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HomeMy WebLinkAbout2009 04 21 memo riverbend nodal implementationMEMORANDUM CITY OF SPRINGFIELD DATE OF HEARING: April 21, 2009 PLANNING COMMISSION TRANSMITTAL TO: Springfield Planning Commission MEMORANDUM FROM: Andy Limbird, Planner II RE: Case No. LRP2009-00001 SUBJECT: Request to adopt a post-acknowledgement plan amendment (PAPA) for the Gateway Refinement Plan area. The plan amendment would implement a Nodal Development Overlay District (NDO) for the 180-acre “McKenzie-Gateway MDR Site”, now commonly identified as the PeaceHealth hospital and campus. ISSUE The Planning Commission is asked to conduct a public hearing for deliberations on the implementation of a Nodal Development Overlay District affecting approximately 180 acres of northwest Springfield. The subject area is identified in adopted plans as the “McKenzie-Gateway MDR Site”. The Commission must decide whether to advise the City Council to approve, approve with conditions, or deny the request. DISCUSSION The subject area is located on the east side of Martin Luther King, Jr. Parkway and west of the McKenzie River. It is bounded on the north by Deadmond Ferry Road and on the south by residential properties on Wayside Loop. Approximately 180 acres are identified for nodal implementation in adopted plans. However, staff advises that the requested plan amendment is limited to land currently inside the City limits (approximately 168 acres). The affected area includes the existing Sacred Heart Medical Center at RiverBend and future commercial, residential and mixed use development areas comprising the RiverBend Master Plan area. As unincorporated areas within the planned nodal implementation area request annexation, the City Council may consider whether to implement the NDO district on a case-by-case basis. The post-acknowledgement plan amendment is consistent with a Conceptual Development Plan adopted for the area in 1994; amendments to the Metropolitan Area General Plan (Metro Plan) and Gateway Refinement Plan adopted in 2005 (Commercial Policy and Implementation Action 5.0); TransPlan; and provisions of the approved RiverBend Master Plan. Springfield City Council directed staff to implement the nodal development overlay plan designation through adoption of the RiverBend Master Plan in 2005 (Attachment 6). RECOMMENDATION Staff recommends approval of the request as described in the attached Staff Report. ACTION REQUESTED Advise the City Council, by motion and signature of the attached order and recommendation by the Planning Commission Chairperson, to approve the request at the public hearing on May 18, 2009. ATTACHMENTS Attachment 1: Staff Report and Findings Attachment 2: Vicinity, Neighborhood and Site Maps Attachment 3: McKenzie-Gateway MDR Area Map Attachment 4: Ordinance No. 6109 Amending the Gateway Refinement Plan Attachment 5: TransPlan Potential Nodal Development Areas Map Attachment 6: Email correspondence from DLCD and Bonnie Ullmann Attachment 7: Planning Commission Order Type IV Metro Plan Amendment Staff Report and Findings Hearing Date: April 21st, 2009 Planning Commission May 18th, 2009 City Council Case Number: LRP 2009-00001 Applicant Property Owners Applicant’s Representative City of Springfield 225 Fifth Street Springfield, OR 97477 See Appendix ‘A’ N/A Date Submitted: January 29, 2009 EXECUTIVE SUMMARY: The subject area is contemplated for nodal development in senior planning documents adopted by the City, including the Metro Plan, TransPlan, the Gateway Refinement Plan, and the RiverBend Master Plan. The Springfield City Council adopted the amended RiverBend Master Plan on June 19, 2006. Condition #12 of the Master Plan approval reads: “The City Council hereby initiates the application of the Nodal Overlay Plan Designation at the entirety of the McKenzie Gateway MDR Site as identified in the Gateway Refinement Plan.” The McKenzie Gateway MDR Site (now more commonly known as Riverbend) was identified in a Conceptual Development Plan prepared by the City in 1994. Council adopted Ordinance 6109 (amending the Metro Plan and Gateway Refinement Plan) on January 10, 2005 with the intent of preserving the potential for nodal development in the Riverbend neighborhood. These adopted plan amendments set the stage for development of this area with the Sacred Heart Medical Center and campus. Consistent with the adopted plan amendments and City Council’s direction, staff are presenting the nodal development implementation action for consideration by the Planning Commission and City Council. REQUEST: Staff are requesting approval to implement the Nodal Development Overlay District (NDO) designation for approximately 170 acres of the PeaceHealth campus. The NDO District would supplement the zoning designations in the area, which include Community Commercial (CC), Mixed Use Commercial (MUC) and Medium Density Residential (MDR). Current zoning for the affected properties is Medical Services (MS), CC and MDR. A Metro Plan Amendment at this time (not during Periodic Review) is known as a Post-Acknowledgement Plan Amendment (PAPA). SITE DESCRIPTION: The affected properties comprise approximately 170 acres and are identified as Assessor’s Map 17-03-14-00, Tax Lot 1900; and Map 17-03-22-00, Tax Lots 100, 200, 903, 904, 3401-3403 and 3600- 4300. The subject properties include the developed Sacred Heart Medical Center site and ancillary buildings; the Women’s Care Center; and vacant future development areas surrounding the hospital. Attachment 1, Page 1 of 11 The affected properties have no jurisdictional wetlands or inventoried Goal 5 natural or historic resources. Although not an inventoried historic resource, a pioneer graveyard discovered during excavation work at the south end of the subject area was surveyed and relocated in 2008. The site is within the Springfield Urban Growth Boundary, and all the subject properties were previously annexed into the City of Springfield. The subject properties are within the Gateway Refinement Plan area. The affected properties are bordered on the east by the McKenzie River. The abutting properties to the north and south are outside the City limits and zoned Low Density Residential (LDR). The areas immediately west of the site are outside the City limits and zoned LDR and MDR. This proposed plan amendment only affects properties currently inside the City limits. However, the ultimate boundaries of the Riverbend nodal development overlay area could logically include properties on Deadmond Ferry Road, Game Farm Road and Baldy View Lane that are outside the current City limits. As these property owners request annexation, the City Council will have the opportunity to incorporate the property into the Riverbend nodal development overlay area on a case- by-case basis. REVIEW PROCESS: The proposed Metro Plan Amendment is a Type II Amendment because it is located inside the city limits and is site specific. In accordance with SDC 5.14-135.B and 5.14-140, a Type II Metro Plan amendment inside the city limits shall be presented to the Planning Commission for consideration and to the City Council for final action. The City Council initiated the Nodal Development Overlay designation for the subject area by adopting the amended RiverBend Master Plan in 2006. Staff initiated this Post-Acknowledgement Plan Amendment on January 29, 2009. A notice and supplementary information was mailed to the Department of Land Conservation and Development (DLCD) on February 12, 2009. Representatives of the affected property owners (PeaceHealth and the Women’s Care Center) were contacted directly in mid-March prior to issuance of the hearing notice. The public hearing notice was mailed out on April 1, 2009 to property owners within 300 feet of the proposed Nodal Development Overlay District implementation area per Section 5.2-115.A.1-14 of the Springfield Development Code (SDC). Advertised notice of the public hearing was published in the local newspaper (Register Guard) on April 11th, 2009, as required in Section 5.2-115.B of the SDC. Since this application was initiated by the City Council, staff have responded to three telephone calls requesting clarification on the proposed amendments and possible impacts to properties adjacent to the subject area. No substantive concerns were raised. Staff provided follow up written clarification to one caller who asked whether a conference center and hotel could be built in the nodal development area. One written comment in support of the proposal was received from Bonnie Ullmann on behalf of the Game Farm Neighbors (Attachment 6). METRO PLAN DESIGNATION: The subject property is designated Commercial and Medium Density Residential as shown in the Metro Plan diagram. Specific Findings related to the Metro Plan are discussed in this report. Attachment 1, Page 2 of 11 METRO PLAN DIAGRAM AMENDMENT CRITERIA OF APPROVAL – SDC 5.14-135.C.1 and 2 "The following criteria shall be applied by the City Council in approving or denying a Metro Plan amendment application: 1. The amendment must be consistent with the relevant Statewide planning goals adopted by the Land Conservation and Development Commission; and 2. Adoption of the amendment must not make the Metro Plan internally inconsistent. CRITERIA OF APPROVAL - SDC 5.14-135.C.1 1. The amendment must be consistent with the relevant Statewide planning goals adopted by the Land Conservation and Development Commission. STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 1: Goal 1 – Citizen Involvement: To develop a citizen involvement program that insures the opportunity for citizens to be involved in all phases of the planning process. Finding 1: Goal 1 addresses the need to develop a citizen involvement program to ensure citizen involvement in all phases of the land use planning process. The Planning Commission and the City Council will hold public hearings and accept testimony on the proposal. Through the procedures established by the City, citizens have received notice of hearings in a generally published local paper (Register Guard) and have the opportunity to be heard regarding the proposed plan amendment. Notice of the public hearings was also given to property owners within 300 feet of the proposed Plan Amendment area in accordance with SDC 5.2-115.A.1-14 requirements. In addition, the provisions of ORS 197.610 regarding local government notice of proposed amendment provided to the Department of Land Conservation and Development has been observed. Since the proposed amendment complies with the City’s citizen involvement program and citizens have opportunities to be involved in the procedure, the proposed amendment is consistent with Goal 1. STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 2: Goal 2: Land Use Planning: To establish a land use planning process and policy framework as a basis for all decision and actions related to use of land and to assure an adequate factual base for such decisions and actions. Finding 2: Goal 2 requires that local comprehensive plans be consistent with the Goals, that local comprehensive plans be internally consistent, and that implementing ordinances be consistent with acknowledged comprehensive plans. Goal 2 also requires that land use decisions be coordinated with affected jurisdictions and that they be supported by an adequate factual base. Because the proposed plan amendment does not affect properties outside the current city limits, the City sent referral notice of the proposed amendment to the City of Eugene and Lane County on April 8, 2009 extending “interested party” status to each government. The City sent the statutorily required notice of the initial public hearing more than 45 days in advance to the state Department of Land Conservation and Development, ensuring that they are given opportunity for comment and review on conformity to applicable statewide planning goals. The DLCD reviewed the submitted materials and advised they do not have concerns or objections with the proposed plan amendment (see Attachment 8). Attachment 1, Page 3 of 11 The Metro Plan and the SDC, as well as the Statewide Planning Goals and applicable statutes, provide policies and criteria for the evaluation of comprehensive plan amendments. Compliance with these measures assures an adequate factual base for approval of the proposed Metro Plan amendment. As discussed elsewhere in this document, the proposed plan amendment is consistent with the Metro Plan and the Goals. Amendments to the Metro Plan and the Gateway Refinement Plan adopted in 2005 and 2006 provide for nodal development in the subject area, and are consistent with the proposed plan amendment. The subject area is also identified as Site 7B on the adopted “Potential Nodal Development Areas” map in TransPlan. Therefore, by demonstrating such compliance, the amendments satisfy the consistency element of Goal 2. STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 3: Goal 3 – Agricultural Land: To preserve and maintain agricultural lands. Finding 3: This goal is inapplicable because as provided in OAR 660-15-000(3), Goal 3 applies only to rural agricultural lands. The subject properties are located within an acknowledged urban growth boundary, are inside Springfield’s corporate limits, and are not in agricultural use. STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 4: Goal 4 – Forest Land: To conserve forest lands by maintaining the forest land base and to protect the state’s forest economy by making possible economically efficient forest practices that assure the continuous growing and harvesting of forest tree species as the leading use on forest land consistent with sound management of soil, air, water, and fish and wildlife resources and to provide for recreational opportunities and agriculture. Finding 4: Goal 4 does not apply within urban growth boundaries, per OAR 660-06-0020, and the area affected by the proposed Plan amendment is inside Springfield’s acknowledged UGB. STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 5: Goal 5 – Open Spaces, Scenic and Historic Area, and Natural Resources: To conserve open space and protect natural and scenic resources. Finding 5: Goal 5 requires local governments to protect a variety of open space, scenic, historic, and natural resource values. Goal 5 and its implementing rule, OAR Ch. 660, Division 16, require planning jurisdictions, at acknowledgment and as a part of periodic review, to (1) identify such resources; (2) determine their quality, quantity, and location; (3) identify conflicting uses; (4) examine the economic, social, environmental, and energy (ESEE) consequences that could result from allowing, limiting, or prohibiting the conflicting uses; and (5) develop programs to resolve the conflicts. The subject properties are not on Springfield’s acknowledged Metro Plan Goal 5 inventory. No threatened or endangered species have been inventoried on the site, and no archaeological or significant historical inventoried resources are located on the site. A pioneer graveyard discovered during site excavation work at the south edge of the RiverBend Master Plan area was surveyed and relocated in 2008. The National Wetland Inventory and Springfield Local Wetland Inventory maps have been consulted and there are no jurisdictional wetlands warranting protection located on the site. A cluster of small, Attachment 1, Page 4 of 11 non-significant wetlands (depicted on the Springfield Local Wetland Inventory, and identified as Site M07 on the Springfield Natural Resources Study) are located near the northeast edge of the subject area. These non-significant wetlands are not identified or contemplated for protection in the RiverBend Master Plan. The McKenzie River is an identified riparian resource that abuts the east boundary of the subject area. A riparian setback and conservation zone has been established within the RiverBend Master Plan area. The proposed plan amendment is only applicable to existing and future urban development areas within the RiverBend Master Plan Area, and will not have an adverse effect on protection or preservation of this resource. Therefore, the proposed amendment does not alter the City’s compliance with Goal 5. STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 6: Goal 6 – Air, Water and Land Resources Quality: To maintain and improve the quality of the air, water and land resources of the state. Finding 6: The purpose of Goal 6 is to maintain and improve the quality of the air, water and land resources of the state. Generally, Goal 6 requires that development comply with applicable state and federal air and water quality standards. In the context of the proposed Metro Plan amendment, Goal 6 requires that the applicant demonstrate that it is reasonable to expect that applicable state and federal environmental quality standards can be met. The proposed plan amendment does not modify any of the Goal 6 related policies of the Metro Plan, nor does it amend the Regional Transportation Plan (TransPlan), the Springfield Development Code, other applicable Goal 6 policies, or any regulations implementing those policies. Most of the subject area lies within the 1-20 Year Time of Travel Zones and Zone of Contribution for the Sports Way wellhead. The northeast edge of the subject area lies outside the mapped Zone of Contribution for Springfield drinking water wells. Because most of the area is regulated by the Drinking Water Protection Overlay District, existing and future development must demonstrate compliance with the City’s Drinking Water Protection standards. The proposed amendment does not alter the City’s compliance with Goal 6. STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 7: Goal 7 – Areas Subject to Natural Disasters and Hazards: To protect life and property from natural disasters and hazards. Finding 7: Goal 7 requires that development subject to damage from natural hazards and disasters be planned and/or constructed with appropriate safeguards and mitigation. The goal also requires that plans be based on an inventory of known areas of natural disaster and hazards, such as areas prone to landslides, flooding, etc. Staff has reviewed the natural constraints map and the FEMA Floodplain Map in relation to the subject area. The subject area is relatively flat and is not subject to landslide hazards. The eastern half of the subject area is within the mapped FEMA 100 year floodplain. A McKenzie River floodplain analysis prepared by David Evans & Associates in November, 2003 has updated the flood level information for the subject area. Existing and future development in the area must demonstrate compliance with the Floodplain Overlay District provisions of the City’s Development Code, including establishing building floor elevations at least one foot above the calculated flood level. Therefore, approval of the proposed Plan Amendment will not alter the City’s acknowledged compliance with Goal 7 through its adopted plans, codes and procedures. Attachment 1, Page 5 of 11 STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 8: Goal 8 – Recreation Needs: To satisfy the recreational needs of the citizens of the state and visitors and, where appropriate, to provide for the siting of necessary recreational facilities including destination resorts. Finding 8: Goal 8 requires local governments to plan and provide for the siting of necessary recreational facilities to "satisfy the recreational needs of the citizens of the state and visitors" and, where appropriate, provide for the siting of recreational facilities including destination resorts. Staff has consulted the Willamalane 20-year Parks and Recreation Comprehensive Plan in relation to Goal 8 compliance. The Willamalane 20-year Parks and Recreation Comprehensive Plan was adopted by the City of Springfield as part of the Metro Plan’s compliance with Goal 8. According to Map 2 of the Comprehensive Plan, two future park and recreation facilities are contemplated within the eastern half of the subject area, which is identified for future residential development. The proposed plan amendment does not preclude the acquisition of public land for provision of recreational facilities, including neighborhood and special use parks as noted in the Comprehensive Plan. Therefore, the proposed plan amendment does not alter the City’s compliance with Goal 8. STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 9: Goal 9 – Economic Development: To provide adequate opportunities throughout the state for a variety of economic activities vital to the health, welfare, and prosperity of Oregon’s citizens. Finding 9: Goal 9 requires the city to provide adequate opportunities for a variety of economic activities vital to the health, welfare, and prosperity of the citizens. Because the nodal development overlay does not supplant the underlying commercial and mixed use zoning of the affected properties, and nodal designation supports and encourages more intensive development of these lands, the proposed amendment will not affect the city's capacity for economic development. Therefore, the proposed amendment does not alter the City’s compliance with Goal 9. STAFF FINDINGS RELATED TO GOAL 10: Goal 10 – Housing: To provide for the housing needs of citizens of the state. Finding 10: LCDC's Housing goal requires cities to maintain adequate supplies of buildable lands for needed housing, based on an acknowledged inventory of buildable lands. The 1999 Eugene-Springfield Metropolitan Area Residential Land and Housing Study is Springfield’s most current adopted housing study related to Goal 10. The City of Springfield is also currently undergoing a new Residential Lands Study that will analyze the housing inventory and projected needs for the next 20 years. Preliminary findings of the Residential Lands Study suggest that there is a need for additional housing within the planning period. Some of the anticipated need could be met through increasing density of existing residential zones. The proposed amendment would increase allowable density levels within the subject area, thus providing more housing options for Springfield residents. The residential component of the subject area is zoned MDR, and is currently vacant. The nodal overlay would allow for housing densities to be increased up to 20% above the base standards of the MDR District. Attachment 1, Page 6 of 11 STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 11: Goal 11 – Public Facilities and Services: To plan and develop a timely, orderly and efficient arrangement of public facilities and services as a framework for urban and rural development. OAR 660-011-0005(7)(a)-(d) Definition of Public Facilities: (a) Water (b) Sanitary Sewer (c) Storm sewer (d) Transportation Finding 11: This goal requires the provision of a timely, orderly and efficient arrangement of public facilities and services. The subject area is located within the Springfield UGB and city limits, and already contains a regional hospital facility and ancillary medical service buildings. The subject area is accessed via recently-completed local and regional transportation improvements, including the Martin Luther King, Jr. Parkway extension, Cardinal Way extension, widening of Beltline Road, and construction of Riverbend Drive. The proposed nodal development overlay will not affect the ability to provide needed services to the subject area. All the required urban services are existing or available to support future residential, commercial and mixed used development on the subject properties. The Metro Plan and associated facility plans have been acknowledged to conform to Goal 11, thereby ensuring that public facilities and services are currently available to the subject site. Therefore, the proposed amendment does not affect the Metro Plan’s compliance with Goal 11. STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 12: Goal 12 - Transportation: To provide and encourage a safe, convenient and economic transportation system. Finding 12: Goal 12 requires local governments to provide and encourage a safe, convenient and economical transportation system. The proposed amendment involves about 170 acres of property, of which approximately 50 acres is already developed with the hospital facility and ancillary buildings. The transportation analysis prepared for the RiverBend Master Plan contemplates build-out of the subject area with a combination of commercial, residential and mixed-use development. Nodal designation of the subject area was contemplated in the regional transportation plan adopted for Eugene-Springfield (TransPlan) and long-range plans adopted by the City. Implementation of the nodal designation for the subject properties is a logical progression of the recent and planned transportation projects that directly or indirectly benefit the subject area, including: Pioneer Parkway roundabout and MLK Jr. Parkway Extension; eastbound Beltline Road off-ramp from I-5; future Gateway/Beltline intersection improvements; Riverbend Drive construction; and installation of signalized intersections on MLK Jr. Parkway at the intersections with Riverbend Drive, Cardinal Way and Game Farm Road East. In addition to street and intersection improvements, the subject properties will derive a direct benefit from the new Bus Rapid Transit (EmX) line currently being constructed to serve the Gateway area of north Springfield. Provision of a highly efficient public transportation system is a key element of the nodal development concept. Two EmX line transit stops are slated for construction within the subject area – one near the intersection of MLK Jr. Parkway and Riverbend Drive, and another to serve the Sacred Heart Medical Center. Any significant intensification of development (beyond that contemplated in adopted plans and studies) will be subject to development review to assure existing transportation capacity is not Attachment 1, Page 7 of 11 exceeded. Therefore, the proposed plan amendment is consistent with Goal 12 and applicable local implementing policies. STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 13: Goal 13 - Energy Conservation: To conserve energy. Land and uses developed on the land shall be managed and controlled so as to maximize the conservation of all forms of energy, based upon sound economic principles. Finding 13: The Energy goal is a general planning goal and provides limited guidance for site-specific plan amendments. The proposed amendment has no direct impact on energy conservation, though it would arguably promote greater energy efficiency by enabling future development at increased density levels and with more transportation options within the subject area. Therefore, the proposed amendment is consistent with, and does not alter, the City’s continued compliance with Goal 13. STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 14: Goal 14 – Urbanization: To provide for an orderly and efficient transition from rural to urban land use. Finding 14: Goal 14 requires local jurisdictions to provide for an "orderly and efficient transition from rural to urban land use". The subject area is within the UGB and the city limits of Springfield, and within an existing urbanized area of the community. A portion of the subject area has been intensively developed with a major hospital facility and medical campus. Therefore, Goal 14 is not applicable to this application. STAFF FINDINGS RELATED TO COMPLIANCE WITH GOAL 15: Goal 15 – Willamette River Greenway: To protect, conserve, enhance and maintain the natural, scenic, historical, agricultural, economic and recreational qualities of lands along the Willamette River as the Willamette River Greenway. Finding 15: Goal 15 does not apply to the proposed plan amendment because the subject area is not located within the Willamette River Greenway. However, similar protection measures for the McKenzie River have been implemented through the development plans adopted for the subject area. STAFF FINDINGS RELATED TO COMPLIANCE WITH GOALS 16-19: Goal 16 through 19: (Estuarine Resources, Coastal Shorelands, Beaches and Dunes, and Ocean Resources). Finding 16: The subject site is not located within any coastal, ocean, estuarine, or beach and dune resources related area. Therefore, Goals 16-19 do not apply to this Plan Map Amendment application. CRITERIA OF APPROVAL - SDC 5.14-135.C.2 2. Adoption of the amendment must not make the Metro Plan internally inconsistent. STAFF FINDINGS RELATED TO 5.14-135.C.2: Finding 17: The application requests amendment of the Metro Plan diagram to implement a nodal development overlay for approximately 170 acres. This section of the application narrative addresses the consistency of the amendment with the applicable policies of the Metro Plan, and to demonstrate Attachment 1, Page 8 of 11 that adoption of the amendment will not make the Metro Plan internally inconsistent as required by the approval criteria in SDC 5.14-135.C.2. This narrative only addresses those policies that apply to the proposal, and does not discuss those portions of the Metro Plan that: (1) apply only to rural or other lands outside of the urban growth boundary; (2) apply to land uses other than the current or proposed designations for the site and will not be affected by the proposed Metro Plan diagram amendment; or (3) clearly apply only to specific development applications such as site plan review submittals or subdivisions. In many instances the goals, policies, and implementation measures apply to specific development proposals that will be addressed through compliance with applicable City regulations during site plan review. The Metro Plan Introduction, Section D provides the following definitions: A goal as a broad statement of philosophy that describes the hopes of the people of the community for the future of the community. A goal may never be completely attainable, but is used as a point to strive for. An objective is an attainable target that the community attempts to reach in striving to meet a goal. An objective may also be considered as an intermediate point that will help fulfill the overall goal. A policy is a statement adopted as part of the Plan to provide a consistent course of action moving the community towards attainment of its goals. Except for the Growth Management Goals, which are addressed below, each of the Metro Plan policies are addressed in the order in which they appear in the Plan Element section of the Plan. Finding 18: Metro Plan Element: Growth Management Policy 1: The urban growth boundary and sequential development shall continue to be implemented as an essential means to achieve compact urban growth. Provision of all urban services shall be concentrated inside the urban growth boundary. The proposed amendment satisfies this policy because the subject property is inside the UGB and city limits and, as such, encourages compact urban growth. Urban services are available at sufficient levels to accommodate existing and future development. Implementation of the nodal development overlay will encourage more compact and efficient land development, which is consistent with this policy. Future development within the affected properties will be subject to development review, and any need for increased capacity will be addressed through this process. The City's development review processes ensure that the appropriate level of services is available to serve existing and future development. Finding 19: Metro Plan Element: A. Residential Land Use and Housing Element Policy A.11: Generally locate higher density residential development near employment or commercial services, in proximity to major transportation systems or within transportation-efficient nodes. The subject area contains an existing major employment center (regional hospital facility and medical service buildings). Vacant commercial and mixed use properties within the subject area are expected Attachment 1, Page 9 of 11 to generate employment opportunities as these sites develop. Additionally, the subject properties are adjacent to the Gateway area, which is a focal point for employment and commercial activities in north Springfield. The Gateway area, including the subject site, is served by major transportation connections that include I-5, Beltline Road, MLK Jr. Parkway, Riverbend Drive, and Gateway Street. The residential component of the RiverBend Master Plan area is planned to be medium density housing, with additional opportunities for residential dwelling units in mixed use zones. Higher dwelling unit densities are planned adjacent to the hospital campus, which is consistent with the principles of nodal development and policies listed in the Residential Land Use and Housing Element. As stated previously, the Gateway EmX bus rapid transit line is currently under construction and is designed to serve the subject site and greater Gateway area of Springfield. There are two transit stops planned to serve the subject area. Provision of a highly efficient transit system that allows users to quickly access nearby commercial and employment centers, downtown Springfield and Eugene, and local educational institutions is consistent with nodal development principles and Metro Plan Policy A.11. Policy A.22: Expand opportunities for a mix of uses in newly developing areas and existing neighborhoods through local zoning and development regulations. The proposed amendment will not change the underlying commercial, mixed use, and medium density residential zoning of the subject area. Implementation of nodal development designation discourages low-intensity automobile-oriented uses and, instead, encourages mixed use development and more compact, efficient land development. The proposed amendment is consistent with Policy A.22 of the Metro Plan. Finding 20: Metro Plan Element: D. Willamette River Greenway, River Corridors, and Waterways Element Policy D.5: New development that locates along river corridors and waterways shall be limited to uses that are compatible with the natural, scenic, and environmental qualities of those water features. The proposed amendment should not have an adverse effect on the existing and planned riparian setbacks and conservation areas along the stretch of the McKenzie River that is adjacent to the subject area. Adoption of the RiverBend Master Plan and subsequent development of the subject area with the Sacred Heart Medical Center identified provisions for protecting and enhancing the riparian zone within the subject area. Increased building setbacks, controlled public access (paved pathways), and riparian restoration zones have been used in the subject area to ensure existing and future development is compatible with the river corridor. As new development is proposed along the river corridor, it will be reviewed for conformity with the adopted Master Plan and riparian protection policies and subject to approval by the City. Therefore, the proposed amendment is consistent with Policy D.5 of the Metro Plan. Finding 21: Metro Plan Element: F. Transportation Element Land Use Policy F.1: Apply the nodal development strategy in areas selected by each jurisdiction that have identified potential for this type of transportation-efficient land use pattern. Land Use Policy F.2: Support application of the nodal development strategy in designated areas through information, technical assistance, or incentives. Attachment 1, Page 10 of 11 Land Use Policy F.3: Provide for transit-supportive land use patterns and development, including higher intensity, transit-oriented development along major transit corridors and near transit stations; medium- and high-density residential development within one-quarter mile of transit stations, major transit corridors, employment centers, and downtown areas; and development and redevelopment in designated areas that are or could be well served by existing or planned transit. Land Use Policy F.4: Require improvements that encourage transit, bicycles, and pedestrians in new commercial, public, mixed use, and multi-unit residential development. Land Use Policy F.5: Within three years of TransPlan adoption, apply the ND, Nodal Development, designation to areas selected by each jurisdiction, adopt and apply measures to protect designated nodes from incompatible development and adopt a schedule for completion of nodal plans and implementing ordinances. Land Use Policy F.19: Establish a BRT system composed of frequent, fast transit service along major corridors and neighborhood feeder service that connects with the corridor service and with activity centers, if the system is shown to increase transit mode split along BRT corridors, if local governments demonstrate support, and if financing for the system is feasible. The subject area is identified as Site 7B on the “Potential Nodal Development Areas for the Eugene- Springfield Metro Area” map of TransPlan. By design, nodal development areas encourage pedestrian, bicycle and transit-oriented transportation uses – something that has already occurred on the Sacred Heart Medical Center site with construction of walking paths, bicycle lanes and bike parking areas, and existing and planned transit service. Future mixed use, commercial, and medium density residential development in the subject area will be required to address these standards. As stated previously, the planned EmX bus rapid transit line will serve the Gateway area including the subject site (the EmX Gateway line is projected to start service in 2010). Finally, the City previously adopted amendments to the Metro Plan and the Gateway Refinement Plan in anticipation of nodal development in the subject area. Implementation of the nodal development designation for the subject area is consistent with provisions of the adopted TransPlan and, therefore, is consistent with Metro Plan Policies F.1 through F.5 and F.19. Finding 22: Metro Plan Element: G. Public Facilities and Services Element Policy G.1: Extend the minimum level and full range of key urban facilities and services in an orderly and efficient manner consistent with the growth management policies in Chapter II-B, relevant policies in this chapter and other Metro Plan policies. The subject area is located inside the Springfield city limits and the UGB. All necessary infrastructure and key urban facilities/services are present to serve existing development or are available to serve future development in the subject area in conjunction with site plan review. Therefore, the proposal is consistent with the above policy. METRO PLAN AMENDMENT CONCLUSION AND RECOMMENDATION Staff finds that the proposed amendment meets the criteria of SDC 5.14-135.C.1 & 2. After review of the adopted City land use plans and studies, evidence provided by staff research, existing uses in the subject area, and the applicable criteria of approval, staff finds that the proposed Metro Plan Amendment is appropriate for the subject area. Attachment 1, Page 11 of 11 NODAL IMPLEMENTATION FOR MCKENZIE-GATEWAY SITE PLANNING CASE LRP2009-00001 Attachment 2, Page 1 of 3 NODAL IMPLEMENTATION FOR MCKENZIE-GATEWAY SITE PLANNING CASE LRP2009-00001 Attachment 2, Page 2 of 3 NODAL IMPLEMENTATION FOR MCKENZIE-GATEWAY SITE PLANNING CASE LRP2009-00001 Attachment 2, Page 3 of 3 ORDINANCE NO 610Q EMERGENCY AN ORDINANCE AMENDING THE GATEWAY REFINENEMENT PLAN BY CHANGING APPROXIMATELY 99 ACRES OF MEDIUM DENSITY RESIDENTIAL PLAN DESIGNATION TO COMMUNITY COMMERCIAL AND MIXED USE PLAN DESIGNATION AT THE GATEWAY MDR SITE AND AMENDING THE GATEWAY REFINEMENT PLAN TEXT TO ALLOW IMPLEMENTATION OF THE COMMUNITY COMMERCIAL AND MIXED USE DESIGNATIONS WITH MIXED USE COMMERCIAL AND MEDICAL SERVICES ZONING DISTRICTS TO ALLOW FOR THE DEVELOPMENT OF A lIOSPITAL ASSOCIATED MEDICAL OFFICE RETAIL AND RESIDENTIAL USES TO PRESERVE THE POTENTIAL FOR NODAL DEVELOPMENT TO REQUIRE A MASTER PLAN TO BE APPROVED BY THE CITY COUNCIL AND DECLARING AN EMERGENCY The City Council ofthe City of Springfield finds that A Article 8 ofthe Springfield Development Code sets forth criteria for refinement plan diagram and text amendments B On April 21 2003 The Springfield City Council approved Gateway Refinement Plan amendments by adopting ordinance 6051 C The April 21 2003 Gateway Refinement Plan amendments were appealed to the Land Use Board of Appeals and to the Oregon Court ofAppeals D On August 19 2004 the Land Use Board ofAppeals LUBA remanded the GatewayRefinementPlanamendmentstothecityforadditionalfindingsinrespecttoStatewide Planning Goal 9 Economic Development Goal 12 Transportation and as instructed by the Court ofAppeals consistency with Metro Plan policies regarding auxiliary uses in the residential designations Eo Subsequent to the LUBA remand the Springfield City Council reopened the record on Metro Plan diagram amendment Journal Number 2002 08 243 and Gateway Refinement Plan amendment Journal Number 2002 08 244 and initiated amendments to the Springfield Development Code Journal Number LRP2004 0020 and Springfield Commercial Lands Study Journal Number LRP2004 0021 F Timely and sufficient notice ofthe public hearing pursuant to Section 14 030 ofthe Springfield Development Code was provided G On November 16 2004 a public hearing on the Gateway Refinement Plan amendment was convened and concluded The record ofthe proceedings was left open for seven days followed by a seven day period ofall participants to submit rebuttal The applicant was given two additional days for rebuttal The Development Services staff notes including criteria ofapproval findings and recommendations together with the testimony and submittals ofthose persons testifying at the hearing or in writing have been considered and are part ofthe record ofthe proceeding Page 1 of 13 110 05 H On December 9 2004 the Springfield Planning Commission voted five in favor one opposed and one abstaining to forward a recommendation that the City Council approve the Gateway Refinement Plan amendments with conditions I On January 10 2005 the Springfield City Council reopened the pubic hearing to accept oral argument and deliberate The City Council voted 5 in favor 1 opposed and 0 abstaining to approve the Gateway Refinement Plan ordinance and declaring an emergency J Evidence exists within the record and the findings attached hereto as Exhibit B that the proposal meets the requirements ofArticle 8 ofthe Springfield Development Code NOW THEREFORE THE CITY OF SPRINGFIELD DOES ORDAIN AS FOLLOWS Section 1 The Gateway Refinement Plan is hereby amended to reflect the text changes depicted in Exhibit B the Gateway Refinement Plan diagram is hereby amended to reflect the changes approved by the Council in the concurrent Metro Plan Diagramamendment Section 2 The above findings A through 1 and the findings set forth in Exhibit C attached hereto and incorporated herein by reference are hereby adopted in support ofthe Gateway Refinement Plan amendments Section 3 This Ordinance replaces Ordinance 6051 adopted by the City Council on April 21 2003 Section 4 If any section subsection sentence clause phrase or portion of this Ordinance is for any reason held invalid or unconstitutional by any court of competent jurisdiction that portion shall be deemed a separate distinct and independent provision and that holding shall not affect the validity of the remaining portions ofthis Ordinance Section 5 This Gateway Refinement Plan amendment is subject to the conditions of approval attached hereto in Exhibit A Section 6 It is hereby found and determined that this Gateway Refinement Plan amendment is a matter affecting the public health safety and welfare and that an emergencythereforeexistsandthatthisordinanceshalltakeeffectimmediatelyuponitspassagebythe Council and approval by the Mayor ADOPTED by the Common Council ofthe City of Springfield by a vote of 5 for and L against and 0 abstaining on this 10th day of January 5 REVIEWED APPROVEDAFO Attest ORDINANCE NO 6109 Page 2 of 13 110 05 EXHIBIT A Conditions of Gateway Refinement Plan Approval Jo No s 2002 08 244 CONDITION 1 Master Plans for property at the McKenzie Gateway MDR site that propose to employ the Mixed Use Commercial District MUC and orthe Medical Services District MS shall include a vehicle trip monitoring plan as a component of a complete application submittal The approval of the plan shall be a requirement of Master Plan approval Trip generation estimates used to create the trip monitoring plan shall be performed using assumptions and methods which are consistent with those employed in the traffic impact analysis submitted to the City of Springfield on October 29 2004 in support ofMetro Plan and Gateway Refinement Plan amendment applications City Journal Numbers 2002 08 243 2002 08 244 Traffic generated by land uses within Master Plan boundaries where the MS and MUC zoning districts are proposed in Phase 1 of the development shall prior to 2010 be limited to a maximum of 1 457 PM Peak Hour vehicle trips Beginning in 2010 for Phase 2 of the development such traffic shall be limited to 1 840 PM Peak Hour vehicle trips PM Peak Hour vehicle trips are defined as the total of entering plus exiting trips measured for the PM Peak Hour ofAdjacent Street Traffic Subsequent Site Plan Review applications for sites within the Master Plan boundaries shall be in compliance with the approved trip monitoring plan Any proposal that would increase the number of allowable PM Peak Hour vehicle trips for the MS and MUC area beyond the above specified limits shall be processed as a refinement plan amendment or a zoning map amendment or Master Plan approval pursuant to SDC 37 040 or Master Plan modification pursuant to SDC 37 040 and 37 060 3 and regardless ofwhich type of process is sought each shall demonstrate compliance with applicable provisions ofthe Transportation Planning Rule for such proposal CONDITION 2 Prior to occupancy of the first phase of any hospit llocated at the Gateway MDR site as approved by a future Master Plan a portion of TransPlan project 727 chapter 3 page 31 Dec 2001 adopted version and as adopted by City of Springfield Ordinance No 5990 dated September 17 2001 shall be constructed by the applicant The portion of the project to be constructed by the applicant is conceptually described as roadway and traffic signal improvements at the Pioneer Parkway OR 126 Eastbound Ramps to Page 3 of 13 1 10 05 ORDINANCE NO 6109 1 Maintain two southbound