HomeMy WebLinkAbout2023 04 04 AIS WS & PH Goshen Metro Plan Amendment COMPLETEAGENDA ITEM SUMMARY Meeting Date: 4/4/2023
Meeting Type: Work Session/Reg. Mtg
Staff Contact/Dept.: Haley Campbell, DPW
Staff Phone No: 541-726-3647
Estimated Time: 2 hours
S P R I N G F I E L D
PLANNING COMMISSION
Council Goals: Encourage Economic Development and
Revitalization through Community
Partnerships
ITEM TITLE: REQUEST FOR METRO PLAN AMENDMENT TO ALLOW FOR WASTEWATER SERVICE
TO BE EXTENDED TO THE RURAL UNINCORPORATED COMMUNITY OF GOSHEN
AND LANE COUNTY’S SHORT MOUNTAIN LANDFILL
ACTION
REQUESTED:
Conduct a joint work session and joint public hearing with the City of Eugene, City of Springfield,
and Lane County Planning Commission.
ISSUE
STATEMENT:
The Eugene, Springfield, and Lane County Planning Commissions will hold a joint public hearing
to consider a proposal to adopt amendments to the Eugene-Springfield Metropolitan Area Plan
(Metro Plan) that will enable future actions to extend Metropolitan Wastewater Management
Commission (MWMC) wastewater infrastructure to serve the needs of the rural unincorporated
community of Goshen and Lane County’s Short Mountain Landfill.
The Lane County Board of Commissioners initiated this Metro Plan amendment to revise jointly
adopted policies in the Metro Plan to allow for the extension of wastewater to Goshen and the
Short Mountain Landfill. The Metro Plan generally prohibits extension of urban-level public
facilities outside the urban growth boundary consistent with Statewide Planning Goals 11 (Public
Facilities and Services) and 14 (Urbanization). Exceptions to the Oregon Administrative Rule
(OAR) can be found in OAR 660-011-0060 for extending wastewater service for the transport of
leachate and to serve an unincorporated community. The proposed amendments would allow the
County to move forward to extend the wastewater system.
ATTACHMENTS: ATT1 – Lane County Staff Report
Exhibit A – Proposed Metro Plan Policy Amendments
Exhibit B – Findings
Exhibit C – Vicinity Map of Goshen and Short Mountain Landfill
Exhibit D – Map of the Goshen Rural Unincorporated Community
Exhibit E – Ordinance No. PA 1282, Pages 36-37
ATT2 – Springfield Staff Report and Findings
DISCUSSION:
The proposed amendments are a Type III Legislative Amendment to the Metro Plan, which
includes public notice and a public hearing before the Eugene, Springfield, and Lane County
Planning Commissions.
The County is currently working to address gaps in the findings for Goal 11 and 14. If there are
revisions to the County’s proposed findings prior to the public hearing, they will be added to the
Planning Commission packet and posted at Springfield Oregon Speaks.
The Commissions may choose to close the public hearing and public record or close the public
hearing but leave the record open for additional public comment through their respective
deliberations. The Eugene Planning Commission deliberation is scheduled for April 25, 2023, the
Lane County Planning Commission deliberation is scheduled for April 18, 2023, and the
Springfield Planning Commission deliberation is scheduled for May 2, 2023. Following the
deliberations, the three commissions will forward a separate recommendation to the Eugene City
Council, Lane County Board of Commissioners, and Springfield City Council, respectively.
STAFF REPORT MARCH 15, 2023 To: Eugene, Springfield, and Lane County Planning Commissions
From: Jared Bauder, Staff (Lane County) Anne Davies, Consultant (Lane Council of Governments) Subject: Joint Public Hearing: Eugene-Springfield Metropolitan Area Plan (Metro Plan),
Amendment to allow for wastewater service to be extended to the rural
unincorporated community of Goshen and Lane County’s Short Mountain Landfill ISSUE STATEMENT At this meeting, the Eugene, Springfield, and Lane County Planning Commissions will hold a
joint public hearing to consider a proposal to adopt amendments to the Eugene-Springfield Metropolitan Area Plan (Metro Plan) that will enable future actions to extend Metropolitan Wastewater Management Commission (MWMC) wastewater infrastructure to serve the needs of the rural unincorporated community of Goshen and Lane County’s Short Mountain Landfill.
Lane County has long been working toward the goal of creating high-paying jobs and promoting industrial development in the unincorporated community of Goshen, which is approximately 3.5 miles south of Eugene at the junction of Interstate 5, Highway 99, and Highway 58. In 2013, the County adopted the Goshen Region Employment and Transition (GREAT) Plan, which zoned
industrial properties located within Goshen for urban levels of development. However,
inadequate public facilities, specifically the lack of wastewater infrastructure, has posed a significant barrier to the desired industrial development. The Goshen wastewater service area includes approximately 444 acres of industrial, commercial, and residential zones. The MWMC provides wastewater services to the Eugene-Springfield metropolitan area in partnership with the
cities of Eugene and Springfield, but its internal policies as well as existing policies in the Metro
Plan prohibit extending wastewater services to areas outside the urban growth boundaries (UGBs) of Eugene and Springfield. The Short Mountain Landfill, which sits approximately 5.5 miles south of Eugene along
Interstate 5, is also located outside the UGBs of Eugene and Springfield. Landfills produce
leachate, a liquid that percolates down through the waste mass. At Short Mountain, the leachate is collected via a collection of pipes and pump stations and transported to an on-site covered storage lagoon. From there it is transported via tanker trucks to the County-owned Glenwood receiving station. At the receiving station the leachate is discharged into the sanitary sewer
system where it goes to the MWMC wastewater treatment facility. The Short Mountain Landfill
is the only permitted municipal landfill in Lane County and accepts solid waste from the surrounding area. Approximately 25-million gallons of leachate are transported annually with an average of 10 to 12 trucks per day. An extension of wastewater infrastructure to Goshen would
Lane County
LAND MANAGEMENT DIVISION
3050 NORTH DELTA HIGHWAY
EUGENE, OREGON 97408
PHONE: 541-682-4065
WEB: lanecounty.org/lmd
Attachment 1, Page 1 of 22
facilitate extending that infrastructure to the landfill as well, thereby eliminating the need for leachate to be transported via truck to be processed.
The Lane County Board of Commissioners initiated this Metro Plan amendment to revise jointly
adopted policies in the plan to allow for the extension of wastewater to Goshen and the Short Mountain Landfill. The proposed amendments would allow the County to move forward to extend the wastewater system. BACKGROUND
More than a decade ago, the Lane County Board of Commissioners identified economic and industrial development in Goshen as a strategic goal. Specifically, the County adopted the following goal: “[B]y 2017, Lane County will transform the existing industrial land in
Goshen to support increased levels of development resulting in jobs that pay no less than
150% of the median wage. Lack of buildable land is a barrier for traded-sector companies that want to locate in Lane County, particularly those companies that require a larger footprint.” At the time, the County projected that 2,000 to 3,000 industrial manufacturing jobs could be created on the existing industrial land. To move toward the strategic goal of industrial
development in Goshen the County adopted the Goshen Regional Employment and Transition
(GREAT) Plan. In September 2012 the Goshen area was designated by the State of Oregon as a Regionally Significant Industrial Area (RSIA). There were only nine RSIAs designated in the state. These
regionally significant sites are areas that are planned and zoned for industrial use that have
competitive advantages that make them difficult or impossible to replicate in the region. The RSIA designation was important for Goshen because it protected the designated lands from being used for non-industrial purposes for a period of ten years. The governing body that approved RSIA1 designations dissolved in 2018 and at this point the ten years has passed,
however, Goshen retains the RSIA distinction. The criteria for an area to be designated a RSIA
included superior access to transportation and freight infrastructure, sites for new or expanding industrial uses that would provide significant additional employment, and located in close proximity to major labor markets. Goshen met these criteria.
County staff undertook an exception to Oregon Statewide Land Use Planning Goal 14
(Urbanization) and associated comprehensive plan and zoning changes. Oregon’s land use planning system allows for local governments to take an exception to a goal when it finds that certain land should be excluded from the requirements of an applicable statewide goal in accordance with the process specified in Goal 2, Part II, Exceptions. The purpose of the Goal 14
exception was to allow urban levels of development on the existing rural industrial zoned lands
of the unincorporated community of Goshen. These changes, referred to as the Goshen Region Employment and Transition (GREAT) Plan, were approved by the County in June 2013. LandWatch Lane County subsequently appealed the adoption of the Plan to the Land Use Board of Appeals (LUBA).
1 Business Oregon now has the Regionally Significant Industrial Sites (RSIS) program, which is a profit sharing
economic development tool that offers state income tax reimbursements for approved industrial site readiness
activities. A local government may apply for RSIS designation if it owns the industrially zoned site or act as a sponsor for a privately owned industrial zoned site. At this time land in Goshen has not gone through the RSIS
process.
Attachment 1, Page 2 of 22
LUBA remanded the decision, with direction to address the issue of addressing adequacy and presence of sewer service to support the exception. In July 2014, the County contracted with the
consulting firm Kennedy Jenks for wastewater feasibility work in response to LUBA’s remand
decision. Kennedy Jenks identified three feasible alternatives to providing wastewater service to Goshen. The study recommended connection to the Metropolitan Wastewater Management Commission (MWMC) regional system as it had the lowest cost of all alternatives considered. The County then re-adopted the GREAT Plan in 2015, and no further appeals were filed.
With financial assistance from Business Oregon and the Department of Land Conservation and Development, the County completed the Goshen Financial and Administration Study, which estimated connection charges for the MWMC connection and identified system administrative functions that would be required for the operation of the Goshen wastewater system. The study
also reviewed several alternatives for system governance, ultimately recommending the Goshen
facilities be incorporated into the MWMC regional system. With additional funding from Business Oregon, Kennedy Jenks, on behalf of the County, completed the draft Project Definition Report in November 2019. The report included the
extension of a pipeline to the Short Mountain Landfill to convey leachate from the landfill to the
proposed wastewater collection system for Goshen. In February 2022, Lane County finalized a Project Definition Report (PDR), that refines the conceptual planning and financial estimates from the 2015 and 2017 studies. The PDR includes route evaluations for gravity sewers and pressure force mains as well as capital cost estimates, connection charge estimates, and a
Permitting Plan with anticipated timelines.
There is no expectation that this project will require money from the cities of Eugene and Springfield. Various funding mechanisms have been discussed and will be finalized after the Metro Plan amendments are approved. There will likely be a combination of funding sources,
including grants and collection fees. Potentially project funding for design and construction can
be obtained from Business Oregon and the State of Oregon Clean Water State Revolving Fund (CWSRF) program administered by the Department of Environmental Quality (DEQ). Lane County may also allocate solid waste management funds for portions of the project that convey leachate from Short Mountain Landfill. Funding connection charges will be determined through
additional financial evaluation to be performed by the County in ordination with the MWMC as
part of the ongoing intergovernmental policy discussions. PROPOSED METRO PLAN AMENDMENTS
Implementation of the Kennedy Jenks report to extend wastewater service to Goshen depends
upon the adoption of several Metro Plan policy amendments. Consistent with Statewide Planning Goals 11 (Public Facilities and Services) and 14 (Urbanization), Oregon administrative rules, and state statute, the Metro Plan generally prohibits
extension of urban-level public facilities outside the UGBs. There are exceptions to these rules,
for example there is a specific provision of OAR 660-011-0060 for extending wastewater service for the transport of leachate. The Metro Plan already includes exceptions to the general rule of extending wastewater service outside the UGB. Policy G.26 of the Metro Plan provides several exceptions to that general rule, as follows:
Attachment 1, Page 3 of 22
“Wastewater and water service shall not be provided outside the UGB except to the
following areas, and the cities may require consent to annex agreement as a
prerequisite to providing these services in any instance:
a. The area of the Eugene Airport designated Government and Education on the
Metro Plan Diagram, the Seasonal Industrial Waste Facility, the Regional
Wastewater Biosolids Management Facility, and agricultural sites used for land
application of biosolids and cannery byproducts. These sites serve the entire
metropolitan area.
b. An existing development outside the UGB when it has been determined that it
poses an immediate threat of public health or safety of the citizens within the
UGB that can only be remedied by extension of the service.
In addition, under prior obligations, water service shall be provided to land within
the dissolved water districts of Hillcrest, College Crest, Bethel, and Oakway.”
Policy G.26 is proposed to be amended to include the Short Mountain Landfill site and the
Goshen area to the list of areas outside the UGBs to which wastewater services will be allowed.
See proposed Metro Plan amendments, attached Exhibit A. Several other policies would also be amended to ensure consistency with the amendments to Policy G.26. PROCEDURAL SUMMARY AND PLANNING COMMISSION ROLE The process being followed for the formal consideration of the legislative adoption package meets or exceeds all the Cities and County procedural requirements for adoption of Type III amendment to the Metro Plan. The legislative process includes public notice and a hearing before the Eugene, Springfield, and Lane County Planning Commissions. At this stage, the
commissions’ roles are to participate in a joint public hearing and subsequently make separate recommendations on the adoption package to their respective elected bodies. The recommendations of the planning commissions must be based on the applicable approval criteria for the proposed amendments. Those criteria and findings addressing the approval criteria are provided in Exhibit B.
NEXT STEPS After the public hearing, each Planning Commission will hold separate deliberation meetings and
form separate recommendations to their respective elected bodies. The Eugene Planning Commission deliberations and potential recommendation to the Eugene City Council is scheduled for April 25, 2023. The Lane County Planning Commission deliberations and potential recommendation to the Lane County Board of Commissioners is scheduled for April 18, 2023. The Springfield Planning Commission deliberations and potential recommendation to the
Springfield City Council is scheduled for May 2, 2023. Following the planning commission recommendations, the Eugene City Council, Springfield City Council, and Lane County Board of Commissioners will hold a joint public hearing to consider the Planning Commissions’ recommendations and adoption of the proposed Metro Plan
amendments. After the public hearing, each jurisdiction will hold separate deliberations.
