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Home My WebLink AboutCorrespondence APPLICANT 5/29/2007 SAtRE ASSOClATES Satre Associates, P C ] 32 E~t BroadwdY SUite 536 rugene Oregon 97401 Phone 541 465 472] rax: 54] 4654722 I 800 662 7094 www satrepc com .. May 29, 2007 , ]' ~ @ ~ 0 III ~ '1'1 I MAY 292001 J-\t8'1"~ -' I ~V~,~ By , Mayor Sid Lelken City Council C/o Gary Karp, Planner 1Il City of SprIngfield 225 Fifth Street SprIngfield, Oregon 97477 Re The Villages at Marcola Meadows Metro Plan Amendment (LRP 2006-00027) Zone Change (ZON 2006-00054) Dear Mayor and Councilors, Please accept this letter for the record regarding the above CI~ files Goal 9, Adopted Plans and Fmdmgs I The adequacy of land inventOrIes must be demonstrated by adopted and acknowledged studies and plans HaVing provided adequate inventOrIes of each type of land meeting Goal 9 and Goal 1 0 needs, local authorIties should strIve to maintain these inventOrIes In an economically sustainable eqUIlibrIum Once adequacy IS established, a local JUrIsdictIOn may adjust those inventOrIes as long as an adequate supply IS maintained In deliberating such adjustments, the approving authorIty may consider additIOnal eVidence However, findings must be based solely on adopted and acknowledged studies and plans The SCLS IS an adopted economic opportunity analysIs acknowledged as meeting the reqUIrements of DIVISion 9 It IS the most recent analysIs even though It addresses Springfield only and was not Incorporated Into the most recent Metro Plan updatc PrIor to It, the most recent commercial land study was adopted In 1992, but that study dealt only with Eugene's portIOn of the metropolitan area The last metro- Wide commercial land economic opportunity analysIs Incorporated Into a Metro Plan update and regarding the SprIngfield portIOn of the metro area came sometime before 1987 Because the standard planning perIod for these studies IS 20 years, any conclusIOns drawn from this prevIOus study would be invalid I OAR 660-009-00 I 0(4)(a) reqUIres consistency with the most recent economic I opportunities analysIs and the comprehensive plan It antICipates the inevitable situatIOn when an economiC opportunities analysIs has been icompleted as a perIodic review task, but ItS recommendations and poliCies have not yet been Incorporated Into the comprehensive plan The most recent commercial Hmds study to be I Incorporated Into the Metro Plan focused only on the Eugene area of the UGB (the I 1992 Eugene study) Though many general economic goals, findings and poliCieS In the Metro Plan are currently relevant to Springfield, many df them have been superseded by those In the SCLS Planners, Landscape Archttects and EnVironmental Specialists CIty ofSpnngfield, Attn Mayor Lelken and CouncIlors The VIllages at Marcola Meadows Plan Amendment and Zone Change (CIty Flies LRP 2006,00027 and ZON 2006-00054) Mav 29_ 2007 ' Page 2 I I The Sprmgfield Natural Resources Study Report IS another document proVIdIng Informatton relevant to Goal 9 findIngs Adopted and acknowledged InVentory updates may be used as a basIs for approvIng a PAPA An Inventory that IS acknowledged to meet the reqUIrements of Goal 9 IS relevant to subsequent decIsIons even If that Inventory was conducted for a non-Goal 9 study The SNRS presents updated, adopted and acknowledged Inventones of commercIal and Industnalland The follOWIng tables present data taken only from adopted and acknowledged land Inventones They show the PAPA meets the requIrements of Goal 9 and OAR DIvIsIon 9 by maIntaInIng an adequate supply of Industnal land, addIng to the relatIvely small Inventory of medIum denstty reSIdentIal land, and redUCIng the projected defiCIt of commercial land Land Supply by Most Recent Acknowledged Type-SpecIfic Study Acres General Use UBG Plan Yr Inventory PAPA 11 Total 11% Med Density Res Metro 2015 239 19 258 8% Commercial Spnngfield 2015 -158 37 -121 23% Industnal (high