through lanes on Pioneer Parkway at the OR 126 eastbound ramp terminal intersection 2 Provide two southbound left turn lanes on Pioneer Parkway at the OR 126 eastbound ramp terminal intersection 3 Widen the eastbound on ramp to provide two lanes to accept the two eastbound turn lanes described above in Number 2 These two on ramp lanes will merge to one lane prior to merging with OR 126 traffic eastbound 4 Widen the eastbound OR 126 off ramp to three lanes for a minimum distance of 300 feet west of Pioneer Parkway and 5 Any necessary signal modifications to accommodate Numbers 1 4 above The funding for these improvements shall come from PeaceHealth s financial responsibility for off site transportation improvements as described in the annexation agreement dated June 4 2002 Lane County Recorder s number 2002 043161 between the applicant and the CIty of Springfield To the extent that these funds are determined to be insufficient to perform the above described improvements the applicant shall be responsible for the additional funding needed Any subsequent Master Plan application for property at the Gateway MDR site that proposes to apply the MS and or MUC zoning district shall include specific designdrawingsfortheabovedescribedimprovementswhichshallbesubmittedtoODOT for approval ODOT approval ofthe proposed design shall be a condition of Master Plan approval CONDITION 3 The master plan required by Residential Element Policy 13 0 by the Annexation Agreement dated May 29th 2002 Recorder s Reception No 2002 043161 Lane County Deeds and Records and by the Annexation Agreement dated June 7 2001 Recorder s Reception No 2001 034714 Lane County Deeds and Records for property owned byPeaceHealth a Washington nonprofit corporation on the date of Council approval of plan amendments 2002 08243 and 2002 08244 shall include a hospital as a component of the master plan Further the hospital and other master plan development on the property referenced in this condition shall be phased as follows No uses will occur before 2008 Phase 1 will occur between 2008 and 2010 and is limited to uses generating no more than 1 457 PM Peak Hour vehicle trips Phase 2 will open no earlier than 2010 and orfollowing construction of the GatewayStreetBeltlineRoadintersectionimprovementsandwillbelimitedtouses generating no more than 1 840 PM Peak Hour vehicle trips for all development on properties redesignated by this ordinance These phases may occur earlier if needed transportation facilities are in place or if required mobility standards are lowered provided mobility standards are maintained Page 4 of 13 110 05 ORDINANCE NO 6109 CONDITION 4 In the event that a master plan with a hospital fails to gain approval by the City Council by May 29 2007 the City Council will initiate amendments to the Metro Plan and the Gateway Refinement Plan to revise the documents to adequately plan for development of the Gateway MDR site without a hospital CONDITION 5 Prior to occupancy of the first phase of any hospital located at the Gateway MDR site as approved by a future Master Plan the applicant shall construct a portion of the Beltline Road Gateway Street Intersection project which is a component of TransPlan Project 606 chapter 3 page 16 July 2002 adopted version The portion of the project to be constructed by the applicant is a traffic signal at the Beltline Road Hutton Road intersection CONDITION 6 Development on property at the McKenzie Gateway MDR site where the MS andor MUC zoning district are applied shall be subject to the following condition Any Subdivision or Site Plan Review application approval that relies upon transp rtation facility improvements to support the subject development shall be in compliance with an approved Master Plan If the subject transportation improvements are not open to travel by the motoring public at the time they are needed to support the Subdivision or Site Plan Review development the approval shall be subject to the enforcement and revocation proceedings of Springfield Development Code 1 050 1 and 2 Page 5 of 13 110 05 ORDINANCE NO 6109 EXHffiIT B Gateway Refinement Plan Text Amendments Jo No s 2002 08 244 Amend Residential Element Policy and Implementation Action 2 Ensure availability of adequate supplies of land appropriate for low medium and high density residential development MaiDtaiD approximately the existiBg balaDee amoDg LDR lIDR aDd HDR desigDated laDds eODsisteDt with lfetro PlaD alloeatioDs while allowine for an appropriate mix of commercial employment and residential uses Amend Residential Element Policy and Implementation Action 12 0 Allow limited rezoning of land within the McKenzie Gateway MDR site to Medical Services MS on land desienated Community Commercial or Mixed Use on the Metro Plan diae ram and rezonine to Mixed Use Commercial MUC on land desienated Mixed Use on the Metro Plan diae ram as implemented durine a Master Plan and or durine the City s nodal implementation proiect Deighborhood eommereial iD order to promote reteDtioD aDd rehabilitatioD of historie properties that may otherwise beeome DOB eODformiDg uses to promote limited publie or semi publie aeeess to aDd view of the l feKeBZie River aDd to allow far provisioD of seFViees speeifieally iDteDded to meet Deeds of future resideDts iD this Mea Amend Residential Element Policy and Implementation Action 12 1 RezoDiDg to NC will be allowed far up to 3 aeres Total ofvaeaDt laDd withiD the MeKeBZie Cateway lIDR Site UDder the followiDgprovisioDs a The property requested for rezoDiDg shall froDt OD a eolleetor or arterial that is either existiDg or plaDDed iB aD adopted CDP for the NleKeDzie Cateway MDR Site or that eurreBtly borders the site b Proposed ZODe ehaDges shall be reviewed UDder a Type III proeedure iB aeeordaDee with rtiele 3 of the SDC aDd shall be eODsisteDt with all provisioDs of SDC rtiele 12 ZODiDg Distriet aDd Overlay District ChaDges Page 6 of 13 1 10 05 ORDINANCE NO 6109 e This type of rezoDing shall Dot be approved uDtil at least 25 pereeDt of the aDtieipated dwelliDg uDits are eODstrueted based OD aD average of 15 dwelliBg UDitS per aere Redesienation of a total of 99 acres land within the city limits at the McKenzie Gateway MDR site to Community Commercial and or Mixed Use throueh the Metro Plan amendment process shall be allowed and shall be implemented by application of Mixed Use Commercial MUC or Medical Services MS zonine district throueh Master Plan approval and or durine the City s nodal implementation proiect Amend Residential Element Policy and Implementation Action 124 NC uses loeated withiD the MeKeDZie Cateway lIDR Site shall meet the following provisioDs iD additioD to the provisioDs of SDC frtiele Mf a The maximum floor area of aDY siBgle NC use shall Dot exeeed 4 000 square feet b ParkiDg areas shall Dot be visible from the lfeKeDZie River eorridor aDd shall be sereeDed from puhlie streets iD a maDDer whieh does Dot obseure visibility of the use aDd e Puhlie aeeess to the lfeKeDZie River shall be provided by NC uses abuttiDg the ripariaD setbaek In addition to all applicable standards and provisions reeulatine development in Sprinefield any development adiacent to the McKenzie River or McKenzie River riparian setback shall provide public access to the McKenzie River or McKenzie River riparian setback Surface parkine areas shall not be visible from the McKenzie River corridor and shall be screened from public streets Add new Residential Element Policy and Implementation ActionI2 5 MU districts within the McKenzie Gateway MDR Site shall meet the provisions of SDC Article 40 Add new Residential Element Policy and Implementation Action 12 6 Within the city limits at the McKenzie Gateway MDR Subarea the Medical Services MS zonine district shall implement the Community Commercial desienation if part of an approved Master Plan for development of a maior medical facility The adopted Master Plan shall demonstrate that the subiect property will be able to accommodate the number of housine units within the rane e for the MDR land use desienation in the Metro Plan and Gateway Refinement Plan Page 7 of 13 110 05 ORDINANCE NO 6109 e e In addition to meetine the standards of the SDC at the time of Master Plan approval the City Council may attach specific conditions on all development within the MS or MUC zones includine but not limited to buildine heieht and setbacks Amend Residential Element Policy and Implementation Action 13 0 A CDP or Master Plan shall be approved under a Type IIIV review process for the areas lare er than 5 acres within the city limits at mapped as the McKenzie Gateway MDR Site on the Refinement Plan diagram subsequent to annexation and prior to aDDexatioD aDd urban development of any portion of thesite Master Plan area Delete 13 1 Residential Element Policy and Implementation Action 13 1 The CitJT shall begiD preparatioD of a CDP by JaDuary 1 1992 and shall approeaCDP DO later thaD JUl T1 1993 ID the iDterim a CDP m be submitted by the initial developer of a POrtiOD of the site A CitJT iDitiated CDP shall iDvolve iBput from the affeeted property owners aDt appropriate publie ageDeies Amend Residential Element Policy and Implementation Action 132 The CDP shall be prepared by aD engiDeer aDd ODe of the fallowiDg aD arehiteet laDdseape arehiteet or plaDDiDg professioDal A Master Plan for the McKenzie Gateway MDR site shall be prepared by a desien team that shall include as determined by the Director the followine consultants architect landscape architect civil eneineer eeotechnical eneineer acoustic eneineer certified arborist transportation ene ineer and a consultant to address riparian issues Amend GRP Residential Element Policy and Implementation Action 133 Page 8 of 13 1 10 05 All development within the McKenzie Gateway MDR Site shall be consistent with ail approved bDPMaster Plan AD approved CDP may be modified by the iDitial developer a subsequeDt developer or the City UDder a Type II review proeess ORDINANCE NO 6109 Amend Residential Element Policy and Implementation Action 134 The CDP In addition to the requirements of SDC Article 37 the Master Plan shall address at a minimum the following development issues a Preservation and enhancement of natural assets identified in this Refinement Plan b Access and circulation needs c Access to arterial and collector streets d Provision of public facilities and services e Development needs of future users 1 LoeatioD of areas larger thaD ODe aere proposed for auxiliary uses iBeludiDg Deighborhood eommereial fg Provision of open space areas and gll Public access to the McKenzie River Amend Residential Element Policy and Implementation Action 135 4pplieatioDs for the iDitial CDP or for substaDtial modifieatioDs to aD approved CDP In addition to the requirements of SDC Article 37 the initial Master Plan application in the McKenzie Gateway MDR site shall include a conceptual street map and bicycle and pedestrian circulation system plan for all annexed property in the McKenzie Gateway MDR site and shall be exempt from the requirements of Section 3 050 2 b of the SDC Delete Residential Element Policy and Implementation Action 13 6 The CDP shall be eODsisteDt with the goals aDd polieies of the lfetro PlaD aDd of this RefiDemeDt PlaD Add new Residential Element Policy and Implementation Action 13 6 Master Plan applications for property within the McKenzie Gateway MDR site submitted prior to the City s completion ofnodal development assessment and implementation shall identify all areas within one Quarter mile of proposed transit stations as beine subiect to the provisions ofthe Nodal Development Overlay District INDO Any proposed uses density and desien in the identified nodal development area shall comply with the standards of Sprinefield Development Code articles 40 and or 41 with the followine exception Uses in the MS and MUC Districts may be exempted from specific provisions ofArticles 40 and Articles 41 and residential and eroup care facilities in the MDR district may be exempted from specific provisions of Article 41 if the respective exemptions are consistent Page 9 of 13 1 10 05 ORDINANCE NO 6109 with the Purpose of the Nodal Development Overlay District and the exemptions are approved by the City Council as part of a master plan In the event that the City Council determines that nodal development is appropriate for the identified nodal area the property shall be re desienated to INDO and all subsequent land use applications shall comply with INDO standards contained within articles 40 and or 41 except as exempted above In the event that the City Council determines that nodal development is inappropriate for areas identified as such on the master plan those areas shall be chaneed throueh a Type II process to reflect the underlyine MS or MUC zonine and any use density or desien on the master plan that does not comply to underlyine zonine desienation shall be chaneed accordinely All subsequent land use applications shall comply with the standards required in the underlyine zonine district Add new Residential Element Policy and Implementation Action 13 7 Page 10 of 13 1 10 05 Master Plans for property at the McKenzie Gateway MDR site that propose to apply the MUC and or MS zonine district pursuant to Residential Policies and Implementation Actions 12 1 and 12 6 shall be subiect to the followine requirements 1 An approved trip mooitorine plan shall be a requirement of Master Plan approval 2 The trip monitorine plan shall demonstrate compliance with all conditions contained within applicable plan amendment adoption ordinance s and trip eeneration estimates shall be performed usine assumptions and methods which are consistent with those employed in the plan amendment traffic impact analysis 3 Traffic eenerated by land uses within the Master Plan boundaries where the MS and MUC zonine districts that are proposed in Phase 1 of the Development shall prior to 2010 be limited to a maximum of 1 457 vehicle trips Beeinnine in 2010 for Phase 2 of the Development traffic eenerated from site development within the subiect districts shall be limited to 1 840 PM Peak Hour vehicle trips Vehicle trips are defined as the total of enterine plus exitine trip as estimated or measured for the PM Peak Hour of Adiacent Street Traffic This trip monitorine plan limits allowed land uses to be consistent with the planned function capacity and performance standards of affected transportation facilities 4 Subsequent Site Plan Review applications for sites within the Master Plan boundaries shall be in compliance with the approved trip monitorine plan ORDINANCE NO 6109 5 Any proposal that would increase the number of allowable PM Peak Hour vehicle trips for the MS and MUC area beyond the limits specified in section 3 above shall be processed as a refinement plan amendment a zonine map amendment or Master Plan approval pursuant to SDC 37 040 or modification pursuant to SDC 37 040 and 37 060 3 and reeardless ofwhich type of process is soue ht each shall demonstrate compliance with applicable provisions of the Transportation Plannine Rule for such proposal Delete Residential Element Policy and Implementation Action 14 0 through 14 8 no change since April 21 2003 Council approval 14 0 DeyelopmeDt Area PlaD DAP shall be approedUDder a Tpe II reyiew proeess prior to development approval for aDY portioD ofthe area mapped as the MeKeDZie Cateway lIDR Site on the RefiDemeDt PlaD Diagram and shall Dot be approved uDless it is eODsisteDt with aD approyed CDP The iDteDt of the DAP is to provide resolutioD of sigaifieaDt developmeDt issues at a seale aDd level of speeifieity that are iDtermediate to the CDP aDd Site PlaD levels All DAP s shall eODfarm to the followiDg requiremeDts 14 1 DAP s shaD address the followiDg developmeDt issues at a miDimum a ProisioD of adequate eireulation far the DevelopmeDt Area and its adjoiDing properties iDeludiDg dedieatioD of right of way for future streets and pathways showD OD the approyed CDP b ProlisioD of eoordiDated exteDsioD of publie faeilities to sen e the site aDd surrouDdiBg properties aDd e IDeorporatioD to the maximum exteDt praetieable of Datural assets identified iB this RefiDemeDt PlaD aDd OD the approved CDP 14 2 D P s shall inelude the followingiDformatioD at a miDimum ll sigaifieaDt site features iDeludiDg draiDageways existiDgvegetationandothernaturalassetsasidentifiediDthisRefinement IIam Proposed buildiDg footpriDts Proposed opeD spaees aDd laDdseaped areas EDgiDeering studies of aDideDtified Datural hazards e g for developmeDt withiD the 100 year floodplaiB Proposed aeeess and eireulatioD iDeluding roads drives parkiDg areas aDd bieyele aDd pedestriaD pathways aDd all other proposed laDd uses 14 3 If the DAP eomplies with all Site PlaD Review staDdards ofthe SDC subsequeDt permitted uses that eODform to the D P shall Dot require additioDal site plaD review This implemeDtatioD aetioD is iDteDded to simplify the developmeDt approval proeess for large Page 11 of 13 110 05 ORDINANCE NO 6109 phased developmeBts b allowiBg a suffieieBtly detailed DAP to meet both DAP aBd Site PlaB requiremeBts 144 D P s shall be eOBsisteBt with the approved CDP aBd with the polieies of the fetro PlaB aBd of this RefiBemeBt JIim 14 5 Site PlaBs for portioBs of a development area shall eOBfarm with aB appr ed DAP provided however that the DAP may be modified as permitted iB implemeBtatioB aetioB 14 6 14 6 SubstaBtial modifieatioBs ofDAP s shaD be reviewed uBder Type II proeedure iB aeeordaBee with rtiele 3 of the SD 14 7 The miBimum DevelopmeBt rea for MDR designated area shall be 5 aeres 14 8 The miBimum size for DevelopmeBt freas may be redueed if approved by the Development SeFViees Direetor iB iBdividual iBstaBees where iBsuffieient vaeaBt laBd oWBership patterns lot eOBfiguration or abuttiBg existiBg uses prohibit eOBsolidatioB of pareels to aehieve a 5 aere DevelopmeBt Area Amend Residential Element Policy and Implementation Action 15 1 Development density may be transferred from natural assets and recreational pathways identified in the Natural Assets Open Space Scenic Areas and Recreation Element or from proposed shared open spaces to buildable portions of the development area provided that the gross density of the development area does not exceed 20 dula aBd the Bet deBsity OB the buildable portioB does Bot eueed 25 dula the maximum density permitted in the underlyine zone Add new Residential Element Policy and Implementation Action 19 0 Density bonuses allowed under Residential Element Implementation Actions 15 1 and 16 3 may be allowed consistent with an approved Master Plan pursuant to SDC Article 37 within the McKenzie Gateway MDR Site Amend Commercial Element Policy and Impleme tation Action 5 0 revised since April212003Councilapproval Provide for future appropriately planned Mixed Use Community Commercial and nodal development desie nated areas BeighborhoodeommereialdevelopmeBtiBtheMediumDeBsityResideBtial development area east of Game Farm Road within the City Limits at Page 12 of13 1 10 05 ORDINANCE NO 6109 the McKenzie Gateway MDR site as identified in TransPlan as potential nodal development sites Amend Commercial Element Policy and Implementation Action 5 1 No more thaB 3 aeres ofNC uses eaB be zOBed as part of the lfedium Density ResideBtial area This rezoniBg shall Bot be approved uBtil at least 25 pereeBt of the aBtieipated total dwelliBg uBits iB the area are eOBstrueted The Beighborhood eommereial area shall be sited iB a loeatioB that presented the least traffie Boise aBd lighting eOBfliets with adjaeeBt resideBtial uses properties iBveBtoried iB the Historie Resourees ElemeBt as sigBifieaBtresourees may be rezoBed to NC aBd are exempt from this provisioB Rezonine of land within the city limits at the McKenzie Gateway MDR site to Mixed Use Commercial MUC and Medical Services MS shall be allowed to implement the Mixed Use and or Community Commercial plan desienations Zone chanees shall demonstrate the ability to meet the demand for commercial lands identified in the Sprinefield Commercial Lands Study SCLS policy I B Commercial uses allowed in zonine districts pursuant to GRP Policy 5 0 above shall be subiect to Master Plan approval and shall be planned in a manner to minimize traffic noise and lie htine conflicts with adiacent residential uses Amend Transportation Element Policy and Implementation Action 13 0 Future transportation system development in the McKenzie Gateway Campus Industrial and the 180 acre MDR sites should occur as needed in conjunction with CI and MDR MUC and MS development Amend Public Facilities Element Policy and Implementation Action 2 2 Require the consideration of the use of storm drainage facilities that store and retain runoff in the McKenzie Gateway Campus Industrial site and within the city limits in the proposed lIDR area east of Came Farm Road South McKenzieGateway MDR Site Require the consideration of the use and enhancement of natural storm water drainage features as part of the overall storm water systems in those areas Page 13 of 13 110 05 ORDINANCE NO 6109 Exhibit C City of Springfield City Council Findings of Fact and Conclusions of Law Metro Plan Map and Gateway Refinement Plan Map and Text Amendments City Journal Numbers 2002 08 243 and 2002 08 244 I INTRODUCTION AND BACKGROUND A Procedural Background On April 21 2003 the City of Springfield City Council adopted Ordinance 6050 and Ordinance 6051 the Decisions or PAPA I Ordinance 6050 amended the Metropolitan Area General Plan Metro Plan Diagram by re designating up to 33 acres of land from Medium Density Residential MDR to Community Commercial CC within the Springfield city limits at the Gateway MDR site1 Ordinance 6051 amended the Gateway Refinement Plan GRP Diagram and text to allow among other things the Medical Services MS zone to be applied to up to 66 acres ofMDR designated land within the Gateway MDR site The Decisions were appealed to the Land Use Board of Appeals LUBA Nos 2003 072 2003 073 2003 077 and 2003 078 LUBA remanded the Decisions back to the City to allow the City to adopt additional findings with respect to Statewide Planning Goals Goals 9 and 12 LUBA s decision in turn was appealed to the Oregon Court ofAppeals In its decision the Court reversed in part and affirmed in part LUBA s decision In particular the Court affirmed LUBA s decision with respect to the Goal 9 and Goal 12 issues The Court however agreed with the petitioners Robin and John Jaqua that the Metro Plan residential land auxiliary use provisions would not allow the City to apply the MS zone to MDR designated property at the Gateway MDR site because according to the Court the size and scope of the proposed hospital development would change the primary 1 Reference to the Gateway MDR site includes only the annexed property owned by PeaceHealth and as depicted on Exhibit D The entire Gateway MDR site is approximately 200 acres in size The City s decision in this matter only applies to approximately 1574 acres ofthe Gateway MDR site within the city limits as depicted in Exhibit D Page 1 of 123 110 05 use of the land from residential to commercial Based on the Court s definition of auxiliary use the Court concluded that the kinds of uses contemplated by the challenged ordinances are not permitted uses in an area designated for residential use If the city wishes to use the area in question for the commercially related uses authorized by the ordinances it will have to un ertake a zone change or other change authorized by the Metro PlanJaqua v City ofSpringfield 194 Or App 573 2004 The Court s and LUBA s decisions are in the record Based on the Court s decision on August 19 2004 LUBA remanded the Decisions to the City As discussed in greater detail below PeaceHealth has elected to revise the original proposal to make certain additional GRP text amendments and to increase the amount of commercially designated land from 33 acres to 44 acres In particular the revised proposal will designate approximately 50 acres as Mixed Use MU and 44 acres as CC on the Metro Plan and GRP diagrams Consequently instead of eventually placing the MS zone on MDR designated land the amendments on remand will allow the MS zoning to be placed on land designated CC and possibly MU on the Metro Plan and GRP diagrams Although the Metro Plan designations in this revised proposal are larger than in the original proposal the eventual zoning of the subject property will be nearly identical as the original proposal In the original proposal the MS zoning was to be located on MDR designated property Through this revised proposal the eventual MS zoning will be located on a mixture ofMU and CC designated property This change responds to the Court s direction B Summary of Request on Remand 1 Diagram Amendments a Description of Amendments The Gateway MDR site is presently designated on the Metro Plan and GRP for residential development Ofthe 157 acres of the Gateway MDR site subject to this approval approximately 1 1 acres are designated for Low Density Residential LDR while the remaining 156 acres are desigriated MDR on both the Metro Plan and GRP diagrams The revised diagram amendments will result in the following designations and allocations Metro Plan Desi nation Acrea e Page 2 of 123 110 05 Mixed Use MU Mixed Use Commercial MUC MS 49 5 Community Commercial CC Medical Services MS 43 9 Medium Density Residential 65 5 Low Density Residential 1 1 The location of the amended Metro Plan Diagram and potential future zoning are attached as Exhibits C l and C 2 b Explanation of Amendments The Court of Appeals held that in order to utilize the Gateway MDR site for a hospital which the Court characterized as a commercial use the City would have to re designate the area from MDR to a commercial designation The Court found that even though the MS zoning regulations specifically allow the MS district to be applied to MDR designated lands the Metro Plan s residential auxiliary use provisions would prevent the size and scope of the MS zoning on MDR designated land In short the Court held that if the City wants to use the Gateway MDR site for a hospital and commercial uses the Gateway MDR site must be re designated as commercial on the Metro Plan and GRP Diagrams In accordance with the Court s direction PeaceHealth has modified the proposal such that the area slated for eventual MS zoning will be applied to land designated CCon the Metro Plan diagram In the original proposal PeaceHealth sought to amend the Metro Plan Diagram to allow for up to 33 acres ofCC designated land with an eventual zoning designation ofMUC and 66 acres ofMDR designated land to be rezoned to MS In the revised proposal PeaceHealth seeks to amend the Metro Plan and GRP Diagrams to designate approximately 50 acres as MU and approximately 44 acres as CC on both the Metro Plan and GRP diagrams with subsequent rezoning of approximately 50 acres as MUC and 44 acres for MS 2 Text Amendments The revised proposal amends the text of the GRP The proposed text amendments are attached hereto Page3 of 123 1 10 05 II PROCEDURE AND APPLICABLE STANDARDS ON REMAND A Scope of Proposal on Remand As discussed above LUBA remanded the Decisions to the City Two bases for the remand addressed only deficiencies in the City s findings findings regarding Goals 9 and 12 Revised findings addressing these Goals are included herein The third basis for remand was that portion of the Decisions that authorized rezoning of the MDR designated property to the MS zone This basis for remand directs the City to modify the underlying plan designation to commercial before imposing the MS zone Nothing in either appellate decision prohibits the land uses proposed in the original proposal or otherwise determined that the MS zone was inappropriate for the proposed hospital On remand PeaceHealth seeks to revise the proposal to address the issues identified in the Court and LUBA decisions In practical effect however the revised proposal is nearly identical to the original proposal Upon ultimate development of PeaceHealth s project the development will still include a hospital mixed commercial uses and residential development The proposed development will be in the same general location as was originally envisioned Indeed the location of the proposed development and the nature of the proposed uses out shown on PeaceHealth s Master Plan have not been modified The Dajor difference however is how the underlying property is designated on the Metro Plan and GRP diagrams Both appellate bodies stated that in order to permit the proposed development on the subject property the City had to change the underlying plan designation of the property to a commercial designation from the existing MDR designation This proposal on remand responds directly to that portion of the Court s decision 1 Reyised Map Amendments The primary difference between the original proposal and the proposal on remand is that instead of placing MS zoning on MDR designated land the MS zoning will be applied to property designated CC and MU on the Metro Plan Diagram This action is consistent with the Court s direction to the City that if the City desires to use the Gateway MDR site for hospital and mixed use commercial uses the City will have to re designate such areas for commercial uses rather than residential uses The MU Metro Plan designation is one that allows a variety of uses including mixed commercial and residential uses The appropriate mix of uses is normally determined through local refinement plans 2 Remand Text Amendments The remand proposal amends the text and map of the GRP Neither the Court nor LUBA concluded that the Decisions violated Goal 9 Rather the Court and LUBA held that the City did not adequately explain how the proposal complied with Page 4 of 123 1 10 05 the SCLS Specifically LUBA held that the City s findings did not adequately explain the differences between SCLS Implementation Strategies and SCLS Policies In particular LUBA found that the City did not adequately explain and apparent inconsistency between Implementation Strategy I B 2 and SCLS Policy I B The map amendments on remand and the City s findings set forth herein further explain the City s policy decision to allocate approximately 94 acres ofMDR designated land to CC and MU A legislative action undertaken by the City as a corollary to the changes set forth in this decision amends SCLS Implementation Strategy I B 2 to clarify that this proposal is an effective method of implementing SCLS Policy I B 3 Authority to Approye Reyised Proposal on Remand Neither the SDC nor the Metro Plan provide any specific procedures or guidelines as to how the City should process an application on remand There is however no prohibition on amending an application on remand LUBA in fact has upheld decisions that have involved substantial modifications on remand The cases addressing an applicant s ability to modify its application on remand from LUBA generally hold that the local government has substantial latitude in determining whether revisions to an application require treatment as a new application See e g Sullivan v City of Woodburn 33 Or LUBA 356 1997 In that opinion LUBA concluded that the city may in the absence of a code prohibition or some other obstacle identified by petitioner find the modified proposal to be a continuation of the original application In this case the revisions proposed by PeaceHealth are directly responsive to the issues raised by LUBA and the Court In particular both LUBA and the Court were concerned with the underlying plan designation for the property planned to become MS zoned property In response the proposal has been modified to re designate portions of the property from MDR to CC and MU Additionally interested parties have had the opportunity to provide written and oral testimony the right to rebuttal and the right to make final arguments to the City Council thus assuring that their substantive rights have not been prejudiced Section IV includes the City s Findings regarding the specific issues raised by the parties participating in this proceeding on remand Finally there is no express prohibition in the SDC limiting the ability to revise a proposal application on remand It is appropriate therefore to process the revised proposal through the remand procedure The text amendments on remand and the City s findings are similarly designed to respond directly to the concerns raised by the Court and LUBA with respect to Goal 9 and Goal 12 As discussed above neither the Court nor LUBA held that the proposal constituted a de facto violation of Goal 9 Rather both held that the City s findings failed to adequately explain how the original proposal was consistent with SCLS Implementation Strategy I B 2 as a means to further SCLS Policy I B The revised amendments directly respond to this issue by providing additional findings Page 5 of 123 1 10 05 J policy support and direction for the re designation of property from MDR to CC and MU tt B Type of Metro Plan Amendment Amendments to th Metro Plan are classified as Type I or Type II amendments depending upon the specific changes sought through the amendment at MetroPlan IV 2 The Court of Appeals determined that the PAPA I amendments to the Metro Plan and GRP approved through the Decisions were site specific amendments appropriately decided under the single jurisdiction Metro Plan s Type II amendment process Consequently the Court held that the Metro Plan did not require that either the City ofEugene or Lane County approve the Decisions As explained below the Metro Plan and GRP amendments on remand remain site specific and relate to property solely within the City of Springfield Accordingly the current proposal is properly characterized as Type II amendments that need only be approved by the City of Springfield The Metro Plan defines Type II amendments as A ny change to the Plan diagram or Plan text that is site specific and not otherwise a Type I category amendment With respect to each amendment the amendments on remand remain Type II site specific amendments In particular individually and collectively the amendments are Type II site specific amendments because they Involve a specific geographically identifiable property Do not change the Metropolitan Urban Growth Boundary Do not change the Metro Plan jurisdictional boundary Do not require a goal exception Do not include a non site specific amendment of the Metro Plan text and Apply only to property located within the Springfield City limits Under the text of the Metro Plan as well as the Court of Appeals and LUBA s decisions the amendments on remand remain Type II site specific amendments Page 6 of 123 1 10 05 1 Metro Plan Diagram and GRP Diagram Amendments As with the original proposal the Metro Plan Diagram amendments on remand are site specific and relate only to property wholly within the City Although the amount of commercially designated land has increased from 33 acres to approximately 44 acres and now includes 50 acres of MU designated land the Metro Plan amendment is solely a plan diagram amendment and applies only to property in the Gateway MDR sub area As both LUBA and the Court found by limiting the diagram amendments to a specified geographic area the diagram amendments are site specific within the meaning ofthe Metro Plan Because the location of the current diagram amendments has not changed the diagram amendments remain Type II site specific amendments 2 GRP Text Amendments Both LUBA and the Court found that original GRP text amendments were Type II site specific text amendments The primary reason for this conclusion was that the text amendments applied solely to a specified geographic area entirely within the City that is the Gateway MDR area described on Exhibit A Although the GRP text amendments have been modified slightly to reflect the modified proposal and the issues identified by LUBA and the Court the modifications do not alter the fact that the GRP text amendments apply solely to an identifiable geographic area entirely within the City of Springfield city limits For the reasons that both LUBA and the Court found the original GRP text amendments to be Type II site specific amendments the current proposal remains a Type II site specific amendment 3 Regional Impact Type II amendments entirely within the boundary of the City of Springfield must only be approved by the City Metro Plan IV Policy 5 d If the amendments have a Regional Impact the non home city in this case the City of Eugene may participate in the decision The City of Eugene has been notified of the proposed amendments and it has not made affirmative findings that the amendments will cause a Regional Impact In fact the City of Eugene has provided no testimony or evidence on remand nor did it provide any testimony or evidence during the course of the original proceeding Consequently the City of Eugene is not required to participate in the decision Page 7of 123 1 10 05 III RESPONSE TO APPROVAL CRITERIA A Applicable Standards and Criteria 1 Metro Plan Amendments Type II Metro Plan amendments are evaluated according to the criteria of approval contained within SDC 7 070 3 which provides The following criteria shall be applied by the City Council in approving or denying a Metro Plan amendment application I The amendment must be consistent with the relevant Statewide planning goals adopted by the Land Conservation and Development Commission and 2 Adoption of the amendment must not make the Metro Plan internally inconsistent 2 Refinement Plan Amendments Refinement plan amendments are subject to the criteria contained in SDC 8 030 which provides in part In reaching a decision the Planning Commission and the City Council shall adopt findings which demonstrate conformance to the following 1 The Metro Plan 2 Applicable State statutes 3 Applicable Statewide Planning Goals and Administrative Rules B Statewide Planning Goals Because the criteria of approval for both the Metro Plan amendments and the GRPamendments require compliance with Statewide Planning Goals the following findings address compliance of all the Metro Plan Diagram and GRP amendments with the Statewide Planning Goals In some instances certain Metro and GRP amendments are discussed individually with respect to a certain goal In other Page 8 of 123 1 10 05 instances the findings relate to all of the amendments Where individual amendments are not referenced the findings relate to all the proposed amendments GOAL 1 CITIZEN INVOLVEMENT The City has an acknowledged citizen involvement program and an acknowledged process for securing citizen input on all proposed plan amendments During the initial proceedings the City provided a greater opportunity for citizens to participate in the decision than is required under the SDC by holding a de novo hearing before both the Planning Commission and the City Council On remand the City held a joint public hearing before the Planning Commission and the City Council The joint hearing was held on November 16 2004 During the initial hearing interested parties were allowed to testify in person and proVide written testimony and evidence The record was then left open for a seven day period to November 23 2004 to allow all participants to provide additional written testimony and evidence The record remained open for an additional seven day period to November 30 2004 to allow all parties the opportunity to submit rebuttal testimony PeaceHealth was then provided an additional two day period in which to provide final rebuttal testimony After the Planning Commission recommended approval of the proposal on remand the City Council held a public hearing on January 9 2005 At the final City Council hearing interested parties were provided a final opportunity to provide argument to the City Council Generally Goal 1 requires every city and county to develop and implement a citizen involvement program As LUBA has recognized Goal 1 does not provide due process protections nor does it dictate the conduct of local government hearings Dobson v PolkCounty 22 Or LUBA 7011992 Rather the manner in which local government hearings are conducted and the procedural requirements for such hearings are governed by statute See ORS Chapter 227 Where notice of a hearing has been provided and public testimony considered LUBA has found no Goal 1 violation Chambers v Josephine Cqunty 13 Or LUBA 180 1985 The Metro Plan contains a citizen involvement program satisfying Goal 1 Metro Plan at III K l to III K 4 The City has complied with these provisions of the Metro Plan The City continued to comply with these provisions throughout the remand proceeding The amendments on remand do not affect the Citizen Involvement element of the Metro Plan Accordingly the amendments do not violate Goal 1 Similarly because the City adhered to the Citizen Involvement Element of the Metro Plan throughout the remand process the City s procedure in reviewing the amendments on remand is consistent with Goal I Section IV of these Findings includes additional findings regarding Goal I compliance in response to testimony provided by interested parties Page 9 of 123 1 10 05 GOAL 2 LAND USE PLANNING Goal 2 requires that local comprehensive plans be consistent with the Goals that local comprehensive plans be internally consistent ahd that implementing ordinance be consistent with acknowledged comprehensive plans Goal 2 also requires that land use decisions be coordinated with affected jurisdictions and that they be supported by an adequate factual base The Metro Plan and the SDC as well as the Statewide Planning Goals and applicable statutes provide policies and criteria for the evaluation of comprehensive plan amendments Compliance with these measures assures an adequate factual base for approval of the amendments As discussed elsewhere in this document the amendments are consistent with the Metro Plan and the Goals Consequently by demonstrating such compliance the amendments satisfy the consistency element of Goal 2 ORS 197 610 requirestheCity to forward a notice of proposed Metro Plan and refinement plan amendments to Department of Land Conservation and Development at least 45 days before the first evidentiary hearing on adoption Notice was provided to DLCD on June 30 2004 The first evidentiary hearing was held on Noverpber 16 2004 Revised notices were sent to DLCD on September 2 2004 Under Goal2 the City is not required to accorrimodate all of the concerns of interested governmental agencies but the City must respond in its findings to the legitimate concerns of affected agencies In the PAPA I proceeding LUBA concluded that the City s responses to affected governmental agencies satisfied Goal 2 Neither the City of Eugene nor Lane County have provided any testimony or other evidence regarding the proposal on remand although they were both provided with notice of proposal on remand GOAL 3 AGRICULTURAL LANDS This goal is inapplicable because it applies only to rural agricultural lands and the subject property is within an acknowledged urban growth bo ndary OAR 660 15 000 3 GOAL 4 FOREST LANDS Goal 4 does not apply within urban growth boundaries OAR 660 06 0020 The areas affected by these plan amendments are inside an acknowledged urban growth boundary Goal 4 is therefore inapplicable Page 10 of 123 1 10 05 GOAL 5 OPEN SPACE SCENIC AND HISTORIC AREAS NATURAL RESOURCES Goal S requires local governments to protect a variety of open space scenic historic and natural resource values Goal S and its implementing rule OAR Ch 660 Division 16 require planning jurisdictions at acknowledgment and as a part of periodic review to 1 identify such reSources 2 to determine their quality quantity and location 3 to identify conflicting uses 4 to examine the economic social environmental and energy ESEE consequences that could result from allowing limiting or prohibiting he conflicting uses and S to develop programs to resolve the conflicts Other than the fir grove located on the subject property no part of the Gateway MDR site is on an acknowledged Metro Plan GoalS inventory No threatened or endangered species have been inventoried on the site No archeological or significant historical inventoried resources are located on the site There are areas of prominent vegetation and a wetland area on the properties subject to these amendments While these natural assets have not been adopted into an acknowledgedGoalS inventory they are inventoried in the GRP The criteria of approval for master plans that will apply to development on the site upon approval of these applications requires that Inventoried natural resources wetlands open space areas archaeology and historic features are evaluated and considered consistent with the Oregon Administrative Rule procedure for Statewide Planning Goal 5 This policy ensures development permitted by these plan amendments will be consistent with Goal S The master plan review will ensure implementation The subject property has been planned and zoned for intensive urban development and use since the Metro Plan and implementing ordinances were acknowledged in 1982 Under the Metro Plan inventoried GoalS resources on sites designated for urban residential industrial and commercial are protected by a program to achieve the goal that limits such development by the application of protective standards at the time of review of specific development applications where Goal S resources have been identified The current amendments do not alter this acknowledged program to achieve the goal Page J 1 ofI23 1 10 05 The Environmental Resources Element of the Metro Plan implements Goals S 6 and 7 and is implemented in turn by the City s land use regulations Objective 2 requires the integration of open space and natural features into the design of urban development Policies 1 2 and 4 require consideration of downstream impacts of development prohibit development in the floodway if it increases flood levels and require site specific soils and geological studies where potential problems exist Policies 18 and 19 restrict development in wetlands areas Policy 20 encourages local governments to regulate development in such a manner as to better control drainage erosion storm runoff and to reduce street related water quality and quantity problems These policies are fully implemented by the City s adopted and acknowledged standards and procedures for the subdivision and development of land