Attachment 1, Page 4 of 22
EXHIBITS A. Proposed Metro Plan policy amendments
B. Findings
C. Vicinity Map of Goshen and Short Mountain Landfill D. Map of Goshen Rural Unincorporated Community E. Ordinance No. PA 1282, Pages 36-37
FOR MORE INFORMATION Staff Contacts:
Jared Bauder, Associate Planner, Lane County
Telephone: 541-682-6949 Email: jared.bauder@lanecountyor.gov Anne Davies, Principal Attorney, Lane Council of Governments (LCOG) Telephone: 541-682-4040
Email: adavies@lcog.org
Attachment 1, Page 5 of 22
Exhibit A
NOTE: Matter in boldface type is proposed to be added; matter in [italic and bracketed] is existing language to be
omitted.
Proposed Metro Plan Amendments
Metro Plan Chapter II-C (Growth Management Goals, Findings, and Policies), Policy 21: Cities shall not extend water or wastewater service to lands that are outside city limits and within a UGB to serve a residence or business without first obtaining a valid annexation petition[,] or a consent to annex agreement, or [when] unless a
health hazard annexation is required. Metro Plan Chapter III-G (Public Facilities and Services Element), Policy G.26: Wastewater and water service shall not be provided outside the UGB except to the
following areas, and the cities may require consent to annex agreements as a
prerequisite to providing these services in any instance:
a. The area of the Eugene Airport designated Government and Education on the
Metro Plan Diagram, the Seasonal Industrial Waste Facility, the Regional
Wastewater Biosolids Management Facility, and agricultural sites used for land
application of biosolids and cannery byproducts. These sites serve the entire
metropolitan area.
b. An existing development outside the UGB when it has been determined that it
poses an immediate threat of public health or safety of the citizens within [the] a
UGB that can only be remedied by extension of the service.
c. Lane County’s Short Mountain Landfill for the transport of leachate only.
d. The rural unincorporated community of Goshen for wastewater only.
In addition, under prior obligations, water service shall be provided to land within the
dissolved water districts of Hillcrest, College Crest, Bethel, and Oakway.
Metro Plan Chapter III-G (Public Facilities and Services Element), Policy G.28:
Except as otherwise allowed under Policy G.26, [C]consistent with local regulations, locate new urban water, wastewater, and stormwater facilities on farm land and urban water and wastewater facilities on forest land outside the UGB only when the facilities exclusively serve land inside the UGB and there is no reasonable alternative.
Attachment 1, Page 6 of 22
Exhibit B
Findings for Metro Plan Amendment to Extend Wastewater Services to the
Rural Unincorporated Community of Goshen and Lane County’s Short Mountain Landfill The findings, below, present local government criteria first, then State criteria. The State criteria are
presented in order of the Statewide Planning Goals. State statutes and administrative rules are addressed
under the Statewide Planning Goal to which they relate.
INTRODUCTION In 2013, the Lane County Board of Commissioners adopted a countywide strategic plan with a key goal
of increasing industrial development and high-paying jobs within the unincorporated community of
Goshen. In support of this goal, the Goshen Region Employment and Transition (GREAT) Plan was
adopted by the County in June of 2013 to promote development for employment uses in Goshen. The
County’s goal was to foster industrial development in the Goshen community, which would bring with it
high-paying jobs. This in turn would promote economic development throughout the region.
Goshen has significant advantages for industrial development including: existing industrial/non-resource
designations; large parcels; proximity of supporting smaller parcels to the larger parcels; close proximity
and direct access to the State Highway system, including I-5, Highway 58, and Highway 99; adjacency
and access to rail; proximity to the urban population centers of Eugene and Springfield for providing an
educated and/or skilled workforce; access to natural resources; proximity and access to utility
infrastructure including natural gas, electrical power, and water; limited natural resource conflicts, and
relatively level topography.
This area is a regional asset with its advantages for industrial growth and economic development, which
would benefit the entire county economy by creating an environment to stimulate job growth.
Additionally, there would be no loss to productive resource lands due to the land already having a non-
resource designation.
Internal Consistency Findings for Metro Plan Amendment to Extend Wastewater Services to Goshen and the Short Mountain Landfill
Lane Code 12.300.030 provides: The following criteria will be applied by the Board of Commissioners and other applicable governing body or bodies in approving or denying a Metro Plan amendment application: A. The proposed amendment is consistent with the relevant Statewide Planning Goals; and B. The proposed amendment does not make the Metro Plan internally inconsistent.
The following are findings addressing LC 12.300.030.B. Chapter II-C Growth Management Goals, Findings, and Policies
Attachment 1, Page 7 of 22
Exhibit B
Policy 4: Lane County shall discourage urban development in urbanizable and rural areas and encourage compact development of outlying communities. Finding 1: The County took an Exception to Statewide Planning Goal 14 in 2013 when it adopted the
GREAT plan for the Goshen area. The County determined at that time that there were reasons justifying
developing the otherwise rural area with urban levels of industrial uses, based on the unique
circumstances of the site and the needs for industrial sites that the Goshen area could fulfill. Thus, it has
already been determined that an urban level of industrial development is appropriate in that area.
Further, the extension of the wastewater pipeline to the Short Mountain Landfill is proposed to convey
leachate generated from the municipal landfill to the proposed wastewater collection system in
Eugene/Springfield. The residents of Eugene and Springfield would benefit from a piped connection
from the regional wastewater facility to the landfill, which serves those same communities. This
connection would eliminate the high costs, environmental impacts, and operational challenges of
transporting leachate from the landfill to the wastewater facility transfer station, as is the current practice.
The intent of the proposed Metro Plan amendment is to develop safe, efficient solutions to wastewater
infrastructure for the existing Short Mountain Landfill and for urban levels of industrial development that
is already planned for the Goshen area. The proposal is consistent with Policy 4.
Chapter III-B Economic Element
Policy B.27: Eugene, Springfield, and Lane County shall improve monitoring of economic development and trends and shall cooperate in studying and protecting other potential industrial lands outside the urban boundary. Finding 2: On October 12, 2021, the Lane County Board of Commissioners directed staff to coordinate
with the Metropolitan Wastewater Management Commission (MWMC), the City of Eugene, and the City
of Springfield to pursue amendments to the Metro Plan to facilitate extending wastewater services to the
rural unincorporated community of Goshen as well as a pipeline extension connection to service Short
Mountain Landfill for conveyance of leachate. Although the economic element no longer applies to
Eugene or Springfield, both cities and the County must jointly adopt any amendments to the Metro Plan.
The industrial development in the unincorporated community of Goshen has been a topic of significant
conversation and action by the Board of Commissioners for more than 10 years. In 2013, the Board
adopted the GREAT Plan, which designated lands within Goshen for urban levels of industrial
development. The major remaining barrier to development of that area is the lack of adequate wastewater
infrastructure. The adoption of the proposed Metro Plan amendment would enable extension of
wastewater services by MWMC, which in turn, would enable the industrial development that has long
been planned for this area.
Likewise, the ability of the Short Mountain Landfill to connect to a piped wastewater system remains a
strong desire of the Lane County Public Works Department. This wastewater is already truck delivered to
the regional wastewater facility at the Glenwood Transfer Station. A piped connection to the regional
wastewater facility would eliminate the high costs, environmental impacts, and operational challenges of
transporting over 25-million gallons of leachate annually by tanker trucks.
Attachment 1, Page 8 of 22
Exhibit B
Chapter IV Metro Plan Review, Amendments, and Refinements
Policy 6.b.iii: Type III Text Amendments include: Amendments to a regional transportation system plan, or a regional public facilities plan, when the participation of all three governing bodies is required by the amendment provisions of those plans. Policy 7.c: A Type III amendment may be initiated by any one of the three governing bodies at any time. Policy 8.a: The initiating governing body of any Type I, II, or III Metro Plan amendment shall notify all governing bodies of the intended amendment and the Type of amendment proposed. If any governing body disagrees with the Type of the proposed amendment that governing body may refer the matter to the processes provided in 8(d) or (e) as appropriate. Policy 8.b: When more than one governing body participates in the decision, the Planning Commissions of the bodies shall conduct a joint public hearing and forward that record and their recommendations to their respective elected officials. The elected officials shall also
conduct a joint public hearing prior to making a final decision. Finding 3: The proposal is a request to amend Chapter II.C, Policy 21; and Chapter III.G, Policy G.26
and Policy G.28 of the Metro Plan via this Type III Metro Plan Amendment. The amendment was
initiated by Lane County, and Lane County has notified the other jurisdictions. The jurisdictions agree
that the proposal is a Type III amendment. The procedures are consistent with Chapter IV of the Metro
Plan.
Statewide Planning Goal Findings for Metro Plan Amendment to Extend Wastewater Services to Goshen and the Short Mountain Landfill
Statewide Planning Goal 1 – Citizen Involvement
Statewide Planning Goal 1 ‐‐ “To develop a citizen involvement program that insures the opportunity for
citizens to be involved in all phases of the planning process.”
Goal 1 is a process goal. The amendment complies with Goal 1 because it will be processed as a
legislative action through the jurisdictions’ acknowledged public procedures for Metro Plan amendments.
This process includes joint public hearings before the City of Eugene, the City of Springfield, and Lane
County’s planning commissions, and joint hearings before the governing bodies of all three jurisdictions.
The joint planning commission hearing is scheduled to be held April 4, 2023. Notices will be sent to
interested parties and the public hearing notice was also published in The Register-Guard newspaper on
March 15, 2023.
The joint hearings before the governing bodies of Lane County, the City of Eugene, and the City of
Springfield is scheduled to be held at a future date yet to be determined.
Statewide Planning Goal 2 – Land Use Planning
Attachment 1, Page 9 of 22
Exhibit B
Statewide Planning Goal 2 ‐‐ “To establish a land use planning process and policy framework as a basis
for all decisions and actions related to use of land and to assure an adequate factual base for such
decisions and actions.”
The land use codes of both cities and Lane County specify the procedures and criteria that were used in
considering this amendment. The findings documents show the record includes an adequate factual base
for the amendment. The record of the original Lane County Rural Comprehensive Plan amendment and
Reasons Exception that was adopted to enable the urban levels of industrial uses in Goshen shows that the
County studied the need for certain employment lands that have access to rail transport. The Goshen
property included in the GREAT plan was determined, through thorough study, to meet the demands for
that type of development. The proposed amendment will enable the development that has been stymied
by lack of infrastructure that this proposal will provide.
Consistent with the Goal 2 coordination requirement, there was a significant exchange, or invitation for
such an exchange, among the cities, Lane County and affected governmental units. The information
obtained in these exchanges was used to balance the needs of the citizens. The County and cities
coordinated and jointly adopted the Metro Plan amendment. For the ordinance adopting this Metro Plan
amendment, intergovernmental coordination included the following:
• The Department of Land Conservation and Development (DLCD) was engaged
through notice of the proposed action and regular contact with the area’s regional
representative.
• City of Eugene, City of Springfield, and Lane County, which will jointly consider
adoption of the Metro Plan amendment, were engaged during the process with staff from
the three entities participating in meetings and providing feedback on the proposed
amendment language and documents. County staff collaborated with City staff to
provide informational updates and work sessions to the elected officials.
• Community of Goshen was engaged through notice of the proposed action published in
The Register-Guard and opportunity to comment.
• Metropolitan Wastewater Management Commission has been included in meetings
and invited to provide feedback on the proposed action. County staff has coordinated with MWMC throughout this process.
Statewide Planning Goal 3 – Agricultural Lands
Statewide Planning Goal 3 ‐‐ “To preserve and maintain agricultural lands. Agricultural lands shall be
preserved and maintained for farm use, consistent with existing and future needs for agricultural
products, forest and open space and with the state's agricultural land use policy expressed in ORS
215.243 and
215.700.”
The proposed action changes a Metro Plan policy to allow extension of sewer services outside the City of
Eugene and City of Springfield’s UGBs. While engineering studies have been conducted, and a proposed
route is roughly outlined, it is not yet clear exactly where the route of the wastewater line will be located.
To the extent any portions of the wastewater pipeline will be located on land zoned for farm use, those
impacts will be addressed in anticipated code changes or development permit. The adoption of the
proposed Metro Plan policy amendment itself does not trigger a Goal 3 analysis.
Statewide Planning Goal 4 – Forest Lands
Attachment 1, Page 10 of 22
Exhibit B
Statewide Planning Goal 4 ‐‐ “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.”
The proposed action changes a Metro Plan policy to allow extension of sewer services outside the City of
Eugene and City of Springfield’s UGBs. While engineering studies have been conducted, and a proposed
route is roughly outlined, it is not yet clear exactly where the route of the wastewater line will be located.
To the extent any portions of the wastewater pipeline will be located on land zoned for forest uses, those
impacts will be addressed in anticipated code changes or development permits. The adoption of the
proposed Metro Plan policy amendment itself does not trigger a Goal 4 analysis.
Statewide Planning Goal 5 – Natural Resources, Scenic and Historic Areas,
and Open Spaces
Statewide Planning Goal 5 ‐‐ “To protect natural resources and conserve scenic and historic areas and
open spaces.”
Goal 5 requires the County to inventory the locations, quality, and quantity of certain natural resources.
Where no conflicting uses are identified, the inventoried resources shall be preserved. Where conflicting
uses are identified, the economic, social, environmental, and energy consequences of the conflicting uses
shall be determined and programs developed to achieve the goal.
Both cities and Lane County have adopted / acknowledged programs for protecting and conserving the
types of resources, areas and spaces referenced in Statewide Planning Goal 5. The administrative rule
that implements Statewide Planning Goal 5 requires application of Goal 5 in limited circumstances for
post-acknowledgment plan amendments (PAPA).