est) Metro 2010 2,954 -56 2,898 -2% Industrial (lowest) Metro 2010 2.432 -56 2,376 -2% Note that the commerCial supply percentage change represents a reduction of the defiCit Source Metro Plan SCLS MILPR MILPT Land Supply by Most Recent Acknowledged Post-Studv Inventory Acres General Use UBG Plan Yr Inventory PAPA 11 Total 11% Source Med Density Res Metro 2015 239 19 258 8% Metro Plan Commercial Springfield 2015 -172 37 -135 22% SNRS Industnal (high est) Metro 2010 2,122 -56 2,066 -3% SNRS Industrial (lowest) Metro 2010 1,600 -56 1,544 -4% SNRS Note that the commerCial supply percentage change represents a reduction of the defiCit The applIcant proposes the follOWIng alternatIve findIng regardIng StateWIde PlannIng Goal 9 (Reference page 6-40 of the May 7, 2007, SprIngfield City Council AIS) FIndIng ThIs applIcatton complIes WIth Goal 9 by addreSSIng the most current adopted and acknowledgcd land studies The proposed PAPA shIfts land from the Industnal Inventory to the commercial and resldent..1 Inventones The proposal maIntaInS an adequate supply of Industnalland based on the' most recent Industnal lands study and on cumulative adopted and acknowledged actIOns SInce that study was completed The change to commercIal designatIOn IS JustIfied by the documented shortage of commercIal land The change to restdentlal desIgnatIon IS JustIfied by the demonstrated Imbalance, analyzed In economIc terms, between a plentIful Industnalland supply and a relatIvely small resIdentIal land supply .' City of Springfield, Altn Mayor Lelken and Councilors The VIllages at Marcola Meadows Plan Amendment and Zone Change (City Flies LRP 2006-00027 and ZON 2006-00054) Mav 29. 2007 Page 3 Compare the Proposed Master Plan to the EXlstmg Conceptual Development Plan We urge the Council to compare the proposed master plan before them With the conceptual development plan currently approved for a portIOn of the site Under current deSignation, zonmg, and CDP, nearly half of the sIte could be fully developed WIth only subdivIsIon and site plan revIew ThiS IS a rare opportumty for the city to approve a comprehensIve and detailed master plan for a 100-acre development Compare thiS to the level of control and detail 10 the eXlstmg CDP apply 109 to only 56 of the 100 acres The Importance of Developmg to Nodal Development Standards ImplementatIOn of the Nodal Development Area overlay deSIgnatIon IS an essentIal element of Tram Plan and the CIty'S efforts to meet State goals for transportatIon demand management In May 200 I, the LCDC approved the Eugene-Sprmgfield Alternative Plan and Performance Measurers that mandated the Implementation of a nodal development strategy As part of that strategy, Spnngfield IS to apply nodal development Metro Plan deSignatIOns and zonmg dlstncts ThiS project WIll help the City meet ItS obligation The ChOice Between CI and Nodal Development The Sprmgfield Nodes Market Analysli> pomts out that CI development does not lend Itself to Viable nodal development The Nodal Area overlay IS a mismatch WIth the Cl deSignatIOn Future development IS very unlikely to accomplish both sets goals The benefits of undetenmned future development under the eXlstmg CDP must be weighed agamst benefits of the proposed Nodal and mixed-use Master Plan before you "Jasper-Natron . Industnal uses may be mcornpatlble WIth nodal development" Sprmgfield Nodes Market AnalYSIS, page VI "Industnal development IS usually not compatIble WIth nodal development because It IS typIcally land-mtenslve (low denSity) and needs to be segregated from other uses because of nOIse and emISSIOns Industnalland supply IS relevant to a diSCUSSion of regIOnal land supply conditions because mdustnalland IS frequently re-zoned for other uses The Eugene-Sprmgfield area had about 2,500 acres ofland 10 1997 zoned for mdustnal uses, while demand was estImated to total 400-700 acres through 2020 ' ThiS surplus of mdustnalland, the potential