within the City While there are slight differences between the revised amendments and those approved through the Decisions for purposes of a Goal S analysis there is no substantive difference between the two versions of the amendments In particular there are no differences between the versions that would implicate Goal S Because no party challenged the amendments consistency with Goal S in the earlier proceeding before LUBA or the Court of Appeals the participants in this remand proceeding cannot now challenge the amendments consistency with GoalS Section IV of these Findings include additional Goal S related findings in response to the specific issues raised during the remand process GOAL 6 AIR WATER AND LAND RESOURCES QUALITY The purpose of Goal 6 is to maintain and improve the quality of the air water and land resources of the state Generally Goal 6 requires that development comply with applicable state and federal air and water quality standards In the context of a PAP A Goal 6 requires that the applicant demonstrate that it is reasonable to expect that applicable state and federal environmental quality standards can be met Applicable state and federal requirements regarding air water and land resources are either implemented through the standards adopted by the SDC and applicable development standards or imposed and enforced by state or federal agencies Because the proposal does not authorize any specific deelopment at this time there can be no direct impact to air water or land resources In fact pursuant to the GRP text amendments no hospital or commercial development may occur until after master plan approval During that phase of the project the potential impacts of the development will be known When development occurs on the subject Property all such development must necessarily comply with local state and federal regulations protecting air water and land resources Given that the subject property is currently zoned for medium density residential development it is reasonable to expect that the incremental increase in development allowable through this proposal will be able to comply with applicable state and federal environmental quality standards Page 12 of 123 1 10 05 While there are slight differences between the amendments on remand and those approved through the Decisions for purposes of a Goal 6 analysis there are no substantive differences between the PAPAl and the amendments on remand that implicate Goal 6 Because no party challenged the amendments consistency with Goal 6 in the earlier proceeding before LUBA or the Court of Appeals the participants in this remand proceeding cannot now challenge the amendments consistency with Goal 6 Section IV of these Findings include additional Goal 6 related findings adopted in response to testimony presented to the City GOAL 7 AREAS SUBJECT TO NATURAL HAZARDS Goal 7 requires that development subject to damage or that could result in loss of life not be planned or located in known areas of natural hazards and disasters without appropriate safeguards The goal also requires that plans be based on an inventory of known areas of natural disaster and hazards No part of the subject property contains steep slopes Before LUBA opponents argued that the amendments did not comply with Goal 7 raising a number of objections LUBArejected the opponents arguments with respect to Goal 7 and held that the Decisions were consistent with Goal 7 As discussed elsewhere although there are variations between the amendments on remand and the PAPA I amendments for purposes of Goal 7 there are no substantive or practical differences The amendments do not affect any additional geographic area nor is any specific develop ent is proposed Consequently for purposes of Goa1 7 there is no substantive change between the amendments on remand and the PAPAl approved amendments the current proposal remains consistent with Goal 7 Notwithstanding LUBA s earlier rejection of Goal 7 related challenges opponents have again raised Goal 7 related challenges The findings in Section IV address these issues GOAL 8 RECREATIONAL NEEDS Goal 8 requires local governments to plan and provide for the siting of necessary recreational facilities to satisfy the recreational needs of the citizens of the state and visitors Responsible governmental agencies must plan to meet these needs 1 in coordination with private enterprise 2 in appropriate proportions and 3 in such quantity quality and locations as is consistent with the availability of the resources to meet such requirements OAR 660 015 000 8 Advisory guidelines for meeting Goal 8 encourage planners to give priority in meeting such needs to areas facilities and uses that a meet recreational needs requirements for high density population centers Page 13 of 123 1110 05 b meet recreational needs of persons oflimited mobility and fin ces c meet recreational needs requirements while providing the maximum conservation of energy both in the transportation of persons tot he facility or area and in the recreational use itself d minimize environmental degradation e are available to the public at nominal cost and f meet needs of visitors to the state The GRP indicates no proposed public park located within the Gateway MDR site The Willamalane Park and Recreation Comprehensive Plan the Springfield Bicycle Plan and TransPlan depict an alignment for a future multi use pathway throughout the site and along the McKenzie River TransPlan the Willamalane Park and Recreation Comprehensive Planand the Springfield Bicycle Plan show the pathway traversing the site from Game Farm Rd South to Deadmond Ferry Road on the north Gateway Refinement Plan Map 1 Natural Assets shows two areas of Other Prominent Vegetation the maple and fir groves and a wetland area listed as MRSS SiteS16 During the PAPAl proceeding in response to public testimony regarding access to the McKenzie River GRP Residential Implementation Action 124 was amended to require that any development adjacent to the McKenzie River must provide public access to the river The amendments on remand have not revised this implementation action The future multi use path will provide a connection within this area and to adjacent areas as well as recreational use within the site The alignment and ultimate function of the pathway will be fully analyzed by the City and Willamalane during the master plan and site plan review stages of site development During the analysis of these future land use decisions the following GRP policies will be applied to the decision in the analysis of the pathway alignment and for the potential for other open space recreational needs Natural Assets Open Space Scenic Areas and Recreation Element 1 5 GRP at 34 The City and Willamalane shall work together topromote and enable recreational and educational use of the McKenzie river side and floodway in ways that are sensitive to the natural resource values and private property uses in the area Page 14 of 123 1 10 05 2 2 The City ofSpringfield and Willamalane shall cooperatively evaluate 1 the potential of the McKenzie Riverfloodway area to help meet long term open spate and recreation needs and 2 thefeasibility and desirability of acquiring and or preserving the floodway area for those purposes 71 GRP page 37 through the site plan review process require wetland delineation of the possible wetland at Game Farm Beltline NRSS Site 16 prior to development approval 84 GRP page 37 Through the site plan review process the City shall encourage reasCnable retention ofexisting trees paying particular attention to those inventoried in this Element as prominent and plentiful vegetation 9 6 GRP page 38 The City and Willamalane shall seek easements for bikewaylpathways along the McKenzie River riparian corridor as identified in Willamalane s 1980 Comprehensive Plan and its 1990 draft PROSplan None of these refinement plan policies will be altered by the proposed amendments The existing planned extensions of multi use paths the existing policies of the Gateway Refinement Plan relating to preservation of natural resources and provision of open space and proposed GRP Residential Implementation Action 124 will ensure the City s and Willamalane s ability to adequately meet the recreational requirements of Goal 8 during the review of any development that these plan amendments will permit Although there are variations between the current revised proposal and the earlier amendments for purposes of Goal 8 there are no substantive or practical differences between the current amendments and those approved by the City through the Decisions The current amendments do not affect any additional geographic area and have no impact on the City s earlier Goal 8 findings Consequently because there is no substantive difference between the proposed amendments and the earlier approved amendments for purposes of Goal 8 the current proposal remains consistent with Goal 8 Finally no party challenged the earlier decisions compliance with Goal 8 Because there are no substantive differences between the present proposal and the earlier proposal with respect to Goal 8 no party may now challenge the proposal s consistency with Goal 8 GOAL 9 ECONOMIC DEVELOPMENT Goal 9 requires the City to provide adequate opportunities for a variety of economic activities vital to the health welfare and prosperity of the citizens Page 15 of 123 1 10 05 The proposed Metro Plan diagram amendments when implemented through the approved master plan will increase the City s capacity for economic development by adding approximately 50 acres ofMU and 44 acres ofCC in place of the existing MDR designations The underlying plan designations will be implemented through MUC and MS zoning on the MU plan designation and MS zoning on the CC plan designation Both zones will facilitate a nodal overlay The redesignation and eventual rezoning to MUC and MS will permit ri1Ultiple economic activities that cannot now take place on the subject property s MDR designation including a robust mix of commercial uses and health services Under the Decisions the City approved a 33 acre redesignation from MDR to CC with an eventual zoning of MUC On appeal LUBA held that the City s findings did not demonstrate that the Decisions were consistent with SCLS Implementation Strategy I B 2 pecause that strategy calls for the rezoning of 10 15 acres within the Gateway MDR site Consequently LUBA found that the Decisions were not consistent with Goal 9 s administrative rules that among other things require local jurisdictions to demonstrate compliance with local Goal 9 related elements of local comprehensive plans 1 Background on SCLS Goal 9 requires that during periodic review local jurisdictions adopt provisions in their comprehensive plan to comply with the requirements of Goal 9 OAR 660 009 0010 2 During the City s most recent periodic review the City undertook a city wide commercial lands study as required by Metro Plan Economic Element Policy 32 and LDCD The City did so and adopted the SCLS which has been acknowledged as being in compliance with Goal 9 Although the SCLS did not amend the Metro Plan the SCLS is intended to guide the City with respectto commercial development In adopting the SCLS the City expressly reserved the right to utilize additional strategies in meeting the commercial needs of the City One of the primary conclusions set forth in the SCLS is that there is a deficit of commercially zoned land within the City The SCLS explains that 255 acres of commercial land will be needed to the year 2015 and most importantly the SCLS identifies a deficit of 158 acres of commercially zoned land within the City The SCLS contains findings policies and implementation measures which are designed to help provide a greater supply of developable commercial land in the City Thus the primary conclusion in the SCLS is that there is an identified deficit of 158 acres of commercial land within the City The current proposal which redesignates a total of approximately 94 acres to MU and CC is consistent with the need to address the defiCit identified in the SCLS OAR 660 009 0010 4 generally requires that when a local jurisdiction changes comprehensive plan designations in excess of two acres to or from commercial it must demonstrate that such change is consistent with the parts Page 16 of 123 1 10 05 of its comprehensive plan which address the requirements of Goal 9 The Metro Plan MU designation is not technically a commercial designation Rather the MU plan designation is an independent designation much like the Airport Reserve Forest Lands and Agricultural Metro Plan designation However because the MU designated land will ultimately have the MUC zone applied it the City has included the 50 acre MU area for purposes of the City s Goal 9 analysis a Releyant Findings in SCLS The primary conclusion of the SCLS is that there is a shortage of suitable commercial siteswithinthe Springfield UGH to meet the long term demand for commercial land as indicated by the vacant commercial land inventory and the demand analysis set forth in the SCLS Similarly the demand analysis conclusion in the SCLS states that the City is faced with a difficult situation There are not enough commercial sites to facilitate quality commercial development or the future demand for commercial land and expanding the UGB is not a feasible option to achieve more commercial acreage SCLS at 31 In order to address this difficult situation the SCLS recognizes that to implement some of the policies to achieve better commercial development certain policies from specific refinement plails may have to be amended or deleted The SCLS recommends several amendments to the various Refinement Plans The implementation strategies identified in the SCLS are tools that the City can utilize to implement the policies of the SCLS Moreover as discussed above the resolution adopting the SCLS provides that the City may utilize additional mechanisms to meet the commercial needs of the City The SCLS describes the findings policies and implementation strategies as follows Afinding is a factual statement resulting from investigation analysis or observation A policy is a statement adopted to provide a consistent course of action moving the community towards attainment of its goals An implementation strategy is a specific course of action the City can take to accomplish the objective of the policy Together the findings policies and implementation strategies establish a factual base of existing supply and demand for commercial land and offer recommendations of specific strategies the City can take to accomplish the objectives of the policies Tht SCLS does not mandate a specific course of action Instead it identifies certain actions that the City may take in order to address the identified deficit of 158 acres of commercial land Through the Decisions the City elected to designate up to 33 acres Page 17 of 123 10 05 of conunercialland in the Gateway MDR site LUBA found that the City did not adequately explain how this was consistent with Implementation Strategy I B 2 which called for the rezoning of 10 15 acres of land to conunercial within the Gateway MDR site In explaining LUBA s difficulty with the City s decision to redesignate 33 acres when the SCLS called for 1 O 15 acres LUBA stated In part because no party offers any argument concerning the comparative legal significance of SCLS policies and implementation strategies we do not mean to foreclose the possibility that the city mightbe able to adopt additional findings that explain why an action that seems so inconsistent with SCLS Implementation Strategy 1 B 2 which is directed specifically at the GRP MDR area is nevertheless consistent with the SCLS We decide here only that the explanation in the challenged decision is inadequate Jaqua slip op 32 Can is not a mandatory term Can is a permissive term and in the context of Implementation Action Strategy 1 B 2 allows the City to rezone 10 to 15 acres to NC but does not mandate that it do so If the City had intended the Implementation Strategies to be mandatory inflexible and the final word on the City s options for implementing the policies of the SCLS the SCLS would have used mandatory words such as must and prohibited Similarly if the City had intended that alternative strategies were to be prohibited there would have been an express prohibition Thus in adopting the SCLS the City exp essly reserved the right to adopt and implement a variety of strategies to assure that the City can meet the identified deficit of conunerciallands in the City One implementation strategy forthe City to meet the identified conunercial lands cteficit is to redesignate 94 acres from MDR to CC andMU SCLS Policy 1 B requires the City to ensure that there is an adequate amount of conunercialland in the McKenzie Gateway area Similarly SCLS Policy 3 A requires the City to redesignate and rezone property within Neighborhood Centers an9 Conunercial Center nodes to Mixed Use Conunercial Neither ofthese policies establishes any minimum or maximum amounts to be redesignated Instead that decision is left to future City action provided that such actions are consistent with the underlying policies The current proposal meets both of these policies by a partially addressing the 158 acre deficit b providing an adequate amount of land within the Gateway MDR area and c establishing the foundation for rezoning the area identified for nodal development toMU Page 18 of 123 1 10 05 Additionally the NC zoning referenced in the Implementation Strategy I B 2 predates the adoption of the new MUC zoning district which enables appropriately scaled commercial uses to be integrated with other uses ina vertical mixed use design including both residential and commercial uses Because the NC zoning does not allow vertical stacking of uses the use ofNC zoning would result in less efficient use of the land base than would the MUC zoning As a practical matter the use ofMUC zoning wilf allow the City the ability to meet nodal development objectives as called for in the Metro Plan the GRP and identified in the SCLS It also will provide for a mix of employment residential and supporting commercial uses With respect to TransPlan the use of the MUC zoning will facilitate implementation of nodal development strategies within the Gateway MDR site Additional SCLS findings policies and implementation measures support the use ofMUC zoning rather than NC zoning For example SCLS Finding 3 provides that that certain TransPlan nodes encompass residential land and that to achieve higher average density to make these nodes function residential land within t e nodes needs to be redesignated and rezoned to Mixed Use Commercial SCLS at 36 The Amendments support and implement this finding Similarly Implementation Strategy 3 Al provides Evaluate inventories based on demonstrated need for the planning period Initiate rezoning or redesignation of surplus land uses where more appropriate for commercial consistent with the Metro Plan SCLS at 36 The City has an acknowledged surplus ofMDR designated land Accordingly it is entirely consistent with this Implementation Strategy to redesignate additional MDR land to MU and CC given the surplus ofMDR designated property in the City Through this proposal the City is reducing a surplus to meet a deficit In the present situation the proposal is to designate a total of approximately 94 acres ofMDR to MU and CC Given the overall 1 58 acre deficit of commercial land in the City the current proposal goes a long way towards reducing this deficit While the 94 acre designation is larger than the 10 15 acres called for in Implementation Strategy I B 2 as discussed above use of the word can in describing the purpose of the implementation strategies demonstrates that 10 15 acres is not a maximum but a recommendation given the facts knOWIl to the City at that time This notion is supported by SCLS Policy I A which calls for the creation of additional commercial land through both zoning and annexation Policy I A merely recognizes that the SCLS has not included every possible mechanism to meet the deficit Indeed even if all the implementation strategies were implemented based on the recommended acreage set forth in the SCLS there would still be a deficit of commercial land Page 19 of 123 1 10 05 4 Because Implementation Strategies are defined by the SCLS as actions that the City can take to accomplish the objectives of the City s overarching policy to provide sufficientland for commercial development the City is not prevented from taking actions in addition to those identified as Implementation Strategies provided of course that such actions are consistent with the Policies and Goals of the SCLS Although th 94 acre proposal is larger than the 10 15 acre suggestion in the SCLS the proposal still directly addresses the overall policy objective to provide adequate commercial land and partially addresses the City s acknowledged deficit of commercial land Finally the City adopted the SCLS pursuant to Resolution No 00 13 That resolution provides in part The Common Council of the City of Springfield does hereby adopt the Springfield Commercial Lands Study as more particularly described and set forth in Attachment A and as modified by Attachment B as the policy document guiding the provision of commercial lands within the Springfield Urban Growth Boundary Nothing herein limits the City Council from using a variety of strategies to implement the policies in the document Emphasis added Thus the adopting resolution expressly provides that the strategies and implementation policies of the SCLS are not the only options available to the City to implement the policies of the SCLS As discussed above one overridiIg policy set forth in the SCLS is to provide an adequate amount of commercial land The current proposal which reduces the deficit of commercial land is a strategy to implement the policies of the SCLS Furthermore although the City has expressly interpreted SCLS Implementation Policy I B 2 to pf0vide no absolute limit on the amount of land within the Gateway MDR area to be redesignated to commercial to meet the overriding policy of SCLS Policy 1 B the City has also approved a legislative amendment to the SCLS which further explains the City s interpretation of this Implementation Policy Thus although the City has elected to amend the SCLS through a separate legislative action the City expressly finds that such amendment is not necessary to approve this proposal Rather the legislative amendment is simply a further support for the City s interpretation that the actions taken through the remand proposal are consistent with the present and amended version of the SCLS Some opponents have argued that rather than demonstrating compliance with the SCLS the City has elected to amend the SCLS That is not the case As the findings above demonstrate the City finds that the proposal on remand is consistent with SCLS IImplementation Strategy I B 2 The legislative amendment to the SCLS is not Page 20 of 123 110 05 necessary to approve this proposal on remand because the proposal is consistent with the current version of the SCLS as well as the amended provisions of the SCLS A considerable amount of testimony was submitted with respect to Goal 9 The findings set forth in Section IV respond to the additional Goal 9 related issues GOAL 10 HOUSING LCDC s Housing goal requires cities to maintain adequate supplies of buildable lands for needed housing as follows Goal To provide for the housing needs ofcitizens ofthe state Buildable landsfor residential use shall be inventoried and plans shall encourage the availability ofadequate numbers of housing units atprice ranges and rent levels which are commensurate with thefinancial capabilities ofOregon households and allowfor the flexibility ofhousing location type and density The 1999 Eugene Springfield Residential Land and Housing Study RLS adopted by the Cities and recognized by DLCD contains a technical analysis which assigns density to the buildable portions of the area subject to the plan amendments Portions of the RLS including the demand aIld supply figures have been adopted as part of the Metro Plan III A 3 If this area were to develop under the current MDR designation and GRP policies staff would review the RLS study to ensure that any residential development would achieve the minimum density assigned to e properties in the RLS Proposed Residential Implementation Action 12 6 requires a similar type of analysis to take place at the master plan level The policy reads the adopted masterplan shall demonstrate that the site will be able to accommodate the number ofhousing units within the range for the MDR land use designation in the Metro Plan and the GRP This language ensures that the same number of dwelling units that could be constructed under the existing MDR designation and zoning will be realized and therefore ensures compliance with Goal 1 O During the crafting of the master plan PeaceHealth will be able to rely on the permitted uses in more than one zoning district to meet the required density The proposed plan amendments will allow for two zoning districts MUC and MS to replace existing MDR zoning on approximately 99 acres of the site The amendments will also facilitate the siting of the nodal overlay on the subject property as well as on adjacent property through the City s nodal implementation project Each of these districts allows residential uses In the MUC district up to 100 percent of any building may be developed for residential uses so long as 60 percent of the total ground floor area wi n the development area is devoted to commercial uses In the MS district Page 21 of 123 1 10 05 housing for the elderly and handicapped and residential care facilities are prjmary uses SDC 22 020 In the area designated nodal which as the proposed GRP policy 13 6 describes the overall density for all districts will be 12 units per acre Additionally in the MDR district there is a 20 unit per acre maximum with a nodal overlay there is no maximum density Density is limited only by the maximum height restriction Proposed Implementation Action 12 6 requires that any future master plan for development of the site iriclude housing density that has been assigned by recognized plans to the areas subject to these plan amendments for this reason alone Goal 10 is satisfied The RLS concludes that the area has 828 acres ofMDR designated land with a demand of 589 acres leaving a surplus of 239 acres This surplus is set forth in the acknowledged Metro Plan The report also concluded that the area has a surplus of 3 646 MDR designated units through the planning horizon The Metro Plan and GRP diagram Amendments on remand propose to redesignate approximately 50 acres from MDR to MU and 44 acres from MDRto CC leaving a surplus of 148 2 acres of MDR designated property At LUBA opponents argued that the Decisions violated Goal 10 LUBA rejected this challenge and found that the Decisionss complied with Goal 10 The primary basis for LUBA s affirmation was the fact that the RLS demonstrates that there is a surplus of239 acresofMDR designated land and that even upon removal of 99 acres from the inventory accounting for the MS and MUC zones in the PAPAl there would still be a surplus ofMDR designated land While the proposal on remand removes close to 99 acres from the MDR designation to a commercial designation as recognized by LUBA even upon such removal under the acknowledged RLS a surplus of 148 2 acres ofMDR designated land will remain The City is obligated to rely on its acknowledged buildable land inventory Set forth in the RLS and Metro Plan Although it is possible that the RLS does not reflect the current MDR inventory due to intervening development as LUBA recognized the City is entitled to rely on the acknowledged inventory in the RLS Indeed as the Court of Appeals has stated under Goal 2 s consistency requirement the City is required to rely on its acknowledged inventory as reflected in the RLS and Metro Plan In DS Parklane Development Inc v Metro 165 Or App 1 2000 the Court of Appeals held that when considering the appropriate amount of land to be brought within the Metro UGB Metro was obligated under Goal 2 to base its computation of need on Metro s acknowledged functional plan and other applicable planning documents Thus unless and until the City amends the RLS or the Metro Plan the Page 22 of 123 1 10 05 City is obligated to utilize the acknowledged inventory when considering whether the current proposal is consistent with Goal 10 and the Goal J a related provisions of the Metro Plan In the PAPA I proceeding LUBA also recognized that notwithstanding the surplus of MDR designated land identified in the RLS after the removal of up to 99 acres from the inventory the amended GRP implementation measures 12 6 require PeaceHealth s master plan to demonstrate that it can accommodate the number of housing units within the range for the previously designated MDR land That requirement is not chang 4 in the proposal on remand The GRP text amendments require that future development on the site provide a sufficient number of residential units at required MDR densities to ensure continued conformance to Goal 10 requirements and to maintain the existing surplus Additionally Residential Implementation Action 12 6 requires that any master plan for the Gateway MDR site demonstrate that the assigned number of dwelling units for this site are preserved This ensures that the proposal will not cause a reduction in the estimated housing inventory for the Metro area ensures that these amendments are in compliance with this policy There is evidence in the record that it is feasible to provide the required number of housing units on the subject property There is ample buildable residential land remaining at the Gateway MDR site to meet these objectives Considerable testimony was presented regarding Goal I O Section IV includes additional GoallO related findings GOAL 11 PUBLIC FACILITIES AND SERVICES This goal requires the provision of a timely orderly and efficient arrangement of public facilities and services Prior to annexation of the property subject to these amendments the property owner and the City entered into several annexation agreements that prohibit development on the properties until an adequate level of urban services are extended to serve the property These urban services are listed in the annexation agreements which have been made part of the record of these proceedings and include but are not limited to sanitary sewers solid waste management water service fire and emergency medical service police protection parks and recreation programs electric service land use controls communication facilities public schools paved streets and storm water controls The annexation agreements also require that a master plan be approved prior to development This requir ment mirrors the policy requirement contained within the proposed GRP Residential ImplementationAction 13 0 Master plan approval criteria require a demonstration the proposed on site and off site public and private Page 23 of 123 1 10 05 improvements are sufficient to accommodate the proposed phased development and capacity requirements of the Public Facilities Plan The restrictions on development contained within the annexation agreements for property subject to these plCnamendments coupled with the master plan criteria of approval ensure compliance with Goal 11 Finally although there are variations between the current revised proposal and the earlier amendments for purposes of Goal 11 there are no practical differences between the current amendments and those approved by the City through the Decisions The current amendments do not affect any additional geographic areas and have no impact on the City s earlier Goal 11 findings Consequently because there is no substantive difference between the proposed amendments and the earlier approved amendments for purposes of Goal 11 the current proposal remains consistent with Goal 11 Finally no party challenged the earlier decisions compliance with Goal 11 Because there are no substantive differences between the present proposal and the earlier proposal with respect to Goal 11 no party may now challenge the proposal s consistency with Goal 11 during this remand proceeding GOAL 12 TRANSPORTATION AND OAR 660 012 0060 1 AND 2 lnthe initial plan amendments PAPA I the City adopted findings explaining how the decisions satisfied Goal 12 PAPA I Record pages 222 and 223 Findings pages 41 and42 The petitioners appeal to LU A did not challenge the Goal 12 findings Therefore the City readopts the same findings in this proceeding The 2004 Transportation Impact Analysis the TIA demonstrates that for all of the affected intersections between 2005 and 2020 Goal 12 is satisfied because development under the proposed plan and zoning designations will either 1 be served by a safe and adequate transportation system currently in place or planned to be in place in time to handle expected impacts or 2 will not create substantially greater or different transportation demands and impacts than development under the existing acknowledged designations The explanation for these findings are contained in Part B below and are incorporated herein by reference 1 TPR OAR 660012 0060 1 and 2 the Transportation Planning Rule a The PAPAl decisions regarding TPR In PAPAl the City adopted findings on the TPR at Findings pages 42 55 PAPAl Record pages 223 236 On appeal the petitioners argued that the findings failed to demonstrate that the City had considered whether the proposed post acknowledgment plan amendments would Page 24 of 123 1 10 05 cause or accelerate the failure of a transportation facility within the planning period between 2004 and 2018 2 LUBA remanded the City s decision and the Court ofAppeals affirmed LUBA s decision regarding the TPR because it concluded that the TPR required the City to address whether a temporary failure of a transportation facility would occur and if so whether the City could implement mitigation measures to correct the failure In affirming LUBA s final order and opinion the court held First we do not understand LUBA s opinion to do more than conclude that an interim failure of an affected facility is a significant effect on a transportation facility under OAR 660 012 0060 2 and that consequently the mitigation measures set out in the rule at subsection 1 must be considered Our understanding and LUBA s does not mean that the rule necessarily requires that before an approved change in land use occurs that road improvements must occur The rule offers alternatives to the locallarid use planning body However importantly the rule does nQt authorize any delay in implementing the mitigating factors in subsection 1 until the end of the planning period once it is determined that a land use regulation significantly effects a transportation facility Jaquav City ofSpringfield 193 Or App 573 2004 b The 2004 TIA The applicant has updated the TIA in response to the decisions by LUBA and the court The 2004 TIA takes into account each affected transportation facility beginning in year 2005 and ending in year 2020 considering background traffic growth and additional traffic generated by the post acknowledgement plan amendments The TIA concludes that any transportation facilities significantly affected by the post acknowledgment plan amendments will either be remedied by improvements in the acknowledged Transportation System Plan for the City of Springfield TrarisPlan or will be remedied through mitigation measures pursuant to OAR 660 012 00601 a d 3 2 For purposes ofthese findings and the 2004 TIA the applicant has changed the planning period required by Oregon Highway Plan Action 1F 2 from 2004 2018 to a beginning year in 2005 and an ending year in 2020 This reflects a new year ofadoption of2005 3 The Transportation Planning Rule is the only transportation related approval criteria at issue in the remand from LuBA As noted above the petitioners did not raise compliance with Statewide Planning Goal 12 Page 25 ofl23 1 10 05 The 2004 TIA relies ori the same methodology as the 2002 TIA but accounts for changes to the assumed designs for elements of the traffic and circulation system in the area of this application The changes are as follows a refinement of the Martin Luther King Jr Parkway design and construction of the Harlow RoadHayden Bridge RoadMartin Luther King Jr Parkway intersection as a roundabout instead of a signalized intersection c Relevant time periods The 2004 TIA is divided into the time periods shown below It takes into account background traffic growth and additional traffic that will be generated by the post acknowledgIent plan amendments The phasing is as follows Between 2005 and 2008 no traffic will be generated by the uses allowed by this application because their construction will be incomplete The 2004 TIA assumes background traffic growth for each year during this time period Phase I 2008 2010 Construction of a hospital and medical office buildings containing 1 185 million square feet These uses will begin to open in 2008 The 2004 TIA assumes that the 1 185 million square feet of development limited to 1 457 pm peak hour vehicle trips will be occupied in 2008 The 2004 TIA assumes background traffic growth for the years 2008 through 2010 Phase 11 2010 2020 The remainder of the PeaceHealth square footage subject to the trip cap limit of 1 840 p m peak hour trips will open in 2010 The 2004 TIA assumes no additional transportation facility construction from 2010 through 2020 The 2004 TIA assumes background traffic growth for the years 2010 through 2020 4 d OAR 660 012 0060 2 The first step in determining compliance with the TPRis todetern1ine whether there is a significant effect If there is no significant effect the City need not consider the mitigation measures under OAR 660 012 0060 1 a d 4 Petitioners at LUBA did not challenge the underlying assumptions ofthe original TIA its methodology or the use ofa trip cap as a mitigation measure pursuant to OAR 660 012 0060l a Page 26 of 123 1110 05 i Adequacy of existing transportation facilities The City must first determine whether existing transportation facilities are adequate to handle the amendments throughout the relevant planning period of 2020 Ifthe City finds the answer to be yes then the City can find that there is no significant effect under OAR 660 012 0060 2 The 2004 TIA shows that all but four existing transportation facilities are adequate to handle the expected trips up to the trip cap maximum of 1 840 p m peak hour trips created as a result of these amendments Throughout the planning period all of the affected intersections will have a volume to capacity v c or a level of service LOS equal to or less than that which would otherwise occur without the approval of these amendments assuming a limitation on vehicle trips Therefore regarding these four facilities the City must address the second step a TransPlan Project No 768 Martin Luther King Jr Parkway Extension Lane County is designing and constructing this project pursuant to an intergovernmental agreement IGA between the City and Lane County PeaceHealth pursuant to its Annexation Agreement has committed to pay for a portion of the construction Lane County will pay for the remainder Based on Page 27 of 123 1110 05 substantial evidence in the whole record the City finds that this project will be complete at the latest by 2008 in time for use in Phase 1 b TransPlan Project No 60615 at Beltline Road This project is contained in the Oregon Transportation Commission State Transportation Improvement Project STIP for the 2004 2007 period This shows that this project will be constructed no later than 2007 c TransPlan Project No 721 Cardinal Way from Game Farm Road to the MDR NorthSouth Connector This project will be constructed as part of the PeaceHealth campus PeaceHeaIth will fully construct the Martin Luther King Jr ParkwayProject prior to the opening of Phase 1 in 2008 d TransPlanProject No 762 North South Collector within the MDR Site This collector is part of the peaceHeaIth campus design It forms River Bend Drive which is the primary direct access to the hospital and medical office buildings to the east of Martin Luther King Jr Parkway PeaceHeaIth will construct this project prior to the opening of Phase 1 111 Significantly affected transportation facilities Notwithstanding the above TSP improvements the application significantly affects the following in ersections a The eastbound ramp terminal at Pioneer Parkway Oregon Highway 126 This Oregon Department of Transportation ODOT transportation facility is part of the Q Street interchange TransPlan Project No 774 The facility will operate below acceptable mobility standards without these proposed amendments To prevent further degradation Oregon Highway Plan Action IF 6 the ramp terminal will be improved as a condition of approval prior to Phase 1 The City adopted this condition as Condition of Approval No 2 in the PAPA I decision Finding page 53 PAPA I Record page 234 Petitioners did not challenge this condition of approval so on remand it may not be reconsidered b 1 5BeIt Line Road Interchange The 1 5Belt Line Road Interchange does not meet ODOT mobility standards Therefore these amendments may not cause further degradation of the facility Page 28 of 123 1 10 05 Transportation improvements are planned prior to the opening of Phase 1 STIP Project Key No 13281 1 5 at Belt Line Interchange Phase 1 in the currently adopted STIP and Project Key No 12833 1 5 at Belt Line Interchange Phase 2 in the adopted 2004 2007 STIP see attached STIP project listings These STIP projects are scheduled for completion concurrent with the Phase 1 development of Peace Health ODOT can reasonably expect to obtain the funds needed to construct these improvements as a one phase project because PeaceHealth has agreed to actas a guarantor to the funding currently anticipated to be a federal earmark in the pending federal transportation authorization bill Based on this guarantee of funds the Oregon Transportation Commission the OTC may move OTIA 3 funding identified in the draft 2006 2009 State Transportation Improvement Program STIP to the adopted 2004 2007 STIP With funds added to the 04 07 STIP and the pending federal earmark guaranteed ODOT will b able to combine phases one and two as a single project to begin in 2005 or 2006 The City finds that substantial evidence in the whole record demonstrates that the facility will be in place prior to the opening of Phase I in 2008 This is based on evidence provided by the Oregon Department of Transportation and by the applicant that the project is programmed to begin construction in time for completion before 2008 and that the project is funded Alternatively the City has imposed as requested by the applicant a condition of approval requiring the phasing as shown above to prevent further degradation or failure of any affected intersection because the phasing will allow needed improvements to occur prior to the opening of uses allowed by these amendments c Belt Line Gateway Intersection This intersection is not significlntly affected because the City has determined pursuant to its authority under TransPlan to allow a reduced level of service Reduction in level of service is also a mitigation measure authorized by OAR 660 o 12 0060 1 d TransPlan TSI Roadway Policy No 2 provides as follows In some cases the level of service on a facility may be substandard The local government jurisdiction may find the transportation system improvement to bring performance up to standard within the planning horizon may not be feasible and safety will not be compromised and broader community goals will be better served by allowing a substandard level of service The limitation on the feasibility of a transportation system improvement may arise from severe constraints including but not Page 29 of 123 1 10 05 The Springfield Common Council implements TransPlan Transportation System Improvement Roadway Policy No 2 Motor Vehicle Level of Service and accepts a temporary level of service reduction until improvements are made to the Gateway Street Beltline Road intersection and I 5 Beltline interchange and the Pioneer Parkway extension now known as the Martin Luther King Jr Parkway is constructed The City has determined that the reduced level of service is less than D This means that prior to the construction of Martin Luther King Jr Parkway the City will flccept a reduced level of service to insure there is no significant effect d Beltline Road at Hutton Road This intersection will exceed mobility standards Level of Service D prior to the opening of Phase 1 because of background traffic growth Installation of a traffic signal will bring this intersection to acceptable standards throughout the planning period The traffic signal is included as the Beltline RoadGateway Road intersection project PeaceHealth has agreed to install the signal as part of its prior commitment to funding Beltline RoadGateway Road improvements before the opening of Phase 1 The applicant asks that the City make this a condition of approval e Mitigation measures OAR 660 012 0060 1 After considering all of the intersections that are not significantly a fected and those that are significantly affected but for which projects in TransPlan will be completed prior to opening of PhaSe I the third step is to consider mitigation measures necessary to maintain or prevent further degradation of affected Page 30 of 123 1 10105 transportation facilities The total number of p m peak hour trips must also be limited to maintain relevant mobility standards Three mitigation measures are proposed 1 Phasing As described in the 2004 TIA the applicant proposes as a condition of approval a phasing plan No uses will open before 2008 Phase I will occur between 2008 and 20 I 0 and will be limited to 1 185 million square feet of hospital and medical buildings and 1 457 pm peak hour trips Phase I occupancy and operational capacity will be coterminous with the completion of improvements to the I 5 Beltline interchange Phase II wjll open no earlier than 2010 will be limited to additional square footage generating no more than the 1 840 p m peak hour trips and its occupancy and operational capacity will be coterminus