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Home My WebLink AboutComments DLCD 3/12/2007 Dregon TI1Lodore R Kulongoskl, Governor Department of Land ConservatIon and Development 1140 WlllaglllespIe Rd ,Ste 13 Eugene, OR 97401-6727 (541) 686-7807 Fax (541) 686-7808 wwwled state or us March 12,2007 Mr Gary Karp City of Spnngfield 225 Fifth Street Sprmgfield, Oregon 97444 ~. .. . . , RE Eugene/Sonngfield PAPA 001-07 Plan diagram amendment and PAPA 003-07 Sonngfield zone change) for 56 acres Dear Gary, Please submit thiS letter mto the record ofthc proposed Metro Plan Amendment and zone change requested for the "Villages at Marcola Meadows" development In addition, the department supports the recommendatIOns to address Goal 12 and the transportatJon planmng rule (TPR) proVided to the city by the Ed W Moore, ODOT on March 9, 2007 and enclosed We would only request an additional conditIOn of approval to be m complIance With Goal 12 that the commercial development proVide connectivity With the eXlstmg, as well as new reSidential development We have read the applIcation and while there appears to be compellmg reasons to redeSignate the property to Commercial, the eVidence to date does not adequately balance nor answer the mam question of contmual shlftmg of one plan deSignation and resultant zone category that IS m low supply to another and vice versa We certamly advocate the contmued efforts by the city to proVide the type of analYSIS of current mventones that could then be adopted for use as the factual mformatlon for deCISIOn makmg and should better address the city's employment lands needs We do see thiS proposal as potentially vulnerable for appeal however and, hke you, not sure on how to resolve thiS pomt In time for the everyday actIOns of the city of Sprmgfield These are Imtlal areas of concern that we are wlllmg to work With the city to scc If they can be resolved to assist m makmg a deCISIOn on thiS plan amendment Please do call me to diSCUSS the attached Issues Smcerely, ~~~~~,!~-k S Wtllamette Valley Regional Representative Enclosure Cc File Ed W Moore, ODOT @ j' PAPA 001-07 Oregon Department of Land ConservatIOn and Development March 12,2007 1. Key Issue Sprmgfield IS low on Campus IndustrIal land, yet the applIcant proposes convertmg a large percentage of Its short-term supply to commercIal and reSIdentIal uses meetmg a need under those zomng categorIes. There are two ways to reach complIance WIth Goal 9: a quantItatIve analYSIS of the supply of needed sItes m a land use category, or a qualItatIve analYSIS of the partIcular sIte as to ItS SUItabIlIty for the zoned use, 2. The applIcant does not supply the cumulatIve actIons to meet CommerCIal needs that have been occurrmg smce the 2002 Commercial study, The applIcant provIdes analYSIS from a data base that has not been adopted for land use purposes nor has It been coord mated WIth the state of Oregon, The state does not know nor has It been provIded an opportumty to dIscuss the assumptIOns m the data base. 3 The applIcant provIdes general comments of a qualItatIve nature regardmg the sIte mcludmg the eXIstence of power lInes and an IrrIgatIon dItch, and the sIte's proxImIty to reSIdentIal and the Kmgsford plant. However, no analYSIS or reasonable conclUSIOns to JustIfy redeslgnatIon are prOVIded. 4, PotentIal problem areas that need better or addItIOnal dIscussIOn, a The subject site IS mcluded m the 2006 update of the MetropolItan IndustrIal Lands Inventory Report as one of the development-ready SItes for short-term mdustrIal use It has been reserved as a development-ready mdustrIal site smce 1995 So far the applIcatIOn doesn't reconCile the borrowmg from one plan element to assist WIth another b Metro Plan's Economic Element PolIcy BI2 discourages plan amendments that change development-ready mdustrIal sites to non- mdustrIal deSignatIOns The proposal IS not consistent With OAR 660- 009-0010(4) because It IS not consistent With the cIty's own mdustrIal conversIOn polICies The applIcant does prOVide other counterbalancmg polICies but doesn't proVide the diSCUSSIOn of how to weight the balancmg c Accordmg to the applIcatIOn, at least 155 acres of mdustrIalland m SprIngfield have already been converted to reSidentIal or commerCIal use Is thIS a large percentage of the remammg mventory or not? Should make a difference to deCISion makers and could mform a way to balance as suggested m "b" above 2 I' PAPA 001-07 Oregon Department of Land ConservatIon and Development March 12, 2007 d Accordmg to the