shortage of residential land, and apparent shortage of commercial land 10 Sprmgfield suggests that some mdustnal land 10 the regIOn might get re-zoned for other uses" 'Industnalland supply and demand estimated by ECONorthwest, Wesl Eugene Parkway /ndUS/r1at Lands Anatys,s, 1997 We note that several things have changed regarding Industnal supply In the last five years (e g , land consumptIOn by development, increasing environmental CIty ofSpnngfield, Ann Mayor Lelken and CouncIlors The VIllages at Marcola Meadows Plan Amendment and Zone Change (CIty Files LRP 2006-00027 and ZON 2006-00054) Mav 29. 2007 Page 4 constramts) Moreover, at the state level there IS Increasmg concern that though the amount of mdustnalland might be adequate In some aggregate, long-run, plannmg sense, the short-run supply of development-ready parcels, especially large ones, may be constramed That, however, IS not a concern for this study on nodal development" Sprmgfield Node, Market AnalysIs, page 3-13 Will We Lose FamIly-Wage Jobs? The CIty can rely on the remaInIng Gateway CI Inventory and other Industrial and commercial lands currently SUitable for development until the 118-acre future supply ofClland In jasper-Natron IS available The tangible benefits of the proposed development outweigh the risks As the adage goes, "A bird In the hand IS worth two In the bush" Please remember, the site was available before Gateway, but was and contInues to be passed over for CI development EhmInatIng 56 acres of CI deSignatIOn does not erase opportunities for the hlgh- paYIng, traded sector employers In Springfield We pOInt agaIn to the DLCD report to the Governor regardIng conversion of Industrial lands It observed that the effort to preserve prime Industrial land IS primarily focused on high-Impact Industries with exactIng or unique site reqUIrements The new-tech jobs that CI was Intended to attract IncreasIngly rely on commercial support and are becomIng more hke commercial uses - they can eaSily locate In commercially zoned areas FactOries prodUCIng WIdgets are disappearIng, Information services are takIng their place Impact on Mohawk Redevelopment The proximIty of as many as 730 new households In Marcola Meadows will Increase the Income ba,e WithIn the Mohawk service area, and undoubtedly Increase bUSIness It will be ImpossIble for the commercial development In Marcola Meadows to absorb all the bUSIness these new reSidences will generate As often happens In nearby commercial diStriCtS, It IS much more hkely the two areas will develop (and redevelop) together, than for one to be left behInd What About School Overcrowdmg? Materials drawn from the 2006 Facilities AdVISOry Report and previously submitted Into the record Include analyses of all SprIngfield schools IncludIng Yolanda Elementary and Briggs Middle School These materials demonstrate that school faclhttes In the system are underused The report contaInS recornrnendattons for dealIng With these situatIOns IncludIng the near-term addltton of classrooms at Yolanda A key school capacity Issue IS the shift of student populatIOn from west Springfield to the east Several faclllttes In the west are under-capacIty, but at the same time are stIli needed and reqUIre repair or replacement It can be difficult to Justify updatIng a faclhty that IS underutllll:ed or will be In the future The Maple school IS the best example Enrollment IS down, but the school requires replacement nonetheless SImilar situatIOns are faced at SprIngfield Middle School and BrattaIn Elementary .' CIty ofSpnngfield, Attn Mayor Lelken and CouncIlors The Villages at Marcola Meadows Plan Amendment and Zone Change (City FIles LRP 2006-00027 and ZON 2006-00054) Mav 29_ 2007 Page 5 An Increase In attendance In west and central Spnngfield WIll help Justify capItal expendItures In such schools as Maple, Bnggs and Yolanda In advance, thank your of your consideratIOn of these rnatenals Sincerely, R