OAR 660‐023‐0250(3) ‐ Applicability
Local governments are not required to apply Goal 5 in consideration of a PAPA unless the
PAPA affects a Goal 5 resource. For purposes of this section, a PAPA would affect a Goal 5 resource only if:
(a) The PAPA creates or amends a resource list or a portion of an acknowledged plan or
land use regulation adopted in order to protect a significant Goal 5 resource or to address
specific requirements of Goal 5;
(b) The PAPA allows new uses that could be conflicting uses with a particular significant
Goal 5 resource site on an acknowledged resource list; or
(c) The PAPA amends an acknowledged UGB and factual information is submitted
demonstrating that a resource site, or the impact areas of such a site, is included in the amended UGB area.
The proposed Metro Plan amendment does not change existing Goal 5 lists or site protections, as
described in OAR 660‐023‐ 0250(3)(a) and (b).
Statewide Planning Goal 6 – Air, Water and Land Resources Quality
Attachment 1, Page 11 of 22
Exhibit B
Statewide Planning Goal 6 ‐‐ “To maintain and improve the quality of the air, water and land resources
of the state.”
“All waste and process discharges from future development, when combined with such discharges from
existing developments shall not threaten to violate, or violate applicable state or federal environmental
quality statutes, rules and standards. With respect to the air, water and land resources of the applicable air
sheds and river basins described or included in state environmental quality statutes, rules, standards and
implementation plans, such discharges shall not (1) exceed the carrying capacity of such resources,
considering long range needs; (2) degrade such resources; or (3) threaten the availability of such
resources.”
The State has not adopted specific requirements for complying with Statewide Planning Goal 6. The
County and cities are in compliance with environmental standards and statutes, including the federal
Clean Water Act and Clean Air Act. The actions taken are consistent with the jurisdictions’ future
compliance with those laws.
Further, this amendment will develop solutions to wastewater infrastructure for the community of Goshen
and the Short Mountain Landfill. Connecting the landfill to a piped wastewater system is an important
goal for the Lane County Public Works Department. The wastewater from the landfill is currently
transported by tanker truck to the regional wastewater facility. A piped connection to the regional
wastewater facility would eliminate the high costs, environmental impacts, and operational challenges of
transporting over 25-million gallons of leachate (liquid that percolates through the waste mass at the
landfill) annually.
Statewide Planning Goal 7 – Areas Subject to Natural Hazards
Statewide Planning Goal 7 ‐‐ “To protect people and property from natural hazards.”
The State has not adopted specific requirements for complying with Statewide Planning Goal 7.
Natural hazards for the purposes of Goal 7 are floods (coastal and riverine), landslides, earthquakes and
related hazards, tsunamis, coastal erosion, and wildfires.
Portions of the pipeline leading from Goshen to the Metropolitan Wastewater Management Commission
(MWMC) connection location may pass through the 100-year flood zone and Willamette Floodway. Lane
Code (LC) 16.244 establishes the requirements for work performed in a floodplain, in addition to other
applicable local, State, and Federal regulations. For development activities within a mapped flood hazard
area, a Floodplain Development Permit, Fill/Removal Permit, or a Floodway Development Permit would
be required before construction commences. A Floodplain Development Permit or a Fill/Removal Permit
apply to all development within the mapped A and AE flood zones; a Floodway Development Permit is
required for all development within the mapped floodway AE zone. These permit reviews can be
completed concurrently with the Willamette Greenway Development permit process (see findings
addressing Statewide Planning Goal 15 below).
In Lane County, outside of urban growth boundaries, a Floodplain Development Permit is a Type I
review process, and the Floodway Development Permit is a Type II process. A primary requirement of a
Floodway Development Permit is that an engineer must certify the project will not reduce flood storage
capacity nor create a rise in the base flood elevation. Because this project involves buried pipelines, a
reduction in flood storage capacity is not expected.
Attachment 1, Page 12 of 22
Exhibit B
Statewide Planning Goal 8 – Recreation Needs
Statewide Planning Goal 8 ‐‐ “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.”
Goal 8 pertains to the recreation needs of citizens and visitors to the state. The actions taken by this
amendment do not impact the city or county’s recreation needs. Therefore Goal 8 does not apply.
Statewide Planning Goal 9 – Economic Development
Statewide Planning Goal 9 ‐‐ “To provide adequate opportunities throughout the state for a variety of
economic activities vital to the health, welfare, and prosperity of Oregon’s citizens.”
As discussed in previous findings, the proposed Metro Plan amendment is intended to pave the way to
provide adequate infrastructure to an area that is already planned and zoned to accommodate an urban
level of industrial development. That development will provide adequate opportunities for a variety of
economic activities in the Goshen community as well as in the larger Lane County region and beyond,
which is vital to the health, welfare, and prosperity of Oregon’s citizens.
As the County and cities continue to grow and flourish it will be necessary for the landfill to
accommodate this growth. Connecting the landfill to a piped wastewater system will be an important part
of that economic development.
The Metro Plan amendment is consistent with Goal 9.
Statewide Planning Goal 10– Housing
Statewide Planning Goal 10 ‐‐ “To provide for the housing needs of citizens of the state.”
Goal 10 generally imposes planning obligations on local governments only for urban and urbanizable
lands within urban growth boundaries. The actions taken by this ordinance do not impact the either
Eugene’s or Springfield’s supply/demand for residential land. Therefore, OAR 660, Division 8 and Goal
10 do not apply.
Statewide Planning Goal 11 – Public Facilities and Services
Statewide Planning Goal 11 ‐‐ “To plan and develop a timely, orderly and efficient arrangement of public
facilities and services to serve as a framework for urban and rural development.”
Statewide Planning Goal 11 is implemented by Oregon Administrative Rule Chapter 660, Division 11.
Under Goal 11 and its implementing regulations, extension of sewer services outside the urban growth
boundary (UGB) is heavily discouraged. Urban level sewer services are meant to be limited to serving
areas inside the UGBs as a way of limiting urban levels of development in rural areas. OAR 660-011-
0060, however, provides some allowances and exceptions to that general rule, articulating when and
where sewer services may be placed on or extended to serve rural lands. For instance, OAR 660-011-
0060(3)(a)(E) allows components of sewer systems that serve land outside a UGB where necessary to
transport leachate from a landfill on rural land to a sewer system inside a UGB. Further, OAR 660-011-
0060(3)(a)(B) allows placing components of a sewer system on rural lands where necessary to serve lands
inside an unincorporated community.
Attachment 1, Page 13 of 22
Exhibit B
Goal 11 directs local governments to “not rely upon the presence, establishment, or extension of a water
or sewer system to allow residential development of land outside urban growth boundaries or
unincorporated community boundaries at a density higher than authorized without service from such a
system.”
The action taken by this amendment would extend the wastewater system to the rural unincorporated
community of Goshen and provide for transport of leachate from the Short Mountain Landfill to a sewer
system inside a UGB. This is compatible with Goal 11. Wastewater services would not be provided along
the route. As specified by the proposed G.26 policy amendment, the extension of the wastewater system
will serve only the rural unincorporated community of Goshen and the landfill for the transport of
leachate.
The Short Mountain Landfill serves the communities inside the UGBs of Eugene and Springfield as it
accepts solid waste from the surrounding area. It is also the only permitted municipal landfill in Lane
County. A piped connection to the regional wastewater facility would eliminate the high costs,
environmental impacts, and operational challenges of transporting leachate from the landfill to the
Glenwood transfer station located within the Metropolitan Wastewater Management Commission
(MWMC) service area. Currently the leachate travels 5.5 miles from the storage lagoons at the landfill to
the discharge point.
The leachate is already handled by the regional wastewater system after being trucked in. By connecting
the landfill to the system through a piped connection, it provides a safe, cost effective, and efficient way
to transport the leachate. This benefits community members within the Metro Plan area inside the UGB,
who are being served by the Short Mountain Landfill.
The County has long been working toward the goal of increasing industrial development and creating
high-paying jobs in the Goshen community. In support of this goal, the Goshen Region Employment and
Transition (GREAT) Plan was adopted by the commissioners in June of 2013 to promote development in
Goshen under urban industrial zoning. At the time of the GREAT Plan’s adoption, extending wastewater
service to the area was not part of the adopted Ordinance, but the need for extending service was
anticipated. With this Metro Plan amendment the County could realize its goal of industrial development
in the area and promoting economic development throughout the region.
The County anticipated the need for the extension of wastewater services in its adoption of Ordinance No.
PA 1282 in 2013. The findings of the Ordinance stated:
“A Goal 11 exception is not necessary or contemplated with this proposal. The County currently
is not proposing to extend sewer to the Community of Goshen with this application. However, if
and/or when a sewer extension to the Community of Goshen is contemplated, the County finds
that the extension of the sewer would not require a Goal 11 exception as allowed in OAR 660-
011-0060(3), which permits extension of sewer from inside a UGB to serve lands inside a nearby
unincorporated community. This issue will be addressed at a later time when and if such
extension is further contemplated.”
See pages 36-37 of Findings and Reasons in Support of Goshen Plan Amendment, Goal 14 Exception,
and Zone Change, attached as Exhibit C to Ordinance No. PA 1282, and included as Exhibit E to this
staff report.
OAR 660‐011‐0060(3)
Attachment 1, Page 14 of 22
Exhibit B
Components of a sewer system that serve lands inside an urban growth boundary (UGB)
may be placed on lands outside the boundary provided that the conditions in subsections (a)
and (b) of this section are met, as follows:
(a) Such placement is necessary to:
(A) Serve lands inside the UGB more efficiently by traversing lands outside the
boundary;
(B) Serve lands inside a nearby UGB or unincorporated community;
(C) Serve lands subject to a Goal 14 exception approved pursuant to OAR 660-014-
0090;
(D) Connect to components of the sewer system lawfully located on rural lands, such
as outfall or treatment facilities; or
(E) Transport leachate from a landfill on rural land to a sewer system inside a UGB;
(b) The local government:
(A) Adopts land use regulations to ensure the sewer system shall not serve land
outside urban growth boundaries or unincorporated community boundaries, except
as authorized under section (4) of this rule; and
(B) Determines that the system satisfies ORS 215.296(1) or (2) to protect farm and
forest practices, except for systems located in the subsurface of public roads and
highways along the public right of way.”
The extension of the wastewater line that would be allowed by the proposed Metro Plan amendment
satisfies subsections (a)(B) and (a)(E) above. The adoption of the GREAT plan in 2013 approved a Goal
14 Exception for the Goshen area, which is a rural unincorporated community. The extension would
serve Goshen, pursuant to subsection (a)(B).. And the rule specifically allows for extension of
components of a sewer system outside the UGB for the transport of leachate from a landfill on rural land
to a sewer system inside the UGB, pursuant to subsection (a)(E). For the purpose of this Metro Plan
amendment, subsection (b) is arguably met at the time of adoption, given that extension of wastewater
service will only be allowed by the proposed language to Goshen and Short Mountain. Additionally, prior
to construction, the County intends to adopt land use regulations prohibiting cross connection in other
areas outside of the Metro Plan boundary.
Goal 11 is satisfied.
Statewide Planning Goal 12 – Transportation
Statewide Planning Goal 12 ‐‐ “To provide and encourage a safe, convenient and economic
transportation system.”
Goal 12 pertains to the transportation system.
OAR 660-012-0060 -- Plan and Land Use Regulation Amendments
(1) If an amendment to a functional plan, an acknowledged comprehensive plan, or a land
use regulation (including a zoning map) would significantly affect an existing or planned
Attachment 1, Page 15 of 22
Exhibit B
transportation facility, then the local government must put in place measures as provided in
section (2) of this rule, unless the amendment is allowed under section (3), (9) or (1 0) of this
rule.
The actions taken by this amendment do not impact the county’s transportation system and would not
significantly affect an existing or planned transportation facility. The main impact likely to result from
the amendment is a reduction is truck travel on I-5 from the transport of leachate. Therefore, Goal 12 is
satisfied.
Statewide Planning Goal 13 – Energy Conservation Statewide
Statewide Planning Goal 13 ‐‐ “To conserve energy.”
The State has not adopted specific rules for complying with Statewide Planning Goal 13. The proposed
Metro Plan amendment satisfies Goal 13 as it will eliminate the need to truck leachate from the landfill to
the MWMC treatment plant. Reducing those truck trips provides a net gain with regard to energy
conservation.
Statewide Planning Goal 14 – Urbanization
Statewide Planning Goal 14 ‐‐ “To provide for an orderly and efficient transition from rural to urban
land use, to accommodate urban population and urban employment inside urban growth boundaries, to
ensure efficient use of land, and to provide for livable communities.”
Goal 14 generally seeks to limit the level of development in rural areas to the levels of uses consistent
with rural lands. As discussed in previous findings, the County took a Goal 14 Exception in 2013 when it
adopted the GREAT plan for the Goshen area. The County determined at that time that there were
reasons justifying developing the otherwise rural area with urban levels of industrial uses, based on the
unique circumstances of site and the needs for industrial sites that the Goshen area could fulfill. Thus, it
has already been determined that an urban level of industrial development is appropriate in that area.
The Goshen community is ideally situated to accommodate the County’s goals. It already has existing
industrial and non-resource designations, which ensures an efficient use of already available land. Goshen
has direct access to major highways and rail, and proximity and access to utility infrastructure including
natural gas, electrical power, and water. It is close in proximity to the urban population centers of Eugene
and Springfield, which provides an educated and/or skilled workforce and provides jobs for livable
communities.
The extension of the wastewater system to the rural unincorporated community of Goshen will facilitate
the County’s goal of attracting industry and industrial development in the area. Goshen has been an
important area of action for the Lane County Board of Commissioners for more than 10 years. This
amendment will remove the remaining barrier to economic development there.
Further, the residents of Eugene and Springfield would benefit from a piped connection from the regional
wastewater facility to the landfill, which serves those same communities. This connection would
eliminate the high costs, environmental impacts, and operational challenges of transporting leachate from
the landfill to the wastewater facility transfer station as is the current practice.