applIcatIOn, both short-term and long-term supplIes of Campus lndustnal (Cl) land are cntIcally madequate, and thIS applIcatIOn proposes convertmg 29% of that cntIcally madequate supply to commercial use e Accordmg to the applIcatIOn, Spnngfield's supply of CI land WIll be depleted by 2015 f The fact that thiS sIte has not yet developed With any CI uses does not JustIfy convertmg It to a regIOnal commercIal retaIl use and reducmg the city's dwmdlIng CI land supply even further - CI code was Just revIsed 2 years ago to potentIally assIst m sltmg Issues - we acknowledge that applIcant does have market expert, Lane METRO dIscuss VIabilIty of site as better for commercIal, but then how to balance It agamst loss of CI mventory? g The cIty may not utIlIze for land use decIsIOn makmg but can consIder the draft Jasper Natron SpecIfic Development Plan desIgnatIOns m determmmg whether thiS applIcatIOn WIll negatively affect the Clland supply The city may only use plans and plan polICies that It has adopted h The 1999 Eugene Spnngfield Lands Study shows a surplus of all types of reSidentIal land If thIS IS stIll true m 2007, then the cIty may not convert Cl land, whIch IS m short supply, to a reSIdentIal use (Part of the proposal IS to mcrease the amount ofMDR land on the sIte) The applIcant doesn't dISCUSS mformatlOn from the city's mOllltormg program Is the mformatlOn aVaIlable from the cIty for the applIcant to use? 5 There IS no dISCUSSIOn of why a regIOnal large retaIl store (e g , a home Improvement center) IS an appropnate use m a MetroPlan Nodal Development Area (#7C) Several large retaIl stores, mcludmg another local large Home Improvement Center eXist m close proxImIty to the sIte They all functIOn as regIOnal retaIl proVIders TypIcally commerCIal uses at a smaller-scale local or neIghborhood commerCIal grocery store, bank are utIlIzed for nodal developments That IS not to say that a larger retaIl store couldn't serve that purpose but what role It WIll play m servmg a nodal development (to take tnps off of the transportatIOn system), and proVIde connectlVlty to dense reSidentIal development should be dIscussed 6 A large retaIl store such as a home Improvement center IS not, as descnbed m the applIcatIOn, a "supportIve transItIon m scale and mtenslty between reSIdentIal 3 ';) . PAPA 001-07 Oregon Department of Land CouservatlOn and Development I I March 12,2007 I neighborhoods and larger commercial uses" On the contrary, a home Improvement center IS the type of larger regIOnal commerCial use ,that IS mcompatJble with a reSidential neighborhood In the context of this site, It very well may be a tranSitIOn between middle and high denSity reSidential and other heavy mdustnal uses Perhaps worth dlscussmg 7 Mixed-use development IS a deSIred type of development for a deSignated node, but this proposal IS tradltJonal development usmg the catch words of mixed-use The different uses (commercial, reSidential, office) are segregated mto different areas ("Villages") over a very large (I OO-acre) area True mixed-use combmes uses wlthm bmldmgs (vertical mixed-use), or at least locates bmldmgs With different uses next to each other (honzontal mixed-use) A large regIOnal one- story retail store like a home Improvement center IS generally not conSidered mixed-use or part of mixed-use, unless the bmldmg has upper floors of housmg umts 8 Because they have not been adopted mto the city's comp plan, the September 2006 ECONorthwest Lane County CommerCial and Industnal Land Supply Report and the economic growth predlctJons for the South Wlllamette Valley may not be used for thiS PAPA or other plannmg purposes "Endorsement" IS not suffiCIent, the city must adopt by ordmance Without the reqmred coordmated analYSIS the raw data base does not comply With Goal 9 Economic Development 9 The proposal should state when the city adopted the 200 I Eugene-Spnngfield Metro Area Public FaCllitJes and ServICes Plan, on which It relies 10 The proposal does not appear to comply With the Goal 2 coordmatlOn reqmrement There should be adequate findmgs regardmg coordmatlOn With the City of Eugene because of the regIOnal nature of the MetroPlan and the UGB a Spnngfield should also coordmate With Eugene on thiS proposal because the Metropolitan Industnal Lands Inventory Report doesn't segregate out a speCific land need for the City of Spnngfield 11 We do agree that the 1999 Eugene Spnngfield Lands Study may be too old to be useful, but untJl more contemporary work IS completed the applicant must do comparatJve analYSIS 4