i<::hct,vd,- tv! 5 et:tve- Richard M Satre, AICP, ASLA, CSl President Satre Associates, P C ~'>. May 29, 2007 RECEIVED. MAY 2 9 2007 BY'~JL Mayor SId Lelken CIty CouncIl c/o Gary Karp, Planner III - gkarp@)Cl spnngfield or us CIty of Spnngfleld 225 FIfth Street Spnngfleld, OR 97477 Re LRP 2006-00027/Z0N 2006-00054, Plan Amendment and Zone Change Dear Mayor and Councllors ThIS letter IS m response to the letter submItted by Goal One CoahtlOn addressed to the CIty of Spnngfleld Planmng CommIsSIOn, dated May 14, 2007 Goal 2 - Land Use Planning , As mdlcated by the Goal One letter, Goal 2, Part I states that the mformatlOn upon whIch land use decIsIOns are made "shall be contamed m the plan document or supportmg documents" Nonetheless, Goal One argues that the Spnngfleld Commercial Lands Study (SCLS) IS merely an unacknowledged mventory and cannot be the basIs of a plannmg decIsIOn because the study has not been acknowledged to be part of the Metro Plan The letter cItes D S Parklane Development, Inc v Metro, 165 Or App 1,22,994 P2d 1205 (2000) and 1000 Fnends of Oregon v CIty of Dundee, 203 Or App 207, 216, 124 P3d 1249 (2005) The D S Parklane case mvolved rehance upon an unacknowledged draft study, a document readlly dlstmgUlshable from the SCLS In the CIty of Dundee case, the CIty rehed upon an unacknowledged bUIldable lands mventory (8LI) rather than the acknowledged plan mventory of bUIldable resIdential land m the comprehensIve plan The court determmed that the 8LI was not a "plan or a plannmg document" ResolutIOn 00-13 adopts the Spnngfleld CommerCIal Lands Study as the pohcy document gUldmg the prOVISIOn of commercial lands wlthm the Spnngfleld urban growth boundary The resolutIOn speCIfically Gl~av~s Swwringm Pott~r & Scott LL' ~~ ...~~ ATTOKNF.Y~ ,\ T LA \X' Phone (541) 686 8833 f" (541) 3452034 975 Oak Street SUite 800 Eugene Oregon 97401 3]56 MudlOg Address PO BoxlJ47 Eugene Oregon 97440 ] 147 Emad mfo@gleaveslawcom Web Slle wwwgleaveslawcom Fredenck A Batson Jon V Buerstane JoshuaA Clark Dame! P Ell1son A J GlUStma Thomas P F Herrmann'" Dan Webb Howard Stephen 0 lane William H Martm'" WalterWMdler Laur.J. T Z Montgomery'" Tanya C O'Neil Standlee G Potter Martha) Rodman Robert S Russell Douglas R Schultz Malcolm H Scot! James W Splckerman Kate A Thompson Jant M Yate~ *Al~o admitted m Washmgton Mayor SId Lelken CIty CouncIl May 29, 2007 Page 2 fmds the study to be consIstent wIth the Penodlc RevIew Order and StatewIde Plannmg Goals and reflects that the study was a result of a penodlc revIew order pursuant to Metro Plan PolIcy 32 of the EconomIc Element of the Metro Plan, whIch speCIfIed such a study as a task for penodlC revIew The study was acknowledged by LCDC m 2006 As dIscussed below, Goal 9 reqUIred the type of change m land use desIgnatIOn here proposed to address not only the acknowledged comprehensIve plan but the "most recent economIC opportumtIes analysIs" The SCLS IS that analysIs as It pertams to commerCIal lands wlthm the Spnngfleld Urban Growth Boundary Goal One also suggests that the SCLS cannot be consIdered because It does not address the entIre metro urban growth boundary area ThIs IS not a convmcmg argument The Eugene CommerCIal Lands Study certamly does not address the whole metro area and, as to the Sprmgfleld CommercIal Lands Study, It was made a penodlC revIew task by DLCD LUBA certamly dId not have any dIffIculty on Issues of ItS applIcabIlIty when It applIed the SCLS m Jaqua v CIty of Spnngfield, 46 Or LUBA 134, 56 (2004) WhIle multl-JunsdlctlOnal cooperatIOn m ImplementatIOn of OAR 660-009-0015 to OAR 660-009- 0025 IS "strongly encouraged" m the Goal 9 rule, It IS not reqUIred See OAR 660-009-0030(1) Goal 9 - Economic Development The new Goal 9 rule, effectIve January 1,2007, IS applIcable to the present applIcatIOn The "fIxed goalpost rule" does not apply to eIther the comprehensIve plan amendment or the zone change because the zone change IS submItted