The Metro Plan amendment complies with Goal 14.
Statewide Planning Goal 15 – Willamette Greenway
Attachment 1, Page 16 of 22
Exhibit B
Statewide Planning Goal 15 ‐‐ “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.”
The proposed action changes a Metro Plan policy to allow extension of sewer services outside the City of
Eugene and City of Springfield’s UGBs. While engineering studies have been conducted, and a proposed
route is roughly outlined, it is not yet clear exactly where the route of the wastewater line will be located.
To the extent any portions of the wastewater pipeline will be located on land within the Willamette River
Greenway, those impacts will be addressed in anticipated code changes or development permits. The
adoption of the proposed Metro Plan policy amendment is consistent with Goal 15.
Statewide Planning Goals 16 to 19 – Coastal Goals
These four goals are not applicable as they address resources that are not present in this portion of Lane
County.
Attachment 1, Page 17 of 22
Exhibit C
Vicinity Map of Goshen & Short Mountain Landfill
Attachment 1, Page 18 of 22
Bureau of Land Management, State of Oregon, State of Oregon DOT,
State of Oregon GEO, Esri Canada, Esri, HERE, Garmin, INCREMENT P,
USGS, EPA, USDA
Lane County, Oregon
The information on this map was derived from digital databases on the LaneCounty regional geographic information system. Care was taken in the creationof this map, but is provided “as is”. Lane County cannot accept any responsibilityfor errors, omissions or positional accuracy in the digital data or the underlyingrecords. Current plan designation, zoning, etc., for specific parcels should beconfirmed with the appropriate agency. There are no warranties, expressedor implied, accompanying this product. However, notification of any errors will be appreciated.0 740 1,480370
Feet
±Goshen Rural
Unincorporated Community
Map of Goshen Rural Unincoporated Community Exhibit D
Attachment 1, Page 19 of 22
Map of Goshen Rural Unincoporated Community Exhibit D
Attachment 1, Page 20 of 22
community create an inconvenience or adverse impacts so significant that it
warrants the location in the community?" Still other uses do not require a
location within the community and should instead be located inside an urban
growth boundary or on other rural industrial land.
Providing land for related industrial businesses will help attract companies that can complement the rail dependent uses. Uses of this nature may not be
feasible until the larger rail dependent uses are successfully operating. It would
benefit the larger region, community and the uses by locating in close proximity
to the rail dependent uses by reducing trips and shipping cost, as well as other
efficiencies.
Proximity to competitors, a skilled workforce, specialized suppliers, and a shared
base of sophisticated knowledge about their industry are reasons that are critical
for allowing the supportive rail related uses.
If the above reasons for either or both categories of use are not satisfactory, the
County finds that the proposed urban levels of industrial development on
undeveloped rural land is necessary to support an economic activity that is
greatly dependent on the "natural resource" of the existing industrial land for the reasons discussed above including the strategic logistical characteristics.
However implausible some may feel the inclusion of the existing industrial land
being considered as a natural resource is, or strained the credibility of the rule
becomes, the County finds that the existing industrial land fits the definition of natural resource as contemplated in this rule provision and therefore qualifies for
this "reason" under this standard.
The County finds that the term "natural resource" is defined in the back of the
"Oregon's Statewide Planning Goals & Guidelines" booklet as found on the DLCD website. The provided definition states: "NATURAL RESOURCES. Air,
land and water and the elements thereof which are valued for their existing and
potential usefulness to man. ,,33 Based on this definition, the County finds that the
existing industrial designated property in Goshen fits the definition of a natural
resource of land. This land is useful to man (within the Community of Goshen, the larger Region-Eugene/Springfield Metro area, Lane County as a whole, and the broader State of Oregon) and further has an increased potential usefulness
by allowing an increased level of industrial development to create jobs. The
industrial land is valued for its unique characteristics giving it an existing and
potential usefulness to man in creating increased economic activity including
providing new jobs to citizens living in the area.
A Goal 11 exception is not necessary or contemplated with this proposal. The
County currently is not proposing to extend sewer to the Community of Goshen
with this application. However, if and/or when a sewer extension to the
33 The term "natural resource" is also defined in OAR 635-410-0010(6). Here it states: "Natural resources" means
land, fish, wildlife, biota, air or water.
FINDINGS AND REASONS IN SUPPORT OF GOSHEN PLAN AMENDMENT, GOAL 14 EXCEPTION, AND ZONE CHANGE
36
Exhibit EOrdinance No. PA 1282, Pages 36-37
Attachment 1, Page 21 of 22
Community of Goshen is contemplated, the County finds that the extension of the
sewer would not require a Goal11 exception as allowed in OAR 660-011-
0060(3), which permits extension of sewer from inside a UGB to serve lands
inside a nearby unincorporated community. This issue will be addressed at a
later time when and if such extension is further contemplated.
The County finds that a new Goal 3 or 4 reasons exception is also not required
due to the original developed and committed exception to Goals 3 or 4 which was
applied to the land on the basis of its preexisting industrial development.
(3) To approve an exception under section (2) of this rule, a county must also
show:
(a) That Goal 2, Part II (c)(1) and (c)(2) are met by showing that the proposed
urban development cannot be reasonably accommodated in or through
expansion of existing urban growth boundaries or by intensification of
development in existing rural communities;
FINDINGS: The proposed urban levels of industrial development is being sought
to allow intensification of development on existing industrially zoned and
designated land within a rural community in conformance with this criterion. The
proposed urban levels of industrial development cannot be reasonably
accommodated in an existing UGB in the region (Eugene or Springfield) as
evidenced by the results of the ECLA and CIBL reports. These reports find that
neither of the City jurisdictions have adequate industrial land capacity within their
existing UGB's to meet their or the regions employment needs. Specifically
identified is a need for large lot industrial sites. Additionally, the County finds that
there is a need for large lot industrial sites that are strategically located in close
proximity to the Interstate freeway system as well as near to and/or served by a
rail line. Together with the need for large sites as discussed in the findings
above, siting supportive urban levels of industrial development in close proximity
to the large rail served sites is a significant competitive advantage that cannot be
provided on sites inside a UGB.
Due to the significant comparative advantages of the Goshen area, specifically
the superior access to highway and rail, the proposed urban level of industrial
development cannot be reasonably accommodated in or through expansion of an
existing urban growth boundary.
The County finds that it is not reasonable to accommodate the proposed urban
industrial development through an expansion of an existing UGB in the region.
There are no sites that have been identified by either city jurisdiction that could
provide for superior highway and rail access. These findings are further
supported when considering the significant comparative advantages of the
Goshen community as discussed above.
FINDINGS AND REASONS IN SUPPORT OF GOSHEN PLAN AMENDMENT, GOAL 14 EXCEPTION, AND ZONE CHANGE
37 Attachment 1, Page 22 of 22
Exhibit A
NOTE: Matter in boldface type is proposed to be added; matter in [italic and bracketed] is existing language to be
omitted.
Proposed Metro Plan Amendments
Metro Plan Chapter II-C (Growth Management Goals, Findings, and Policies), Policy 21: Cities shall not extend water or wastewater service to lands that are outside city limits and within a UGB to serve a residence or business without first obtaining a valid annexation petition[,] or a consent to annex agreement, or [when] unless a
health hazard annexation is required. Metro Plan Chapter III-G (Public Facilities and Services Element), Policy G.26: Wastewater and water service shall not be provided outside the UGB except to the
following areas, and the cities may require consent to annex agreements as a
prerequisite to providing these services in any instance:
a. The area of the Eugene Airport designated Government and Education on the
Metro Plan Diagram, the Seasonal Industrial Waste Facility, the Regional
Wastewater Biosolids Management Facility, and agricultural sites used for land
application of biosolids and cannery byproducts. These sites serve the entire
metropolitan area.
b. An existing development outside the UGB when it has been determined that it
poses an immediate threat of public health or safety of the citizens within [the] a
UGB that can only be remedied by extension of the service.
c. Lane County’s Short Mountain Landfill for the transport of leachate only.
d. The rural unincorporated community of Goshen for wastewater only.
In addition, under prior obligations, water service shall be provided to land within the
dissolved water districts of Hillcrest, College Crest, Bethel, and Oakway.
Metro Plan Chapter III-G (Public Facilities and Services Element), Policy G.28:
Except as otherwise allowed under Policy G.26, [C]consistent with local regulations, locate new urban water, wastewater, and stormwater facilities on farm land and urban water and wastewater facilities on forest land outside the UGB only when the facilities exclusively serve land inside the UGB and there is no reasonable alternative.
Attachment 1, Page 1 of 1
Exhibit B
Findings for Metro Plan Amendment to Extend Wastewater Services to the
Rural Unincorporated Community of Goshen and Lane County’s Short Mountain Landfill The findings, below, present local government criteria first, then State criteria. The State criteria are
presented in order of the Statewide Planning Goals. State statutes and administrative rules are addressed
under the Statewide Planning Goal to which they relate.
INTRODUCTION In 2013, the Lane County Board of Commissioners adopted a countywide strategic plan with a key goal
of increasing industrial development and high-paying jobs within the unincorporated community of
Goshen. In support of this goal, the Goshen Region Employment and Transition (GREAT) Plan was
adopted by the County in June of 2013 to promote development for employment uses in Goshen. The
County’s goal was to foster industrial development in the Goshen community, which would bring with it
high-paying jobs. This in turn would promote economic development throughout the region.
Goshen has significant advantages for industrial development including: existing industrial/non-resource
designations; large parcels; proximity of supporting smaller parcels to the larger parcels; close proximity
and direct access to the State Highway system, including I-5, Highway 58, and Highway 99; adjacency
and access to rail; proximity to the urban population centers of Eugene and Springfield for providing an
educated and/or skilled workforce; access to natural resources; proximity and access to utility
infrastructure including natural gas, electrical power, and water; limited natural resource conflicts, and
relatively level topography.
This area is a regional asset with its advantages for industrial growth and economic development, which
would benefit the entire county economy by creating an environment to stimulate job growth.
Additionally, there would be no loss to productive resource lands due to the land already having a non-
resource designation.
Internal Consistency Findings for Metro Plan Amendment to Extend Wastewater Services to Goshen and the Short Mountain Landfill
Lane Code 12.300.030 provides: The following criteria will be applied by the Board of Commissioners and other applicable governing body or bodies in approving or denying a Metro Plan amendment application: A. The proposed amendment is consistent with the relevant Statewide Planning Goals; and B. The proposed amendment does not make the Metro Plan internally inconsistent.
The following are findings addressing LC 12.300.030.B. Chapter II-C Growth Management Goals, Findings, and Policies
Attachment 1, Page 1 of 11
Exhibit B
Policy 4: Lane County shall discourage urban development in urbanizable and rural areas and encourage compact development of outlying communities. Finding 1: The County took an Exception to Statewide Planning Goal 14 in 2013 when it adopted the
GREAT plan for the Goshen area. The County determined at that time that there were reasons justifying
developing the otherwise rural area with urban levels of industrial uses, based on the unique
circumstances of the site and the needs for industrial sites that the Goshen area could fulfill. Thus, it has
already been determined that an urban level of industrial development is appropriate in that area.
Further, the extension of the wastewater pipeline to the Short Mountain Landfill is proposed to convey
leachate generated from the municipal landfill to the proposed wastewater collection system in
Eugene/Springfield. The residents of Eugene and Springfield would benefit from a piped connection
from the regional wastewater facility to the landfill, which serves those same communities. This
connection would eliminate the high costs, environmental impacts, and operational challenges of
transporting leachate from the landfill to the wastewater facility transfer station, as is the current practice.
The intent of the proposed Metro Plan amendment is to develop safe, efficient solutions to wastewater
infrastructure for the existing Short Mountain Landfill and for urban levels of industrial development that
is already planned for the Goshen area. The proposal is consistent with Policy 4.
Chapter III-B Economic Element
Policy B.27: Eugene, Springfield, and Lane County shall improve monitoring of economic development and trends and shall cooperate in studying and protecting other potential industrial lands outside the urban boundary. Finding 2: On October 12, 2021, the Lane County Board of Commissioners directed staff to coordinate
with the Metropolitan Wastewater Management Commission (MWMC), the City of Eugene, and the City
of Springfield to pursue amendments to the Metro Plan to facilitate extending wastewater services to the
rural unincorporated community of Goshen as well as a pipeline extension connection to service Short
Mountain Landfill for conveyance of leachate. Although the economic element no longer applies to
Eugene or Springfield, both cities and the County must jointly adopt any amendments to the Metro Plan.
The industrial development in the unincorporated community of Goshen has been a topic of significant
conversation and action by the Board of Commissioners for more than 10 years. In 2013, the Board
adopted the GREAT Plan, which designated lands within Goshen for urban levels of industrial
development. The major remaining barrier to development of that area is the lack of adequate wastewater
infrastructure. The adoption of the proposed Metro Plan amendment would enable extension of
wastewater services by MWMC, which in turn, would enable the industrial development that has long
been planned for this area.
Likewise, the ability of the Short Mountain Landfill to connect to a piped wastewater system remains a
strong desire of the Lane County Public Works Department. This wastewater is already truck delivered to
the regional wastewater facility at the Glenwood Transfer Station. A piped connection to the regional
wastewater facility would eliminate the high costs, environmental impacts, and operational challenges of
transporting over 25-million gallons of leachate annually by tanker trucks.