with the completion of improvements to the Beltline RoadGateway Road intersection This mitigation measure is allowed pursuant to OAR 660 012 0060l a which provides Limiting allowed land uses to be consistent with the planned function capacity and performance standards of the transportation facility The City finds that these phasing limitations limit allowed land uses so they are consistent with the planned function capacity and performance standards of the transportation facilities This ensures that there will be no interim mobility standard failures 2 Trip Cap Limitation The applicant requests that the City readopt Condition of Approval No 1 Finding page 3 PAPA I Record page 37 No party challenged this condition in the first phase of this proceeding so it may not be challenged now In addition a condition of approval is added to reflect the Phase I development limit of 1 457 pm peak hou trips 3 Roadway Improveme ts The applicant requests that the following1conditionsbeimposedtoensurethatroadwayimprovementsinTransPlanare provided when necessary a Condition of Approval No 2 for the remanded decision Decision pages 3 and 4 PAPA I Record pages 37 and 38 Pioneer Parkway Q Street improvements b PeaceHealth shall be required to install a traffic signal tthe intersection ofBeltline Road and Hutton Road prior to the opening of Phase 1 The City adopted findings for the Pioneer Parkway Q Street interchange improvement explaining Condition of Approval No 2 Finding page 53 PAPA I Record page 234 No party challenged that condition of approval The City readopts the PAPA I findings for this condition Page31 of 123 111 0 05 The City finds based on the TIA that the proposed conditions of approval will limit land uses until programmed and unprogrammed TransPlan projects are constructed and none of the intersections will be further degraded or significantly affected because ofthe trip cap f Coordination with affected agencies OAR 60 012 060 3 This section of the TPR requires that the determinations made under the prior sections be coordinated with affected transportation facilities providers and other affected local governments The applicant has met with ODOT region and district officials and City of Springfield transportation officials Additionally pursuant to the statutory notice requirements the City has provided an opportunity to comment on the applicant to each of the above agencies to the Lane Transit District LTD and to Lane County the County The City finds that this section of the TPR is satisfied g OAR 660 012 0045 3 5 The City adopted findings on these TPR sections at Findings pages 54 and 55 PAPA I Record pages 127 and 128 No party challenged these findings so they may not be challenged in this phase of the proceeding The remaining section of transportation related findings concern issues raised prior to the close of the record The city council hereby adopts the findings as set forth below A Noyember 16 2004 Joint Hearing Response to Issues Raised in the by Rob Zako Mr Rob Zako representing 1000 Friends of Oregon raised issues regarding compliance with the TPR His issues and the responses to his issues are shown below i Use of the Correct Version of TransPlan Mr Zako asked the Council and Commission to confirm that PeaceHealth has used the correct TransPlan document and not the pending Regional Transportation Plan RTP Jim Hanks of JRH Engineering confirmed that he used the July 2002 version of TransPlan TransPlan is the acknowledged Transportation System Plan TSP for the Eugene Springfield area Page 32 of 123 110 05 ii Conditions of Approyal Mr Zakoargued that conditions of approval and agreements proposed by PeaceHealth to satisfy the TPR might be ignored or changed by the City Council in a later proceeding Mr Zako s concerns are unfounded for two reasons First OAR 660 012 0060 authorizes conditions to address transportation facilities that are significantly affected by a post acknowledgement amendment OAR 660 012 0060 1 a expressly allows limiting allowed land uses to be consistent with the plan function capacity and performance standards of the transportation facility The phasing and the trip cap the trip cap was previously approved in the first phase of this proceeding by the Springfield City Council conditions of approval arelimitations on land uses so that the proposal remains consistent with the planned function capacity and performance standards of the affected transportation facilities The transportation facility improvements proposed by PeaceHealth the Pioneer Parkway Oregon Highway 126 eastbound ramps and the traffic signal at Hutton and Belt Line are TransPlan improvements that PeaceHealth has elected to fund and install prior to Phase 1 of its project PeaceHealth previously asked that the same condition be imposed on the Pioneer Parkway Oregon Highway 126 eastbound ramps in the first decision and no party obJected to that condition These conditions of approval will become conditions of an ordinance amendment and the City Coulcil may not amend them without amending the ordinance Second OAR 660 012 0060 1 b authorizes amendments to a TSP to provide transportation facilities that are adequate to support the proposed land uses However this subsection is only one of the four kinds of conditions allowed An amendment to the TSP is not required to provide appropriate conditions as allowed by OAR 660 0 12 0060 1 These conditions of approval will become conditions of an ordinance amendment and the City Council may not amend them without amending the ordinance which requires notice and a public hearing iii 1 5 Belt Line Road Interchange Funding PeaceHealth is committed to assisting the City and ODOT with appropriate funding for the 15 Belt Line Road interchange project The proposed phasing plan requires that those improvements be in place before Phase 1 may open Therefore while PeaceHealth s assistance with the funding may result in the 1 5 Belt Line Road interchange project being completed earlier a funding agreement is unnecessary to satisfy the TPRbecause Phase 1 may not occur until the appropriate 1 5 Belt Line Road interchange facilities have been constructed Page 33 of 123 1 10 05 iv Discussion of Nodal Deyelopment Issues No permit for development is before the Council and the Commission in this proceeding PeaceHealthmust obtain subsequent approvals from the City prior to developing the property These approvals include Master Plan and Site Development Review applications The appropriate opportunity to discuss nodal development techniques is in those proceedings To the extent these issues involve Statewide Planning Goal 12 Transportation no party raised Goal 12 in the first decision B Response to Issues Raised by Kirstin Green Kirstin Greene asserted that bicycles transit and pedestrians were not included in the project Although her testimony might be moreappropriate at a Master Plan hearing an extensive network of bicycle and pedestrian facilities will be integrated into site planning PeaceHealth has also adopted a strong transportation demand management program for the campus to continue its success as the highest rate of transit usage of any employer in Lane County Bus Rapid Transit BRT has been fully integrated into the site to include an exclusive bus lane in the median of RiverBend Drive and two BRT stations As Ken Hamm stated in his testimony PeaceHealthhas worked closely with LTD to develop transit facilities routing etc to serve the RiverBend campus C Questions Asked by City Council and Planning Commission Members i Highway 126 Improvements Councilor Ralston asked the applicanttodescribe the Pioneer Parkway and Oregon Highway 126 eastbound improvements PeaceHealth has proposed a condition of approval See Staff Report page 1 4 Cond tion of Approval 2 that it make these improvements prior to the opening of Phase I PeaceHealth previously requested and the CitY Council previously imposed an identical condition of approval in the first decision ii Construction Traffic Commissioner Carpenter asked whether construction traffic for the PeaceHealth project had been counted in the TPR OAR 660 012 00601 provides as follows Amendments to functional plans acknowledged comprehensive plans and land use regulations which significantly affect a transportation facility Page 34 of 123 110 05 shall assure that allowed land uses are consistent with the identified function capacity and performance standards of the facility Emphasis added This part of the TPR applies to proposed allowed land uses It does not apply to the construction traffic necessary to develop the land uses Were this the case as explained below it would be impermissible for construction traffic to reach the site Moreover the site to be developed currently allows a variety of uses and construction traffic is perfectly permissible for those uses construction Therefore construction traffic as explained below is part of the background traffic assuined in the 2004 TIA One can see the quandary ifconstruction traffic were separately counted in addition to trips from a future development Consider an example where a given intersection were failing and the TPR prohibited additional trips until the failing intersection were improved If construction traffic were counted then a literal interpretation of the TPR would require that the very construction workers needed to fix the failing intersection would notbe able to arrive to do the requisite work except on foot bike or bus No case decided to date on the TPR requires this result Second construction traffic was addressed in the 2004 TIA submitted to demonstrate compliance with the TPR Construction traffic is implicit in the background trip generation in the regional traffic model in that trips from construction works is generated either from the homes or places of business for construction workers suppliers etc going to or from the site In addition based on the traffic patterns at the critical locations in the area the PM peak hour is the time of analysis Construction traffic tends to have negligible impacts during the PM and AM peak hour as shifts for construction workers typically work petween 7 00 a m and 3 30 p m which are considered off peak periods Moreover PeaceHealth is coordinating with the City of Springfield to ensure that construction traffic will enter and exit the site from Beltline Road and avoid impacts to the greatest degree possible with residents in the Game Farm neighborhood Finally as noted above no party raised the issue of construction traffic previously and under the Law of the Case doctrine it may not be raised in this phase of the proceeding iii What Years Did PeaceHealth Use to Analyze Transportation Impacts PeaceHealth analyzed all years between 2005 and 2020 As the 2004 TIA explains PeaceHealth has analyzed the impact of this proposal on affected transportation facilities between the years of 2005 and 2020 However as a practical matter there is no need to address the years 2005 2007 since the proposed phasing Page 35 of 123 110 05 plan would not allow development prior to 2008 unless necessary transportation facilities are in place 3 Response to Issues Raised After the Noyember 16 2004 Joint Hearing A Noyember 23 2004 letter from Kathleen Moulton Ms Moulton s letter raises two issues Whether the 2004 Transportation Impact Analysis the 2004 TIA addressed the ability of emergenyvehicles to navigate heavy traffic on Belt Line Road and whether PeaceHealth considered the regional ramifications of the post acknowledgement plan amendment These issues were not raised in Petitioners brief to the Oregon Land Use Board of Appeals LUBA in the appeal of the first decision of this app ication Therefore pursuant to the law of the case doctrine they may not be raised now Ms Moulton fails to identify relevant approval criteria regarding these issues There is no criterion requiring an applicant to conduct a separate analysis of the ability of emergency vehicles to navigate heavy traffic Further there is no criterion relevant to transportation issues requiring an analysis of regional rartlifications of the application Notwithstanding that this issue is very vague even ifthere were a regional ramification requirement PeaceHealth has addressed it in the 2004 TIA which analyzed all affected transportation facilities B November 23 2004 Letterfrom 1000 Friends of Oregon i Statewide Planning Goal Goal 12 The Petitioners did not raise Goal 12 in their appeal of the first decision on this application and pursuant to the law of the case doctrine are precluded from raising it now Notwithstanding that the Petitioners assignment of errorin their brief to LUBA was styled as Goal 12 the p titions for review dealt only with the Transportation Planning Rule TPR Nothing prevented the Petitioners including 1000 Friends of Oregon from making specific arguments about Goal 12 their petitions for review Having failed to do so they present no argument as to why they are entitled to do so now The City Council and Planning Commission should reject these arguments because they are too late ii TransPlan Related Issues 1000 Friends of Oregon suggests in a number of places that PeaceHealth is not using the correct version of TransPlan Mr McKenney s November 23 2004 Page 36 of 23 1 0 05 memorandum notes at page 2 that the July 2002 TransPlan version is the cUrrent TransPlan version This version is in the LUBA record beginning on page 409 Prospective amendments to TransPlan are irrelevant to this application because they are neither adopted nor acknowledged The Oregon Court of Appeals has said that cities are required to apply acknowledged provisions of their Plan where relevant not unadopted and unacknowledged versions of their Plan Moreover 1000 Friends of Oregon s comments on TransPlan and whether it complies with provisions of the Transportation Planning Rule OAR 660 012 0035 2 a d 0035 5 c A E and 00551 a are not relevant to this application TransPlan is not the subject of this decision to the extent 1000 Friends of Oregon has concerns about TransPlan it is either too late with those concerns in the wrong forum or must wait until TransPlan isin a forum for it to raise these arguments Finally the City adopted findings regarding all relevant provisions of the TPR including OAR 660 012 0045 in the first decision on this matter Record pages 97 98 and no party appealed those findings Issues regarding compliance with various aspects of the TPR could have been but were not raised in the first phase of this proceeding and are waived 1000 Friends of Oregon Argued that the 2004 TIA Should Have Included the Royal Caribbean Proposed Call Center As Mr McKenney correctly points out in his memorandum although applications for land use approval have been submitted and are being reviewed by the City they have not been approved Because they have not been approved there is no obligation under applicable law for PeaceHealth or the City to consider potential trips generated by those as of yet unapproved applications which may never be approved In any event the 2004 TIA shows that the PeaceHealth development when added to full development of the Campus Industrial area which includes the Royal Caribbean Cruise Line call center site and background traffic as modeled in the regional EMME 2 model will not have a significant effect on any transportation facility through the year 2020 with proposed conditions of approval iii iy 1000 Friends of Oregon Argued that It Has Had Inadequate Time to Review the 2004 TIA PeaceHealth submitted the 2004 TIA to the Springfield Planning Department on October 29 2004 1000 Friends of Oregon has an obligation to continue to review the record in this matter by going to the City and asking to see the contents of the record Chauncey v Multnomah County 23 Or LUBA 599 1992 Had they done so they would have had 18 days prior to the November 16 2004 public hearing to Page 37 of 123 1 10 05 review the 2004 TIA Moreover they had 14 days after the hearing to comment In total 1000 Friends of Oregon had 32 days or more than a month to review the 2004 TIA Their substantial rights have not been prejudiced because they have had more than adequate time to review the 2004 TIA and could have found the 2004 TIA simply by reviewing the record v Construction of New Transportation Facilities Beyond TransPlan Private Funding of Improyements and Temporary Reduction in Performance Standards by the City The City responded to these issues in the first decision as either conditions of approval Record pages 177 178 or findings Record pages 87 88 90 94 96 that could have been challenged in the first appeal ofthis decision Having failed to do so it is too late for 1000 Friends of Oregon to raise these issues now Regarding temporary reduction in performance standards for the intersection of Belt Line Road and Gateway Road the City ofSpringfield made that decision in a prior proceeding City Resolution 02 44 adopted in 2002 may not be challenged in this proceeding Moreover the City of Springfield adopted that resolution pursuant to TransPlan Finally the City adopted a condition of approval Record pages 17 7 178 permitting PeaceHealth to fund unfunded TransPlan projects No party challenged that condition or the concept underlying the condition and the concept may not be challenged in this matter yi Amendments to TransPlan 1000 Friends of Oregon argues that amendments to TransPlan are either required or should be required by the City of Springfield However nothing in the relevant provisions of the Transportation Planning Rule OAR 660 012 0060l a d require an amendment to TransPlan The phasing plan is a condition limiting allowed land uses An amendment to TransPlan is not required to accomplish the phasing plan A condition of approval temporarily reducing mobility standards has been made pursuant to TransPlan and is not a mitigation condition The condition is a substantive provision determining the minimum acceptable standard for that intersection Finally funding of improvements for TransPlan facilities is allowed pursuant to LUBA s decision in Craig Realty Group v City of Woodburn 39 Or LUBA 384 2001 under the second part of that decision s three part TPR test LUBA has held Page38 of 123 1 10 05 that the TPR may be satisfied by projects shown in the acknowledged transportation system plan that are guaranteed to be in place prior to the time they are needed By allowing PeaceHealth to fund these unfunded TransPlan projects the City achieved this goal yii Increase in Hospital Use PeaceHealth has committed to a maximum number of vehicle trips during the p m peak hour period the period during which mobility standards are measured The City included the trip cap in the first decision Record page 177 and no party challenged that condition Therefore the condition may not be challenged now The 2004 TIA analysis shows thatthe trip capped PeaceHealth development when added to full development of the Campus Industrial area which includes the Royal Caribbean Cruise Line call center site and background traffic as modeled in the regional EMME 2 model will not have a significant effect on any transportation faciiity through the year 2020 C November 19 2004 Letterfrom Carol James Ms James argued that the 1992 Oregon Transportation Plan is not satisfied Ms James fails to explain how this plan is relevant and even if it is relevant cites no specific criteria from the 1992 Oregon Transportation Plan Moreover since it could have been raised in the first phase of this proceeding it may not be raised now Ms James also cited a 2002 TransPlan goal This issue could have been raised in the first phase of this proceeding and may not be raised now D November 23 2004 Letter from the Oregon Department of Transportation This letter satisfies the Goal 2 and OAR 660 012 0060 3 coordination requirements The City is required to coordinate with effective governmental entities such as the Oregon Department of Transportation by giving them an adequate notice of an application providing them with a reasonable opportunity to comment and incorporating their comments as much as possible into the City s decision ODOT s comments do not require incorporation into the City s decision The ODOT letter contains two important comments ODOT staff found no technical flaws with the 2004 TIA Page 39 of 123 1 10 05 ODOT assumed that mitigation is necessary to satisfy the Transportation Planning Rule and notes that the trip cap and the Oregon Highway 126 eastbound ramps and Pioneer Parkway improvements are necessary to satisfy the Transportation Planning Rule E November 30 2004 Letter from Al Johnson Mr Johnson raised several issues regarding PeaceHealth s proposed conditions of approval pursuantto OAR 660 912 00601 a d As an initial matter Mr Johnson may not raise Goal 12 or TransPlan with respect to transportation issues unless he can show that these are issues that could not have been raised in the first phase of this proceeding Mr Johnson s Petition for Review did not raise Goal 12 or TransPlan issues and his failure to do so prevents him from raising them in this proceeding unless he is able to demonstrate they are related to issues that could not have been raised the first time Mr Johnson argued that PeaceHealth has the burden of proof to show that the conditions will be enforceable Mr Johnson offered no authority forthis proposition and in fact the conditions proposed by PeaceHealth are made pursuant to the Transportation Planning Rule which has no requirement that the conditions be demonstrated to be enforceable Moreover PeaceHealth previously proposed and the City approved conditions of approval based ort the Transportation Planning Rule Mr Johnson did not object to those conditions and may not now object to virtually the same conditions The Court of Appeals decision in Jaqua noted that the Transportation Planning Rule allows conditions of approval to mitigate significant effects on transportation facilities Had the court believed there was an enforceability requirement it certainly would have identified that requirement Mr Johnson also cited the case of Neste Resins v City ofEugene 23 Or LUBA 55 1992 as relevant to this case However the first sentence in the quoted portion of the decision makes Neste Resins inapplicable to this case LUBA said in that case The problem is that those conditions were not imposed on the propertY as part of the challenged Metro Plan amendment In this case PeaceHealth has proposed and City staff has recommended to the City Council and Planning Commission that the Transportation Planning Rule allowed conditions of approval be imposed as conditions to the decision Given this fact it is unclear why Mr Johnson believes that the conditions are unenforceable and he has failed to explain his position in any event This is an issue that could have been raised in the first phase of this proceeding and is now being raised fo the first L Page 40 of 123 1 10 05 time with no explanation from Mr Johnson r garding why it is relevant to the approval criteria Finally Mr Johnson objected to the ability of PeaceHealth to take advantage of an amended Transportation Planning Rule in the future PeaceHealth has not proposed that a prospective rule amendment be considered as a condition of approval PeaceHealth recognizes it is subject to the current Transportation Planning Rule However should the Transportation Planning Rule be amended in the future PeaceHealth sees no reason why it should not be able to take advantage of that rule F November 30 2004 Letter from Rob Zako Mr Zako argued that the additional condition of approval number 3 is highly objectionable His arguments arewithout merit since he apparently fails to understand how an open record works The record was open until November 30 both he and other opponents had the opportunity to object to the proposed condition Proposed conditions are not new evidence and even ifit had been new evidence ORS 197 763 6 gives Mr Zako the ability to request that the record be reopened which he failed to do The fact that both Mr Zako and Mr Johnson have responded to the requested condition demonstrates that his argument alleging an inability to respond to the condition is without merit Further PeaceHealth s suggested additional condition constituted one paragraph it does not seem particularly difficult to respond to one paragraph Mr Zako also raised an argument that the conditions are unenforceable However if the City adopts the conditions of approval recommended by staff and PeaceHealth those conditions become part of an ordinance and may only be amended after appropriate notice and public hearings PeaceHealth simply does not understand Mr Zako sproblems with conditions of approval authorized by the Transportation Planning Rule which is the rule he has championed throughout this proceeding Mr Zako argued that the Jaqua decision requires the roads to be built when needed PeaceHealth agrees and that is why it has requested the conditions of approval allowed by the Transportation Planning Rule Moreover Mr Zako s plea that adequate funding be required is clearly without merit The Court of Appeals in the Jaqua decision said that mitigation is provided in the four conditions of approval allowed by the Transportation Planning Rule the court did not require any analysis of funding It is PeaceHealth s risk as to whether the necessary facilities are in place when needed If not under the current version of the Transportation Planning Rule PeaceHealth would have to wait until those facilities are there Page 41 of 123 1 10 05 Mr Zako also discussed funding of the 1 5 Belt Line Interchange Project Funding of that project is irrelevant to the decision before the City Council and Planning Commission While PeaceHealth has offered to assist the City and the Oregon Department of Transportation with the funding it is irrelevant to the criteria before the City Council and Planning Commission GOAL 13 ENERGY CONSERVATION The Energy goal is a general planninggoal and provides limited guidance for site specific map and text changes However the availability of a large employer in proximity to a commercial and residential node and centered around a transit station as proposed by Residential Implementation Action 13 6 will provide transportation options that will serve to reduce energy consumption Any future development will be subject to applicable energy efficiency requirements established by building codes and as may apply through applicable provisions of the SDC Goal13 s Planning Guidelines in AA call for land use planning to combine increasing density gradients along high capacity transportation corridors to achieve greater energy efficiency The cUlrent amendments as did the previous amendments will enable the development of a hospital within the Gateway MDR site as well as Jhe potential for implementation of nodal development objectives with a mix of residential medical office general office and appropriately scaled supporting services proximate to the hospital The record demonstrates that PeaceHealth is actively working withLane Transit District to provide for standard transit and Bus Rapid Transit service with convienient access to the hospital Placing this mix of uses within convenient walking distance on a high capacity transit corridor implements the guidelines in Goal 13 to enable efficient arrangement of uses and conserve energy LUBA has upheld a city s finding of compliance with Goal 13 where findings noted the placement of facility near public services including mass transit and commercial areas Hubenthal v City of Woodburn 39 Or LUBA 20 2000 The subject property accommodates a planned Bus Rapid Transit LUBA has also stated that Goal 13 is directed at the development of local energy policies and implementing provisions and does not state requirements with respect to other land use provisions even ifthose provisions have incidental impacts on energy use and conservation Barnard Perkins Corp v City ofRivergrove 34 Or LUBA 660 1998 Finally although there are variations between the current revised proposal and the earlier amendments for purposes of Goal 13 there are rio substantive or practical differences between the current amendments and those approved by the City through the Decisions that would affect the City s earlier determination of compliance with Page 42 of 123 1 10 05 Goal 13 The current amendments do not affect any additional geographic areas and have no impact on the City s earlier Goal 13 findings Consequently because there is no substantive difference between the proposeq amendments on remand and the PAP A I amendments for purposes of Goal 13 the current proposal remains consistent with Goal 13 Finally no party challenged the PAPA I compliance with GoalIJ Because there are no substantive differences between the present proposal and the PAPA I proposal with respect to Goal 13 no party may now challenge the proposals consistency with Goal 13 during this remand proceeding GOAL 14URBANIZATION Goal 14 requires local jurisdictions To provide for an orderly and efficient transition from rural to urban land use The Gateway MDR site is within the Metro Area UGB within the city limits of Springfield arid within the fully developed and served urbanized area of the community The amendments are intended to facilitate efficient use of the site for urban uses thereby facilitating the compact urban growth form which is the subject of the LCDC s Urbanization goal In the PAPAl proceeding opponents argued the amendments violate Goal 14 because portions of the subject property abut the UGB Goal 14 the Metro Plan and the GRP do not refer to edge areas or otherwise demand special treatment to property based on the fact that the property abuts a UGB Goal 14 in general and Factor 4 in particular apply to the amendment of urban growth boundaries LUBA has held that Goal 14 applies to the conversion of rural to urban land use consistent with the standards set forth in Goal 14 LUBA has rejected arguments that Goal 14 applies to an argument concerning efficient use of urban land where rural land has already been converted to urban land Consequently Goal 14 is not directly applicable since the Amendments relate to prQperty wholly within the Springfield city limits and the UGB Goal 14 establishes the seven factors as the basis for establishment and change of the boundaries in the UGB and does not apply to development permitted within established UGBs Finally although there are variations between the current proposal on remand and the PAPAl amendments for purposes of Goal 14 there are no substantive or practical differences between the current amendments and those approved by the City through the Decisions that would affect the City s earlier determination of compliance with or the applicability of Goal 14 The current amendments do not affect any additional geographic areas and have no impact on the City s earlier Goal 14 findings Consequently because there is no substantive difference between the proposed amendments on remand and the PAPA I amendments for purposes of Goal 14 the current proposal remains consistent with Goal 14 Finally no party challenged the earlier decisions compliance with Goal J4 before LUBA Because there are no Page 43 of 123 1 10 05 substantive differences between the present proposal and the earlier proposal with respectto Goal 14 no party may now challenge the proposal s consistency with Goal 14 during this remand proceeding Notwithstanding that opponents failed to raise any Goal 14 challenge to LUBA in the earlier proceeding opponents have restated their Goal 14 arguments again to the City Section IV below includes additional Goal14 related findings GOAL 15 WILLAMETTE RIVER GREENWAY This goal is inapplicable because the Gateway MDR site is not within the boundaries of the Willamette River Greenway GOALS 16 19 COASTAL GOALS These goals are inapplicable to this proposal Page 44 of 123 1 10 05 C Metro Plan Consistency 1 Map Amendment The original proposal sought to amend the Metro Plan Diagram by converting up to 33 acres ofMDR designated land to CC Based on the Court s direction that the hospital and associated commercial uses must be located on commercially designated land the current proposal seeks to re designate approximately 50 acres as MU and 44 acres as CC on the Metro Plan Diagram Concurrent GRP policies allow the MS zoning district to be applied to the CC and MU plan designations and the MUC zoning district to be applied to the CC plan designation a Community Commercial Centers The Metro Plan chapter II section E 2 includes the following description of the Commanity Commercial category This category includes more commercial activities than neighborhood commercial but less than major retail centers Such areas usually develop around a small department store and supermarket The development occupies at least five acres and normally not more than 40 acres This category contains such general activities as retail stores personal services financial insurance and real estate offices private recreation facilities such as movie theaters and tourist related facilities such as motels When this category is shown next to medium or high density residential the two can be integrated into a single overall complex local regulations permitting As discussed above approximately 44 acres of the MDR designated property will be re designated CC with an eventual zoning of MS There are a number of reasons that the CC designation is an appropriate designation First and foremost the Court of Appeals clearly determined that the proposed medical and commercial services were commercial in nature The Court stated By comparison the city s actions in this case change the universe of primary use of the area from residential to nonresidential The proposed regional hospital project and adjoining medical and commercial services authorized by the ordinances are not mere adjuncts or supplements to residential use They will become in fact and in effect the primary uses of the land and they will by their intrinsic nature change the overall use of the land in the area from residential to commercial We therefore conclude Page 45 of 123 1 10 05 based on our understanding of the meaning of the word auxiliary as used in the context of the Metro Plan that the kinds of uses contemplated by the challenged ordinances are not permitted uses in an area designated for residential use If the city wishes to use the area in question for the commercially related uses authorized by the ordinances it will have to undertake a zone change or other change authorized by the plan Jaqua v City ofSpringfield 193 Or App 573 589 emphasis added The Court as well as the PAPAl opponents clearly consider the hospital and related commercial activities to fall within the commercial element of the Metro Plan Consequently following the Court s direction in order to eventually apply the MS zone the underlying Metro Plan Diagram designation must be one of the Metro Plan s commercial designations The following text explains first why the CC designation is the appropriate designation and then explains why the remaining commercial designations described in the Metro Plan other than CC are inappropriate for the portion of the property to be zoned MS for the purpose of locating a hospital Given the Court s direction in Jaqua the City reviewed the commercial Metro Plan designations and determined that for the portion of the property where a hospital will be sited the CC Metro Plan designation is most appropriate As a starting point the City reviewed the current Metrq Plan designations for the existing Sacred Heart Hilyard Campus as well as the McKenzie Willamette Hospital site Sacred Heart Hilyard Campus is designated CC on the Metro Plan Diagram McKenzie Willamette Hospital is designated Major Retail CommerciaMRCThe fact that both of the region s hospitals are designated commercial on the Metro Plan diagram demonstrates the local jurisdictions policy decision that the commercial designation is appropriate Moreover the CC designation is one of the most comprehensive commercial designations designed to capture a wide variety of commercial uses including retail office and service uses As explained in the Metro Plan Community Commercial Centers are at least 5 acres and normally not more than 40 acres PeaceHealth proposes to re designate 44 acres to Cc It should be stressed that the 40 acre reference is not a limitation nor is it a maximum Unlike the NC district which expressly states that NC sites shall not exceed 5 acres the Metro Plan description of the CC designation contains no such prohibition Although the 44 acre designation is approximately 4 acres larger than the 40 acre guidance set forth in the Metro Plan as discussed above there is no prohibition on redesignating more than 40 acres to Cc The use of the word normally when referring to 40 acres indicates that typically CC areas are not greater than 40 acres but does not mandate that they not exceed 40 acres This combined with the fact that no other commercial designation is Page 46 of 123 1 10 05 appropriate demonstrates that the CC designation is the correct commercial designation under the Metro Plan The CC designation will be adjacent to the MU and MDR Metro Plan designations As required by the amended GRP Implementation Measures discussed above a Master Plan will be required for the Gateway MDR site that will include a comprehensive development plan that will incorporate the MS hospital and commercial uses the MUC retail and commercial uses as well as the MDR designated land The Metro Plan text description of the CC provides in part When this category CC is shown next to medium or high density residential the two can be integrated into a single overall complex local regulations permitting Thus because the Gateway MDR site will include CC MU and MDR and will be comprehensively developed pursuant to a master plan it is appropriate to designate this portion of the property CC to allow for such an integrated approach as described by the Metro Plan text describing the CC designation 2 Inappropriateness of other Commercial Designations The Major Retail Center designation is not appropriate because according to its description it is designed for at least 25 r tail stores one or more of which is a major anchor department store having a total floor space of at least 100 000 square feet Metro Plan II E 3 As explained by the Metro Plan the types of developments with the Major Retail Center designation include the Valley River Center the Mohawk commercial area and the Eugene central business district PeaceHealth s development proposal is not on the siie or scale of the description of the Major Retail Center No retail center on the scale described in the Metro Plan is proposed nor is any major anchor department store proposed It is anticipated that the Nodal Development Overlay will be applied through the Citys nodal development implementation project to overlay the CC and MU plan designations The Existing Strip Commercial designation is inappropriate because as the name implies it refers to existing commercial lands No such existing development exists on the subject property The Neighborhood Commercial designation is inappropriate because it may only be applied to sites not larger than five acres Metro Plan II E 5 Because the proposed development will exceed five acres the NC plan designation is inappropriate Page 47 of 123 1 10 05 The Strip or Street Oriented Commercial designation is similarly inappropriate because according the the Metro Plan this designation is limited to pre existing commercial developments The Metro Plan generally discourages the use of this desingation and provides that they should be limited to existing locations and transformed into more desireable commercial patterns if possible Metro Plan II E 6 Consequently this designation is inappropriate 3 Mixed Use Diagram Designation In the PAPA I PeaceHealthsought to redesignate up to 33 acres of MDR designated land to CC with an eventual zoning overlay of MUC In the proposal on remand PeaceHealth seeks to redesignate approximately 50 acres from MDR to the MU Metro Plan designation with the eventual MUC zoning applied to the 50 acres Although the underlying Metro Plan designation has changed in the proposal on remand fromCC to MU the utimate development will remain the same as the PAPAl proposed because the proposed zoning is still MUC There is no practical difference between the proposal on remand and the PAPA I proposal Additionally as required by the GRP text amendments the subject area will still be required to be developed pursuant to a master plan The Metro Plan describes the MU designation as follows This category represents areas where more than one use might be appropriate usually as determined by refinement plans on a local level For example the Whitaker Refinement Plan includes several areas where a mix of compatible uses based in part on existing development are designated In the absence of a refinement plan the underlying plan designation shall determine the predominant land use The proposed GRP text and map amendments allow for a robust mix of uses on the subject property Consistent with its master planning effort PeaceHealth seeks to apply theMUC zoning district to allow for a complementary mix of medical general office and supporting commercial retail functions with the potential to also include residential uses all in a vertical mixed use development pattern allowed and encouraged by the MUC zoning district see SDC 40 010 Approval of the Metro Plan and GRP diagram amendment to MU in this instance will more appropriately reflect the recent establishment of the MUC zoning district as a means to implement this designation Page 48 of 123 1 10 05 D Response to Text of Metro Plan This section addresses the consistency of the proposal with applicable policies of the Metro Plan While there are a number of Metro Plan policies the findings below discuss only those policies that apply to the proposal on remand In general the findings below do not discuss those portions of the Metro Plan that 1 apply only to rural or other lands outside ofthe urban growth boundary 2 apply to land uses other than the current or proposed designations for the site and will not be affected by the proposed Plan diagram and text amendments or 3 clearly apply only to specific development applications e g Site Plan Review submittals subdivisions etc In many instances the goals policies and implementation measures apply to specific development proposals that will be addressed through compliance with applicable City regulations during master plan and site development review During the public comment period no party argued that additional policies are applicable to this proposal After approval of the Decisions the City of Eugene Lane County and the City of Springfleldadopted a number of amendments to the Metro Plan For the most part the amendments are housekeeping amendments and do not affect either the earlier Decisions or the City s review on remand The newly adopted 2004 amendments to the Metro Plan are in the record The findings below address both the Metro Plan policies in the form prior to the adoption of the 2004 amendments and the recently adopted Metro Plan amendments Where applicable Metro Plan policies have been amended by the 2004 amendments the City has elected to make findings on both versions of the Metro Plan to ensure that no party may later argue that the City should have addressed an earlier or later version of the Metro Plan As demonstrated below very few of the Metro Plan policies applicable to this proposal were affected by the 2004 amendments More importantly those that were amended did not include any substantive changes Where a policy has been amended through the 2004 amendments the changes are shown to the following policies together with a discussion of whether the change has any impact on the City s findings of compliance with the applicable Metro Plan provisions Where the policy has not been changed that is noted as well The Metro Plan Introduction Section D provides the following definitions A goal as a broad statement of philosophy that describes the hopes of the people of the community for the future of the community A goal may never be completely attainable but is used as a point to strive for Page 49 of 123 1 10 05 An objective is an attainable target that the community attempts to reach in striving to meet a goal An objective may also be considered as an intermediate point that will help fulfill the overall goal A policy is a statement adopted as part of the Plan to provide a consistent course of action moving the community towards attainment of its goals 1 For the Metro Plan Map amendment the amendment must not make the Metro Plan internally inconsistent SDC 7 070 3 b 2 For the Gateway Refinement Plan the proposed amendments must demonstrate consistency with the Metro Plan SDC 8 0301 Except for the Growth Management Goals which are addressed below each of the Metro PI n policies are addressed in the order in which they appear in the Plan Element section of the Metro Plan E Metro Plan Elements 1 Growth Management Policies 1 The urban growth boundary and sequential development shall continue to be implemented as an essential means to achieve compact urban growth Provision of all urban services shall be concentrated inside the urban growth boundary The 2004 Metro Plan amendments do not modify this policy The revised proposal continues to satisfy this policy for two reasons First the Gateway MDR site is inside the metropolitan UGB and as such encourages compact urban growth Secondly urban services are available at sufficient levels to accommodate the development resulting from this application Upon approval of the revised proposal PeaceHealth will remain bound by annexation agreements that restrict development on the Gateway MDR site until such time that afull level of urban services are extended to serve that future development The City s master plgn and site plan review processes will ensure that the appropriate level of these services is efficiently extended to each phase of future development 2 The UGB shall lie along the outside edge of existing and planned rights of way thatform a portion of the UGB so that thefull right ofway is within the UGB Page 50 of 123 1 10 05 The 2004 Metro Plan amendments do not modify this