contemporaneously WIth the comprehensIve plan amendment See Fnends of Applegate Watershed v Josephme County, 44 Or LUBA 786 (2003) OAR 660-009-0010(4) states "For a post-acknowledgement plan amendment under OAR chapter 660, dIvIsIOn 18, that changes the plan deSIgnatIOn of land m excess of two acres wlthm an eXlstmg urban growth boundary from an mdustnal use deSIgnatIOn to a non-mdustnal use deSIgnatIOn, or any other employment use deSIgnatIOn to any other use Mayor Sid Lelken City Council May 29,2007 Page 3 designatIOn, a City or county must address all applicable planmng reqUirements, and (a) Demonstrate that the proposed amendment IS consistent with ItS most recent economic opportumtles analysIs and the parts of ItS acknowledged comprehensive plan which address the reqUirements of this divIsIOn " The Agenda Item Summary packet, at pages 6-26 through 6-28, sets forth the applicant's analysIs of the mventones for the affected mventones, medIUm density residentIal, commercial, and mdustnal Updated tables are attached hereto as Exhibit A Goal One would argue that the analysIs IS deficient because "The JunsdlctIonally focused SCLS does not analyze supply and demand for the entire Metro UGH area and cannot be relied upon to establish consistency with the reqUirements of OAR 660-009-0010(4), which establishes that the proposed PAPA be consistent with both the most recent economic opportumtIes analysIs (I e the 2000 SCLS) and the comprehensive plan " Goal One letter, p 5 The SCLS IS the most recent economic opportumty analysIs for commercial lands The only other analyses that eXist m the Metro Plan area IS the Eugene Commercial Lands Study, WhiCh, of course, only addresses the Eugene portIOn of the Metro Plan, and the Commercial Economic Opportumty AnalysIs mcorporated mto the Metro Plan, mcludmg the Spnngfleld portIOn of the Metro Plan area, created sometIme before 1987 The rule calls for consistency with the most recent economic opportumty analysIs for the area To not consider the SCLS would be mconslstent with that rule Goal One also faults heavy reliance on the 2000 SCLS to analyze supply and demand because no consideratIOn IS given to the amount of land added to the commercIal mventory by means of applicant ImtIated and City approved zone changes and plan amendments smce that study The admmlstratlve rule calls for consistency with economiC analysIs and does not reqUire an analysIs updated by anecdotal mformatlOn It IS noted, however, the SNRS did con tam Mayor SId Lelken CIty Councll May 29, 2007 Page 4 mventory adjustments to the time of the study and reflects a shortage of commercIal lands Goal One contends that rellance cannot be placed on the Spnngfield Natural Resource Study (SNRS), adopted by Ordmance No 6150 on November 28, 2005 1t IS argued that, whIle the mventones mIght be relevant to the proposal, an analysIs of the entire UGB area IS necessary to establlsh an accurate pIcture of the supply of commercIal lands Here agam, there IS the unsupported assertIOn that any mventory that does not encompass the entire Metro area IS of no Import There sImply IS no basIs for thIs assertIOn The SNRS IS the last true mventory to be adopted and acknowledged Policies of the Economic Element of the Metro Plan The pollC1es most dIrectly relevant to the proposal are Pollcles 6 and 12 Pollcy 6 states "Increase the amount of undeveloped land zoned for hght mdustnal and commerCIal uses correlatmg the effective supply m terms of sUltablllty and avallablllty for the projectIOns of demand" Pollcy 12 states "DIscourage future Metro Plan amendments that would change development-ready mdustnallands (sItes defmed as short-term metropolltan Industnal Lands Speczal Study, 1991) to non-mdustnal designatIOns" The Metro Plan addresses the Issue of conflIct between pollcles "The respective JunsdlctlOns recognIze there are apparent conflicts and mconslstencles between and among some goals and pollcles