Attachment 1, Page 2 of 11
Exhibit B
Chapter IV Metro Plan Review, Amendments, and Refinements
Policy 6.b.iii: Type III Text Amendments include: Amendments to a regional transportation system plan, or a regional public facilities plan, when the participation of all three governing bodies is required by the amendment provisions of those plans. Policy 7.c: A Type III amendment may be initiated by any one of the three governing bodies at any time. Policy 8.a: The initiating governing body of any Type I, II, or III Metro Plan amendment shall notify all governing bodies of the intended amendment and the Type of amendment proposed. If any governing body disagrees with the Type of the proposed amendment that governing body may refer the matter to the processes provided in 8(d) or (e) as appropriate. Policy 8.b: When more than one governing body participates in the decision, the Planning Commissions of the bodies shall conduct a joint public hearing and forward that record and their recommendations to their respective elected officials. The elected officials shall also
conduct a joint public hearing prior to making a final decision. Finding 3: The proposal is a request to amend Chapter II.C, Policy 21; and Chapter III.G, Policy G.26
and Policy G.28 of the Metro Plan via this Type III Metro Plan Amendment. The amendment was
initiated by Lane County, and Lane County has notified the other jurisdictions. The jurisdictions agree
that the proposal is a Type III amendment. The procedures are consistent with Chapter IV of the Metro
Plan.
Statewide Planning Goal Findings for Metro Plan Amendment to Extend Wastewater Services to Goshen and the Short Mountain Landfill
Statewide Planning Goal 1 – Citizen Involvement
Statewide Planning Goal 1 ‐‐ “To develop a citizen involvement program that insures the opportunity for
citizens to be involved in all phases of the planning process.”
Goal 1 is a process goal. The amendment complies with Goal 1 because it will be processed as a
legislative action through the jurisdictions’ acknowledged public procedures for Metro Plan amendments.
This process includes joint public hearings before the City of Eugene, the City of Springfield, and Lane
County’s planning commissions, and joint hearings before the governing bodies of all three jurisdictions.
The joint planning commission hearing is scheduled to be held April 4, 2023. Notices will be sent to
interested parties and the public hearing notice was also published in The Register-Guard newspaper on
March 15, 2023.
The joint hearings before the governing bodies of Lane County, the City of Eugene, and the City of
Springfield is scheduled to be held at a future date yet to be determined.
Statewide Planning Goal 2 – Land Use Planning
Attachment 1, Page 3 of 11
Exhibit B
Statewide Planning Goal 2 ‐‐ “To establish a land use planning process and policy framework as a basis
for all decisions and actions related to use of land and to assure an adequate factual base for such
decisions and actions.”
The land use codes of both cities and Lane County specify the procedures and criteria that were used in
considering this amendment. The findings documents show the record includes an adequate factual base
for the amendment. The record of the original Lane County Rural Comprehensive Plan amendment and
Reasons Exception that was adopted to enable the urban levels of industrial uses in Goshen shows that the
County studied the need for certain employment lands that have access to rail transport. The Goshen
property included in the GREAT plan was determined, through thorough study, to meet the demands for
that type of development. The proposed amendment will enable the development that has been stymied
by lack of infrastructure that this proposal will provide.
Consistent with the Goal 2 coordination requirement, there was a significant exchange, or invitation for
such an exchange, among the cities, Lane County and affected governmental units. The information
obtained in these exchanges was used to balance the needs of the citizens. The County and cities
coordinated and jointly adopted the Metro Plan amendment. For the ordinance adopting this Metro Plan
amendment, intergovernmental coordination included the following:
• The Department of Land Conservation and Development (DLCD) was engaged
through notice of the proposed action and regular contact with the area’s regional
representative.
• City of Eugene, City of Springfield, and Lane County, which will jointly consider
adoption of the Metro Plan amendment, were engaged during the process with staff from
the three entities participating in meetings and providing feedback on the proposed
amendment language and documents. County staff collaborated with City staff to
provide informational updates and work sessions to the elected officials.
• Community of Goshen was engaged through notice of the proposed action published in
The Register-Guard and opportunity to comment.
• Metropolitan Wastewater Management Commission has been included in meetings
and invited to provide feedback on the proposed action. County staff has coordinated with MWMC throughout this process.
Statewide Planning Goal 3 – Agricultural Lands
Statewide Planning Goal 3 ‐‐ “To preserve and maintain agricultural lands. Agricultural lands shall be
preserved and maintained for farm use, consistent with existing and future needs for agricultural
products, forest and open space and with the state's agricultural land use policy expressed in ORS
215.243 and
215.700.”
The proposed action changes a Metro Plan policy to allow extension of sewer services outside the City of
Eugene and City of Springfield’s UGBs. While engineering studies have been conducted, and a proposed
route is roughly outlined, it is not yet clear exactly where the route of the wastewater line will be located.
To the extent any portions of the wastewater pipeline will be located on land zoned for farm use, those
impacts will be addressed in anticipated code changes or development permit. The adoption of the
proposed Metro Plan policy amendment itself does not trigger a Goal 3 analysis.
Statewide Planning Goal 4 – Forest Lands
Attachment 1, Page 4 of 11
Exhibit B
Statewide Planning Goal 4 ‐‐ “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.”
The proposed action changes a Metro Plan policy to allow extension of sewer services outside the City of
Eugene and City of Springfield’s UGBs. While engineering studies have been conducted, and a proposed
route is roughly outlined, it is not yet clear exactly where the route of the wastewater line will be located.
To the extent any portions of the wastewater pipeline will be located on land zoned for forest uses, those
impacts will be addressed in anticipated code changes or development permits. The adoption of the
proposed Metro Plan policy amendment itself does not trigger a Goal 4 analysis.
Statewide Planning Goal 5 – Natural Resources, Scenic and Historic Areas,
and Open Spaces
Statewide Planning Goal 5 ‐‐ “To protect natural resources and conserve scenic and historic areas and
open spaces.”
Goal 5 requires the County to inventory the locations, quality, and quantity of certain natural resources.
Where no conflicting uses are identified, the inventoried resources shall be preserved. Where conflicting
uses are identified, the economic, social, environmental, and energy consequences of the conflicting uses
shall be determined and programs developed to achieve the goal.
Both cities and Lane County have adopted / acknowledged programs for protecting and conserving the
types of resources, areas and spaces referenced in Statewide Planning Goal 5. The administrative rule
that implements Statewide Planning Goal 5 requires application of Goal 5 in limited circumstances for
post-acknowledgment plan amendments (PAPA).
OAR 660‐023‐0250(3) ‐ Applicability
Local governments are not required to apply Goal 5 in consideration of a PAPA unless the
PAPA affects a Goal 5 resource. For purposes of this section, a PAPA would affect a Goal 5 resource only if:
(a) The PAPA creates or amends a resource list or a portion of an acknowledged plan or
land use regulation adopted in order to protect a significant Goal 5 resource or to address
specific requirements of Goal 5;
(b) The PAPA allows new uses that could be conflicting uses with a particular significant
Goal 5 resource site on an acknowledged resource list; or
(c) The PAPA amends an acknowledged UGB and factual information is submitted
demonstrating that a resource site, or the impact areas of such a site, is included in the amended UGB area.
The proposed Metro Plan amendment does not change existing Goal 5 lists or site protections, as
described in OAR 660‐023‐ 0250(3)(a) and (b).
Statewide Planning Goal 6 – Air, Water and Land Resources Quality
Attachment 1, Page 5 of 11
Exhibit B
Statewide Planning Goal 6 ‐‐ “To maintain and improve the quality of the air, water and land resources
of the state.”
“All waste and process discharges from future development, when combined with such discharges from
existing developments shall not threaten to violate, or violate applicable state or federal environmental
quality statutes, rules and standards. With respect to the air, water and land resources of the applicable air
sheds and river basins described or included in state environmental quality statutes, rules, standards and
implementation plans, such discharges shall not (1) exceed the carrying capacity of such resources,
considering long range needs; (2) degrade such resources; or (3) threaten the availability of such
resources.”
The State has not adopted specific requirements for complying with Statewide Planning Goal 6. The
County and cities are in compliance with environmental standards and statutes, including the federal
Clean Water Act and Clean Air Act. The actions taken are consistent with the jurisdictions’ future
compliance with those laws.
Further, this amendment will develop solutions to wastewater infrastructure for the community of Goshen
and the Short Mountain Landfill. Connecting the landfill to a piped wastewater system is an important
goal for the Lane County Public Works Department. The wastewater from the landfill is currently
transported by tanker truck to the regional wastewater facility. A piped connection to the regional
wastewater facility would eliminate the high costs, environmental impacts, and operational challenges of
transporting over 25-million gallons of leachate (liquid that percolates through the waste mass at the
landfill) annually.
Statewide Planning Goal 7 – Areas Subject to Natural Hazards
Statewide Planning Goal 7 ‐‐ “To protect people and property from natural hazards.”
The State has not adopted specific requirements for complying with Statewide Planning Goal 7.
Natural hazards for the purposes of Goal 7 are floods (coastal and riverine), landslides, earthquakes and
related hazards, tsunamis, coastal erosion, and wildfires.
Portions of the pipeline leading from Goshen to the Metropolitan Wastewater Management Commission
(MWMC) connection location may pass through the 100-year flood zone and Willamette Floodway. Lane
Code (LC) 16.244 establishes the requirements for work performed in a floodplain, in addition to other
applicable local, State, and Federal regulations. For development activities within a mapped flood hazard
area, a Floodplain Development Permit, Fill/Removal Permit, or a Floodway Development Permit would
be required before construction commences. A Floodplain Development Permit or a Fill/Removal Permit
apply to all development within the mapped A and AE flood zones; a Floodway Development Permit is
required for all development within the mapped floodway AE zone. These permit reviews can be
completed concurrently with the Willamette Greenway Development permit process (see findings
addressing Statewide Planning Goal 15 below).
In Lane County, outside of urban growth boundaries, a Floodplain Development Permit is a Type I
review process, and the Floodway Development Permit is a Type II process. A primary requirement of a
Floodway Development Permit is that an engineer must certify the project will not reduce flood storage
capacity nor create a rise in the base flood elevation. Because this project involves buried pipelines, a
reduction in flood storage capacity is not expected.
Attachment 1, Page 6 of 11
Exhibit B
Statewide Planning Goal 8 – Recreation Needs
Statewide Planning Goal 8 ‐‐ “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.”
Goal 8 pertains to the recreation needs of citizens and visitors to the state. The actions taken by this
amendment do not impact the city or county’s recreation needs. Therefore Goal 8 does not apply.
Statewide Planning Goal 9 – Economic Development
Statewide Planning Goal 9 ‐‐ “To provide adequate opportunities throughout the state for a variety of
economic activities vital to the health, welfare, and prosperity of Oregon’s citizens.”
As discussed in previous findings, the proposed Metro Plan amendment is intended to pave the way to
provide adequate infrastructure to an area that is already planned and zoned to accommodate an urban
level of industrial development. That development will provide adequate opportunities for a variety of
economic activities in the Goshen community as well as in the larger Lane County region and beyond,
which is vital to the health, welfare, and prosperity of Oregon’s citizens.
As the County and cities continue to grow and flourish it will be necessary for the landfill to
accommodate this growth. Connecting the landfill to a piped wastewater system will be an important part
of that economic development.
The Metro Plan amendment is consistent with Goal 9.
Statewide Planning Goal 10– Housing
Statewide Planning Goal 10 ‐‐ “To provide for the housing needs of citizens of the state.”
Goal 10 generally imposes planning obligations on local governments only for urban and urbanizable
lands within urban growth boundaries. The actions taken by this ordinance do not impact the either
Eugene’s or Springfield’s supply/demand for residential land. Therefore, OAR 660, Division 8 and Goal
10 do not apply.
Statewide Planning Goal 11 – Public Facilities and Services
Statewide Planning Goal 11 ‐‐ “To plan and develop a timely, orderly and efficient arrangement of public
facilities and services to serve as a framework for urban and rural development.”
Statewide Planning Goal 11 is implemented by Oregon Administrative Rule Chapter 660, Division 11.
Under Goal 11 and its implementing regulations, extension of sewer services outside the urban growth
boundary (UGB) is heavily discouraged. Urban level sewer services are meant to be limited to serving
areas inside the UGBs as a way of limiting urban levels of development in rural areas. OAR 660-011-
0060, however, provides some allowances and exceptions to that general rule, articulating when and
where sewer services may be placed on or extended to serve rural lands. For instance, OAR 660-011-
0060(3)(a)(E) allows components of sewer systems that serve land outside a UGB where necessary to
transport leachate from a landfill on rural land to a sewer system inside a UGB. Further, OAR 660-011-
0060(3)(a)(B) allows placing components of a sewer system on rural lands where necessary to serve lands
inside an unincorporated community.
Attachment 1, Page 7 of 11
Exhibit B
Goal 11 directs local governments to “not rely upon the presence, establishment, or extension of a water
or sewer system to allow residential development of land outside urban growth boundaries or
unincorporated community boundaries at a density higher than authorized without service from such a
system.”
The action taken by this amendment would extend the wastewater system to the rural unincorporated
community of Goshen and provide for transport of leachate from the Short Mountain Landfill to a sewer
system inside a UGB. This is compatible with Goal 11. Wastewater services would not be provided along
the route. As specified by the proposed G.26 policy amendment, the extension of the wastewater system
will serve only the rural unincorporated community of Goshen and the landfill for the transport of
leachate.
The Short Mountain Landfill serves the communities inside the UGBs of Eugene and Springfield as it
accepts solid waste from the surrounding area. It is also the only permitted municipal landfill in Lane
County. A piped connection to the regional wastewater facility would eliminate the high costs,
environmental impacts, and operational challenges of transporting leachate from the landfill to the
Glenwood transfer station located within the Metropolitan Wastewater Management Commission
(MWMC) service area. Currently the leachate travels 5.5 miles from the storage lagoons at the landfill to
the discharge point.
The leachate is already handled by the regional wastewater system after being trucked in. By connecting
the landfill to the system through a piped connection, it provides a safe, cost effective, and efficient way
to transport the leachate. This benefits community members within the Metro Plan area inside the UGB,
who are being served by the Short Mountain Landfill.