policy The revised proposal continues to satisfy this policy because the UGB includes the full rights of way relevant at the Gateway MDR site including Pioneer Parkway a project shown on TransPlan The UGB at the Gateway MDR site follows the McKenzie River along the eastern portion of the subject site and continues along the McKenzie as the river flows northwest All rights of way that currently serve the site and that are anticipated to serve future development are within the UGB As such all of the streets that will eventually serve the site will be upgraded to full urban standards 3 Controi oj location timing and financing of the major public investments that directly influence the growth form of the m tropolitan area shall be planned and coordinated on a metropolitan wide basis The 2004 Metro Plan amendments do not modify this policy Th major public investments relevant to PeaceHealth s proposal are those affecting public services particularly transportation The proposal on remand continues to provide for the coordination of these improvements as they relate to the Gateway MDR site The major transportation facilities tha will serve the eventual development of the Gateway MDR site are identified in TransPlan The transportation analysis in the record demonstrates that these facilities are sufficient to accommodate the development the amendments will allow As a component of the development of the site PeaceHealth will be required to construct portions of several new on site collector streets that have been identified in TransPlan as financially constrained PeaceHealth is also bound by several annexation agreements to contribute financially to facilitate the construction of off site transportation imprvements at Pioneer Parkway and 1 105 and at the Beltline Gateway intersection The findings responding to the TPR and Goal 12 further explain the public and private investments related to the proposal 8 Land within the Urban Growth Boundary may be convertedfrom urbanizable to urban only through annexation to a city when it is found that a A minimum level of key urban facilities and services can be provided to the area in an orderly and efficient manner b There will be logical area and time within which to deliver urban services and facilities Conversion of urbanizable land to urban shall also be consistent with the Metropolitan Plan The 2004 Metro Plan amendments do not modify this policy Page 5 of 23 1110 05 The Gateway MDR site subject to the revised proposal is within the Urban Growth Boundary When the Gateway MDR site and portions thereof were brought into the UGB and the city limits the Lane County Local Boundary Commission and the City determined that a minimum level of key urban facilities and services can be provided to the site in a logical progression both in terms of geography and time Further the Boundary Commission decision determined that conversion of urbanizable land to urban was consistent with the Metro Plan All of the property within the Gateway MDR site affected by the revised proposal is located within the Springfield city limits While urban services do not currently serve the entire site annexation agreements between the PeaceHealth and the City specify the urban services that must be extended to the site prior to any development on the site The City Council and the Lane County Local Government Boundary Commission have adopted findings of fact that key urban services will be extended to the site in an orderly and efficient manner and that they will be sufficient to serve future development Several other policies under this Metro Plan Element were modified through the 2004 Metro Plan amendments The amended policies however did not apply to the original proposal and nothing in the modified proposal would require the modified proposal to be measured against the amended policies of this element Moreover the amendments are not material and do not modify the City s earlier position that these policies are inapplicable to the present review 2 Residential Land Use and Housing Element Policies A Encourage the consolidation of residentially zonedparcels to facilitate more optionsfordevelopment and redevelopment ofsuch parcels The 2004 Metro Plan amendments do not modify this policy The Gateway MDR site subject to the revised proposal consists of a few large parcels all of which are currently owned by PeaceHealth PeaceHealth plans to develop an integrated project on the site that will include medical residential and commercial uses Additional consolidation of the parcels is not necessary for development of the site The revised proposal and the text amendments to the GRP require that the consolidated property be comprehensively planned pursuant to a master plan This witI facilitate options for development and will implement this Metro Plan policy Page 52 of 123 1110 05 A 2 Residentially designated land within the UGB should be zoned consistent with the Metro Plan and applicable plans and policies however existing agricultural zoning may be continued within the area between the city limits and the UGB until rezoned for urban uses The 2004 Metro Plan amendments do not modify this policy Prior to development and in conjunction with the master plan the Gateway MDR site will be zoned consistent with the Metro Plan and GRP diagrams as am nded by this revised proposal The revised proposal continuities to establish the policy necessary to both redesignate the subject property Residential Implementation Action 121 and rezone the property Residential Implementation Action 12 0 This policy arrangement eliminates the potential for a plan zone conflict in conformance with this Metro Plan policy The property is within the UGB sotheprovisions of this policy relating to lands outside the UGB do not apply A3 Provide an adequate supply of buildable residential land within the UGBfor the 20 year planningperiod at the time ofPeriodic Review The 2004 Met o Plan amendments do not modify this policy This policy calls for ensuring an adequate supply of residentially designated land within the region consistent with the requirements of Goal 10 requirement A 5 Develop a monitoring system that measures land consumption land values housing type size and density Reports should be made to the community on an annual basis The 2004 Metro Plan amendments do not modify this policy This policy is not directly applicable to this proposal because the obligation to prepare the monitoring reports is an obligation of the three adopting jurisdictions A 6 Eugene Springfield and Lane County shall encourage a community dialogue when the annual monitoring report on land supply and housing development is made public to addressfuture Periodic Review requirements that relate to meeting the residential land supply needs of the metropolitan area The 2004 Metro Plan amendments do not modify this policy The opponents argue that the 2003 Springfield Residential Land Monitoring Report must be relied upon by the City in determining whether there is sufficient buildable land within the City of Springfield In particular the opponents argue that the monitoring report is more current and therefore the City must base its decision Page 53 of 123 1I 0 05 on the monitoring report rather than the Buildable Lands Inventory set forth at pages III A 3 to 4 in the Metro Plan The City finds that reliance on the monitoring report rather than the acknowledged and adopted inventory in the Metro Plan would conflict with Policy A 6 Amendments to the Metro Plan may not leave the Metro Plan inconsistent Reliance on the monitoring report which has not been adopted by the City the City of Eugene or Lane County would be inconsistent with the Metro Plan By the express terms of this policy the monitoring report is to be used to encourage a community dialogue regarding the buildable lands inventory during the next periodic review None of the Residential Element policies including A 6 require or even suggest that the monitoring report should be used instead of the adopted inventory Indeed the express terms of policy A 6 state that the monitoring reports should be used to address future needs not current inventories A 8 Require development topay the cost as determined by the local jurisdiction of extending public services and infrastructure The cities shall examine ways to provide subsidies or incentives for providing infrastructure that support affordable housing andor higher density housing The 2004 Metro Plan amendments do not modify this policy Although no development is proposed or specifically authorized in the revised proposal on remand when development commences PeaceHealth will be required to pay appropriate costs to extend public services and infrastructure to the site validly imposed on it by the City In addition the Annexation Agreements acknowledge that additional infrastructure may be required as a condition of specific development approval These requirements will come in the form of required construction or in the assessment of Systems Development Charges that have been calculated to capture the cost of providing regional service capacity Through its annexation agreement with the City PeaceHealth is obligated to assist in on site and off site infrastructure improvements without public subsidy i A 11 Generallf locate higher density residential development near employment or commercial services in proximity to major transportation systems or within transportation efficient nodes The 2004 Metro Plan amendments do not modify this policy The proposal on remand like the PAPAl proposal will facilitate the location of nodal overlay on MDR MS andMUC zoning districts Each will allow for a higher residential density that the current Gateway MDR zoning Higher density residential development on the Gateway MDR site will be located within approximately one quarter mile of existing and future employment and commercial services as well as future high capacity transit i e Phase 2 of the Bus Rapid Transit Page 54 of 123 1 10 05 system PeaceHealth s contribution of right of way and construction funding for extension of the Pioneer Parkway as well as the development of an internal collector street system within the RiverBend site will provide convenient transit access to serve future employment and residential development at densities conducive to supporting transit service A 12 Coordinate higher density residential development with the provision of adequate infrastructure and services open space and other urban amenities The Gateway MDRsite is within the city limits of Springfield Pursuant to the annexation agreements with the City PeaceHealth is required to extend all urban services necessary for future development into the site including extension of sanitary sewer and water trunk lines and the extension of the Pioneer Parkway The revised proposal will continue to facilitate the City s nodal implementation project which when complete will allow for a higher density of dwelling units at the Gateway MDR site Density in the INDO district is not specified but is limited by height TheINDO district coordinates this higher density with the provision of infrastructure such as BRT and has specific design requirements for the provision of open space and other urban amenities Moreover through the master planning process the City will ensure that residential development will be consistent with all applicable City standards including infrastructure services open space and other urban amenities The 2004 Metro Plan amendments do not modify this policy A 13 Increase overall residential density in the metropolitan area by creating more opportunitiesfor effectively designed in fill redevelopment and mixed use while considering impacts of increased residenii ldensity on historic existing and future neighborhoods The 2004 Metro Plan amendments do not modify this policy The revised proposal will continue to create opportunities for effectively designed in fill by enabling a mixed use development at higher than average residential densities thereby providing an effective mix of uses i e medical office residential and appropriately scaled commercial retail uses to serve existing and future neighborhoods in the Gateway area Specifically the Metro Plan diagram amendments are necessary antecedents to applying the City s new Mixed Use Commercial zoning district on a portion of the site The Metro Plan Diagram amendments will ultimately allow for nearly 50 acres ofMUC zoning and nearly 44 acres of MS zoning at the Gateway MDR site Both zoning designations will facilitate the City s nodal implementation project The City s INDO district requires a minimum of 12 dwelling units per acre whereas the existing MDR zoning of the site requires 10 units per acre The INDO District applied to the MUC MS and MDR Page 55 of 123 110 05 zones will also allow for a mixture of uses not curren ly available to developers The Gateway MDR site subject to the revised proposal is undeveloped so implementation of the proposal will have no direct affect on existing neighborhoods A 17 Provide opportunities for a full range of choice in housing type density size cost and location The 2004 Metro Plan amendments do not modify this policy Adoption of the revised proposal will not limit the City s ability to provide a full range in housing types In fact the residential housing on the Gateway MDR site is planned to be part of a unique development that will allow people to live in proximity to their work will offer easy access to transportation facilities and will be located in a pleasant area with views of the McKenzie River and access to a trail system along the river The proposal will also widen the range of housing types available at the Gateway MDR site by adding the MUC to an area dominated by MDR designation The MUC designation allows for the mix of residential and commercial uses in a vertical arrangement Additionally Residential Implementation Actions 12 0 121 and 13 6 and Commercial Element Policy 5 0 will facilitate the City s nodal implementation project Once implemented the INDO district will allow for a mixture of uses and a mixture of housing types Implementation Action 19 0 will allow for a housing density bonus ifdevelopers offer low moderate income housing opportunities A 22 Expand opportunitiesfor a mix of uses in newly developing areas and existing neighborhoods through local zoning anddevelopment regulations The 2004 Metro Plan amendments do not modify this policy The application of the MUC District and Residential Implementation Actions 12 0 121 and 13 6 and Commercial Element Policy 5 0 will facilitate the implementation of the nodal overlay which allows for a mix of uses and ensure compliance with this Metro Plan policy 3 Economic Element Policies B 1 Demonstrate a positive interest in existing and new industries especially those providing above above wage and salary levels and increased variety ofjob opportunities a rise in the standard of living and utilization of our existing Page 56 of 123 1 10 05 comparative advantage in the level of education and skill of the resident labor force The 2004 Metro Plan amendments do not modify this policy Approval of the revised proposal will assist in achieving this goal by providing for increased opportunity for new health care related employment in the City In general the hospital is expected to provide above average wage and salary levels an increased variety of job opportunities a rise in the standard of living and utilization of the region s existing comparative advantage in the level of education and skills of the resident labor force by providing a new and expanded job opportunity for medical professionals and other individuals at this location B 2 Encourage economic development which utilizes local and imported capital entrepreneurial skills and the resident laborforce The 2004 Metro Plan amendments do not modify this policy The eventual development enabled by the proposal will utilize both local and imported capital and will employ the resident labor force in a variety of skilled semi skilled and unskilled positions The construction of and the use of a hospital associated medical uses and the retail and residential node that these proposal will permit and facilitate will utilize local and imported capital encourage entrepreneurial skills and will employ members of the local labor force The MUC zoning which will allow for retail and commerciaL uses will allow entrepreneurs to establish businesses at the Gateway MDR site B3 Encourage local residents to develop job skills and other educational attributes that will enable them tofill existing job opportnities The 2004 Metro Plan amendments do not modify this policy The revised proposal furthers this policy by providing job opportunities both through the construction and operation of the hospital as well as through the eventual mixed use development opportunities that will encourage local residents to develop their job skills and other educational attributes B 6 Increase the amount of undeveloped land zonedfor light industry and commercial uses correlating the effective supply in terms of suitability and availability with the projections of demand The 2004 Metro Plan amendments do not modify this policy Page 57 of 123 110 05 The revised proposal will add nearly 50 acres of undeveloped Mixed Use Commercial and nearly 44 acres to Community Commercial with the MS zoning applied consistent with recommendations to increase the commercial lands Inventory made in the Springfield Commercial Lands Study The revise4 proposal supports this policy by increasing the amount of undeveloped land zoned for commercial uses because it provides for additional commercial land consistent with the region s desire to have a surplus B ll Encourage economic activities which strengthen the metropolitan area s position as a regional distribution trade health and service center The 2004 Metro Plan amendments do not modify this policy The proposal will enable the development of a regionally important medical center that will strengthen the metropolitan area s position as a premier locale for healthcare services B 14 Continue efforts to keep the Eugene and Springfield central business districts as vital centers of the metropolitan area The 2004 Metro Plan amendments do not modify this policy The revised proposal will not detract from the City s central business district s position as a vital center of the metropolitan area because the large tracts of land at RiverBend needed to accommodate the proposed medical center are not available within the central business district of the City Moreover there is nothing to suggest thatthe development of mixed use commercial uses at the Gateway MDR site would cause existing businesses in the Gity to relocate to the new development Additionally while not located in the Eugene central business district PeaceHealth is dedicating approximately 60 million toward renewal of the existing Sacred Heart Medical Center in Eugene The dual campus strategy will result in the retention and consolidation of approximately 1 800 jobs at the Hilyard campus Further relocating outpatient services from the existing Eugene Clinic s te in downtown Eugene to the Hilyard campus provides an outstanding opportunity for in fill and redevelopment at the Eugene Clinic site more proximate to the Eugene central business district While it is in the interest of both Cities downtowns to locate large employers proximate to the services and transportation options the downtowns provide the siting of physically large MS districts such as is proposed in the Springfield downtown would result in multiple non conforming uses and potential business and residential relocations This large scale single use would possibly detract from the pedestrian scale of the existing downtown and the vision for the downtown as a commercial node Page 58 of 123 1110 05 B I5 Encourage compatibility between industrially zoned lands and adjacent areas and local planning programs The 2004 Metro Plan amendments do not modify this policy The development proposed by PeaceHealth within the Gateway MDR site must first gain master plan approval by the City During this review the staff and the Springfield Planning Commission will review the application to ensure that any component of the proposed development will be compatible with the Campus Industrial area located adjacent to the Gateway MDR site to the north across Deadmond Ferry Rd The proposal is compatible with the industrially zoned lands to the north and will be made so through the local planning program in the City including but not limited to the master plan and site plan review processes B I6 Utilize processes and local controls which encourage retention oflarge parcels or consolidation ofsmallparcels in industrial or commercially zoned land tofacilitate their use or reuse in a comprehensive rather than piecemeal fashion The 2004 Metro Plan amendments do not modify this policy The circumstances surrounding the proposal are unique in that PeaceHealth is the sole property owner that own annexed property at the Gateway MDR site The common holdings present the City with approximately 177 acres of property that can be planned for through the City s comprehensive master plan process in conformance with this Metro Plan policy The revised proposal therefore satisfies this policy becausejt encourages the retention of a large parcel of land proposed to be zoned in part cOlnmercial to facilitate its use in a comprehensive fashion The land will be reusedln acomprehensive fashion through the master plan and site plan review process B I8 Encourage the development of transportation facilities which would improves access to industrial and commercial areas and improve freight movement capabilities by implementing the policies and projects in the Eugene Springfield Metropolitan Area Transportation Plan TransPlan and the Eugene Airport Master Plan The 2004 Metro Plan amendments do not modify this policy The proposal supports this policy because it will encourage the development of transportation facilities that will improve access to a commercial area and improve freight movement capability by implementing the policies and projects in TransPlan relevant to this application The proposal requires that any development on the Gateway MDR site achieve master plan approval The criteria of master plan Page 59 of 123 1 10 05 approval require that proposed on site and off site public and private improvements are sufficient to accommodate the proposed development Adequate transportation access to the up to entire MUC and MS area and to the Campus Industrial area to the north will be accounted for in the master plan B 22 Review loca ordinances and revise them topromote greaterflexibilityfor promoting appropriate commercial development in residential neighborhoods The 2004 Metro Plan amendments do not modify th s policy The City adopted SDC Articles 40 Mixed Use Zoning Districts and Article 41 Nodal Development Overlay District in July of 2002 T ese new zoning districts are intended to implement TransPlans policy objectives of integrating pedestrian scaled commercial establishments adjacent to and within residential areas The GRP Residential Implementation Actions 12 0 12 1 and 13 6 proposed through this revised proposal require that the required master plan include comply with the development and siting standards of SDC Articles 40 and 41 The current proposal achieves this policy by reviewing relevant local ordinances e g the GRP and proposes revisions to them to promote greater flexibility for promoting appropriate commercial development in a limited part of the INDO site area in and around residential neighborhoods B 23 Provide for limited mixing ofoffice commercial and industrial uses under procedures which clearly define the conditions under which such uses shall be permitted and which a preserve the suitability of the affected areas for their primary uses b assure compatibility and c consider the potentialfor increased traffic congestion The 2004 Metro Plan amendments do not modify this policy The proposal satisfies this policy for several reasons First the proposed text amendments will provide for the limited mixing of commercial and office uses Such mixing will be accomplished under procedures in the Citys Master Plan and Site Plan Review processes which clearly define the conditions under which such uses can be permitted Additionally the proposal preserves the suitability of the MDR site area for residential uese Further the proposal assures compatibility because the Master Plan and Site Plan Review processes are required to be followed B 28 Recognize the vital role of neighborhood commercialfacilities in providing services and goods to a particular neighborhood The 2004 Metro Plan amendments do not modify this policy Page 60 of 123 1 10 05 Through the City s nodal implementation project it is anticipated that portions of the MDR zoned property that at the Gateway MDR site will have the nodal overlay applied to it In this case up to 20 percent of the gross floor area of the residential developments can be dedicated to commercial uses as regulated by SDC Article 40 Also the MUC zoning proposed for approximately 50 acres of the site allows for supporting commercial retail uses to be blended with other medical and general office functions to serve the surrounding area with neighborhood commercial services This provides assurance that an appropriate level of neighborhood commercial facilities can be provided to the future residents of the site B l9 Encourage the expansion or redevelopment ofexisting neighborhood commercialfacilities as surrounding residential densities increase or as the characteristics of the support population change The 2004 Metro Plan amendments do not modify this policy Given the significant development medical retail office and residential that is expected to occur on the Gateway MDR site based on the proposal and required master plan commercial diagram and text designations in this area support this policy because they provide for a mixed use commercial area that supports the proposed office and residential development 4 Environmental Resources Element The Environmental Resources Element has been substantially revised The findings below first address the policies that were addressed in the previous decision in the order that they appeared in that decision but with the new corresponding policy number shown The findings then address the new applicable policies of this element of the Metro Plan Policies elS Springfield Lane County and Eugene shall consider downstream impacts when planningfor organization flood control urban storm runoff recreation and water quality along the Willamette and McKenzie Rivers The 2004 Metro Plan amendments do not modify this policy Development on the GatewayMDR site will be required to conform with natural resource and open space policies and standards contained in the GRP and the SDC Any development on the Gateway MDR site must conform with the SDC and the Springfield Engineering Design Standards and Procedures Manual Both documents contain requirements and standards intended to minimize the amount and Page 61 of 123 1 10 05 rate of stormwater runoff from developments and promote water quality PeaceHealth s storm drainage proposal for future development will be reviewed at both the master plan and again at the site plan review level to ensure compliance with the City s regulations The proposed development will use existing natural amenities as focal points for design while protecting and enhancing the site s scenic and natural resources and will not negatively impact the productivity or use of agricultural uses adjacent to the 1site or across the river In fact on a preliminary basis PeaceHealth continues to harvest the existing filbert orchard on the site and is maintaining the nursery tree stock on site for future use in site and street tree plantings The design of the RiverBend campus and hospital in particular will take advantage of the scenic value associated with the existing tand of Douglas fir trees proximity to the McKenzie River for visual access to and physical access along the river and the vistas of the Coburg Hills and other prominent topographic features off site Whereas the river s edge currently is marked by non native invasive species the site s master plan will include means of enhancing and restoring the site s riparian environment Pursuant to the annexation agreement between PeaceHealth and the City a riverside buffer will be retained that exceeds the City s setback standards established in recently adopted SDC language in conformance with the federal Endangered Species Act Therefore future development associated with the proposed Plan diagram and text amendments will be required to conform with standards and policies that ensure conformance with the above objective C 30 Except as otherwise allowed according to FEMA regulations development shal be prohibited in floodways ifit could result in an increased flood leveL The floodway is the channel of a river or other water course and the adjacent land area that must be reserved to discharge a one percentchanceflood in any given year The 2004 Metro Plan amendments do not modify this policy Although the proposal does not directly involve a development proposal the subsequent submittal of a required master plan will more directly address this policy consistent with the above policy PeaceHealth will not propose any development within the designated floodway that would increase flood elevations downstream Any proposed uses in the floodway will be largely ofa passive nature e g recreational facilities riparian enhancements that will allow potential flood flows to pass through the site unabated as required by SDC Article 27 SDC Article 27 Floodplain Overlay District will apply to any development at the Gateway MDR site that is within the 100 year flood hazard area including the floodway SDC27 040 3 excludes any encroachments including fill new construction substantial Page 62 of 123 1 10 05 improvements or other development in the floodway unless a registered engineer certifies that the encroachment will not result in any increase in flood levels C32 Local government shall require site specific soil surveys and geologic studies where potential problems exist When problems are identified local governments shall require special design considerations and construction measures be taken offset the soil and geologic constraints present to protect life and property public investments and environmentally sensitive areas The 2004 Metro Plan amendments do not modify this policy The Gateway MDR site contains no problematic soils or areas of geologic hazard or constraint that would be applicable to this policy The riparian area along the McKenzie River is an environmentally sensitive area PeaceHealth s preliminary plans recognize the sensitivity of this area and will incorporate appropriate land use and environmental safeguards to protect this area During the review of any master plan as required by the proposal and during any subsequent site plan review application the City Engineer will verify that the soil type is adequate to accommodate any proposed development C19 Agricultural production shall be considered an acceptable interim and temporary use on urbanizable land and on vacant and underdeveloped urban land where no conflicts with adjacent urban uses exist The 2004 Metro Plan amendments do not modify this policy The Gateway MDR site has a small hazelnut filbert orchard and an area east of Baldy View Lane that is in grass seed andor wheat production These agricultural uses are an interim and temporary use on urbanizable land until the PeaceHealth project is developed SDC Article 18 which regulates commercial districts permits agricultural cultivation of undeveloped land and thus ensures that the approval of the Amendments will not cause an inconsistency with the Metro Plan C26 Local governments shall continue to monitor to plan for and to enforce applicable air and water quality standards and shall cooperate immediately in applicable federal state and local air and water quality standards The 2004 Metro Plan amendments do not modify this policy The SDC was amended in August 2002 to achieve compliance with federal regulations relating to water quality in streams containing threatened and endangered species such as the McKenzie River Techniques necessary to ensure water quality standards will be applied to the future development that is anticipated through the Page 63 of 123 1 10 05 adoption of this proposal and required under the master plan and site plan review processes Lane Regional Air Pollution Authority is a member of the City s Development Review Committee and will review any future development proposals for this site to ensure compliance with air quality regulations C2l When planningfor and regulating development local governments shall consider the needfor protection of open spaces including those characterized by significant vegetation and wildlife Means ofprotecting open space include but are not limited to outright acquisition conservation easements planned unit development ordinances streamside protection ordinances open space tax deferrals donations to the public and performance zoning The 2004 Metro Plan amendments do not odify this policy The City has at its disposal several methods of conserving open space on the Gateway MDR site These include the imposition of a 75 foot building setback from the McKenzie River as part of its new Code language responding to Endangered Species Act protections and density transfers established in the Gateway Refinement Plan Residential Element Implementation Action 15 1 for protecting identified natural assets PeaceHealth s development proposals that will be submitted as part of a master plan will be required to meet or exceed the riparian setback standard and otherwise seek to conserve significant vegetation such as the Douglas fir grove identified in the GRP as other prominent vegetation Through these and other design elements offered in PeaceHealth s master plan a s bstantial amount of open space will remain conserved on site and incorporated into the overall design of the site These issues will more appropriately be addressed through the review process of the master plan However nothin in this proposal alters the Citys ability to encourage open space protection or the GRP policies that help conserve open space on the subject property The Springfield Bicycle Plan and TransPlan show an off street multi use path along the river frontage of the applicant s property Plan Amendment Residential Element Policy 13 0 and the recorded annexation agreements require that a master plan be approved prior to development of the applicant s site Willamalane will have a representative on the City s Development Review Committee and will participate in the review and recommendation to the City Council on the master plan and subsequent site plan review applications and will ensure that this metro plan policy is complied with Cll Local government shall protect endangered and threatened plant and wildlife species as recognized on a legally adopted statewide list after notice and opportunityfor public input The 2004 Metro Plan amendments do not modify this policy Page 64 of 123 IIi 0 05 The proposal satisfies this policy because no endangered and threatened plant and wildlife species have been identified on the site Further the applicant will provide appropriate environrilental safeguards pursuant to applicable SDC standards so that any such species located downstream in the McKenzie and Willamette Rivers will be unaffected by this proposal Threatened aquatic species are found in the McKenzie River adjacent to the site The SDC was amended in August of 2002 to incorporate standards designed to protect water quality and to apply these standards to new development and redevelopment Any development approved pursuant to this or any later development proposal will be subject to these standards and will be in conformance with this Metro Plan policy C 22 Design of new street highway and transitfacility shall consider noise mitigation measures where appropriate The 2004 Metro Plan amendments do not modify this policy LTD has indicated that the transit service would remain on MLK Parkway south of the subject site Appropriate noise mitigation measures will be considered if deemed appropriate and during development of the site and through master plan approval The master plan required by Residential Implementation Action 13 0 prior to any development is required by Residential Implementation Action 13 2 to include the consultation ofan acoustic engineer The Planning Director and the City Engineer will review the master plan and subsequent site plan review applications with the evidence supplied by this professional and will require mitigation measures where appropriate and will ensure compliance with this Metro Plan policy 5 Willamette River Greenway Riyer Corridors and Waterway Element Policies D l Periodically local government shall review Greenway boundaries uses and potential acquisition areas to ensure continued compliance with state and local Greenway goals The 2004 Metro Plan amendments do not modify this policy The proposal satisfies appropriate Greenway driven policies and concerns Consistent with the statement in this portion of the Metro Plan PeaceHealth intends to utilize the riparian area along the McKenzie River for open space and recreational purposes The development anticipated upon adoption of the proposal will be reviewed by the City to ensure compliance with the SDC The SDC contains requirements for a minimum of a 75 foot setback from the top of bank along the Page 65 of 123 1 10 05 McKenzie River and limits the uses within this setback therefore ensuring a greenway buffer along the river During master plan review the potential for acquisition of areas to ensure continued compliance will be evaluated D 5 New development that locates along river corridors and waterways shall be limited to uses that are compatible with the natural scenic and environmental qualities of those waterfeatures The 2004 Metro Plan amendments do not modify this policy Although no development is proposed as part of this proposal it establishes the basis for subsequent submittal of a master plan required for future development on the Gateway MDR site The record includes evidence reflecting a substantial and credible body ofempincal research that demonstrates the positive effects of access and views of natural environments and natural light in speeding patient recovery times PeaceHeaIth sproposed iocation of hospital and medical service uses along the McKenzie River corridor is inherently compatible with and seeks to conserve and enhance the natural scenic and environmental qualities of the McKenzie River The proposal enables the future development of a compatible mix of supporting uses away from the river corridor to complement the planned hospital and medical services development Additionally Residential Implementation Action 12 6 reserves the ability of the City Council to regulate the height and setbacks of during master plan review City officials and the public will have an opportunity during the master plan review to review uses and arrangement of development to ensure that the development is compatible with the natural scenic and environmental qualities of those water features 6 Environmental Design Element Policies E In order to promote the greatest possible degree of diversity a broad variety of commercial residential and recreational land uses shall be encouraged when consistent with otherplanning policies The 2004 Metro Plan amendments do not modify this policy The Gateway MDR is currently designated MDR The proposal will establish Metro Plan and eventual zoning designations that allow a diverse mosaic of hospital residential and commercial uses to be arranged in way that will allow for nodal development principles to be realized in the area The proposal enables the development of a master plan for an integrat d live work environment that embraces the site s natural amenities enhances recreational opportunities and helps meet other Page 66 of 123 1 10 05 objectives outlined in the GRP The proposal will allow for a mix of uses that currently are not permitted at the Gateway MDR site and will therefore increase the diversity of commercial and residential development Additionally the required master plan review will include a review of recreational land at the site to ensure that it is adequate to serve the future residents and other uses of the site and ensures compliance with this policy B 2 Natural vegetation natural waterfeatures and drainageways shall be protected and retained to the maximum extent practical Landscaping shall be utilized to enhance those naturalfeatures This policy does notpreclude increasing their conveyance capacity in an environmentally responsible manner The 2004 Metro Plan amendments do not modify this policy To the extent natural vegetation large trees is protected by the City s GoalS designations PeaceHealth will be required to comply with any applicable City requirements protecting these resources during the master plan review process The McKenzie River to the extent it is considered a natural water feature will be proteCted through compliance with buffer requirements set forth in the applicable annexation agreement and through the application of the stormwater quality requirements of the SDC As part of the master plan landscaping will be used to enhance the natural vegetation in the McKenzie River area s required by SDC Article 32 and will be reviewed at site plan review All eventual development must comply with SDC Article 31 SDC 31240 contains standards for protecting open drainage ways as described in this Metro Plan policy Additionally PeaceHealth will be required to submit a comprehensive drainage plan with the master plan The City Engineer will review this pl to ensure compliance with the standards of the Code and ensure compliance with this policy B3 The planting of street trees shall be strongly encouraged especially for all new developments and redeveloping areas wherefeasible and new streets and reconstruction of major arterials within the urban growth boundary The 2004 Metro Plan amendments do not modify this policy SDC Section 32 0S0requires street trees to be planted as a component of development Planting of street trees will be a condition of development approval and implements this policy Page 67 of 123 1 10 05 E4 Public and private facilities shall be designed and located in a manner that preserves and enhances desirable features of local and neighborhood areas and promotes their sense of identity The 2004 Metro Plan amendments do not modify this policy Residential Implementation Action 13 6 requires that development within mile of the future BRT transit station at the Gateway MDR site be designed in conformance with SDC Articles 40 and 41 Articles 40 and 41 contain required design features that promote pedestrian scaled development including connections to the surrounding existing neighborhoods This coupled with ability of the City Council to regulate height in master plan as indicated in Residential Implementation Action 12 6 will ensure the City s ability to require design features that enhance the local neighborhoods These will include a retail component in the nodal area to provide goods and services to the surrounding neighborhood and a multi use path along the McKenzie River and shown in TransPlan and the Springfield Bicycle Plan to provide recreational opportunities to existing residents Finally PeaceHealth has expressed an intention to work with the neighbors living west of Game Farm Road South to ensure that the development between Pioneer Parkway and Game Farm Road South is appropriate for that area and to the extent practical preserves and enhances the desirable feature of the local and neighborhood area while promoting the identity of the area E 5 Carefully develop sites that provide visual diversity to the urban area and optimize their visual and personal accessibility to residents The 2004 Metro Plan amendments do not modify this policy The Gateway MDR site provides visual diversity in the Springfield urban area PeaceHealth has explained that the proposed design will incorporate broad vistas through open areas and will leave the McKenzie River riparian area in an open state for visual accessibility Moreover the design and configuration of the eventual development permitted will be reviewed during the required master plan process by the City to ensure visual and personal accessibility to residents Pedestrian bicycle and vehicle access to the sight from surrounding residential areas will be a requirement of master plan approval E 7 The development of urban design elements as part of local and refinement plans shall be encouraged The 2004 Metro Plan amendments do not modify this policy Page 68 of 123 110 05 The proposal includes policies that require development of portions the PeaceHealth property to be designed to comply with design elements of SDC Articles 40 and 41 These two Articles contain the City newest urban design elements therefore this Metro Plan policy has been complied with E 8 Site planning standards developed by localjurisdictions shall allowfor flexibility in design that will achieve site planning objectives while allowing for creative solutions to design problems The 2004 Metro Plan amendments do not modify this policy SDC Article 11 Variances and Modifications of Provisions provides developers with a vehicle to achieve flexibility in the standards of the SDC that may not be congruent to the design objectives of future development at the GatewayMDR site Additionally Residential Implementation Action 13 6 exempts hospitals and associated medical uses in the MS and INDO Districts from specific development standards if the developer can demonstrate and that the City Council concurs that the Purpose of the Nodal Overlay District 40 010 1 is met This flexibility allows for the compliance with this Metro Plan policy PeaceHealth has indicated the development will incorporate the flexibility inherent in the SDC to achieve optimum creative solutions for the development of this