when makmg decIsIOns not based on the Metro Plan Not all of the goals and pollcles can be met to the same degree m every mstance Use of the Metro Plan reqUIres a balancmg of ItS vanous components on a case-by-case basIs, as well as a selectIOn of those goals, objectives, and pollcles most pertment to the Issue at hand" Mayor Sid Lelken City Councll May 29, 2007 Page 5 Oregon LUBA cases confirm that where plan pollcles conflIct, the governmg body may consIder and balance those plan pollcles favormg some over others based on that balance See Welch v Czty of Portland, 28 Or LUBA 439 (1994) Among the other factors, the particular language used m a pollcy can bear upon how those pollcles are weighed Pollcy 6 clearly calls for an mcrease m the amount of undeveloped land "zoned for llght mdustnal and commercial uses correlatmg the effectIVe supply m terms of sUltablllty and aVallablllty with proJectIOns of demand" while Pollcy 12 only seeks to "dIscourage" amendments changmg mdustnalland to nonmdustnal deSIgnatIOns In Bothman v Czty of Eugene, 5 I Or LUBA 426 (2006), the pollcy called upon the CIty to "recognIze" eXlstmg use and discouraged reZOnIng of the subJect property LUBA recognIzed that the pollcy expressed a clear pollcy preference that this particular parcel retam ItS eXlstmg zonmg LUBA stated "WhIle that preference IS not absolute, and can be overcome by suffICient reasons and/ or competmg pollcy consideratIOns, wntten context pollcy clearly reqUIres the city to at least consrder whether the appllcant has establlshed a baSIS to overcome that pollcy preference" In that mstance, the pollcy was directed at the particular property at Issue and LUBA found the pollcy not mandatory but one that must be consIdered The Goal One CoalltlOn argument that Pollcy 6 only speaks to zonmg, not change m Plan deSignatIOn, of land for commerCIal use has no valldlty ObvIOusly, additIOnal land wllI not be avaIlable for rezonmg to a commercIal zone If the land IS not redeSignated for that purpose In the present case, the record establlshes that the particular site has long been avaIlable for speClalllght mdustnal use yet has not been I developed With the CI uses The site has constramts not recognIzed m the Metropohtan IndustnaI Lands Special Study It IS m prOXImity to the Kmgsford charcoal plant, overhead electncalllnes and nearby rail lmes whIch cause problems to certam types of high technology mdustnes Also, not contemplated at the tIme of the Metropolltan IndustnaI Lands SpecIal Study was a shortage of commercial lands m Mayor Sid Lelken CIty CouncIl May 29, 2007 Page 6 SprmgfleId revealed by the SCLS The agenda packet on pages 6-28 through 6-34 puts forth additIOnal JustifIcatIOn for welghmg EconomIc Element Pollcy 6 more heavIly Goal One states that all 30 of the EconomIc pollcles "should be addressed m some manner" That IS not the case All relevant pollcles should be addressed Policy 5 - Provide existing industrial activities sufficient adjacent land for future expansion. There IS no eVIdence that there are eXlstmg mdustnal activIties m the area of the subJect sIte with need of addItIOnal adJacent land for expansIOn The fact that the land has remamed undevcloped for many years IS mdlcatlOn that there IS not the need for that expansIOn Policy 7 - Encourage mdustrlal park development, mcludmg areas for warehousing and distributive mdustrIes and research and development actIvitIes. This pollcy is Irrelevant It IS dIrected to the Issue of the manner of mdustnal development, Ie, m an mdustnal park rather than Isolated developments Policy 9 - Encourage the expansion of existing and the location of new manufacturing activities which are characterized by low levels of pollution and efficient energy use. Agam, thIS pollcy IS not relevant to the Issue at hand The pollcy encourages the nurtunng of particular mdustnes, those charactenzed by llttle pollutIOn and energy efficIency Policy 15 - Encourage