The County has long been working toward the goal of increasing industrial development and creating
high-paying jobs in the Goshen community. In support of this goal, the Goshen Region Employment and
Transition (GREAT) Plan was adopted by the commissioners in June of 2013 to promote development in
Goshen under urban industrial zoning. At the time of the GREAT Plan’s adoption, extending wastewater
service to the area was not part of the adopted Ordinance, but the need for extending service was
anticipated. With this Metro Plan amendment the County could realize its goal of industrial development
in the area and promoting economic development throughout the region.
The County anticipated the need for the extension of wastewater services in its adoption of Ordinance No.
PA 1282 in 2013. The findings of the Ordinance stated:
“A Goal 11 exception is not necessary or contemplated with this proposal. The County currently
is not proposing to extend sewer to the Community of Goshen with this application. However, if
and/or when a sewer extension to the Community of Goshen is contemplated, the County finds
that the extension of the sewer would not require a Goal 11 exception as allowed in OAR 660-
011-0060(3), which permits extension of sewer from inside a UGB to serve lands inside a nearby
unincorporated community. This issue will be addressed at a later time when and if such
extension is further contemplated.”
See pages 36-37 of Findings and Reasons in Support of Goshen Plan Amendment, Goal 14 Exception,
and Zone Change, attached as Exhibit C to Ordinance No. PA 1282, and included as Exhibit E to this
staff report.
OAR 660‐011‐0060(3)
Attachment 1, Page 8 of 11
Exhibit B
Components of a sewer system that serve lands inside an urban growth boundary (UGB)
may be placed on lands outside the boundary provided that the conditions in subsections (a)
and (b) of this section are met, as follows:
(a) Such placement is necessary to:
(A) Serve lands inside the UGB more efficiently by traversing lands outside the
boundary;
(B) Serve lands inside a nearby UGB or unincorporated community;
(C) Serve lands subject to a Goal 14 exception approved pursuant to OAR 660-014-
0090;
(D) Connect to components of the sewer system lawfully located on rural lands, such
as outfall or treatment facilities; or
(E) Transport leachate from a landfill on rural land to a sewer system inside a UGB;
(b) The local government:
(A) Adopts land use regulations to ensure the sewer system shall not serve land
outside urban growth boundaries or unincorporated community boundaries, except
as authorized under section (4) of this rule; and
(B) Determines that the system satisfies ORS 215.296(1) or (2) to protect farm and
forest practices, except for systems located in the subsurface of public roads and
highways along the public right of way.”
The extension of the wastewater line that would be allowed by the proposed Metro Plan amendment
satisfies subsections (a)(B) and (a)(E) above. The adoption of the GREAT plan in 2013 approved a Goal
14 Exception for the Goshen area, which is a rural unincorporated community. The extension would
serve Goshen, pursuant to subsection (a)(B).. And the rule specifically allows for extension of
components of a sewer system outside the UGB for the transport of leachate from a landfill on rural land
to a sewer system inside the UGB, pursuant to subsection (a)(E). For the purpose of this Metro Plan
amendment, subsection (b) is arguably met at the time of adoption, given that extension of wastewater
service will only be allowed by the proposed language to Goshen and Short Mountain. Additionally, prior
to construction, the County intends to adopt land use regulations prohibiting cross connection in other
areas outside of the Metro Plan boundary.
Goal 11 is satisfied.
Statewide Planning Goal 12 – Transportation
Statewide Planning Goal 12 ‐‐ “To provide and encourage a safe, convenient and economic
transportation system.”
Goal 12 pertains to the transportation system.
OAR 660-012-0060 -- Plan and Land Use Regulation Amendments
(1) If an amendment to a functional plan, an acknowledged comprehensive plan, or a land
use regulation (including a zoning map) would significantly affect an existing or planned
Attachment 1, Page 9 of 11
Exhibit B
transportation facility, then the local government must put in place measures as provided in
section (2) of this rule, unless the amendment is allowed under section (3), (9) or (1 0) of this
rule.
The actions taken by this amendment do not impact the county’s transportation system and would not
significantly affect an existing or planned transportation facility. The main impact likely to result from
the amendment is a reduction is truck travel on I-5 from the transport of leachate. Therefore, Goal 12 is
satisfied.
Statewide Planning Goal 13 – Energy Conservation Statewide
Statewide Planning Goal 13 ‐‐ “To conserve energy.”
The State has not adopted specific rules for complying with Statewide Planning Goal 13. The proposed
Metro Plan amendment satisfies Goal 13 as it will eliminate the need to truck leachate from the landfill to
the MWMC treatment plant. Reducing those truck trips provides a net gain with regard to energy
conservation.
Statewide Planning Goal 14 – Urbanization
Statewide Planning Goal 14 ‐‐ “To provide for an orderly and efficient transition from rural to urban
land use, to accommodate urban population and urban employment inside urban growth boundaries, to
ensure efficient use of land, and to provide for livable communities.”
Goal 14 generally seeks to limit the level of development in rural areas to the levels of uses consistent
with rural lands. As discussed in previous findings, the County took a Goal 14 Exception in 2013 when it
adopted the GREAT plan for the Goshen area. The County determined at that time that there were
reasons justifying developing the otherwise rural area with urban levels of industrial uses, based on the
unique circumstances of site and the needs for industrial sites that the Goshen area could fulfill. Thus, it
has already been determined that an urban level of industrial development is appropriate in that area.
The Goshen community is ideally situated to accommodate the County’s goals. It already has existing
industrial and non-resource designations, which ensures an efficient use of already available land. Goshen
has direct access to major highways and rail, and proximity and access to utility infrastructure including
natural gas, electrical power, and water. It is close in proximity to the urban population centers of Eugene
and Springfield, which provides an educated and/or skilled workforce and provides jobs for livable
communities.
The extension of the wastewater system to the rural unincorporated community of Goshen will facilitate
the County’s goal of attracting industry and industrial development in the area. Goshen has been an
important area of action for the Lane County Board of Commissioners for more than 10 years. This
amendment will remove the remaining barrier to economic development there.
Further, the residents of Eugene and Springfield would benefit from a piped connection from the regional
wastewater facility to the landfill, which serves those same communities. This connection would
eliminate the high costs, environmental impacts, and operational challenges of transporting leachate from
the landfill to the wastewater facility transfer station as is the current practice.
The Metro Plan amendment complies with Goal 14.
Statewide Planning Goal 15 – Willamette Greenway
Attachment 1, Page 10 of 11
Exhibit B
Statewide Planning Goal 15 ‐‐ “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.”
The proposed action changes a Metro Plan policy to allow extension of sewer services outside the City of
Eugene and City of Springfield’s UGBs. While engineering studies have been conducted, and a proposed
route is roughly outlined, it is not yet clear exactly where the route of the wastewater line will be located.
To the extent any portions of the wastewater pipeline will be located on land within the Willamette River
Greenway, those impacts will be addressed in anticipated code changes or development permits. The
adoption of the proposed Metro Plan policy amendment is consistent with Goal 15.
Statewide Planning Goals 16 to 19 – Coastal Goals
These four goals are not applicable as they address resources that are not present in this portion of Lane
County.
Attachment 1, Page 11 of 11
Exhibit C
Vicinity Map of Goshen & Short Mountain Landfill
Attachment 1, Page 1 of 1
Bureau of Land Management, State of Oregon, State of Oregon DOT,
State of Oregon GEO, Esri Canada, Esri, HERE, Garmin, INCREMENT P,
USGS, EPA, USDA
Lane County, Oregon
The information on this map was derived from digital databases on the LaneCounty regional geographic information system. Care was taken in the creationof this map, but is provided “as is”. Lane County cannot accept any responsibilityfor errors, omissions or positional accuracy in the digital data or the underlyingrecords. Current plan designation, zoning, etc., for specific parcels should beconfirmed with the appropriate agency. There are no warranties, expressedor implied, accompanying this product. However, notification of any errors will be appreciated.0 740 1,480370
Feet
±Goshen Rural
Unincorporated Community
Map of Goshen Rural Unincoporated Community Exhibit D
Attachment 1, Page 1 of 2
Map of Goshen Rural Unincoporated Community Exhibit D
Attachment 1, Page 2 of 2
Ordinance No. PA 1282, Pages 36-37
community create an inconvenience or adverse impacts so significant that it warrants the location in the community?" Still other uses do not require a location within the community and should instead be located inside an urban growth boundary or on other rural industrial land.
Providing land for related industrial businesses will help attract companies that can complement the rail dependent uses. Uses of this nature may not be feasible until the larger rail dependent uses are successfully operating. It would benefit the larger region, community and the uses by locating in close proximity to the rail dependent uses by reducing trips and shipping cost, as well as other efficiencies.
Proximity to competitors, a skilled workforce, specialized suppliers, and a shared base of sophisticated knowledge about their industry are reasons that are critical for allowing the supportive rail related uses.
If the above reasons for either or both categories of use are not satisfactory, the County finds that the proposed urban levels of industrial development on undeveloped rural land is necessary to support an economic activity that is greatly dependent on the "natural resource" of the existing industrial land for the reasons discussed above including the strategic logistical characteristics. However implausible some may feel the inclusion of the existing industrial land being considered as a natural resource is, or strained the credibility of the rule becomes, the County finds that the existing industrial land fits the definition of natural resource as contemplated in this rule provision and therefore qualifies for this "reason" under this standard.
The County finds that the term "natural resource" is defined in the back of the "Oregon's Statewide Planning Goals & Guidelines" booklet as found on the DLCD website. The provided definition states: "NATURAL RESOURCES. Air,
land and water and the elements thereof which are valued for t eir existing and potential usefulness to man. ,,33 Based on this definition, the County finds that the existing industrial designated property in Goshen fits the definition of a natural resource of land. This land is useful to man (within the Community of Goshen, the larger Region-Eugene/Springfield Metro area, Lane County as a whole, and the broader State of Oregon) and further has an increased potential usefulness by allowing an increased level of industrial development to create jobs. The industrial land is valued for its unique characteristics giving it an existing and potential usefulness to man in creating increased economic activity including providing new jobs to citizens living in the area.
A Goal 11 exception is not necessary or contemplated with this proposal. The County currently is not proposing to extend sewer to the Community of Goshen with this application. However, if and/or when a sewer extension to the
33 The term "natural resource" is also defined in OAR 635-410-0010(6). Here it states: "Natural resources" means
land, fish, wildlife, biota, air or water.
FINDINGS AND REASONS IN SUPPORT OF GOSHEN PLAN AMENDMENT, GOAL 14 EXCEPTION, AND ZONE CHANGE
36
Exhibit E
Attachment 1, Page 1 of 2
Community of Goshen is contemplated, the County finds that the extension of the
sewer would not require a Goal 11 exception as allowed in OAR 660-011-
0060(3), which permits extension of sewer from inside a UGB to serve lands
inside a nearby unincorporated community. This issue will be addressed at a
later time when and if such extension is further contemplated.
The County finds that a new Goal 3 or 4 reasons exception is also not required
due to the original developed and committed exception to Goals 3 or 4 which was
applied to the land on the basis of its preexisting industrial development.
(3) To approve an exception under section (2) of this rule, a county must also
show:
(a) That Goal 2, Part II (c)(1) and (c)(2) are met by showing that the proposed
urban development cannot be reasonably accommodated in or through
expansion of existing urban growth boundaries or by intensification of
development in existing rural communities;
FINDINGS: The proposed urban levels of industrial development is being sought
to allow intensification of development on existing industrially zoned and
designated land within a rural community in conformance with this criterion. The
proposed urban levels of industrial development cannot be reasonably
accommodated in an existing UGB in the region (Eugene or Springfield) as
evidenced by the results of the ECLA and CIBL reports. These reports find that
neither of the City jurisdictions have adequate industrial land capacity within their
existing UGB’s to meet their or the regions employment needs. Specifically
identified is a need for large lot industrial sites. Additionally, the County finds that
there is a need for large lot industrial sites that are strategically located in close
proximity to the Interstate freeway system as well as near to and/or served by a
rail line. Together with the need for large sites as discussed in the findings
above, siting supportive urban levels of industrial development in close proximity
to the large rail served sites is a significant competitive advantage that cannot be
provided on sites inside a UGB.
Due to the significant comparative advantages of the Goshen area, specifically
the superior access to highway and rail, the proposed urban level of industrial
development cannot be reasonably accommodated in or through expansion of an
existing urban growth boundary.
The County finds that it is not reasonable to accommodate the proposed urban
industrial development through an expansion of an existing UGB in the region.
There are no sites that have been identified by either city jurisdiction that could
provide for superior highway and rail access. These findings are further
supported when considering the significant comparative advantages of the
Goshen community as discussed above.
FINDINGS AND REASONS IN SUPPORT OF GOSHEN PLAN AMENDMENT, GOAL 14 EXCEPTION, AND ZONE CHANGE
37
Exhibit E
Attachment 1, Page 2 of 2
Staff Report and Findings
Springfield Planning Commission
Type 3 Amendment to the Metro Plan
Hearing Date: April 4, 2023
Case Number: 811-23-000017-TYP4
Applicant: Lane County
Request
The City received an application for a Type 3 Metro Plan amendment from Lane County. Adoption of the
proposed Metro Plan amendments would allow the extension of wastewater infrastructure to the
unincorporated community of Goshen and to the Short Mountain Landfill which are located outside the
urban growth boundaries (UGBs) of Eugene and Springfield. Inadequate infrastructure has posed a barrier
to development of Goshen’s 444 acres of industrial, commercial, and residentially zoned properties. As
noted in Lane County’s Staff Report, the Goshen area was designated by the State of Oregon as a Regionally
Significant Industrial Area (RSIA) for its access to transportation/freight infrastructure, sites for industrial
areas that would provide significant employment opportunities, and its proximity to major labor markets.
Thus, the County has already determined that an urban level of industrial development is appropriate for
the area.