site 7 Transportation Element Land Use Policies F I Apply the nodal development strategy in areas selected by each jurisdiction that have identified potentialfor this type oftransportation efficient land use pattern The revised proposal continues to implement this policy because it will allow for the imposition of nodal development in this area pursuant to TransPlan s recommendation that this area be a node The revised proposal and the eventual development further this policy by providing for mixed use commercial adjacent to a large hospital development with surrounding residential development The synergistic effect of the combined three land use areas developed through an overall master plan provides opportunities for nodal development Residential Implementation Action 13 6 requires that the master plan for the applicant s site show that all development within one quarter mile of transit stops be designed in conformance with the standards of Article 41 Nodal Development Overlay District The City is currently undergoing nodal implementation in six sites throughout the city the Gateway MDR site is one of these sites It is anticipated that the City s action for redesignation of the appropriate Page 69 of 123 1 1005 t property at the Gateway MDR site will be processed concurrently with the master phm and will ensure that this Metro Plan policy is complied with F 3 Provide for transit supportive land use patterns and development including higher intensity transit oriented development along major transit corridors and near transit stations medium and high density residential development within one quarter mile of transit stations major transit corridors employment centers and downtown areas and development and redevelopment in designated areas that are or could be well served by existing or planned transit Residential Implementation Action 13 6 requires the applicant to comply with SDC Article 41 in areas within one quarter mile of the proposed transit stop ensures that this policy is implemented The proposal and the eventual development will provide for a transit supportive land use pattern with higher than average densities and a BRT line extending through the site The development will incorporate medical services office c mmercial and residential land use F 4 Require improvements that encourage transit bicycles and pedestrians in new commercial public mixed use and multi unit residential development The SDC has been acknowledged by the DLCD as being consistent with Transportation Planning Rule 12 including containing adequate provisions for bicycles and pedestrians facilities PeaceHealth will be required to comply with these standards for any development approved by these plan amendments Additionally the City and Lane Transit District have determined that Bus Rapid Transit phase 2 will extend BRT to the Gateway MDR site The master plan approval process will ensure that the transit stop is appropriately placed to encourage transit use F 5 Within three years of TransPlan adoption apply theND NodalDevelopment designation to areas selected by each jurisdiction adopt and apply measures to protect designated nodes from incompatible development and adopt a schedule for completion of nodal plans and implementing ordinances The City Council has directed City staff to perform the analysis necessary to apply the Nodal overlay to six sites within the City The Gateway MDR site is one of these sites The assessment of this site is underway It is anticipated that the redesignation of appropriate property at the Gateway MDR Site will be processed concurrently with the applicant s master plan therefore this policy is fulfilled The proposal furthers this policy by incorporating an amendment to the GRP text encouraging application of Nodal Development to the site Moreover PeaceHealth expressed its intention to actively consider nodal development participation for a portion of this area Page 70 of 123 1110 05 Transportation Demand Management Policies F 6 Expand existing TDMprograms and develop new TDMprograms Establish TDM benchmarks and ifthe benchmarks are not achieved mandatory programs may be established Residential Implementation Action 13 7 requires a Trip Allocation Plan to be submitted with the required master plan and imposes a trip cap to areas subject to these plan amendments The trip cap will encourage the applicant to voluntarily implement Transportation Demand Management techniques at their site and implements this metro plan policy F 8 Implement TDM strategies to manage demand at congested locations The trip cap required by Residential Implementation Action 13 7 in addition to the extension of BRT are strategies intended to reduce congestion PeaceHealth will be required to submit a Transportation Impact Analysis for both the required master plan and subsequent site plan review applications The TIAs will provide information that will allow the City to analyze the potential use of additional TDM strategies Transportation System Improyements System Wide F IO Protect and manage existing andfuture existing transportation infrastructure Residential Implementation Action 13 7 imposes a vehicle trip cap to areas subject to these Amendments and ensures that the find ngs regarding capacity in the applicant s TIA are realized and ensures compliance with this policy The proposal and the conditions of approval protect and manage existing and future transportation infrastructure because as explained in sections of this application addressing the transportation planning rule and the Oregon Highway Plan this application maintains acceptable volume to capacity v c ratios at relevant intersections Additional findings relating to this and other transportation related policies are discussed under the Goal 12 findings s et forth above The City Council incorporates those findings here with respect to these transportation policies F II Develop or promote intermodallinkages for connectivity and ease of transfer among all transportation modes The Gateway MDR site will have intermodallinkages between BRT and pedestrianandbicyclefacilitiesMoreoverPeaceHealthwillberequiredtoprovidebicycleand pedestrian connections through the areas subject to these plan amendments to surrounding residential area as required by SDC Articles 31 an 32 BRT and or Page 71 of 123 1 10 05 traditional bus service will provide transit linkage to the site All intermodallinkages will be reviewed by the City at the master plan and site plan review process to ensure that this Metro Plan policy is implemented F 13 Support transportation strategies that enhance neighborhood livability This proposal furthers this policy by encouraging development of areas adjacent to a transit line with connectivity to pedestrian and bicycle links The BRT line the on site pedestrian and bicycle facilities and the required linkages to the surrounding developed residential areas as approved by the required master plan will create livability within new neighborhoods at the Gateway MDR site and will enhance livability in existing surrounding neighborhoods Transportation System Improyements Roadways Metro Plan page 111 F 8 F 15 motor vehicle level of service policy 1 Use motor vehicle level of service standards to maintain acceptable and reliable performance on the roadway system These standards shall be usedfor a Identifying capacity deficiencies on the roadway system b Evaluating the impacts on roadways of amendments to transportation plans acknowledged comprehensive plans and land use regulations pursuant to the TPR OAR 660 12 0060 c Evaluating development applicationsfor consistency with the land use regulations of the applicable local governmentjurisdiction This application implements this policy because as explained elsewhere the affected roadways will not experience an unacceptable decline in capacity due to this application The applicant has submitted a Traffic Impact Analysis in support of the proposed plan amendments The TIA has been reviewed by the City Transportation Engineer and by ODOT who have determined that the plan amendments as conditioned comply with this Metro Plan policy The City Council finds that the Amendments are consistent with this policy 2 Acceptable and reliable performance is defined by the following levels of service under peak hour traffic conditions LOS E within Eugene s Central Area Transportation Study CATS area and LOS D elsewhere These amendments do not change the definition of acceptable and reliable performance As these findings explain and the traffic analysis demonstrates upon adoption of these Metro Plan amendments required levels of service will be maintained Page 72 of 123 1 10105 3 Performance standardsfrom the OHP shall be applied on statefacilities in the Eugene Springfield metropolitan area In some cases the level of service on a facility may be substandard The local governmentjurisdiction mayfind that transportation system improvements to bring performance up to standard within the planning horizon may not be feasible and safety will not be compromised and broader community goals would be better served by allowing a substandard level ofservice The limitation on thefeasibility of a transportation system improvement may arise from severe constraints including but not limited to environmental conditions lack ofpublic agency financial resources or land use constraint factors It is not the intent of TSI Roadway Policy 2 Motor Vehicle Level ofService to require deferral of development in such cases The intent is to defer motor vehicle capacity increasing transportation system improvements until existing constraints can be overcome or develop an alternative mix of strategies such as land use measures TDM short term safety improvements to address the problem The amendments do not affect the use of performance standards from the OHP on state transportation facilities As the findings elsewhere in this decision demonstrate the Amendments and eventual development will maintain required volume to capacity V IC ratios on state facilities F 17 Manage the roadway system to preserve safety and operational efficiency by adopting regulations to manage access to roadways and applying these regulations to decisions related to approving new or modified access to the roadway system The amendments do not affect the adoption or application of access management regulations Existing and proposed access to the Gateway MDR site is through roadways subject to the SDC SDC Article 32 contains standard that regulate access to these roadways These standards will be applied to any development authorized by these plan amendments during the development review process and will ensure compliance with this Metro Plan policy Transportation System Improvements Transit Metro Plan page III F 9 F 18 Improve transit service and facilities to increase the system s accessibility attractiveness and convenience for all users including the transportation disadvantaged population The Gateway MDR site has been identified by LTD and the City as a BRT phase 2 service area LTD is on the City s Development Review Committee and will provide recommendations to the Planning Commission and the City Council during the master Page 73 of 123 1 10 05 plan review on the most efficient way to provide traditional and rapid transit service to any development permitted by these plan amendments F 19 Establish a BRT system composed offrequent fast transit service on major corridors and neighborhoodfeeder service that connects with the corridor service and with activity centers ifthe system is shown to increase transit mode split along BRT corridors iflocal governments demonstrate support and iffinancing for the system is feasible The City is working with LTD to facilitate the extension of the BRT line to serve the area subject to these plan amendments in conformance with this Metro Plan policy Transportation System Improyements Bicycle F 22 Construct and improve the region s bikeway system and provide bicycle system supportfacilities for both new development and redevelopmentexpansion The amendment further this policy by providing for an opportunity for extensive bike system improvements adjacent to and connecting with the local roadway network on the site While these amendments do not directly affect the provision of bicycle service to the subject area the Springfield Bicycle Plan shows bicycle connections and a multi use path through the areas subject to these plan amendme ts The construction of these bicycle facilities as well as bicycle support facilities such as covered bicycle parking in conformance with SDC 31 220 will be a requirement of development approval and will implement this Metro Plan policy F 23 Require bikeways along new and reconstructed arterial and major collector streets TransPlan implements this policy by requiring b keways along all new and reconstructed arterial and major collector streets The areas subject to these amendments will contain arterial and collector streets that will be improved with bikeways as provided for in TransPlan Pioneer Parkway will contain a bikeway F 24 Require bikeways to connect new development with nearby neighborhood activity centers and major destinations SDC 32 090 requires bikeways to be connected to nearby neighborhood activity centers and major destinations This SDC provision will be applied to any development permitted by the proposal at the time of master plan and subsequent site plan review and implements this policy This proposal and the Metro Plan amendments further this policy by providing bikeways to connect this development Page 74 of 123 110 05 with nearby neighborhood activity centers and major destinations including retail and employer destinations to the northwest and north and retail destinations to the south Transportation System Improvements Pedestrian F 26 Provide for a pedestrian environment that is well integrated with adjacent land uses and is designed to enhance the safety comfort and convenience of walking Residential Implementation Action 13 6 requires all development within one quarter mile of proposed transit stops at the Gateway MDR site to be developed in accordance with the standards of SDC Article 41 These standards are designed to create a pedestrian environment that is integrated with adjacent land uses and to encourage walking Implementation Action 13 6 will require the master plan application be designed in a friendly pedestrian environment integrated with adjacent land uses and not only designed to enhance the safety comfort and convenience of walking but will encourage pedestrian activity F 27 Provide for a continuous pedestrian network with reasonably direct travel routes between destination points The Metro Plan amendments and future development will achieve this policy by providing for a system of interconnected pedestrian pathways Residential Implementation Action 13 5 requires that the initial master plan for the Gateway MDR site include a conceptual pedestrian circulation system plan for all annexed portions of the Gateway MDR site There is enough annexed territory at the site to allow for a comprehensive review of this plan to ensure consistency with this Metro Plan policy F 28 Construct sidewalks along urban area arterial and collector roadways except freeways SDC 32 040 requires sidewalks to be installed along both sides of all minor arterial collector and local roadways within the City This standard will be applied to any development permitted by these Amendments and therefore ensure compliance with this Metro Plan policy Page 75 of 123 1 10 05 Transportation System Finance F36 Require that new development payforits capacity impact on the transportation system The requirements of the annexation agreements for annexed property within the area subject to these amendments requires future developers to pay over 11 million dollars to construct off site transportation improvements to accommodate traffic If additional impacts are identified during the development review process the City has a policy of exacting additional improvements that are proportional to the impacts of the proposed development F 37 Consider and include among short term project priorities those facilities and improvements that support mixed use pedestrian friendly nodal development and increased use ofalternative modes The amendments and the eventual development of the Gateway MDR site will encourage the development of appropriate transportation improvements through applicant funded improvements including transportation infrastructure Residential Implementation Action 13 6 requires development permitted by these plan amendments to be designed in conformance with the nodal standards adopted in Articles 40 and 41 and ensures consistency with this Metro Plan policy 8 Public Facilities and Seryice Element Seryices to Deyelopment Within the Urban Growth Boundary Planning and Coordination Policies G 1 Extend the minimum level andfull range of key urbanfacilities and services in an orderly and efficient manner consistent with the growth management policies in Chapter II B relevant policies in this chapter and other Metro Plan policies Development at the Gateway MDR site is restricted by recorded annexation agreements until such time as a minimum level of key urban services are extended to serve the site The specific sizing and phasing of these services will be reviewed and approved by the City during the master plan process Therefore any development approved by this proposal is guaranteed to have these services and this application is in conformance with this policy Approval of the amendments will result in the extension of key urban facilities and services in an orderly and efficient manner to a site within the City s UGB G 2 Use the Planned Facilities Map of the Public Facilities and Services Plan to guide the general location of water waste water storm water and electrical projects Page 76 of 123 1 10 05 in the metropolitan area Use localfacility master plans refinementplans and ordinances as the guide for detailedplanning and project implementation The amendments will permit development that will utilize the facilities as planned for in the PFP The proposal will allow development that will result in implementation of the Planned Facilities Map of the PFP No amendments to this plan are required therefore this application is in conformance with this Metro Plan policy G3 Modifications and additions to or deletions from the project list in the Public Facilities and Seryices Plan for water waste water and storm water publicfacility projects or significant changes to project location from that described in the Public Facilities and Services Plan maps 1 2 and 3 requires amending the Public Facilities and Seryices Plan and the Metro Plan exceptfor the following omitted The amendments propose no additions to or deletions from the referenced project list The amendments will permit development that will utilize the facilities as planned for in the PFP No amendments to this plan are required therefore this application is in conformance with this Metro Plan policy G 5 The cities shall continue jointplanning coordination with major institutions such as universities and hospitals due to their relatively large impact on local facilities and services PeaceHealth has been in constant contact with the City regarding its proposal to locate a major medical facility at the Gateway MDR site and will be required to work with the City to ensure that public facilities are not overloaded by development of the Site The City s coordination with McKenzie Willamette Hospital has resulted in the creation of the Hospital Support Overlay District SDC Article 27 that was adopted with the Development Code in 1987 and also in the creation of the Medical Services District Article 22 adopted in 1989 The City of Eugene and Lane County have been notified of this proposal on remand and have been provided an opportunity to participate Although Lane County participated in the appeal of the original proposal neither the City of Eugene nor Lane County have elected to participate in the proposal on remand Because the City of Eugene has elected not to participate and has not made findings that the amendments will result in a Regional Impact the City has complied with this Metro Plan policy Staffwill continue to coordinate with both hospitals in the future in conformance with this Metro Plan policy Page 77 of 123 1 10 05 G 8 The cities and county shall coordinate with cities surrounding the metropolitan area to develop a growth management strategy This strategy will address regional public facility needs The amendments further this policy by encouraging the development of a site within the existing urban growth boundary which implements the regional growth management strategy The three jurisdictions have adopted the PFP and the Metro Plan both of which contain growth management strategies and address regional pubic facility needs The amendments do not permit development that is incongruent with or requires the amendment of either of these documents therefore it is consistent with this Metro Plan policy Seryices to DeyelopmentcWithin the Urban Growth Boundary Water G 9 Eugene and Springfield and their respective utility branches EWEB and Springfield Utility Board SUB shall ultimately be the water service providers within the urban growth boundary The area subject to these amendments is entirely annexed and will be served by SUB in conformance with this Metro Plan policy G 10 Continue to take positive steps to protect groundwater supplies The cities county and other service providers shall manage land use and public facilities for groundwater related benefits through the implementation of the Springfield Drinking Water Protection Plan and other wellhead protection plans Management practices instituted to protect groundwater shall be coordinatedamong the City of Springfield City ofEugene and Lane County Areas subject to these amendments fall within the 5 and 10 year time of travel as depicted on the Springfield Wellhead Protection Map As such all development permitted by these plan amendments will be subject to the provisions of SDC Article 17 Drinking Water Protection Overlay District thus ensuring compliance with this Metro Plan policy G 11 Ensure that water mai1J extensions within the urban growth boundary include adequate consideration offire flows Water mains will be brought to the site in conjunction with the planned extensions of Pioneer Parkway and Cardinal Way and will also be available from the north from Deadmond Feny Road through the Baldy View rightofway The appropriate portions of this planned water extension will be done prior to development permitted by these amendments The Springfield Fire Chief in consultation with SUB determined during the annexation proceedings for the area subj ct to the amendments Page 78 of 123 1 10 05 that adequate fire flow would be available to serve development Therefore this Metro Plan pol cy has been complied with Services to Development Within the Urban Growth Boundary Stormwater Policies G 13 Improve surface and groundwater quality and quantity in the metropolitan area by developing regulations or instituting programs for storm water to omitted Approval of these amendments and the eventual development will result in a development that relies on the steps implemented by the local governments to ensure groundwater quality The provisions of SDC Article 17 regarding groundwater protection and SDC Articles 31 and 32 relating to stormwater quality will be imposed upon any development permitted by these amendments G 14 Implement changes to storm waterfacilities and management practices to reduce the presence ofpollutants regulated under the Clean Water Act and to address the requirements ofthe Endangered Species Act The development of the site must comply with applicable local regulations intended to implement this policy The SDC as amended in August of2002 requires stormwater facilities and management practices for pollutants regulated under the Clean Water Act and address the requirements of the ESA These standards will be applied to any new developments permitted by these amendments and ensure compliance with this Metro Plan policy G 15 Consider wellhead protection areas and surface water supplies when planning storm waterfacilities The provisions of SDC Article 17 and Articles 31 and 32 consider wellhead protection and water quality of surface waters The requirements of these articles will be applied to any development permitted by these amendments at the time of development review and ensures compliance with this policy G 16 Manage or enhance waterways and open storm water systems to reduce water quality impactsfrom runoff and to improve storm water conveyance SDC Article 32 and 32 and the City s Engineering Design Standards and Procedures Manual contain standards that manage and enhance waterways and open stormwater systems and reduce water quality impacts These requirements will be applied to any development permitted by the amendments and ensure compliance with this policy Approval of the amendments willresult in a development which minimizes water rPage 79 of 123 1 II0 05 The City s development application fee schedule contains a graduated fee related to the amount of impervious surface in a development This provides a financial incentive for developers to install less impervious surfaces The City s Mixed Use and Nodal Overlay districts which will apply to developments permitted by the Amendments include a maximum number of parking spaces which limits impervious surfaces G 19 Maintainjlood storage capacity within thejloodplain to the maximum extent practical through measures that may include reducing impervious surface in the jloodplain and adjacent areas No development is proposed as part of these application and any issues regarding flood storage capacity are more appropriately addressed during master plan site plan review or other comparable processes PeaceHealth is bound by annexation agreement to produce flood studies to accompany the required master plan TheCity Engineer will evaluate the drainage plan to ensure conformance with this policy and with the requirements of SDC Article 27 which regulates floodplain development and which has been recognized as being in conformance with this Metro Plan policy as well as Goal 7 Services to Development Within the Urban Growth Boundary Schools G 21 The cities shall initiate a process with school districts within the urban growth boundary for coordinating land use and school planning activities The cities and school districts shall examine the following in their coordination efforts omitted The Gateway MDR site is within the 4J School District The school district reviewed the annexation request and determined that the inclusion of this area in the city limits was consistent with their planning policies and projections The number of dwelling units required by proposed Residential Implementation Action 12 6 is consistent with the density projections for the area as designated entirely MDR Therefore the Amendments will not affect the school district s projections Page 80 of 123 110 05 Services to Deyelopment Within the Urban Growth Boundary Financing Policies G36 Require development topay he cost as determined by localjurisdiction of extending urban facilities This does notpreclude subsidy where a development willfulfill goals and recommendations in the Metro Plan and other applicable plans determined by the localjurisdiction to be ofparticular importance or concern Any development permitted by these amendments and the resulting master plan will be required to extend services at the developer s expense that is proportionate to the impacts of the development This will come in the form of required construction or in the assessment of Systems Development Charges SDCs that have been calculated to capture the cost of providing regional service capacity G37 Continue to implement a system of user charges SDCs and other public financing tools where appropriate tofund operations maintenance and improvement or replacement of obsolete facilities or system expansion The applicant will be required to pay appropriate SDC charges The City assesses SDCs on new developments in the City Any development at the Gateway MDR site must contribute SDCs at the time of development 9 Parks and Recreation Facilities Element Policies H 4 Encourage the development ofprivate recreational facilities Willamalane is on the City s Development Review Committee and will participate in the review of any development permitted by the amendments The City will coordinate with Willamalane to ensure both public and private recreational facilities are adequately planned for at the master plan level This review will ensure compliance with this policy 10 Historic Preservation Element Policies Ll Adopt and implement historic preservation policies regulations and incentive programs that encourage the inventory preservation and restoration ofstructures landmarks sites areas of cultural historic or archeological significance consistent with overall policies To the extent an inventoried adopted historic structure is on the site the applicant will be required to comply with applicable governing tegulations SDC Article 30 Historic Oveday District regulates the alteration of inventoried significant Goal 5 historic resources in Springfield While there are three contributing historic Page 81 of123 1 10 05 structures as identified in the GRP in the area affected by the amendments none of these are considered primary or significant GoalS historic resources that are subject to the provisions of SDC Article 30 11 Energy Element Policies J3 Land allocation and developmentpatterns shall permit the highestpossible current and future utilization of solar energy for space heating and cooling in balance with the requirements of other planning policies The amendments do not affect the possible utilization of solar energy in future development Conunercial uses are as able to take advantage of solar energy as residential uses The MS MUC and MDR zoning districts permitted by the amendments will be subject to the solar setback standards ofSDC 16 050 5 where they abut residential areas to the north The application of these standards at the development review phase will ensure that this policy is met J 4 Encourage development that takes advantage of natural conditions such as microclimate and utilizes renewable energy supplies such as solar energy to milimize nonrenewable and overall energy consumption Although no development is proposed as part of this approval any development that does occur on the Gateway MDR site will take advantage of the natural conditions of the area for a variety of purposes including maximization of solar energy utilization During the development review phase of any uses permitted by these amendments the City will endeavor to encourage the use of renewable energy and take advantage of natural conditions that would minimize energy consumption consistent with applicable City development regulations J 7 Encourage medium and high density residential uses when balanced with other planning policies in order to maximize the efficient utilization of all forms of energy The greatest energy savings can be made in the areas of space heating and cooling and transportation For example the highest relative densities of residential development shall be concentrated to the greatest extent possible in areas that are or can be well served by mass transit paratransit and foot and bicycle paths These amendments will result in conunercial development adjacent to relatively higher density residential development and the proposed hospital campus thereby providing opportunities to reduce travel distance between home work and shopping and reducing energy consumption This will not result in residential development being located any further from public transportation facilities or paths than is already planned because the application proposes to change the Plan Map designation of Page 82 of 123 1110 05 residential land to commercial land The amendments will allow for MDRnodal development adjacent to areas zoned for MS and MUC MDR with a nodal overlay has no maximum density the density is limited by a maximum height restriction This potential density will encourage developers to utilize creative techniques in the design of the residential areas of the areas affected by the Amendments J 8 Commercial residential and recreational land uses shall be integrated to the greatest extentpossible balanced with all planning policies to reduce travel distances optimize reuse of waste heat and optimize potential on site energy generation The amendments will allow for MUC and MS and MDR and will facilitate the designation of a nodal overlay This will allow for a mixing of commercial and residential uses that is not currently possible at the site This mixture of use will allow future residents and users of the site to live work and shop within a Goncise geographic area This will allow for a reduction of travel distances and will implement this policy The amendments will enable the development of a comprehensive master plan for the applicant s property that will integrate a mix of commercial residential office and retail uses with hospital and medical uses The proximity and arrangement ofuses will be illustrated on the applicant s required master plan Page 83 ofl23 III 0 05 F Consistency With Gateway Refinement Plan For The Metro Plan and GRP Diagram Amendments 1 Summary This section of this findings addresses the applicable Policies and Implementation Actions and Implementation Measures of the GRP as applied to the GRP diagram amendments Certain Policies and Implementation Measures have been omitted from these findings where they either 1 impose a duty on the City to act in a certain way and that duty is clearly not affected by these amendments 2 apply to land uses other than the current or proposed designations for the Gateway MDR site and will not be affected by the amendments or 3 clearly apply only to development applications Additionally as discussed above with respect at the Metro Plan Goals and Objectives these findings do not address the Goals of the GRP Residential Element Policies and Implementation Actions 1 0 The City shall through site plan review home and neighborhood improvement programs andor other relatedprograms actively participate in efforts to maintain and enhance existing residential neighborhoods and attract compatible multifamily developments that would enhance the Gateway Refinement Plan area This proposal does not affect Site Plan Review for future development proposals However the amendments will enable the retention of a significant area designated MDR and available for multi family residential developments compatible with the mix of other uses and hospitalmedical uses planned at RiverBend 15 0 Encourage the incorporation of significant naturalfeatures shared open spacesscenic areas and recreational pathways into developmentplans No specific development is proposed as part of this application therefore it is not appropriate to consider incorporation of natural features at this time Nothing approved through these amendments will preclude the City from protecting the resources identified in this Implementation Action This policy will be implemented through the master planning process 16 0 The City shall encourage and facilitate comprehensive development ofa range in type and affordability of quality housing opportunities within the area mapped as the McKenzie Gateway MDR Sit by taking the following actions Page 84 of 123 1110 05 The amendments will enable a mix of residential and non residential uses on the site which will be the subject of a subsequent master plan This master plan will consider a range of housing types in the context of a comprehensive master plan for the entire site Therefore while approval of the amendments constitutes encouragement and facilitation of comprehensive development and a range of housing opportunities on the site no specific development is proposed or approved as part of this approval and it is more appropriate to consider development of a range of housing opportunities through the master plan process rather than through this application Nonetheless as explained elsewhere PeaceHealth will have to provide a number of housing units within the range currently allowed under the existing MDR zoning Nothing in these amendments precludes the comprehensive development of a range of housing opportunities 16 1 At the property owners request the City shall work with the property owners and appropriate state federal and nonprofit agencies to seek financing assistance for housing developments and associated public facilities and amenities where a minimum of 20 ofthe total units wouldprovide low moderate income housing opportunities consistent with US Department of Housing and Urban Development HUD guidelinesfor low moderate income No specific development is proposed as part of this proposal therefore it is not appropriate to consider such specifics on the development of a range of housing opportunities at this time 17 0 Mitigate adverse impacts ofpublic facilities on residential areas No specific development is proposed as part of this proposal therefore it is not appropriate to consider the impacts of public facilities at this time 17 1 Future electrical substations roads fire stations and sanitary and storm sewer facilities shall be buffered to the extent reasonably practical from existing residential developments and residentially designated areas Acceptable buffering shall include a combination of landscaping set backs berms wood or masonryfences or walls and other methods that provide aesthetic buffering Landscaping setbacks and other means of buffering the above cited facilities will be considered appropriately through the master plan and site review processes and not through the adoption of these amendments 18 0 The City ofSpringfield shall evaluate the potential of redesignating some portion of the land east ofBaldy View Land which is currently designated Page 85 of 123 110 05 MDR to LDRin the context of the next Metro Plan Update or Periodic Review Process whichever comesfirst in order to expand the range of housing opportunities available in the Gateway Refinement Plan Area This proposal does not affectthe MDR designated land located east of Baldy View Lane 4 Commercial Element Goals 1 Improve the appearance and vitality of all commercial activities in the Gateway Refinement Plan area especially those that promote regional economic development and provide everyday neighborhood services The CC and MU Metro Plan designations and MUC and MS zoning will help to ensure the long term vitality of the GRP area and provide the opportunity for a compatible mix of medical office and commercial retail uses that will provide everyday support services to the site and allow for medical services that promote regional economic development Any potential issues regarding the appearance of future commercial mixed use development will be addressed through the master plan and site plan review processes 2 Minimize potential conflicts between residential and commercial development Although no specific development is proposed as part of this proposal the required master plan and my specific development proposals including the placement of the MUC zoning for the site will carefully consider the interaction of the commercial and residential uses of the site and the interaction of site uses with adjacent development It is through the master plan and site plan review processes that designs can be evaluated to determine if there are any potential conflicts between residential and commercial development and how such conflicts may be minimized and or mitigated 3 Ensure availability of an adequate supply of land appropriate for commercial development As noted previously in these findings Springfield s acknowledged Commercial Lands Study SCLS found there to be a deficit of needed commercial lands city wide and specifically in the McKenzie Gateway area This application will result in an increased supply of commercial land and is therefore consistent with the SCLS and this goal The findings under Goal 9 discuss this issue in greater detail Page 86 of 123 1 10 05 Policies and Implementation Actions 1 0 Provide for appropriate buffering between commercial and adjacent residential uses The amendments will result in development of commercial uses as allowed in the Mixed Use CommerciaCommunity Commercial zoning districts Such uses will be located adjacent to land designated for residential uses on and adjacent to the Gateway MDR site Through the required master plan for the Gateway MDR site PeaceHealth will be required to provide an appropriate buffer between these different uses consistent with this policy and the regulations in the master planning process The precise method and width of buffering will most appropriately be addressed during the master plan and site plan review processes 4 0 Recognize existing neighborhood commercial scale uses utilize NC and GO Refinement Plan designations to accommodate the uses where appropriate providing a buffer for residential areas from more intensive commercial uses and arterial streets There are no existing neighborhood commercial scale uses on the site 6 0 Resolve conflicts between plan designations and zoning There are no current conflicts between the site s plan designations and zoning The CC designation and MUC zoning will be applied through the master plan or nodal implementation process thus resolving any temporary conflict 5 Natural Assets Open Space Scenic Areas and Recreation Element Goals S 1 Provide for development of the Gateway Refinement Plan area that is sensitive to and integrates to the maximum degree practicable the multiple functions and values associated with the area s natural assets open space scenic areas and recreation opportunities Approval of the amendrrients will not affect compliance with this goal because the amendments do not allow for any specific development Although the amendments do not propose any specific development future development proposed to occur on the site through the master plan will be sensitive to the natural resources present by integrating these natural amenities into the overall design for a healing environment at RiverBend All development must be consistent with all applicable SDC regulations which implement this Goal While relevant to Page 87 of 123 110 05 the master plan rather than these amendments PeaceHealth s overall design for the site will be required to include significant open space conservation of the major tree groves and areas for passive recreation and enjoyment of the area s ecology as well as enhancements to the functions and values of the river s riparian corridor consistent with SDC regulatiops 2 Utilize the functions and values of the Refinement Plan area s natural assets e g swales and drainageways to assist and accommodate development while maintaining their ability to provide long term buffering ofthe natural resource values outside the UGB from urban development within the UGB The McKenzie River riparian area located along the eastern edge of the site will provide an important and effective buffer between site development and the McKenzie River and the resources on the far bank of the river Provisions in PeaceHealth s annexation agreement and new City code standards will ensure appropriate development buffers along the river s riparian corridor Adoption of the amendments will not change th functions and values of the site s natural assets because the areas proposed for redesignation will not result in a greater impact on those assets mapped in the GRP than the current residential designation Moreover because no development is proposed at this time there can be no impact on natural areas through the adoption of these amendments 3 Emphasize the Refinement Plan area as a Gateway to the McKenzie by maintaining and enhancing the attributes that contribute significantly to the area s visual character and by improving and encouraging public access to and use of the river where appropriate Because the length of the site adjacent to the McKenzie River is in a single institutional ownership there is an outstanding opportunity to realize the GRP s goals to provide the public with physical and visual access to and along the river PeaceHealth s designs will be required to encorporate vistas and access with in the master plan and Site Plan Review processes Again because no development is proposed or approved through these amendments there can be no impact to these resources as a result of this decision Through the master plan and site development review process these attributes will be considered and all applicable SDC provisions implementing this policy must be adhered to 4 Provide for recreational and educational opportunities that utilize protect and enhance the significant natural and cultural values associated with key natural resources scenic areas and open spaces that include where practical remnants of the area s agricultural character Page 88 of 123 1 10 05 Adoption of the amendments will not affect the ability to provide educational and recreational opportunities The proposed change from the current residential designation to commercial and mixed use designations will not reduce those opportunities because there is nothing inherent in a commercial use that has a greater effect on those opportunities than a residential use The ability to integrate proposed future development with natural resources scenic areas etc will be reviewed through the master plan process rather than this proposal 5 Encourage and plan for recreational opportunities within the Refinement Plan area that contribute economic benefits to the community The master plan is expected to preserve open space conserve natural resources and provide compatible recreational opportunities in a comprehensively planned development on the site Moreover through the masfer plan process PeaceHealth will be required to comply with all applicable SDC regulations implementing this policy Nothing in the amendments will affect the ability to provide these beneficial recreational opportunities because there is nothing inherent in