compatibility between mdustrially zoned lands and adjacent areas in local planning program. The pollcy IS Irrelevant as are Goal One's comments under the pollcy Policy 16 - Utilize processes and local controls which encourage retention of large parcels or consolidation of small parcels of industrially or commercially zoned land to facilitate their use or reuse in a comprehensive rather than piecemeal fashion. i The pollcy IS dIrected to CIty "process" and "controls" and doe;s not go the Issue of whether thIS land should be converted to other uses Mayor SId Lelken City Council May 29, 2007 Page 7 WhIle the pollcy directs the staff to encourage retentIOn of large parcels of mdustnally zoned and designated land, the pohcy goes more to dlscouragmg parcellzatlOn of such properties, whIch mIght discourage their use m a comprehcnslve manner Policy 21 - Reserve several areas within the UGH for large scale, campus type, hght manufacturmg uses. Several areas, much larger than the subJect site, remam for large scale, campus type llght manufactunng use, as shown on the Metro Plan DIagram Policy 28 - Recogmze the vital role of neighborhood commercial facilities in providing services and goods to a partIcular neighborhood ThIs pollcy has no appllcablllty to the proposal The pollcy IS directed pnmanly at makmg prOVISIOn for and preservmg the commerCIal facllltles that serve particular neighborhoods The proposed redeslgnatlOn IS consistent wlthm the pollcles of the EconomIc Element of the Metro Plan LUBA will defer to Spnngfleld's mterpretatlOn of those pollcles unlcss they are "clearly wrong" See Jaqua v Spnngfield, supra The Goal One letter addressed Goal 10 - Housmg It cntlclzes a proposal for addmg an addItIOnal 19 acres of residential land The Metro Plan does not prohIbIt surpluses of the vanous mventones Goal 12 - TransportatIOn IS discussed m the Goal One letter A transportatIOn Impact analysIs has been submitted and approved by the City Goal One raises the Issue of Goal 6 - Air, Water, and Land Resources Quallty Goal One contends that the additIOnal traffiC from thiS development WIll encourage more auto use and auto emIssIons and that thiS should be conSIdered under Goal 6 LUBA has made clear that Goal 6 IS llmlted, by ItS terms, to discharges from the proposed development Itself See Marcott Holdmgs, Inc v CIty ofTzgard, 30 Or LUBA 101 (1995) Goal One cItes Goal 13 - Energy and fmds that the proposed development IS contrary to that goal because the CoalltlOn deems It an Mayor Sid Lelken City Council May 29, 2007 Page 8 auto-dependent use Goal 13 has rarely been relled upon as a basIs for a deCIsIOn m particular land use cases The goal IS pnmanly directed towards the development of local government land management Implementmg measures whIch maximIze energy conservatIOn and IS not appllcable to mdlvldual land use actIOns Conclusion It IS submitted that the appllcatlOn does satlsfactonly address Statewide Goals, apphcabIe pollcy documents, and the Metro Plan Respe tfully su Jca cc SC Sprmgfleld, LLC Attachment ExhIbit A - Tables A " EXHIBIT A Land Supply by Most Recent Acknowledged Type-Specific Study Acres Inventory PAPA f1 Total 239 19 258 -158 37 -121 2,954 -56 2,898 2,432 -56 2,376 General Use Med Density Res Commercial Industrial (high est) I nd ustrlal (lowest) UBG Metro Springfield Metro Metro Plan Yr 2015 2015 2010 2010 f1% 8% 23% -2% -2% Note that the commercial supply percentage change represents a reduction of the deficit Land Supply by Most Recent Acknowledged Post-Study Inventory Acres General Use UBG Plan Yr Inventory PAPA f1 Total Med Density Res Metro 2015 239 19 258 Commercial Springfield 2015 -172 37 -135 Industrial (high est) Metro 2010 2,122 -56 2,066 Industrial (lowest) Metro 2010 1,600 -56 1 544 Note that the commercial supply percentage change represents a reduction of the deficit Source Metro Plan SCLS MILPR MILPT f1% Source 8% Metro Plan 22%SNRS -3% SNRS -4% SNRS