Further, the extension of the wastewater pipeline to the Short Mountain Landfill is proposed to convey
leachate generated from the Lane County landfill to the metropolitan wastewater collection system. This
connection would eliminate the high costs, environmental impacts, and operational challenges of
transporting approximately 25-million gallons of leachate annually with an average of 10 to 12 tanker trucks
per day to the County-owned Glenwood receiving station, as is the current practice.
Nature of the Proposal
In 2013, the Lane County Board of Commissioners adopted a countywide strategic plan with a key goal of
increasing industrial development and high-paying jobs within the unincorporated community of Goshen.
In support of this goal, the Goshen Region Employment and Transition (GREAT) Plan was adopted by the
County in June of 2013 to promote development for employment uses in Goshen. The County’s goal was
to foster industrial development in the Goshen community, which would bring with it high-paying jobs.
This in turn would promote economic development throughout the region.
Goshen has significant advantages for industrial development including: existing industrial/non-resource
designations; large parcels; proximity of supporting smaller parcels to the larger parcels; close proximity
and direct access to the State Highway system, including I-5, Highway 58, and Highway 99; adjacency
and access to rail; proximity to the urban population centers of Eugene and Springfield for providing an
educated and/or skilled workforce; access to natural resources; proximity and access to utility
infrastructure including natural gas, electrical power, and water; limited natural resource conflicts, and
relatively level topography.
This area is a regional asset with its advantages for industrial growth and economic development, which
would benefit the entire county economy by creating an environment to stimulate job growth.
Additionally, there would be no loss to productive resource lands due to the land already having a non-
resource designation.”
Attachment 2, Page 1 of 13
Areas to be Served
The unincorporated community of Goshen includes approximately 444 acres of industrial, commercial, and
residential development that lies 3.5 miles south of Eugene at the junction of Interstate 5, Highway 99, and
Highway 58. The Short Mountain Landfill includes 575 acres of land for the Lane County landfill and sits
5.5 miles south of Eugene along Interstate 5. Both areas are located outside the UGBs of Eugene and
Springfield.
Notification and Written Comments
In accordance with Springfield Development Code (SDC) 5.14.115(C)(2), proposals to amend a
fundamental principal as specified in Metro Plan Chapter II A, are classified as a Type 3 Metro Plan
amendment requiring approval by Springfield, Eugene, and Lane County.
In accordance with SDC 5.14.130, the property owner/public agency-initiated amendment to the Metro
Plan diagram is processed as a Type 4 (legislative) land use action.
In accordance with the Oregon Administrative Rules (OARs) 660-018-0020, prior to adopting a change to an
acknowledged comprehensive plan or land use regulation, local governments are required to notify the state
Department of Land Conservation and Development (DLCD) at least 35 days prior to the first evidentiary
hearing. Lane County submitted a Notice of Proposed Amendment to the DLCD on February 28, 2023, which
is 37 days prior to the joint Eugene, Springfield, and Lane County Planning Commission public hearing on
the matter.
In accordance with SDC 5.1.615(A), Type 4 legislative land use decisions require notice in a newspaper of
general circulation. Notification of the joint Planning Commission public hearing was published in the legal
notices section of The Register Guard on March 15, 2023. Staff has not received any public comments as of
the writing of this staff report.
In accordance SDC 5.1.620, an amendment to the Metro Plan can be initiated by a property owner or public
agency at any time. The application was submitted on January 27, 2023 and the joint hearing is scheduled
for April 4, 2023.
In accordance with SDC 5.1.630, the Type 4 legislative change must be adopted by ordinance and the City
Council decision for the Metro Plan amendment is final only upon concurrence with Lane County
Commissioners and the City of Eugene City Council. The Planning Commission’s recommendation must
address all the applicable approval standards and criteria and any written or oral testimony. See the
applicable Criteria of Approval response below.
Criteria of Approval
Section 5.14.135 of the SDC contains the criteria of approval for the decision maker to utilize during review
of Metro Plan diagram amendments. The Criteria of approval are:
SDC 5.14.135 CRITERIA
A Metro Plan amendment may be approved only if the Springfield City Council and other applicable
governing body or bodies find that the proposal conforms to the following criteria:
(A) The amendment shall be consistent with applicable Statewide Planning Goals; and
(B) Plan inconsistency:
Attachment 2, Page 2 of 13
(1) In those cases where the Metro Plan applies, adoption of the amendment shall not make the Metro
Plan internally inconsistent.
(2) In cases where Springfield Comprehensive Plan applies, the amendment shall be consistent with the
Springfield Comprehensive Plan.
The findings provided below are largely the same as the findings provided by Lane County and include one
addition finding to address a Springfield-specific criterion related to the Springfield Comprehensive Plan
(SDC 5.14.135 (B)(2). Findings that differ from Lane County’s are shown in blue italics, including the
Springfield-specific finding.
A. Consistency with Applicable State-Wide Planning Goals
Goal 1 – Citizen Involvement
Statewide Planning Goal 1 ‐‐ “To develop a citizen involvement program that insures the
opportunity for citizens to be involved in all phases of the planning process.”
Goal 1 is a process goal. The amendment complies with Goal 1 because it will be processed as a
legislative action through the jurisdictions’ acknowledged public procedures for Metro Plan
amendments. This process includes joint public hearings before the City of Eugene, the City of
Springfield, and Lane County’s planning commissions, and joint hearings before the governing
bodies of all three jurisdictions.
The joint planning commission hearing is scheduled to be held April 4, 2023. Notices will be sent to
interested parties and the public hearing notice was also published in The Register-Guard newspaper
on March 15, 2023.
The joint hearings before the governing bodies of Lane County, the City of Eugene, and the City of
Springfield is scheduled to be held at a future date yet to be determined.
Goal 2 – Land Use Planning
Statewide Planning Goal 2 ‐‐ “To establish a land use planning process and policy framework as a
basis for all decisions and actions related to use of land and to assure an adequate factual base for
such decisions and actions.”
The land use codes of both cities and Lane County specify the procedures and criteria that were used
in considering this amendment. The findings documents show the record includes an adequate
factual base for the amendment. The record of the original Lane County Rural Comprehensive Plan
amendment and Reasons Exception that was adopted to enable the urban levels of industrial uses in
Goshen shows that the County studied the need for certain employment lands that have access to rail
transport. The Goshen property included in the GREAT plan was determined, through thorough
study, to meet the demands for that type of development. The proposed amendment will enable the
development that has been stymied by lack of infrastructure that this proposal will provide.
Consistent with the Goal 2 coordination requirement, there was a significant exchange, or invitation
for such an exchange, among the cities, Lane County and affected governmental units. The
information obtained in these exchanges was used to balance the needs of the citizens. The County
Attachment 2, Page 3 of 13
and cities coordinated and jointly adopted the Metro Plan amendment. For the ordinance adopting
this Metro Plan amendment, intergovernmental coordination included the following:
• The Department of Land Conservation and Development (DLCD) was engaged
through notice of the proposed action and regular contact with the area’s regional
representative.
• City of Eugene, City of Springfield, and Lane County, which will jointly consider
adoption of the Metro Plan amendment, were engaged during the process with staff from
the three entities participating in meetings and providing feedback on the proposed
amendment language and documents. County staff collaborated with City staff to provide
informational updates and work sessions to the elected officials.
• Community of Goshen was engaged through notice of the proposed action published in
The Register-Guard and opportunity to comment.
• Metropolitan Wastewater Management Commission has been included in meetings
and invited to provide feedback on the proposed action. County staff has coordinated
with MWMC throughout this process.
Goal 3 – Agricultural Land
Statewide Planning Goal 3 ‐‐ “To preserve and maintain agricultural lands. Agricultural lands
shall be preserved and maintained for farm use, consistent with existing and future needs for
agricultural products, forest and open space and with the state's agricultural land use policy
expressed in ORS 215.243 and 215.700.”
The proposed action changes a Metro Plan policy to allow extension of sewer services outside the
City of Eugene and City of Springfield’s UGBs. While engineering studies have been conducted,
and a proposed route is roughly outlined, it is not yet clear exactly where the route of the wastewater
line will be located. To the extent any portions of the wastewater pipeline will be located on land
zoned for farm use, those impacts will be addressed in anticipated code changes or development
permit. The adoption of the proposed Metro Plan policy amendment itself does not trigger a Goal 3
analysis.
Goal 4 – Forest Land
Statewide Planning Goal 4 ‐‐ “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.”
The proposed action changes a Metro Plan policy to allow extension of sewer services outside the
City of Eugene and City of Springfield’s UGBs. While engineering studies have been conducted,
and a proposed route is roughly outlined, it is not yet clear exactly where the route of the wastewater
line will be located. To the extent any portions of the wastewater pipeline will be located on land
zoned for forest uses, those impacts will be addressed in anticipated code changes or development
permits. The adoption of the proposed Metro Plan policy amendment itself does not trigger a Goal 4
analysis.
Goal 5 – Natural Resources, Scenic and Historic Areas, and Open Spaces
Attachment 2, Page 4 of 13
Statewide Planning Goal 5 ‐‐ “To protect natural resources and conserve scenic and historic areas
and open spaces.”
Goal 5 requires the County to inventory the locations, quality, and quantity of certain natural
resources. Where no conflicting uses are identified, the inventoried resources shall be preserved.
Where conflicting uses are identified, the economic, social, environmental, and energy
consequences of the conflicting uses shall be determined and programs developed to achieve the
goal.
Both cities and Lane County have adopted / acknowledged programs for protecting and conserving
the types of resources, areas and spaces referenced in Statewide Planning Goal 5. The
administrative rule that implements Statewide Planning Goal 5 requires application of Goal 5 in
limited circumstances for post-acknowledgment plan amendments (PAPA).
OAR 660‐023‐0250(3) ‐ Applicability
Local governments are not required to apply Goal 5 in consideration of a PAPA
unless the PAPA affects a Goal 5 resource. For purposes of this section, a PAPA
would affect a Goal 5 resource only if:
(a) The PAPA creates or amends a resource list or a portion of an acknowledged plan
or land use regulation adopted in order to protect a significant Goal 5 resource or
to address specific requirements of Goal 5;
(b) The PAPA allows new uses that could be conflicting uses with a particular
significant Goal 5 resource site on an acknowledged resource list; or
(c) The PAPA amends an acknowledged UGB and factual information is submitted
demonstrating that a resource site, or the impact areas of such a site, is included
in the amended UGB area.
The proposed Metro Plan amendment does not change existing Goal 5 lists or site protections, as
described in OAR 660‐023‐0250(3)(a) and (b). To the extent any portions of the wastewater
pipeline will be located within a resource site or the impact area of a resource site, those impacts
will be addressed in anticipated code changes or development permits. The adoption of the
proposed Metro Plan policy amendment itself does not trigger a Goal 5 analysis.
Goal 6 – Air, Water and Land Resources Quality
Statewide Planning Goal 6 ‐‐ “To maintain and improve the quality of the air, water and land
resources of the state.”
All waste and process discharges from future development, when combined with such discharges
from existing developments shall not threaten to violate, or violate applicable state or federal
environmental quality statutes, rules and standards. With respect to the air, water and land resources
of the applicable air sheds and river basins described or included in state environmental quality
statutes, rules, standards and implementation plans, such discharges shall not (1) exceed the carrying
capacity of such resources, considering long range needs; (2) degrade such resources; or (3) threaten
the availability of such resources.”
Attachment 2, Page 5 of 13
The State has not adopted specific requirements for complying with Statewide Planning Goal 6. The
County and cities are in compliance with environmental standards and statutes, including the federal
Clean Water Act and Clean Air Act. The actions taken are consistent with the jurisdictions’ future
compliance with those laws.
Further, this amendment will develop solutions to wastewater infrastructure for the community of
Goshen and the Short Mountain Landfill. Connecting the landfill to a piped wastewater system is an
important goal for the Lane County Public Works Department. The wastewater from the landfill is
currently transported by tanker truck to the regional wastewater facility. A piped connection to the
regional wastewater facility would eliminate the high costs, environmental impacts, and operational
challenges of transporting over 25-million gallons of leachate (liquid that percolates through the
waste mass at the landfill) annually.
Goal 7 – Areas Subject to Natural Hazards
Statewide Planning Goal 7 ‐‐ “To protect people and property from natural hazards.”
The State has not adopted specific requirements for complying with Statewide Planning Goal 7.
Natural hazards for the purposes of Goal 7 are floods (coastal and riverine), landslides, earthquakes
and related hazards, tsunamis, coastal erosion, and wildfires.
Portions of the pipeline leading from Goshen to the Metropolitan Wastewater Management
Commission (MWMC) connection location may pass through the 100-year flood zone and
Willamette Floodway. Lane Code (LC) 16.244 establishes the requirements for work performed in a
floodplain, in addition to other applicable local, State, and Federal regulations. For development
activities within a mapped flood hazard area, a Floodplain Development Permit, Fill/Removal
Permit, or a Floodway Development Permit would be required before construction commences. A
Floodplain Development Permit or a Fill/Removal Permit apply to all development within the
mapped A and AE flood zones; a Floodway Development Permit is required for all development
within the mapped floodway AE zone. These permit reviews can be completed concurrently with the
Willamette Greenway Development permit process (see findings addressing Statewide Planning
Goal 15 below).
In Lane County, outside of urban growth boundaries, a Floodplain Development Permit is a Type I
review process, and the Floodway Development Permit is a Type II process. A primary requirement
of a Floodway Development Permit is that an engineer must certify the project will not reduce flood
storage capacity nor create a rise in the base flood elevation. Because this project involves buried
pipelines, a reduction in flood storage capacity is not expected.
Goal 8 – Recreational Needs
Statewide Planning Goal 8 ‐‐ “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.”
Goal 8 pertains to the recreation needs of citizens and visitors to the state. The actions taken by this
amendment do not impact the city or county’s recreation needs. Therefore Goal 8 does not apply.