any of the commercial use mixed uses that would have a greater impact on recreational opportunities than a residential use o 6 Provide sufficient high quality accessible recreational services opportunities to residents within the Refinement Plan area and expand the recreationaleducational opportunities associated with the area s ntltural and historic values for enjoyment and education of the entire community The amendments do not affect the ability to provide recreational opportunities or services and the bove policy is more appropriately assessed in relation to the required master plan for the site 7 Develop a pathway system that encourages bicycle transportation throughout the Refinement Plan area providespublic access to the McKenzie River and riparian areas and enables recreationaleducational appreciation of the area s natural assets and open space scenic areas As part of its master plan PeaceHealth will be required to propose an integrated network of on street bike lanes sidewalks and off street multi use trails and pathways that will meet the above goal Adoption of these amendments will not affect the ability to provide this pathway system because there is nothing inherent in the uses allowed pursuant to the amendments will prevent development of this system The master plan process will be the more appropriate venue for establishing conformance with this goal and all development must comply with applicable provisions of the SDC implementing this policy Page 89 of 123 110 05 8 Connect the Refinement Plan area to a broader recreational and natural resource system through pedestrian and bicycle pathways and protected waterside riparian areas As noted above the master plan for the site will include not only an integrated pedestrianbicycle network internally but also will provide effective connections to the City and metropolitan system of pathways sidewalks and bicycle lanes All development must be consistent with applicable provisions of the SDC implementing this policy The amendments do not affect the ability to provide such a system but conformance with the above goal is appropriately considered through the review of the master plan and not this proposal The amendments will not affect the ability to provide a pathway system because there is nothing inherent in commercial uses that would prevent a pathway from being developed that a residential use wouldn t also prevent 9 Maintain prominent mature vegetation as shown on the Natural Assets Map on page 39 for its scenic airfiltration and noise reduction qualities to the greatest degree practicable While no development is proposed or approved under this proposal PeaceHealth s master plan is expected to conserve the mature tree stands the riparian zones and other natural assets illustrated in the GRP as much as practicable and subject to all master plan and other SDC requirements The changes proposed by this proposal will not increase the likelihood of more removal of mature vegetation because such activities are equally likely under the residential designation 10 Minimize the potential threats to life and property related to development within thefloodway of the McKenzie River consistent with the Metro Plan goal to p rotect life and propertyfrom the effects ofnatural hazards p III C 6 Policy 3 It is not appropriate to evaluate the potential threats to life and property related to development on the site because no development is proposed as part of this application While the above goal will be more properly gauged through the master plan process PeaceHealth s plans do not include any building development within the McKenzie River floodway As discussed above with respect to Goal 7 all development will be required to comply with SDC Article 27 which implements this Ipolicy as well as the requirements of Goal 7 11 Maintain the quality of water in the McKenzie River and the local aquifer The City s identified wellhead protection zones encompass portions of the site and area subject to proposed redesignation Future uses within these various Time of Page 90 of 123 1 10 05 Travel zones will have to conform to all provisions in the Springfield Development Code Article 17 Drinking Water Protection Overlay District to maintain groundwater quality The master plan and Site Plan Review processes are the appropriate venues for determining specific conformance with the above policy as there is nothing inherent within any uses allowed in the proposed Plan designations that would necessarily harm groundwater quality Likewise management of stormwater runoff from future development on the sit will be assessed through the master plan and Site Plan Review processes to ensure protection of the quality of McKenzie River water It should be noted however that the topography on the site and direction of surface water flows is generally to the northwest and away from the river as it abuts the site to the east Additionally the site possesses highly permeable soils that may be suitable for alternative stormwater management methods provided that such proposals conform with Article 17 requirements PeaceHealth s annexation agreement with the City requires that the RiverBend master plan include a comprehensive stormwater management plan consistent with best management practices promulgated in the City of Portland s storm water management manual All of the above issues will be addressed through the master plan process rather than as part of this application Policies and Implementation Actions 1 0 Protect the waterside riparian corridors and natural vegetative fringes associated with the McKenzie River and Maple Island Slough Adoption of the amendments will not result in an increased impact on the riparian corridors because the subject property is currently designated for residential development Moreover nothing inherent in the amendments will have any impact to these resources because no development is approved through these Amendments 1 4 Until a comprehensive study and management plan is completed by the City for this area of the McKenzie River thefollowing interim protection measures shall be applied to the entire McKenzie River riparian area as Page 91 of 123 110 05 recommended by the metropolitan Natural Resources Special Studysee GRP Tech Supp Appendix C It is not appropriate to address the applicability of a management plan or intetim management measures to site development at this time because no development is proposed as part of this application All interim measures will necessarily be complied with during the master plan and Site Development Review process 2 0 Recognize the unsuitability due toflood hazard of the McKenzie River floodway for urban development and explore its suitability forfulfilling community recreation needs and for buffering the river oriented natural resource system Although a portion of the floodway is located on the site no specific development is proposed as part of this application therefore it is inappropriate to evaluate development within the floodway at this time As discussed above with respect ot Goal 7 all development must comply with SDC Article 27 which implements this policy as well as Goal 7 3 0 Ensure adequate storm drainage management planning emphasizing the minimization of negative impacts on water quality and quantity resulting from development in the Refinement Plan area It is not appropriate to address storm drainage management planning at this time because no development is proposed as part of this approval Storm drainage will be addressed during the master plan and Site Plan Review processes 4 0 Protect and enhance the natural resource values associated with the open drainageways and swales throughout the Refinement Plan area Because no development is proposed as part of this approval it is inappropriate to address protection of any open drainageways or swales present on the site at this time PeaceHealth s master plan for the site will be required to incorporate existing and new open drainages swales and other stormwater management measures with opportunities for natural resource protection and enhancement and will be required to comply with all applicable SDC provisions relating to stormwater 7 0 All known and potential wetland areas shall be delineated prior to development approval Delineated wetlands and wetland mitigation projects shall be maintained to ensure continued provision of wetland functions and values Page 92 of 123 1 10 05 Although no development approval is being sought as part of the amendments the two small wetlands on the site have been delineated and the Division of State Lands has concurred with that wetland delineation 7 1 Through the site plan review process require wetland delineation of the possible wetland at Game Farm Belt Line NRSS site S16 prior to development approval NRSS site S 16 appears to extend onto the Site however the most recent maps associated with the updated Natural Resources Study do not include site S16 The two jurisdictional wetlands on the Site each 0 02 acres in size have been delineated 8 0 Maintain and enhance the scenic and open space amenity values in the RefinementPlan area to the maximum extentpracticable Any impacts on scenic values will be appropriately addressed during the master plan and site plan review processes Because the amendments do not allow for any development scenic and open space amenities are not affected by the Amendments All future development must be consistent with this policy and the SDC provisions implementing this policy Page 93 of 123 110 05 6 Historic Resources Element Goals 1 As development and change in the Gateway Refinement Plan area occurs the retention and rehabilitation of significant historic resources should be achieved in order to maintain the area s historidculturallinkages topast settlement patterns and to maintain the educational cultural and aesthetic amenity values associated with them Although some contributing historic resources may be located on the site no significant historic resources are located on the site Because no development is proposed as part of this application it is not appropriate to address conservation of historic resources at this time Nonetheless the contributing resources on site do not have significance such that they are governed by SDC Article 30 and the GRP as primary historic resources 2 Establish policies and incentives where possible to ensure sufficient consideration and documentation of identified significant historic resources so thatfuture developments andor demolitionsfully address the identified resources either through on site preservation offsite preservation or through archival documentation of the resource Springfield Development Code Article 30 Historic Overlay Zone serves as the policy basis for treatment of significant Goal 5 historic resources in the GRP The existing contributing historic resources identified on the site are not inventoried as primary resources meriting protection under SDC Article 30 3 Provide policy guidelines adequate to ensure compliance with Statewide Planning Goal 5 and the Metro Plan as they pertain to historic preservation specific to the newly identified significant historic resources within the Gateway Refinement Plan area Springfield Development Code Article 30 Historic Overlay Zone serves as the policy basis for treatment of historic resources in the GRP The existing contributing historic resources identified on the site are not inventoried as primary resources meriting protection under SDC Article 30 Page 94 of 123 1 10105 Policies and Implementation Actions 2 0 On site retention ofsignificant GoalS historic resources shall be encouraged However moving the structures shall be allowed Although some contributing historic resources may be located on the site no significant historic resources are located on the site Because no development is proposed as part of this application it is not appropriate to address conservation or disposition of historic resources at this time The existing contributing historic resources identified on the site are not inventoried as primary resources meriting protection under SDC Article 30 7 Transportation Element Goals 1 Provide for a safe and efficient transportation system for the Gateway Refinement Plan area Nothing in this proposal will affect provision of alternative transportation modes or their inclusion in the master plan for RiverBend More specific findings are set forth with respect to Goal 12 3 Minimize adverse traffic impacts of high volume arterial streets on adjoining residential neighborhoods The TIA considers the planned extension of Pioneer Parkway through the site and signalized intersections connecting with the existing Cardinal Way This will have the effect of significantly reducing adverse impacts of traffic volumes on Game Farm Road South that are incompatible with the road s design and function and which have long plagued residents of the Game Farm neighborhood While not directly a consequence of the proposed plan amendments the rIA demonstrates that future development at RiverBend will not have adverse impacts on adjoining neighborhoods but instead will help minimize the existing impacts consistent with the above goal by virtue of PeaceHealth s participation in improving the Pioneer Parkway extension and Page 95 of 123 1 10105 other connecting streets Again more specific findings are set forth with respect to Goal 12 and the TPR 4 Plan and design an efficient and flexible transportation system for undeveloped lands within the Refinement Plan area to ensure minimum traffic impacts See response to Goal l above 6 Provide for the safe and effective movement ofpedestrians and bicyclists in the Gateway Refinement Plan area Because no specific development is proposed as part of this proposal the movement of pedestrians and bicyclists will not be affected by these amendments Moreover the planned transportation improvements are consistent with TransPlan which in turn implements these goals This goal will more appropriately be addressed as part of PeaceHealth s master plan for the site 7 Establish a network ofpedestrian and bicycle pathways that connects the Refinement Plan area to a broader metropolitan transportation and recreational system Because no specific development is proposed as part of the amendments it will not impact the establishment of pedestrian and bicycle pathways Moreover the planned transportation improvements are consistent with TransPlan which in turn implements these goals This goal will more appropriately be addressed as part of PeaceHealth s master plan for the site Policies and Implementation Actions 1 0 Discourage use of local residential streets by commercial and industrial traffic Future mixed use commercial development on the site will be accessed primarily from the Pioneer Parkway extension and associated collector streets The details of site access are more appropriately addressed during the master plan and site plan review processes Moreover the planned transportation improvements are consistent with TransPlan which in turn implements these goals 4 0 Limit access to minor arterials as redevelopment occurs Future development on the site will have limited access onto minor arterials such as the Pioneer Parkway extension Instead PeaceHealth will be developing an integrated collector street system for the site as required in the GRP This system is Page 96 of 123 1 10105 considered in conjunction with the TIA and will be more fully illustrated with detailed access and circulation through PeaceHealth s master plan for the site 5 0 Coordinate with LTD to improve the efficiency and convenience of bus service to the area This application has no effect on the operation of the bus system or coordination of bus service because no development is proposed but such coordination will occur as part of PeaceHealth s master planning process More specific Findings regarding this policy are set forth under Goal 12 6 0 Promote bicycling by developing a complete bicycle network within the Refinement Pldn area The amendments have no effect on the bicycle network because no development is proposed as part of the application but this will be considered as part of the RiverBend master plan All transportation related provisions in the SDC and TransPlan related to bicycle transportation must be complied with during master plan reVIew 6 1 Construct on street bike lanes along Game Farm Road North and Game Farm Road South as specified by TransPlan projects 670 671 Explore the feasibility of developing an offstreet bike path along the section of the former Southern Pacific right ofway that runsfrom Harlow Road to Game Farm Road South This proposal has no effect on the bicycle network because no development is proposed as part of the approval of the amendments A comprehensive bicycle network and appropriate connections will be developed as part of PeaceHealth s master plan for the site and all transportation related requirements of the SDC and TransPlan must be addressed through that process 63 Design and construct the projects on the attached project list to include on street bicycle lanes This application has no effect on the bicycle network because no development is proposed as part of the proposal Provision of bike lanes and future streets will be subject to future master planning for the site pursuant to the SDC and TransPlan 7 0 Encourage walking by providing sidewalks and paths throughout the area Page 97 of 123 1 10105 Design of a complete network of sidewalks and pathways will be included as part of the site s master plan and not part of this application subject to the provisions of the SDC and TransPlan 7 1 Require full street improvements in conjunction with new residential commercial and industrial developmentprojects during the site plan review process This proposal has no effect on street improvements because no development is proposed as part of the application however all such improvements required under the SDC and TransPlan will be provide through the master plan process 74 Upgrade Game Farm Road South between Harlow and Belt Line Roads to a 2 3 lane city standard street including sidewalks and bike paths consistent with TransPlan project 275 If the Pioneer Parkway is extended to serve a north south arterialfunction 17 on the Transportation Element Project List the improved Game Farm Road South shall be a two lane facility only Although not directly relevant to the proposed Plan amendments PeaceHealth is working with the City and County to develop the extension of Pioneer Parkway which will obviate the need to improve Game Farm Road South to urban standards at least in the short term This policy and the transportation related improvements are more particularly addressed under the findings for Goal 12 8 0 Encourage concentrations ofpedestrian and transit amenities in high activity areas and along arterial streets with high pedestrian traffic This proposal will enable the development of higher density development in conjunction with the proposed hospital and associated mix of uses at RiverBend An extensive system of pedestrian ways and incorporation of transit at the core of the development will function in conjunction with the high activity uses planned for the Site Pursuant to the applicable provisions of the SDC and TransPlan the future development approved under the master plan will necessarily be required to include these amenities 9 0 Plan and design new residential and special light industrial developments in a manner that reduces walking distances forpotential transit users and makes transit ridership more convenient The planned location of commercial mixed use development and existing and future employment opportunities proximate to the planned Bus Rapid Transit station and residential development on the site will offer opportunities to live work and shop Page 98 of 123 1 10105 within convenient distance for pedestrians and for transit riders Because no development is proposed this provision is not directly applicable although all future development must comply with this provision 9 1 Encourage the placement ofbuildings within newly developed sites close to the street system providing a convenientpedestrian transit system Although the arrangement and mix of land uses enabled by the amendments will help provide destinations convenient for pedestrian and transit access actual building placement and orientation will appropriately be considered through the master plan and site plan review processes rather than as part of this application 11 0 Plan and design new streets in a manner that reduces substandard dead end streets provides adequate access and circulation particularly for emergency vehicles and that minimizes long straight road sections in order to reduce speeding problems and detours through residential neighborhoods Street layout access and circulation will appropriately be addressed through the master planning process 13 0 Future transportation system development in the McKenzie Gateway SLI and the l80 acre MDR sites should occur as needed in conjunction with SLI and MDR development and shall include pedestrian bicycle and transit facilities to reduce vehicle trip generation Design of transportation systems for all modes of travel will be incorporated in the site s master plan Because no development is proposed as part of this proposal it is inappropriate to address transportation system development at this time however to the extent applicable additional findings regarding transportation related issues are discussed under Goal 12 findings 14 0 Design new transportation facilities to accommodate future traffic increases with minimum impact on residential neighborhoods 0As noted previously the Pioneer Parkway extension will have demonstrable beneficial impacts in reducing traffic on Game Farm Road South and through the local neighborhood However the design of this and other transportation facilities is appropriately assessed through the master plan process instead of the Plan amendment process 23 0 Connect pathway networks through open space corridors bike and pedestrian paths and on street bike route connectors both within the Gateway boundaries and beyond to the regional pathway system Page 99 of 123 1 10105 Pathway networks and connections to the regional system will be considered fully through the master plan process Adoption of the amendments has no impact on pathway networks because no development is proposed and nothing inherent in the amendments would affect such pathways 233 Provide on street bike routes as part ofstreet construction ofprojects listed on the attached project list where important to the overall bikeway network While not directly relevant to this application on street bike lanes will be provided on all new collector streets within the RiverBend site pursuant to SDC requirements 24 0 The City shall design and construct a north south arterial corridor in the Gateway Refinement Plan area in order to ensure accommodation of increased trafficflows associated with future development ofthe north Gateway area in a manner that minimizes impacts on existing Gateway area residences PeaceHealth is participating as a stakeholder in discussions with neighborhood residents and City and County officials in seeking to determine the best option for a North Link between Beltline and Game Farm Road EastDeadmond Ferry Road to provide needed campus industrial access and to minimize neighborhood impacts The City Council pared down a list of several options for location of the North Link to two both of which are located outside of the Site Therefore the proposed Plan amendments have no bearing on the selection of the preferred North Link option Additionally the findings under Goal 12 more particularly discuss the transportation related elements of the GRP 25 0 Facilitate the efficient operation of transportation systems serving the commercially developed areas The applicantion s TIA demonstrates that development on the RiverBend campus through the planning horizon will not have a significant effect on transportation systems in the area that would be contrary to the above policy While the proposed Plan amendment allows for future mixed use commercial development no development is proposed as part of this Plan amendment application 25 1 Providefor thefuture expansion of the intersection of Gateway Street and Belt Line Road when reviewing site plans for developments fronting this intersection Nothing in this application affects the City s ability to review site plans for developments fronting on Gateway Street and Belt Line Road and no part of the site fronts onto this intersection However through its annexation agreement with the Page 100 of 123 1 10 05 City PeaceHealth has committed to providing 7 000 000 for future improvements to this intersection 25 2 Provide for transit bicycle and pedestrian facilities as part of new retail and office commercial development Provision for such facilities will be considered appropriately through the master plan and Site Plan Review processes 26 0 Ensure that the future road system in the area identified as the McKenzie Gateway MDR Site meets the transportation needs of the area in a manner that is sensitive to the interests and concerns of the property owners and residents of local neighborhoods The PeaceHealth master plan for the Site will illustrate a comprehensive road network consistent with the above policy 26 1 Alignments and other design characteristicsfor all road improvements andor additions to the road system within the urbanizable area identified on the Refinement Plan Diagram as the McKenzie Gateway MDR site shall be determined and establishedjoinjly by the Lane County Board of Commissioners and the Springfield Cjty Council With the exception of the exact North Link option the alignment and design of the Pioneer Parkway extension has been approved by both governments as has the conceptual collector street layout for the Site PeaceHealth s master plan will demonstrate conformance with these approved general layouts but the proposed Plan amendments do not directly affect the above implementation action 8 Public Facilities Element Goals 1 Provide an adequate level ofpublic sanitary sewers storm drainage facilities and water and electric service in a timely and efficient manner in order to support development consistent with adopted land use designations PeaceHealth s annexation agreement and SDC provisions require the development of all necessary public infrastructure to support future development which will be assessed as part of the required master plan process Nothing in this proposal conflicts with the ability to provide adequate public facilities to development because there is no specific development proposed as part of this application To the extent Page 101 of 123 1 10 05 this Goal applies to this proposal there is evidence in the record that demonstrates that required public facilities will be available 2 Phase the construction of new facilities so they are completed in an economically efficient manner and so they do not unnecessarily disrupt either developedfacilities or undevelopedproperty prematurely This goal does not apply to this proposal because the phasing of construction of public facilities should be addressed through the master plan process or when construction of those facilities is proposed 3 Design and construct public facilities to minimize impacts on surrounding uses and maximize the quality of life within the area No development is proposed as part of this application therefore at this time it is inappropriate to address impacts from construction of public facilities 4 Incorporate use and enhancement of naturalfeatures ie natural drainage areas into public facilities planning and construction to the greatest degree possible PeaceHealth s required master plan will consider the means of complying with the above goal No development is proposed as part of this proposal therefore there is no impact on planning and construction of public facilities from this application Policies and Implementation Actions 2 0 Provide storm drainagefacilities to newly annexed areas Although the site is a newly annexed area there is ample room on the site for storm drainage facilities A change in designation from residential to commercial and mixed use by itself does not affect the provision of storm drainage facilities and the siting and design of those facilities is more appropriately addressed during the master plan and site plan review processes 2 2 Require the consideration of the use ofstorm drainage facilities that store and retain runoffin the McKenzie Gateway SLI site and incthe proposed MDR area east of Game Farm Road South Require the consideration of the use and enhancement of natural storm water drainagefeatures as part of the overall storm water systems in these areas PeaceHealth s annexation agreement with the City echoes the above implementation action by requiring that future master plans and site planning use the City of Portland s stormwater management design manual to incorporate the use of best Page 102 of 123 1 10 05 management practices Conformance with these provisions will be appropriately considered through the master plan and Site Plan Review processes There is nothing inherent in the change from a residential to a commercial or mixed use designation that would affect the ability to consider the construction of storm drainage detention facilities or the use of natural storm water drainage features during the site plan reVIew process 4 0 Continue providingpure and ample supplies of water to the Refinement Plan area Springfield Utility Board officials have indicated that there is an ample supply of high quality potable water to serve future development on the site There is nothing inherent in the change in designation to commercial and mixed use that will result in the failure to provide ample water supplies 4 2 All storm drainage systems serving properties north ofBelt Line Road shall be designed to ensure the continued purity ofthe Rainbow wellfield to the north Although a small portion of the site is located north of Belt Line Road and within the delineated wellhead protection zones there is nothing inherent in the proposed change in designation that will result in an adverse impact on the Rainbow SUB well field Any impacts on the well field are more appropriately addressed during the Site Plan Review process IV CITY COUNCIL FINDINGS IN RESPONSE TO CITIZEN INPUT 1 Remand did not leave anypart of the previous decisions intact Several parties argued that the remand orders issued by LUBA and the Court of Appeals did not leave any portion of the Decisions in tact This argument is directly contrary to LUBA s remand order which provides in part Indeed footnote 8 in the court s opinion discusses findings the city should be able to provide with respect to one ofLUBA s bases for remand which does not suggest that the court felt that its disposition of Jaquas petition for review rendered moot or unnecessary further proceedings on remand Further the challenged ordinances adopt a number of amendments and other actions some or all ofwhich may survive notwithstanding the court s conclusion that the regional hospital complex facilitated by the ordinances is inconsistent with the Metro Plan In short we cannot say that the challenged ordinances are prohibited as a Page 103 of 123 1 10105 matter of law Accordingly remand is the appropriate disposition Jaqua v City ofSpringfield Or LUBA LUBA Nos 2003 077 and 2003 078 August 19 2004 slip op 2 emphasis added Thus in a remand decision from LUBA that no party elected to challenge LUBA specifically held that some or all of the original proposal may survive The revised proposal on remand responds to the remand order 2 The proposal cannot be sited on CC designated property a new plan designation must be created for the PeaceHealtlt proposal Several opponents including most specifically the Jaquas have argued that the CC designation is inappropriate for the ultimate development of a hospital In very general terms the opponents argue that there is no existing Metro Plan designation that could accommodate the pr posed hospital development In other words PeaceHealth would not be able to relocate anywhere in either Springfield Eugene or unincorporated Lane County unless and until the three jurisdictions initiated Type I Metro Plan amendments creating a new designation and agreeing on its location Throughout the earlier proceedings the opponents characterized the proposed hospital as a commercial use The Court of Appeals agreed with the Jaquas and also characterized the hospital as a commercial use Jaqua v City ofSpringfield 193 Or App 573 589 2004 Now that the underlying property is proposed to be designated as commercial the opponents argue that no current plan designation is appropriate The opponents contention that the proposed hospital which is not being approved through this application is not a commercial use under the Metro Plan ignores the fact that the existing Sacred Heart Medical Center is located on CC designated property Indeed both the City of Eugene and the City of Springfield allow hospitals outright in commercial zones There is no indication whatsoever in the Metro Plan that somehow hospitals have no designation under the Metro Plan and that a new designation must be created before a hospital can relocate or expand Indeed the Metro Plan identifies health services as a key urban facility and service Thus the City finds that it would be entirely inconsistent for the Metro Plan to identify the services that hospitals provide as key and yet fail to provide any place for such services to be provided Had the three jurisdictions intended to force the existing hospitals to remain in their present location until a new Metro Plan designation could be developed and applied the City concludes that the Metro Plan would have at least alluded to such a drastic prohibition Opponents have also argued that the Metro Plan limits hospitals in commercial zones to certain but unstated sizes In other words the opponents suggest that hospitals of Page 104 of 123 1 10105 a certain size might be allowed on commercial land but noUhe size of hospital proposed by PeaceHealth The City finds that there is no such restriction either implicit or explicit in the Metro Plan Regardless of whether the hospital is characterized as regional hospital project or a neighborhood hospital there is no such distinction in the Metro Plan This argument also ignores the fact that PeaceHealth plans to relocate its hospital to Springfield Thus to the extent that the proposed hospital is a regional hospital the same can be said for the existing hospital Both cities have determined that hospitals are appropriate uses in commercial zones and the Metro Plan does not include any size restriction as suggested by the opponents Consequently the City concludes that the CC designation is appropriate 3 Community Commercial designation limited to accommodating subregional needs in areas of not more than 40 acres The Metro Plan description of the Community Commercial designation includes no absolute acreage restriction As these findings explain in greater detail above the reference to 40 acres is not a limitation or an absolute threshold Moreover there is nothing in the Metro Plan description which would limit uses on CC designated property to subregional needs The existing Sacred Heart Medical Facility is currently located on CC designated property Under the opponent s reasoning the existing hospital should be considered a non confomiing use because such hospitals are not allowed on CC designated property This argument also ignores the fact that the existing Sacred Heart Medical Facility was located on the same property prior to the adoption of the Metro Plan Had the three adopting jurisdictions determined that the CC designation was appropriate for only subregional needs presumably the adopting jurisdictions would not have designated the existing Sacred Heart Medical Facility as Cc LDCD s prior acknowledgment of the Metro Plan which occurred long after the establishment of the hospitap has deemed the CC designation to be a suitable designation for the existing regional hospital site further demonstrating that the CC designation is not limited to subregional hospitals and other uses catering to subregional needs Moreover the Metro Plan explains that the CC designation contains tourist related facilities such as motels Under the opponents reasoning motels in CC designated areas could only cater to subregional tourists in other words local Springfield tourists staying in local motels Moreover the notion that CC designated lands are intended only to cater to subregional needs conflicts with Metro Plan Economic Element policies to encourage economic activities which strengthen the metropolitan area s position as a regional distribution trade health and service center It is impossible to become a regional center for health ifthe health services allowed under the commercial designations are limited to subregional needs Consequently Page 105 of 123 1 10105 the City finds that acceptance of the opponents argument would directly conflict with the express language policy and purpose of the Metro Plan s CC designation 4 The amendments will leave the Gateway area Springfield and the Metro Area without an adequate supply of residential land In denying the aquas earlier Goal I 0 challenge LUBA found For purposes of resolving petitioners Goal 10 assignments of error the critical findings include the city s finding that the RLS identifies a 239 acre surplus ofMDR designated land and for the reasons explained in the findings that surplus likely understates the city s actual residential development potential since land such as floodplains and MUC zoned lands that may not be counted in assessing the adequacy of the city s inventory ofMDR designated land nevertheless may be developed residentially Therefore as the city explains elsewh re in its findings even if the 99 acres that are being planned and zoned to allow commercial and hospital use were to result in those 99 MDR designated lands no longer being capable of residential development the Metro Plan inventory ofMDR designated land would still retain a surplus of such land The city does not rest solely on the post decision surplus of MDR designated land The city takes a number of steps to ensure that its decisions to plan and zone 99 acres of the 180 GRP MDR designated acres to allow hospital and other commercial development in fact do not prevent realization of the residential development potential of that MDR designated area Those steps include allowing density transfers and imposing a condition of approval that the applicant demonstrate during the master plan process that development of the GRP MDR area as amended will include a number of residential units that falls within the range that would have been possible under the pre amendment GRP Most of petitioners challenges are directed at this aspect of the two decisions arguing that it will produce housing in the floodplain that has not been shown to be needed or housing that exceeds the MDR 20 unit per acre maximum However as PeaceHealth points out Goal 10 does not prohibit the city from providing more high density housing than it may Page 106 of123 1 10105 have identified as being needed in the RLI Hubenthal v City of Woodburn 39 Or LUBA 20 32 2000 Similarly while the OAR 660 008 0005 2 definition of b uildable l and states that land within the I OO year floodplain is generally considered unbuildable for purposes of density calculations there is nothing in Goal 10 that prohibits residential development within floodplains Jaqua slip op 33 Thus LUBA expressly found that even with the removal of99 acres ofMDR designated land the proposal would not violate Goal 10 In fact the current proposal removes less than 99 acres Moreover the amendments require PeaceHealth to demonstrate that it can accommodate the number of housing units within the range for MDR land PeaceHealth has submitted evidence into the record which demonstrates that it is feasible to provide a number of housing units on the site within the expressed MDR range Thus the City finds that even ifPeaceHealth was subject to a no net loss standard which it is not given the surplus identified in the Metro Plan the proposal would not have the effect of reducing the inventory Indeed LUBA expressly found that the proposal was consistent with Goal 10 even withthe removal of up to 99 acres ofMDR designated land Consequently the City finds that the opponents are barred from again raising a new Goal 10 challenge in the round of the proceeding Nonetheless the City has adopted the findings above under Goal I 0 as well as the following findings To varying degrees each of the opponents argues that the City s 2004 monitoring report is the controlling document and that it does not show a 239 acre surplus The 2004 monitoring report is not an applicable planning document under D S Parklane Development Inc v Metro 165 Or App 1 22 2000 and its progeny In fact if the City were to rely onthe monitoring report such reliance would result in a violation of Goal 2 This issue is discussed in greater detail below The opponents also argue that there is not substantial evidence to demonstrate that housing can be constructed on the remaining MDR designated land PeaceHealth s floodplain analysis demonstrates that housing can be constructed on the MDR designated land Moreover the excerpt from the proposed master plan shows that it is feasible to construct the required number of units on the property There is substantial evidence in the record to demonstrate that housing can be constructed on MDR designated land within the floodplain and within the range that would have been possible under the existing MDR designation Moreover the City s Floodplain Overlay District Article 27 specifically allows development within the floodplain and establishes the standards and criteria for such development The floodplain Page 107 of 123 1 10105 analysis in the record demonstrates that housing within the floodplain can meet the development standards of the Floodplain Overlay District 5 The currenJ amendments may be in part site specific but they are also inconsistent with the non site specific text and diagram of the Metro Plan None of the opponents have provided any substantive argument or evidence to explain how the revised proposal on remand is somehow not site specific Both LUBA and the Court of Appeals found that the original amendments were site specific While the revised proposal on remand is different in some respects the opponents fail to explain how these differences render the amendments non site specific This issue is simply not raised with sufficient specificity to allow the City to respond 6 The notices supplied to DLCD improperly described the proposal on remand and therefore the notice to the City ofEugene Lane County and DLCD were insufficient for the City ofEugene and Lane County to determine whether the proposal on remand resulted in regional impact The opponents testimony did not explain how the notices were deficient Consequently the opponents have failed to raise this issue with sufficient specificity to allow the City to respond to the issue The notices to DLCD include the text of the GRP amendments and specifically provide that the Metro Plan diagram will be amended to redesignate 99 acres for MDR to a combination ofMU and Cc While there are slight differences in the text amendments as finally adopted and as sent to DLCD none of the changes substantively modify the proposal such that the amendments now create a regional impact which could warrant the participation of the City of Eugene Without further explanation from the opponents as to why the notices are deficient the City cannot respond in any greater detail 7 The amendments violate Goal 1 The opponents do not explain how the amendments violate Goal I other than to say that their other testimony demonstrates a violation of Goal I Without a specific challenge the opponents have not adequately raised a Goal I challenge The fact that all of the opponents have testified and submitted reams of testimony demonstrates that they have been able to participate in this process 8 The amendments violate Goal 2 s consistency and coordination elements With respect to the consistency element of Goal 2 as LUBA found in the earlier proceeding Page 108 of 123 1 10 05 The petitioners in this appeal couch many of their arguments as Goal 2 plan consistency or coordination arguments or evidentiary and findings failures under Goal 2 We address elsewhere in this decision their arguments that the disputed Metro Plan and GRP amendments conflict with other unamended plans or constitute a Goal 2 failure because they also constitute failures under other statewide planning goals We reject without further discussion their separate related Goal 2 arguments Jaqua slip op 13 As LUBA found in the earlier proceeding the Jaquas primary objection is that the amendments conflict with various elements of the Metro Plan As described elsewhere the current proposal is consistent with the Metro Plan and therefore does not violate Goal 2 With respect to coordination the City of Eugene and Lane County have received notice of the proposals on remand Neither the City of Eugene nor Lane County have submitted any comments 9 The amendments violate Goal 5 The Jaquas express concern about the effect the proposal may have on nearby inventoried Goal 5 resources In their testimony the Jaquas did not challenge the statement in the draft findings that no part of the Gateway MDR site is on an acknowledged Metro Plan Goal 5 inventory The draft findings also noted that although vegetation and a wetland area are inventoried on the GRP there is no indication that these resources have been placed on an adopted inventory of Goal 5 resources or that the Goal 5 process has been completed for them Again the Jaquas do not challenge that statement The Jaquas comments relative to Goal 5 do not identify any resource for which the Goal 5 process has been completed Jaquas comments merely mention Goal 5 resources that have been inventoried The resources at issue are not subject to the amendments will remain in the same comprehensive plan and zoning