and studies that have been coordmated With the DLCD These mclude the most recent acknowledged mventocj, the 2005 Spnngfield Natural Resource Study Report, which updated Industnal and ReSidenTIal mventones m the Metropolitan UGB and the Commercial mventory m the Spnngfield UGB Tins document was acknowledged by the DLCD m December 2006 CONSISTENCY WITH THE METRO PLAN DLCD Comment 4 b Item #4 b alleges tbat the proposal IS not consistent With OAR 660-009-0010(4) because It IS not consistent With the City'S mdustnal converSIOn poliCies In fact, the applicant's responses, reVised responses, and tbe Plannmg ComrrusslOn Staff Report discuss tins Issue at length and present substanTIve arguments demonstratmg compliance With comprehensive plan poliCies As discussed begmrung on page 4 of the March 17, 2007 reVised Goal 9 responses, and begmrung on page 1-60 of the P1anrung ComrrusslOn Staff Report, there IS no requrrement to meet every policy perfectly and completely and WithOUt contradiCTIOn The Metro Plan acknowledges tins fact and address conflicts and mconslstencles between and among goals and poliCies Although the proposal IS mconslstent With Economic Policy B 12, It IS consistent With Econorrllc Policy B 6 and other econOrrllC poliCies m the Metro Plan and the Spnngfield CommercIal Lands Study Item #4 b also calls for "a diSCUSSion of how to weight the ba1ancmg" The reVised Goal 9 responses and the diSCUSSion m the "Inventory EqUllibnum" seCTIon of tins document The Vlll.ges .1 Marcol. Meadows - Responses to DLCD Concerns March 26, 2007 page20f6 , , , , " l' present methods of correlatmg the relevant mventones and detenrumng a reasonable balance between them -- ~~@~D\'fl~] ill MAR 2 6 01 NODAL DEVELOPMENT DLCD Comments 5, 6, 7 By Items #5, 6, and 7 all queslion the mcluslOn of a home Improvement center 11 me prehmmary plan for the proJect Item #5 states that there IS no diSCUSSIOn of why a home rmprovement center IS appropnate maN odal Development Area In fact, tlus apphcatlon does not seek to apply the Nodal Development Area deSignation to the land on wluch the home Improvement store Will be proposed by the Master Plan apphcatlOn Potenlial Node 7C IS not an offiCial node The proposed PAPA would create an offiCial node on 80 acres of MedIUm DenSity Resldenlial and Commercial land that do not mc1ude the pOSSible Site of the home Improvement center As proposed by the applicant, a home Improvement center affiliated With the proposed Nodal Development Area Will augment the neighborhood retail traffic of the stores wltlun the Nodal Development deSignatIOn, thereby mcreasmg their chances for commercial success Item #6 disputes the transllional1ayout, scale, and deSign of the prelml1nary plan that accomparues thiS apphcalion It states that a home Improvement center IS mccmpalib1e With a resldenlia1 neighborhood However, the pre1munary plan separates the home Improvement center from the proposed MedIUm DenSity ReSidential development by means of an extensively landscaped area for wetland ffi1ligatlOn and open space Direct views of the home rmprovement center Will be screened from the resldenlia1 sectIOn by heavily planted berms agamst an 8- foot retammg wall Velucular and pedestnan paths from new and eXiling resldenlial areas to the home Improvement center will first pass through neighborhood commercIal areas The home Improvement center Itself Will be deSigned to resemble a senes of smaller retail spaces, slffi1lar m scale to the others, rather than a smgle monolithic fayade The proposed commercial areas Will be a very effecl1ve transition between the new and eXlstmg resldenlial areas to the west and north, and the eXlstmg heavy mdustna1 uses to the southeast Item #7 reiterates the earlier challenge to a home Improvement center ill a nuxed-use proJect, but agam, the center IS not a part of the areas deSignated for Nodal Development or Mixed-use The comment also espouses a versIOn of what "true In1Xed-use" IS, that It must be vertically mtegrated or at least honzontally mtegrated to some undefined standard However, the Spnngfield Development Code has no such standards for Mixed- Use Zorung and Nodal Development Overlays The prehmmary plan has been prepared to meet or exceed all of the requirements of the adopted Nodal and Mixed-Use regulatIOns ~ The VIllages at Marcola Meadows - Responses to DLCD Concerns March 26, 2007 page 3 of6 /D)~ @ ~ D \Yl ~--'JI till MAR 2 6 D 1 ~ INVENTORY EQUILIBRIUM DLCD COJ1:!IT1ents 4 a, b, d, f, h Items #4 a, b, d, f, and h all request further dJscusslOn, analysIs and ral10nale for sluftmg land m the CI mventory to other deslgnal10ns By The apphcant's March 17, 2007 document revised prevIous Goal 9 responses to address these comments The analYSIS and ratlOnale for the proposed shifts of mventory are discussed further below The three sectors of the economy represented by the three pnnclp1e land mventones (resldenl1al, commercial, and mdustnal) are economically mterdependent and eqUlhbnum between the mventones IS essenl1a! to economic health To put It simply, people need places to work, shop, and live Growth m one sector of the economy Will spur growth m the other two If the mventory of land for one sector, mdustry for mstance, IS especially large compared to the others, that mventory may be elastic and affordable and therefore contnbute to, or at least facilitate, an expansIOn of that sector However, small or non- eXistent mventones ofland for the other sectors create very melastlc supply curves As expansIOn of the mdustnal sector creates an upward sluft of the resldenl1a1 and commercial land demand curves, the me1asl1clty of supply Will dnve up pnces rapidly Because the sectors are mterdependent, nsmg pnces ofland for the other sectors will squelch the