designations and will be subject to any existing buffer requirements Under Goal 5 the program to achieve the goal referenced by the Jaquas is not effective until the Goal 5 process including the economic social economic and environmental ESEE consequences analysis and the decision to allow prohibit or limit conflicting uses has been completed Until that occurs there is no program to achieve the goal that is no program has been adopted to implement the decisions made in the Goal 5 evaluation process Page 109 of 123 1 10105 Under applicable land use case law only GoalS resources on an adopted inventory and for which the GoalS process has been completed are subject to protection under GoalS Since the referenced resources do not fall into that category the Jaquas comments are not relevant Further the criteria for approving a master plan require that at the development stage the City consider inventoried resources in a manner consistent with the Goal S administrative rule The proposal itself includes buffers intended to prevent these resources from being adversely affected by future development under the Master Plan In comments directed to Goal 10 Jaquas attempt to use the City s incomplete Goal S process to challenge the adequacy of the City s existing buildable lands inventory The Jaquas comments regarding the effect adopting the Springfield Inventory of Natural Resource Sites on May 3 2004 will have on the existing buildable lands inventory are incorrect and mischaracterize Oregon s Goal S process J aquas statement that The approval of the inventory of Natural Resource Sites was an important step towards completion of Springfield s Natural Resource Planning responsibilities but was only a step is important to understanding the Goal S process In that statement the Jaquas recognize that the adoption of the inventory does not protect Springfield s natural resources The Jaquas are incorrect in asserting that adoption of the inventory left the region wide impact on the buildable lands inventory up in the air because adopting the inventory neither protects these sites nor modifies the existing buildable lands inventory The adoption of the inventory simply establishes a list of resource sites that will be considered for protection sometime in the future The decision to protect these sites will take place only after the City completes the Goal S process including the required ES EE analysis and decides which sites will be protected from conflicting uses which conflicting uses will be allowed outright or which conflicting uses will be allowed with limitations Until these decisions are made the existing buildable lands inventory remains in effect The Jaquas fail to distinguish an on going but incomplete process intended to protect resources some time in the future from a completed process that actually protects the resources The Jaquas reference to Home Builders Assoc v City ofEugene 41 OR LUBA 370 447 2002 is irrelevant because the Jaquas fail to make that distinction In Home Builders as quoted by the Jaquas LUBA s decision related to code amendments changing tree and stream buffer protection on Goal 9 and Goal 10 land inventories Obviously in Home Builders the City of Eugene actually adopted amendments that either implemented new protections or otherwise changed the ability of land owners to use land as allowed under Goal 9 or Goal 10 Page 110 of 123 10105 In this instance no such change has occurred and no such change is as yet being considered by the City Any change that is likely to occur under the Springfield Goal 5 process will not take place until some undetermined future date If and when the City adopts new protections or modifies existing protections in a way to prevent or limit the use of land currently listed on Goal 9 and Goal 10 inventories then the issue will be ripe for consideration Jaquas reliance on the comments offered by Mr Metzger regarding the City s approach to GoalS is misplaced According to the Jaquas Mr Metzger stated that the City would require applicants proposing development involving inventoried resources to prepare an ESEE analysis and a program to protect the resources as part of its GoalS process Such an approach is impermissible for several reasons First it is completely inconsistent with Goal S s intention to proactively protect natural resources and to warn land owners of the limitations the local government places on their land to protect such resources Second Goal 5 places an obligation on local government to inventory evaluate and protect certain significant natural resources The City cannot simply delegate its responsibility to balance the public interest of protecting or developing a natural resource to the land owner This approach would also have t e land owner developing the program to protect the resource which is also the City s responsibility 10 The record does not contain substantial evidence demonstrating compliance with the requirements of Goal 6 The Jaquas make an unsubstantiated and unspecific claim that the findings do not comply with Goal 6 They contend that the proposed Master Plan shows that drainage will go to the river that the floodplain is proposed to be filled that additional federal discharge and fill permits will be required The sic record does not contain substantial evidence demonstrating compliance with the requirement of Goal 6 This statement makes no connection to the requirements of Goal 6 nor does it identify what if any state or federal statutes laws regulations or rules are implicated The Jaquas claims that some unidentified federal permits are necessary and that drainage going to the river implicates some other unidentified regulatory process lacks sufficient specificity to allow the City or PeaceHealth to provide a reasoned response The Jaquas also seem to imply that the referenced discharge will be directly to the river which is not accurate based on information in the record The record contains a number of reports and studies provided by PeaceHealth relating to the hydraulic biological and environmental impacts expected to result from the Page III of 123 1110 05 proposal and the ways in which such impacts will be avoided or compensated for Those studies and reports include but are not limited to I Phase III Geotechnical Investigation and Seismic Hazard Study October 2 2003 Foundation Engineering Inc 2 Phase II Geotechnical Investigation March 6 2003 FEI 3 PeaceHealth Site Development Subsurface Investigation May 20 2002 FEI 4 McKenzie River Floodplain Assessment November 3 2003 David Evans Assoc 5 Stormwater Drainage Master Plan for PeaceHealth RiverBend Campus April 2003 KPFF Consulting Engineers and 6 Habitat Characterization and Rare Plant Surveys September 2002 Coyote Creek Environmental Services In addition to these materials the record includes wetland delineations and other information regarding natural resources and the possible effects the proposed action might have on such resources Further based on its review the City has concluded that the application is consistent with Goal 5 6 and 7 In spite of Jaquas unsubstantiated contention to tqe contrary these reports and studies prepared by professional engine ers and environmental specialists constitute substantial credible evidence that is in the record and available for the City to use to prepare the findings required by Goal 6 Further the Jaquas provide no credible evidence refuting the information in the referenced studies The City s obligation under Goal 6 is to prepare findings based on substantial evidence in the record that it is feasible for applicable state and federal environmental laws statutes and rules to be met The City is not required to usurp any state or federal agency s authority by evaluating the proposed amendment against particular standards or to otherwise conduct any agency s evaluation With respect to Jaquas contention that some drainage will occur into the river without more specificity in the opponent s comments that issue cannot be addressed with any precision However stormwater can be one such discharge and can implicate a state r gulatory system the NPDES permit program implemented by DEQ To demonstrate the substantial evidence that is available in the record and the City s ability to prepare adequate findings the City notes the following Page 112 of 123 1 10105 The Stormwater Drainage Master Plan for PeaceHealth RiverBend Campus KPFF Consulting Engineers KPFF April 2003 Stormwater Plan provides the necessary substantial evidence to determine that the appropriate authorization for stormwater can be obtained if necessary That document demonstrates for example that there will not be a direct discharge into the river but that stormwater will be discharged into the City s existing system which is already authorized KPFF explains that stormwater going to that system will be treated to maintain water quality by using bioswales andor filter systems and that the required best management practices to protect water quality will be implemented See for example pages II 14 of the Stormwater Plan Taken as a whole the Stormwater Plan and other studies relating to water quality floodplain function and stormwater detention constitute substantial evidence necessary for the City to make adequate findings against Goal 6 on this Issue The Storm water Plan and the McKenzie River Floodplain Assessment David Evans and Associates Inc DEA November 2003 Floodplain Assessment also constitute substantial evidence in the record to allow the City to prepare findings that it is feasible that the floodplain development standards can be met DEA s material was prepared by experienced professional engineers registered in Oregon Their report constitutes credible evidence that the City can rely upon The KPFF Stormwater Plan states that in accordance with the recommendations of FEMA and the City of Springfield no development is being proposed within the floodway that could significantly alter flow characteristics Proposed development within the floodway is comprised of no more than pathways possible outdoor recreational facilities and appropriate features See page 6 of the Stormwater Plan Further based on the KPFF engineering analysis the Stormwater Plan notes that the planning and design of stormwater management will be founded upon the mass grading concept of protecting development from flooding by raising it abovethe floodplain elevation For the purposes of this report all design calculations assumptions and recommendations are based on the more conservative FEMA flood elevations for development and are referenced in the appendix of this report See pages 5 6 of the Stormwater Plan Again the requirement is whether the City has substantial evidence in the record upon which to prepare the necessary findings under Goal 6 The information provided by KPFF and DEA and other relevant testimony constitutes such substantial evidence The aquas also claim that additional federal discharge and fill permits will be required However they fail to identify the source of that contention or the federal permits Without specific information it is impossible for the City to respond directly to this claim with any certainty Page 113 of 123 1 110105 The proposal makes no such statement regarding the need for a federal discharge permit Nevertheless the information listed above and other information in the record constitutes evidence that for example discharges to wetland can be avoided because the resource is small compared to the entire site Hence no federal or state fill permit IS necessary As demonstrated above the record contains substantial evidence sufficient to allow the City to prepare the findings required by Goal 6 Further the Jaquas attempted to raise particular issues but did so without sufficient specificity to allow a reasoned and complete response by the City With respect to the adequacy of the David Evans Associates Inc DEA floodplain analysis the City finds that it is acceptable from a technical perspective The study was prepared by registered engineers The City recognizes that experts may differ on particular issues without either being incorrect With that in mind the City accepts the material provided by DEA related to the McKenzie River floodplain as substantial evidence Public Facilities Plan Policy G 21 The Jaquas also contend that the application would violate Policy G 21 That policy relates to placement of fill in the floodplain and the need to maintain flood storage capacity The Stormwater Plan prepared by KPFF provides substantial evidence that the proposed development can be constructed in accordance with the recommendations of FEMA and the City that no development is proposed within the floodway that could significantly alter flood flow characteristics and that any development proposed within the floodway would consist of no more than pathways outdoor recreational facilities and appropriate landscaping features see Stormwater Plan at page 6 In addition KPFF indicates that development will be protected from flooding by raising it above the floodplain elevation The existing ordinances relating to development in floodplains Article 27 will ensure that the capacity of the floodplain is maintained The Stormwater Plan at page II includes a list of assumptions that will ensure that flood capacity is maintained including the fact that all parcels will be required to detain on site the volume of stormwater runoff created by the 100 year post development design storm and to release that water at the maximum allowable 25 year post development According to KPFF the development strategy proposal will ensure that capacity of downstream infrastructure will not be exceeded during the horizon ofthe proposed master plan See Stormwater Plan at page 12 Page 1140f123 1 10105 Public Facilities Plan Policy G 19 The Jaquas contend that Policy G 19 would be violated Policy G 19 requires that the City maintain flood storage capacity within the floodplain to the maximum extent practicable through measures that include reducing impervious surfaces in the floodplain and adjacent areas The Stormwater Plan notes on page 13 that the volume of storm runoff would be actively reduced by the following three strategies I Discharge clean storm water roof runoff directly into ground infiltration facilities 2 Maximize infiltration by utilizing landscaped areas 3 Facilitate evaporation by increasing the number of trees onsite approximately 4 SOO additional trees are planned These practices are consistent with Policy G 19 and the City finds that based on such information and other evidence in the record Policy G 19 will be met Public Facilities Plan Policy G 16 The Jaquas contend that the proposal would violate Policy G16 which requires that waterways be managed or enhanced and open storm water systems used to reduce water quality impact from runoff and to provide improved stormwater conveyance The Stormwater Plan page 13 notes that the primary conveyance of public stormwater within the campus will be provided by underground pipe storm drain system for the western section of the development but that an open channel swale will be used for the eastern half In addition onsite open channels and swales will be incorporated into the project design wherever feasible and practicable This approach is consistent with Policy G 16 1L The amendments violate Goal 9 because the amendments are not based upon inventories establishing that the RiverBend MDR area is suitable for increased activity and growth after taking into consideration the health of the current economic base The Jaquas argument confuses the general Goal 9 requirement that local jurisdictions adopt comprehensive plans that contribute to a stable and healthy economy with the requirements of OAR 660 009 0010 4 applicable to the amendment of comprehensive plans that change plan designations of lands in excess of two acres to or from commercial or industrial use The Metro Plan is acknowledged as being in compliance with Goal 9 and the proposal on remand does not amend any of the Goal 9 related elements of the Metro Plan Rather the proposal is to redesignate MDR Page 115 of 123 1110105 designated land to a mixture ofCC and MU designated land Because the Metro Plan Diagram amendment exceeds two acres the City must demonstrate compliance with OAR 660 009 00 I 0 4 As LUBA recognized below w hen a post acknowledgment plan amendment PAPA affecting more than two acres triggers the requirements of the Goal 9 rule as is the case here the city is required to do one of three things I demonstrate that the PAPA complies with the parts of the acknowledged comprehensive plan that were adopted to comply with the Goal 9 rule 2 comply with the planning requirements in OAR 660 009 00 IS through 660 009 0025 in adopting the PAPA or 3 pursue a combination of I and 2 Jaqua slip op 29 As LUBA found in approving the earlier amendments the City was not required to undertake an economic opportunities analysis provided that the City could demonstrate that the diagram amendment was consistent with the SCLS Notwithstanding this holding the Jaquas appear to argue that Goal 9 imposes an independent obligation to prepare some other type of economic analysis Their testimony spans a number of pages and makes numerous allegations regarding the impact of the proposed hospital Yet the J aquas do not explain what applicable goal statute or ordinance would require such an analysis In short the City finds the J aquas argument regarding potential economic impacts does not relate to any of the approval criteria A portion of the Jaquas argument regarding compliance with the SCLS relates to Goal 10 rather than the SCLS Without providing any substantive argument the Jaquas allege that the City has not demonstrated that it is more appropriate to designate MDR land as commercial The Jaquas argument relies in part on their assertion that because the underlying property is currently designated as MDR the City has already determined that the property is more appropriate for residential use Under this reasoning the City could never rezone property from any designation to commercial because by the mere fact that property is zoned for one use shows that such use is more appropriate This argument would render SCLS Implementation Strategy 3 A I which specifically authorizes the re designation of property pointless 12 The amendments violate Goal 10 because the City must rely on the 2004 monitoring report The opponents argue that the City is required to base its decision on the 2004 Residential Lands Monitoring Report Similarly each ofthe opponents argue that the RLS requires the City to rely on the 2004 monitoring report instead of the Page 116 of 123 1 10105 acknowledged inventory in the RLS The City finds that reliance on the data in the 2004 Monitoring Report would conflict with Metro Plan s Residential Element The jaquas first argue that the RLS by including a policy that requires the preparation of annual monitoring reports demonstrates that the clear purpose of the monitoring reports is to provide a basis for determining on an ongoing basis whether supplies remain adequate as projected The jaquas cite nothing in either the 2004 Monitoring Report or more importantly the RLS or the Metro Plan which would suggest that the Metro Plan partners are required or even allowed to rely on monitoring reports when considering Metro Plan amendments that affect residentially designated land There is in fact nothing in the RLS the 2004 Monitoring Report or the Metro Plan that even remotely suggests that the 2004 Monitoring Report controls over the acknowledged inventory set forth in the Metro Plan In fact the Metro Plan clearly explains that the purpose of the monitoring reports is to provide a dialogue in the community to address future Periodic Review requirements related to residential land supply needs The jaquas then argue that the policy in the RLS requiring the preparation of monitoring reports demonstrates that the uptake assumptions of the 1999 report are not intended to be relied upon as the basis for plan amendments removing lands from Goal 10 inventories during the planning period Again the jaquas do not cite any provision in the RLS or the 2004 Monitoring Report for that assertion The jaquas then argue that the RLS acknowledges the shortcomings of its projections by requiring ongoing monitoring to assure that those projections retain their validity Again the jaquas do not city any provision of the RLS for this proposition The mere fact that the RLS requires the preparation of a monitoring report does not either expressly or impliedly suggest that the Metro Plan partners believed the RLS to be deficient or that it should not be relied upon In fact the City finds that the express language of the Metro Plan dictates that monitoring reports areto be used to address future Period Review requirements Citing Holcombe v City ofFlorence 45 Or LUBA 59 2003 affd without opinion 190 Or App 305 2003 the jaquas argue that the City must rely on the 2004 Monitoring Report because the RLS acknowledges its shortcomings Holcombe is not on point In Holcombe the applicant sought among other things to redesignate land from industrial to residential The petitioner argued that to do so violated Goal I 0 because the acknowledged buildable lands inventory concluded that there was sufficient buildable land within the urban growth boundary to meet the needs for residential housing throughout the planning period The petitioner cited D S Parklane for the proposition that the need for residential development be based on the buildable lands Page I I7 of 23 1 10 05 inventory and not other evidence that is inconsistent with the buildable lands inventory In concluding that the City of Florence could rely on updated housing demand information LUBA explained We might agree with petitioner that the city erred in adopting a decision inconsistent with its comprehensive plan buildable lands inventory and hence contrary to Goal 2 if the city s comprehensive plan concluded thatthebuildable lands inventory accurately reflected the anticipated need during the planning period However the 2000 2020 FCP explicitly acknowledges that the 1997 buildable lands inventory does not account for an extremely high population increase from between 1999 and 2001 average annual increase of 6 9 percent and an accelerated consumption of the residential land base to accommodate that increase The 2000 2020 FCP states in relevant part The 20 year Land Use Plan Map designates lands as residential which are appropriate for residential land uses and development within the UGB The July 1997 Residential Land Use Analysis concluded that those lands so designated comprise a sufficient supply of buildable lands to accommodate all expected types of housing anq all anticipated income levels for the 2000 2020 planning period However by 2000 it was becoming apparent that the high growth rate in Florence was utilizing residential lands at an accelerated rate The City debated whether to prepare an updated Residential Lands Analysis at that time or to continue with a much delayed completion of periodic review It was decided to complete periodic review and to deal with the need for expanded residential lands as a post acknowledgement Plan amendment 20002020 FCP IS 16 Holcombe at 69 Based on these provisions of the city s 2000 2020 FCP LUBA held that it was appropriate to rely on updated information because i the comprehensive plan explicitly indicated that the buildable lands inventory is outdated and not an accurate reflection of the city s actual need for residential land and ii provisions in the City s comprehensive plan expressly stated that the need for additional residential Page 118 of 123 1 10 05 land would be dealt with through post acknowledgement plan amendments rather than through an update of the buildable lands inventory Id In other words the city s comprehensive plan in Holcombe specifically directed the City to ignore the buildable lands inventory and to deal with residential demand through post acknowledgement plan amendments That is not the case here Moreover the applicable comprehensive plan policy at issue in Holcombe 2000 2020 FCP Land Use Policy 4 allowed plan amendments if the applicants could demonstrate that the amendment was based on new information that was either unavailable or overlooked at the time of Comprehensive Plan adoption Id fn 7 Unlike Holcombe neither the RLS nor the Metro Plan acknowledge any shortcomings of the RLS More importantly nothing in the RLS or the Metro Plan i dicate that Goal 10 inventories are to be meqsured by the 2004 Monitoring Report or through post acknowledgement plan amendments Perhaps most importantly the City has adopted the monitoring report Mere presentation to the City Council does not transform the 2004 Monitoring Report into an acknowledged planning document Moreover the 2004 Monitoring Report did not include Lane County or Eugene Finally Metro Plan Residential policy A 6 expressly provides that the purpose of the monitoring report is to promote a region wide dialogue to address future Periodic Review requirements that relate to meeting the residential land supply need of the Metro area Thus the City finds that reliance on the unadopted and unacknowledged monitoring report would violate the Metro Plan including Residential Policy A 6 13 Nodal development compliance through future RiverBend Master Plan Considerable evidence was submitted by Kirstin Greene on behalf of the aquas and Rob Zako of 1000 Friends critiquing the RiverBend Master Plan as alternately not meeting nodal development criteria or being located outside of a node yet still being inconsistent with the nodal development strategy outlined in TransPlan Both contend that the proceedings to review the proposal upon remand are the appropriate venue and that the issue is ripe for review The City Council finds that this is not the appropriate venue for review of the RiverBend Master Plan In her November 30 2004 correspondence to the City Ms Greene refers to zone changes and amendments requested by PeaceHealth Because no application for master plan or zone change approval was submitted with the original proposal and has not been submitted for concurrent review with this remand proceeding there is no application for master plan andor zone change before the City Therefore her statement the issues we raise are directly related to the original application and remand is incorrect Page 119 of 123 1 10105 Approval of plan amendments under the original proposal and remand must be addressed before the City can consider a master plan and zone changes that would implement the policy directives established by Council approval of the proposal In this proceeding there is no specific development proposal before the City Ms Green s client Mr Johnson acknowledged this in the first paragraph of his November 30 2004 letter to the City where he stated This is not an application for a development permit This is an application for a package of plan text and map amendments Therefore the City finds that Ms Greene s critique of the RiverBend Master Plan is not timely Similarly so is evidence submitted by Mr Zako regarding the unadopted TGM Quick Response grant study and other materials pertaining to specific development proposals for the subject site Although the RiverBend Master Plan is not relevant to the remand proceeding the City adopts the following findings in response to certain issues raised by Ms Greene and Mr Zako Ms Greene asks in her November 30 2004 letter that ifthe previously approved GRP Implementation Action 13 6 is sustained which allows for certain code standards to be flexed or exempted then what standards will apply The answer lies in Action 13 6 itself which requires that a Master Plan that seeks exemption from certain code standards must demonstrate consistency with the Purpose of the Nodal Development Overlay District The objectives established in the Purpose section of SDC Article 41 Nodal Development Overlay District are identical to those nodal development objectives referenced by Mr Zako in his correspondence Since any future Master Plan would have to conform with the literal application of Code standards for Mixed Use zones and or nodal development overlay zones or otherwise demonstrate consistency with the nodal development objectives established in Code and TransPlan Mr Zako s concern that the Master Plan is not or cannot be developed in a nodal fashion is unfounded Mr Zako requested that evidence be put into the record from the City s consultant ECONorthwest on a nodal development implementation study presented to the Council in May 2003 Summary Report Nodal Implementation Project dated May 12 2003 Although the City has yet to fully implement its program for nodal development implementation it has established Code provisions for MU zones SDC Article 40 and nodal overlay zone SDC Article 41 The consultant advised the City to make amendments to rticles 40 and 41 of the Springfield Development Code to increase flexibility where acceptable while implementing requirements where Page 120 of 123 1 10105 necessary for development that is compatible with nodal development goals Summary Report pg 4 This is precisely what Action 13 6 does further the means to realize the community s nodal development objectives by providing flexibility not currently available through the Code 14 Glenwood Proposal The opponents argue that the City should consider whether the Glenwood site or other sites in central Eugene are more appropriate than the subject property In short none of the approval criteria allow the City to consider whether the Glenwood site or any Eugene are appropriate or more appropriate than the subject property The Jaqlias however allege that Goal 14 and Goal 9 require consideration of the Glenwood site In particular the jaquas argue that Goal 14 requires that the conversion ofurbanizable land to urban uses shall be based upon the encouragement of development within urban areas before conversion of urbanizable areas The underlying property is not urbanizable Rather it is urban because it is located within an incorporated city Moreover the property is already designated on the Metro Plan for urban uses Therefore the Goal 14 conversion factors do not apply Citizens for Florence v City ofFlorence 35 Or LUBA 255 1998 With respect to Goal 9 the jaquas cite Opus Development COlp v City ofEugene 141 Or App 249 1996 and argue that in redesigating land to commercial uses impacts to existing inventories of commercial land must be considered The jaquas reliance on Opus is misplaced because in that case the City of Eugene was removing commercial land from its inventory and the issue was whether taking into account removal of commerciaUands from the inventory the remaining inventory was sufficient under Goal 9 The current proposal will add commercial land to the inventory which as the Commercial Lands Study indicates is lacking in commercial land Consequently the City finds that it is not appropriate to reexamine the existing inventories to see if they are sufficient when the Commercial Lands Study demonstrates that they are insufficient 15 A regional medical center cannot be sited on CC or MU land These designations are intendedfor uses much more limited in scope In the earlier proceeding the jaquas argued that the hospital is a commercial use For example before LUBA the jaquas argued that GRP Residential Element Policy 12 0 i mplicitly amends the Metro Text by replacing limited rezoning for neighborhood commercial with unlimited rezoning for mixed use commercial at levels and with uses that Page 121 of123 110105 the Metro Plan text classifies as community commercial and major retail III In challenging GRP Residential Implementation Action 121 the aquas asserted As amended it protects commercial development potential of a substantial portion of the MDR area In so doing it effectively reallocates the affected area from the Metro Plan s Goal 10 residential lands inventory and plan diagram allocation to the Metro Plan s Goal 9 commercial lands inventory In their statement of the case to LUBA the aquas argued that the C ity unilaterally authorized a major commercial use a regional general hospitalon 66 acres of the best of the rest of the Gateway MDR general plan diagram area IThus not only have the aquas asserted that the hospital is a commercial use they have also explicitly stated that the use and the intensity of the use are classified as community commercial Although the aquas now assert that the proposed CC and MUC designations are inappropriate and are intended for uses that are much more limited in scale scope and impact the aquas do not explain why this is the case As explained elsewhere the City finds that the CC designation is appropriate 16 The new proposal which includes CC and MU could lead to vast amounts of commercial development on the edge of the city notpreviously authorized The aquas argue that the revised proposal will open the door to a wide range of related and unrelated commercial uses at RiverBend The aquas provide no substantive argument and ignore the fact that the City has the final word on the master plan approval 17 The proposals are quasijudicial subject to procedural requirements of ORS 197 763 The aquas and the Goal I Coalition both argue that the proposals are quasi judicial subject to the procedural requirements ofORS 197 763 On April 21 2003 the City adopted Ordinances 60S0 and 60S 1 Ordinance 60S0 amended the Metro Plan Diagram by redesignating up to 33 acres ofMDR designated land to CC Ordinance 60S0 was ultimately remanded by LUBA On remand the revised proposal seeks to redesignate approximately 44 acres ofMDR designated land to CCand approximately SO acres ofMDR designated land to MUC This revision Page 122 of 123 110105 responds directly to the Court of Appeals decision which directed the City to redesignate the underlying property to a commercial designation if the City wanted to apply the MS zone to the property Also on April 21 2003 the City adopted Ordinance 6051 Ordinance 6051 included a number of text amendments to the Gateway Refinement Plan As with Ordinance 60S0 Ordinance 60S 1 was also ultimately remanded by LUBA On remand the revised proposal largely mirrors the original proposal but includes certain revisions to reflect the remand orders from LUBA and the Court of Appeals Assuming thatORS 197 763 applies in the context ofa remand hearing on these two ordinances the opponents have provided no substantive argument as to what requirements ofORS 197 763 the City has failed to follow Neither the aquas nor the Coalition have explained the nature of the City s error The City has provided adequate notice of the City hearings All documents have been made available to the public The record was left open for seven days to allow parties to submit additional evidence The record was also left open an additional seven days for rebuttal including the right to submit additional rebuttal evidence The City Attorney made the appropriate statement regarding hearing procedure at the hearing Thus it is unclear how the City has violated 0RS 197 763 with respect to the remand of Ordinances 60S0 and 60S 1 Thus to the extent that ORS 197 763 applies the City has followed the requirements and neither the aquas nor the Coalition have explained how the City has violated ORS 197 763 Page 123 of 123 1 10105 Jl I I 1 L rh Belt Line Rd tT h II Ii III IIT I 1 I I I I I II I I V yQ 100 VAyrr Q VA OJ Irrrrr Im tlJ IITT1 I 111Tl LxIIIIIBI1111 TI1111 1 1 I I I I L LJIlIl CL I tmmrrH III t TIf n IU A t fLI3Ar J2 m t IrITIiJ Ll t 1 I IT 1 I I l LI oM IT II I I c l crCj 111 J I I tI r7lIILfFol II L T r I r lliH11tMrITTII bs i@ Exhibit D Site A 500 0 500 Feet II file:///S|/...mmission/2009-04-21/RS%20Riverbend%20Nodal%20Implementation%20LRP2009-00001/att6a%20email%20from%20DLCD.txt[2/7/2019 2:01:37 PM] From: MOTT Gregory Sent: Tuesday, March 24, 2009 9:48 AMTo: LIMBIRD Andrew Subject: FW: Springfield PAPA 001-09: Amending Gateway Refinement Plan Andy,Go ahead and place the email train from Ed into the record. Wherever your staff report mentions correspondence or comments from the public and interested parties be sure and identify that DLCD reviewed this proposal and had no comments. gmott From: Ed Moore [mailto:ed.w.moore@state.or.us] Sent: Tuesday, March 24, 2009 9:40 AM To: MOTT Gregory; MOORE Ed W (OR) Cc: LIMBIRD Andrew Subject: RE: Springfield PAPA 001-09: Amending Gateway Refinement Plan Greg,your correct, Gloria's comments are directed at Exhibit B. Given your clarification, we have no comments on the proposed PAPA. Cheers, Ed Ed Moore AICPSo Willamette Valley Regional RepresentativeDLCD Springfield Office 644 A StreetSpringfield, OR 97478 971.239.9453ed.w.moore@state.or.us | www.oregon.gov/LCD >>> On 2009.03.23 at 15:47, in message <C1E1D2BFD0E40040BA644474C38411A6D5A0B78801@spifs030.Springfield1.net>, MOTT Gregory <gmott@ci.springfield.or.us> wrote:Ed, Thanks for the opportunity to review Gloria's comments. I'm assuming her comments are directed at Exhibit B in our notice of proposed amendment. That exhibit is an ordinance adopted by Council in 2005 as part of a remand ordered by LUBA on a proposal to amend the Gateway Refinement Plan to allow the development of the RiverBend campus. We're not proposing to change any of that ordinance; we provided it as context to the one policy in that document that requires this site to be redesignated for nodal development. We are not proposing to change the distribution of the underlying zoning nor are we proposing to change the permitted uses except to prohibit some commercial activities that are currently permitted but will be prohibited upon redesignation as nodal overlay. Thanks again. Greg Mott From: Ed Moore [mailto:ed.w.moore@state.or.us] Sent: Monday, March 23, 2009 10:31 AM Attachment 6, Page 1 of 4 file:///S|/...mmission/2009-04-21/RS%20Riverbend%20Nodal%20Implementation%20LRP2009-00001/att6a%20email%20from%20DLCD.txt[2/7/2019 2:01:37 PM] To: MOTT Gregory Subject: Fwd: Springfield PAPA 001-09: Amending Gateway Refinement Plan Greg, As we discussed, let me know if you would like me to submit these suggestions as part of the official record. don't see any of them as deal stoppers; but per our no surprises agreement and given the late date that I received them I don't feel the need to submit them if they would delay your adoption. Ed Ed Moore AICP So Willamette Valley Regional Representative DLCD Springfield Office 644 A Street Springfield, OR 97478 971.239.9453 ed.w.moore@state.or.us<mailto:ed.w.moore@state.or.us> | www.oregon.gov/LCD<http://www.oregon.gov/LCD> >>> On 2009.03.20 at 12:26, in message <49C38B8A.6954.00FC.0@lcd.state.or.us>, Gloria Gardiner wrote: Hi, Ed. Sorry my comments are so late. Monday 3/23 is the fax deadline. My comments are on the amendments in Exhibit B. [ ] is a suggested deletion; a suggested addition is in bold. Residential Element Policy and Implementation Actions Action 2: I recommend revising as follows to ensure consistency with Goal 10:Housing, OAR 660, division 8, and the needed housing statutes in ORS chapter 197: "Ensure availability of [adequate] needed supplies of land for low-, medium-, and high- density residential development while allowing for an appropriate mix of commercial, employment and residential uses." "Adequate" is too vague and undefined. This policy should be clearly consistent with Springfield's obligation to ensure a supply of land in the UGB to meet the housing needs of all of its residents according to its housing land needs analysis. Action 12.6: I recommend revising the last sentence as follows for consistency with the Goal 10:Housing, OAR 660, division 8, and the needed housing statutes in ORS chapter 197: "In addition to meeting the standards of the SDC, at the time of Master Plan approval, the City Council may attach specific conditions on all development within the MS or MUC zones including but not limited to building height and setbacks. The standards, conditions, and procedure for needed housing shall be clear and objective and shall not have the effect, either alone or cumulatively, of discouraging needed housing through unreasonable cost or delay." This policy should make clear that there is a limit on the standards and conditions that City Attachment 6, Page 2 of 4 file:///S|/...mmission/2009-04-21/RS%20Riverbend%20Nodal%20Implementation%20LRP2009-00001/att6a%20email%20from%20DLCD.txt[2/7/2019 2:01:37 PM] Council may impose on approval of needed housing in this plan area. As written, it suggests that the city may use any standards and impose any conditions on needed housing development. Action 15.1: As drafted, this "density transfer" provision decreases residential density on development sites that contain natural resources or open space. The policy provides that housing units may be moved from unbuildable Goal 5 resource areas, recreational pathways, or shared open space, to buildable areas of the development, at the same maximum density as the base zone. However, unless the city re-zones more land in the development area to residential, there is no place to put the transferred units; the buildable part of the site can currently be developed up to the maximum density for the base zone. The only way to truly transfer density from one part of a site to another is to take the calculated number of units for the unbuildable area and transfer them to the buildable area, which means allowing a higher density in the buildable portion of the site (i.e., clustering the allowed housing on the buildable portion of the site and preserving the unbuildable portions from development), so that the site's overall density doesn't fall below the base zone standard. This is what some cities' PUD regulations do. Gloria Gardiner | Urban Planning Specialist Planning Services Division Oregon Dept. of Land Conservation and Development 635 Capitol Street NE, Suite 150 | Salem, OR 97301-2540 Office: (503) 373-0050 ext. 282 | Fax: (503) 378-5518 gloria.gardiner@state.or.us<mailto:gloria.gardiner@state.or.us> | www.oregon.gov/LCD<http://www.oregon.gov/LCD> Attachment 6, Page 3 of 4 file:///S|/...09-04-21/RS%20Riverbend%20Nodal%20Implementation%20LRP2009-00001/att6b%20email%20from%20bonnie%20ullmann.txt[2/7/2019 2:02:27 PM] From: Bonnie Ullmann [ullmann@uoneuro.uoregon.edu] Sent: Wednesday, April 08, 2009 11:48 AMTo: LIMBIRD Andrew Subject: Planning Case LRP 2009-00001 Dear Mr. Limbird and members of the Planning Commission and City Council, I would like to lend my support to implementing a Nodal Development Overlay District for any portions of the Gateway Refinement Plan area. In particular, at this time, I support the overlay on the southern portion of the PeaceHealth property. My reasoning for support of this planning designation is that I believe it will lend a more viable commercial and residential area in the long run. It will benefit the Game Farm Neighbors area by implementing design standards for commercial land. This will improve the overall liveability of the Game Farm area by addressing traffic issues and community cohesiveness. An attractive and viable development plan will go a ways toward compensation of the Game Farm neighborhood for the great increase in population, traffic and decreased attractiveness of our properties since the boom in development interests in our home area. I have been educating myself by having participated in Springfield citizen planning committees that addressed the idea of nodal development in our neighborhood. I believe nodal development to be a tremendous strategy for long-term, far-reaching good planning that ultimately will be beneficial to the Game Farm Neighbors area. I sincerely believe that the long term residents of the area should have the advantage of city planning that demonstrates foresight at this point in time. Springfield's commitment to nodal development is very encouraging and I am fully behind the concept. Please let me know if I can help in the process. Please add my support to the written record for the public hearing. Sincerely,Bonnie Ullmann --Bonnie Ullmann ullmann@uoneuro.uoregon.edu 3350 Oriole StreetSpringfield, OR 97477-7551 USA 541-520-0921 Mobile541-747-7580 Message/home 541-747-7580 FAX541-346-4506 Work Attachment 6, Page 4 of 4 Planning Commission Order LRP2009-00001 April 21, 2009 Page 1 of 1 RECOMMENDATION TO THE CITY COUNCIL BEFORE THE PLANNING COMMISSION OF THE CITY OF SPRINGFIELD METRO PLAN DIAGRAM AMENDMENT ( RECOMMENDATION TO IMPLEMENTATION OF NODAL DESIGNATION ( THE CITY COUNCIL ( Case Number: LRP2009-00001 ( ( NATURE OF THE APPLICATION The proposed Metro Plan amendment will implement a Nodal Development Overlay District (NDO) designation for approximately 170 acres of the Riverbend area of northwest Springfield, which includes the existing Sacred Heart Medical Center and campus. The NDO designation will be supplementary to the current commercial, mixed use, and medium density residential zoning for the subject area. 1. The above referenced plan amendment action was initiated by the City Council upon adoption of the amended RiverBend Master Plan in June, 2006. Timely and sufficient notice of the public hearing, pursuant to Springfield Development Code Section 5.2-115, has been provided. 2. The plan amendment action is consistent with provisions of the adopted Metro Plan, TransPlan and Gateway Refinement Plan as described in the attached staff report. 3. On April 21, 2009, the Planning Commission held a public hearing regarding the proposed plan amendment. The Development Services Department staff notes and recommendation together with the oral testimony and written submittals of the persons testifying at that hearing have been considered and are part of the record of this proceeding. CONCLUSION On the basis of this record, the proposed amendment is consistent with the criteria of SDC Section 5.14-135.C.1&2. This general finding is supported by the specific findings of fact and conclusion in the Staff Report and Findings. RECOMMENDATION The Planning Commission hereby recommends to the City Council to approve the plan amendment as recommended herein, Case Number LRP2009-00001, at their May 18, 2009 meeting. __________________________________ Planning Commission Chairperson ATTEST: AYES: _____ NOES: _____ ABSENT: _____ ABSTAIN: _____