expansIOn of the mdustnal sector, despite ItS apparently adequate land supply Tlus cause - effect sequence doesn't have to be played out step by step for the mechamsm to work Industnes consldenng expansIOn Will study the overall land market and anl1clpate these problems Unless these market forces are understood by policy makers, the lack of growth m a sector well supplied With land Will have no apparent cause Conversely, If the mventones for all three pnnclple sectors are suffiCient and balanced, expanSIOn of one sector Will spur orderly and proportIOned growth m the otbers Therefore It IS essenl1al for the health of the economy to mamtam eqUlhbnurn between the mventones Tlus nuses the questIOn of how to deternune when the mventones are out of eqUlhbnurn and how to restore It In tlus parl1cu1ar mstance, commercial mventones are proJected to be completely depleted by the end of the planrung penod That fact alone IS enough to Jusl1fy sluftmg land from an mventory where there IS a so-called "surplus" The questIOn remams how should we compare, and If needed, reapportIOn two mventones (mdustnal and resldenl1a1) when pOSll1ve balances of each are proJected for the end of the planrung penod The method presented on pages 11 and 12 of the March 17th reVised Goal 9 findmgs uses data from the U S Census Bureau and gUlde1mes from the Oregon Department of Land ConservatlOn and Development to establish a correlatIOn between the mventones of mdustnal and resldenl1a11and Bnefly, the method estlIDates the denSity of full-tlIDe employees livmg on resldenl1a1land and Job density on mdustna1land Employee denSIty IS denved from U S Census data on mdlvldual and household mcome, and The V,llages at Marcola Meadows - Responses to DLCD Concerns March 26, 2007 page 4 of6 Metro Plan target dwellmg densIties opporturuty ana1ysls guJde1mes 'il):~DIT1!AUJ "I ;'~~ M~IR .6 0 '1 Job density IS based on DLCD econ01lliC .' J Tlus method of analysIs establishes a clear and ratIOnal Justification for reapportlomng land as proposed by the applicatIOn Shlftmg land from one mventory to another to aclueve eqUllibnum between the mventones IS sound econ01lliC and land planrung practice that Will faCilitate and stabilize econ01lliC growth and the effiCient use ofland DLCD COMMENT #9 Item #9 asks when the Eugene-Springfield Metropolrtan Area Publrc FacllrtlCs and Services Plan, 2001 was adopted by the City Spnngfield approved Ordmance No 5992 November 5, 2001 adopting the Eugene-Springfield Metropolrtan Area Publrc Facllrtles and Services Plan 'as a refmement plan of the Metl 0 Plan DLCD COMMENT # 10 Item #10 questIOns whether Goa12 requirements for coordmatlOn With other JunsdictlOns have been met Referral of .he proposed Metro Plan diagram amendment was sent to the City of Eugene and Lane County on March 16, 2007 The applicant's findmgs and the Planrung ComnusslOn Staff Report for March 27, 2007 mclude diSCUSSIOns demonstratmg comphance wlth Goal 2 In addition to those comments, the followmg IS offered regardmg coordmatlOn Wlth other Junsdlctlons The Eugene/Spnngfield Metropohtan Area General Plan (Metro Plan) proVides pohcy regardmg coordmatlon With JunsdlctlOnal partners wltlun the metropolitan area m review and declSlon-makmg on proposed amendments to the Metro Plan SpeCifically, Metro Plan pohcles are contamed m the Metro Plan document's Chapter IV Me/ro Plan ReView, Amendments, and Refinements Wltlun Said chapter, Pohey 3 stipulates that Metro Plan amendments shall be claSSified as a Type I or Type II amendment Policy 3 a states "A Type I amendment shall mclude any change to the U1 ban growth boundary (UGB) or the Metro Plan Boundary (Plan Boundary) of the Metro Plan, any change that reqUIres a goal exceptIOn to be taken under Statewide Planning Goal 2 that IS not related to the UGB expansIOn, and any amendment to the Metro Plan text that IS non- site specific " Policy 3 b states "A Type II amendment shall Include any change to the Metro Plan DlagJ am or Metro Plan text that IS site specific and not otherwIse a Type I category amendment " The VIllages at Marcola Meadows - Responses 10 DLCD Concerns March 26, 2007 page 5 of6 ,-- ,i , , Policy 5 sets forth the condlhons under wluch the govemmg bodies of the three metropolitan JunsdlCtlOllS participate m the approval process for Metro Plan amendments Policy 5 estates "DeCISIOns on all Type II amendments wlthm City lzmlfs shall be the sole responslbzllty of the home City " Tlus proposed amendment . Includes site-specific changes to the Metro Plan Diagram . Does not mclude any change to the UGB or the Metro Plan Boundary . Does not reqUIre a goal exceptIOn to be taken under Statewide Planlllng Goal 2 that IS not related to the UGB expanSIOn, and . Does not mclude any non-site speCific amendment to the Metro Plan text Therefore, tlus proposed amendment must be clasSified as a Type II amendment The speCific site for wluch the amendment IS proposed IS located wholly wltlun the Spnngfie1d City 1111UtS, as demonstrated by the Spnngfie1d Zomng Map Given these CITcumstances and the Cited Met' 0 Plan poliCies, the City of Spnngfie1d 1S the home City and has sole responsibility for the deCISIOn on tlus amendment The City IS responsible for provldmg nohce to all affected governmental uruts, wluch It has done The City IS also responsible for respondmg m ItS fmdmgs to the 1egitunate concerns or affected governmental UllltS At tlus hme, the public record has not closed and there remam opportumhes for comments and City to responses Therefore, to the degree that a determmatlOn can be made at Ius hme, and With regard to coordmatlOn, the proposal IS consistent With Goal 2 '~~@[OW~], J1J MAR 26 07 } By_ The VIllages at Marcola Meadows - Responses to DLCD Concerns March 26, 2007 page 6 of6