Goal 9 – Economic Development
Attachment 2, Page 6 of 13
Statewide Planning Goal 9 ‐‐ “To provide adequate opportunities throughout the state for a variety
of economic activities vital to the health, welfare, and prosperity of Oregon’s citizens.”
As discussed in previous findings, the proposed Metro Plan amendment is intended to provide
adequate infrastructure to an area that is already planned and zoned to accommodate an urban level
of industrial development. That development will provide adequate opportunities for a variety of
economic activities in the Goshen community as well as in the larger Lane County region and
beyond, which is vital to the health, welfare, and prosperity of Oregon’s citizens.
As the County and cities continue to grow and flourish it will be necessary for the landfill to
accommodate this growth. Connecting the landfill to a piped wastewater system will be an
important part of that economic development.
The Metro Plan amendment is consistent with Goal 9.
Goal 10 - Housing
Statewide Planning Goal 10 ‐‐ “To provide for the housing needs of citizens of the state.”
Goal 10 generally imposes planning obligations on local governments only for urban and
urbanizable lands within urban growth boundaries. The actions taken by this ordinance do not
impact the either Eugene’s or Springfield’s supply/demand for residential land. Therefore, OAR
660, Division 8 and Goal 10 do not apply.
Goal 11 – Public Facilities and Services
Statewide Planning Goal 11 ‐‐ “To plan and develop a timely, orderly and efficient arrangement of
public facilities and services to serve as a framework for urban and rural development.”
Statewide Planning Goal 11 is implemented by Oregon Administrative Rule Chapter 660, Division
11. Under Goal 11 and its implementing regulations, extension of sewer services outside the urban
growth boundary (UGB) is heavily discouraged. Urban level sewer services are meant to be limited
to serving areas inside the UGBs as a way of limiting urban levels of development in rural areas.
OAR 660-011-0060, however, provides some allowances and exceptions to that general rule,
articulating when and where sewer services may be placed on or extended to serve rural lands. For
instance, OAR 660-011-0060(3)(a)(E) allows components of sewer systems that serve land outside a
UGB where necessary to transport leachate from a landfill on rural land to a sewer system inside a
UGB. Further, OAR 660-011-0060(3)(a)(B) allows placing components of a sewer system on rural
lands where necessary to serve lands inside an unincorporated community.
Goal 11 directs local governments to “not rely upon the presence, establishment, or extension of a
water or sewer system to allow residential development of land outside urban growth boundaries or
unincorporated community boundaries at a density higher than authorized without service from such
a system.”
The action taken by this amendment would extend the wastewater system to the rural
unincorporated community of Goshen and provide for transport of leachate from the Short Mountain
Landfill to a sewer system inside a UGB. This is compatible with Goal 11. Wastewater services
would not be provided along the route. As specified by the proposed G.26 policy amendment, the
Attachment 2, Page 7 of 13
extension of the wastewater system will serve only the rural unincorporated community of Goshen
and the landfill for the transport of leachate.
The Short Mountain Landfill serves the communities inside the UGBs of Eugene and Springfield as
it accepts solid waste from the surrounding area. It is also the only permitted municipal landfill in
Lane County. A piped connection to the regional wastewater facility would eliminate the high costs,
environmental impacts, and operational challenges of transporting leachate from the landfill to the
Glenwood transfer station located within the Metropolitan Wastewater Management Commission
(MWMC) service area. Currently the leachate travels 5.5 miles from the storage lagoons at the
landfill to the discharge point.
The leachate is already handled by the regional wastewater system after being trucked in. By
connecting the landfill to the system through a piped connection, it provides a safe, cost effective,
and efficient way to transport the leachate. This benefits community members within the Metro Plan
area inside the UGB, who are being served by the Short Mountain Landfill.
The County has long been working toward the goal of increasing industrial development and
creating high-paying jobs in the Goshen community. In support of this goal, the Goshen Region
Employment and Transition (GREAT) Plan was adopted by the commissioners in June of 2013 to
promote development in Goshen under urban industrial zoning. At the time of the GREAT Plan’s
adoption, extending wastewater service to the area was not part of the adopted Ordinance, but the
need for extending service was anticipated. With this Metro Plan amendment the County could
realize its goal of industrial development in the area and promoting economic development
throughout the region.
The County anticipated the need for the extension of wastewater services in its adoption of
Ordinance No. PA 1282 in 2013. The findings of the Ordinance on pages 36-37 stated:
“A Goal 11 exception is not necessary or contemplated with this proposal. The County
currently is not proposing to extend sewer to the Community of Goshen with this
application. However, if and/or when a sewer extension to the Community of Goshen is
contemplated, the County finds that the extension of the sewer would not require a Goal 11
exception as allowed in OAR 660-011-0060(3), which permits extension of sewer from
inside a UGB to serve lands inside a nearby unincorporated community. This issue will be
addressed at a later time when and if such extension is further contemplated.”
OAR 660‐011‐0060(3)
Components of a sewer system that serve lands inside an urban growth boundary (UGB)
may be placed on lands outside the boundary provided that the conditions in subsections (a)
and (b) of this section are met, as follows:
(a) Such placement is necessary to:
(A) Serve lands inside the UGB more efficiently by traversing lands outside the
boundary;
(B) Serve lands inside a nearby UGB or unincorporated community;
(C) Serve lands subject to a Goal 14 exception approved pursuant to OAR 660-014-
0090;
Attachment 2, Page 8 of 13
(D) Connect to components of the sewer system lawfully located on rural lands, such
as outfall or treatment facilities; or
(E) Transport leachate from a landfill on rural land to a sewer system inside a UGB;
(b) The local government:
(A) Adopts land use regulations to ensure the sewer system shall not serve land
outside urban growth boundaries or unincorporated community boundaries, except
as authorized under section (4) of this rule; and
(B) Determines that the system satisfies ORS 215.296(1) or (2) to protect farm and
forest practices, except for systems located in the subsurface of public roads and
highways along the public right of way.”
The extension of the wastewater line that would be allowed by the proposed Metro Plan amendment
satisfies subsections (a)(B) and (a)(E) above. The adoption of the GREAT plan in 2013 approved a
Goal 14 Exception for the Goshen area, which is a rural unincorporated community. The extension
would serve Goshen, pursuant to subsection (a)(B). And the rule specifically allows for extension
of components of a sewer system outside the UGB for the transport of leachate from a landfill on
rural land to a sewer system inside the UGB, pursuant to subsection (a)(E). For the purpose of this
Metro Plan amendment, subsection (b) is arguably met at the time of adoption, given that extension
of wastewater service will only be allowed by the proposed language to Goshen and Short
Mountain. Additionally, prior to construction, the County intends to adopt land use regulations
prohibiting cross connection in other areas outside of the Metro Plan boundary.
Springfield finds that the County’s findings rely upon OAR 660-01100060(3) to overcome the
prohibition under OAR 660-011-0060(2) on extending sewer lines from within a UGB, outside the
UGB, without need for an exception to Goal 11. However, the findings do not fully address
subsection (3)(b). Additional findings and/or conditions of approval are needed to demonstrate that
land use regulations will ensure the sewer system does not serve other areas outside the UGB, and
that the system will protect farm and forest practices per ORS 215.296 or else that the sewer will be
entirely located in the subsurface of public roads and highways along the public right of way.
Therefore, Goal 11 is not yet satisfied.
Goal 12 – Transportation
Statewide Planning Goal 12 ‐‐ “To provide and encourage a safe, convenient and economic
transportation system.”
Goal 12 pertains to the transportation system.
OAR 660-012-0060 -- Plan and Land Use Regulation Amendments
(1) If an amendment to a functional plan, an acknowledged comprehensive plan, or a
land use regulation (including a zoning map) would significantly affect an existing
or planned transportation facility, then the local government must put in place
measures as provided in section (2) of this rule, unless the amendment is allowed
under section (3), (9) or (1 0) of this rule.
Attachment 2, Page 9 of 13
The actions taken by this amendment do not impact the county’s transportation system and would
not significantly affect an existing or planned transportation facility. The main impact likely to
result from the amendment is a reduction is truck travel on I-5 from the transport of leachate.
Therefore, Goal 12 is satisfied.
Goal 13 – Energy Conservation
Statewide Planning Goal 13 ‐‐ “To conserve energy.”
The State has not adopted specific rules for complying with Statewide Planning Goal 13. The
proposed Metro Plan amendment satisfies Goal 13 as it will eliminate the need to truck leachate
from the landfill to the MWMC treatment plant. Reducing those truck trips provides a net gain with
regard to energy conservation.
Goal 14 - Urbanization
Statewide Planning Goal 14 ‐‐ “To provide for an orderly and efficient transition from rural to
urban land use, to accommodate urban population and urban employment inside urban growth
boundaries, to ensure efficient use of land, and to provide for livable communities.”
Goal 14 generally seeks to limit the level of development in rural areas to the levels of uses
consistent with rural lands. As discussed in previous findings, the County took a Goal 14 Exception
in 2013 when it adopted the GREAT plan for the Goshen area. The County determined at that time
that there were reasons justifying developing the otherwise rural area with urban levels of industrial
uses, based on the unique circumstances of the site and the needs for industrial sites that the Goshen
area could fulfill. Thus, it has already been determined that an urban level of industrial development
is appropriate in that area.
The Goshen community is ideally situated to accommodate the County’s goals. It already has
existing industrial and non-resource designations, which ensures an efficient use of already available
land. Goshen has direct access to major highways and rail, and proximity and access to utility
infrastructure including natural gas, electrical power, and water. It is close in proximity to the urban
population centers of Eugene and Springfield, which provides an educated and/or skilled workforce
and provides jobs for livable communities.
The extension of the wastewater system to the rural unincorporated community of Goshen will
facilitate the County’s goal of attracting industry and industrial development in the area. Goshen has
been an important area of action for the Lane County Board of Commissioners for more than 10
years. This amendment will remove the remaining barrier to economic development there.
Further, the residents of Eugene and Springfield would benefit from a piped connection from the
regional wastewater facility to the landfill, which serves those same communities. This connection
would eliminate the high costs, environmental impacts, and operational challenges of transporting
leachate from the landfill to the wastewater facility transfer station as is the current practice.
Springfield finds that the Short Mountain landfill sewer extension is consistent with Goal 14. The
landfill is not an urban use itself, and so extending the sewer system to serve this use does not locate
an urban use in a rural area which would run afoul of Goal 14. Provided that the Goal 11
Attachment 2, Page 10 of 13
requirements can be met to limit impacts to farm and forest uses and prevent other connections to
the sewer outside of the UGB, Goal 14 is met for the Short Mountain landfill sewer connection.
However, the current Goal 14 findings above are inadequate for the Goshen sewer extension
because they rely upon the Goal 14 “reasons” exception (adopted by Lane Co. Ordinance No. PA
1282, as amended by Ordinance PA 1317 on remand from the Land Use Board of Appeals), without
findings that the 2013 exception is applicable to this specific set of Metro Plan amendments. Per
OAR 660-004-0018(1), “Exceptions to one goal or a portion of one goal … do not authorize uses,
densities, public facilities and services, or activities other than those recognized or justified by the
applicable exception.”
OAR 660-004-0018(4) provides the relevant requirements for “reasons” exemptions to the
statewide planning goals:
(4) “Reasons” Exceptions:
(a) When a local government takes an exception under the “Reasons” section of ORS
197.732(1)(c) and OAR 660-004-0020 through 660-004-0022, OAR 660-014-0040, or
OAR 660-0140-090, plan and zone designations must limit the uses, density, public
facilities and services, and activities to only those that are justified in the exception.
(b) When a local government changes the types or intensities of uses or public facilities
and services within an area approved as a “Reasons” exception, a new “Reasons”
exception is required.
The findings for the Metro Plan amendment should either explain why the MWMC sewer extension
is the same type and intensity of “public facilities and services” recognized or justified by the 2013
exception under subsection (4)(a), or include a new reasons exception under (4)(b).
Therefore, the Metro Plan amendment does not yet comply with Goal 14.
Goal 15 – Willamette River Greenway
Statewide Planning Goal 15 ‐‐ “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.”
The proposed action changes a Metro Plan policy to allow extension of sewer services outside the
City of Eugene and City of Springfield’s UGBs. While engineering studies have been conducted, and
a proposed route is roughly outlined, it is not yet clear exactly where the route of the wastewater line
will be located. To the extent any portions of the wastewater pipeline will be located on land within
the Willamette River Greenway, those impacts will be addressed in anticipated code changes or
development permits. The adoption of the proposed Metro Plan policy amendment is consistent with
Goal 15.
Goals 16-19 Estuarine Resources, Coastal Shorelands, Beaches and Dunes, and Ocean Resources
These four goals are not applicable as they address resources that are not present in this portion of
Lane County.
B. Plan Inconsistency
Attachment 2, Page 11 of 13
1. In those cases where the Metro Plan applies, adoption of the amendment shall not make the
Metro Plan internally inconsistent.
Chapter II-C Growth Management Goals, Findings, and Policies
Policy 4: Lane County shall discourage urban development in urbanizable and rural areas
and encourage compact development of outlying communities.
The County took an Exception to Statewide Planning Goal 14 in 2013 when it adopted the
GREAT plan for the Goshen area. The County determined at that time that there were reasons
justifying developing the otherwise rural area with urban levels of industrial uses, based on the
unique circumstances of the site and the needs for industrial sites that the Goshen area could
fulfill. Thus, it has already been determined that an urban level of industrial development is
appropriate in that area.
Further, the extension of the wastewater pipeline to the Short Mountain Landfill is proposed to
convey leachate generated from the municipal landfill to the proposed wastewater collection
system in Eugene/Springfield. The residents of Eugene and Springfield would benefit from a
piped connection from the regional wastewater facility to the landfill, which serves those same
communities. This connection would eliminate the high costs, environmental impacts, and
operational challenges of transporting leachate from the landfill to the wastewater facility
transfer station, as is the current practice.
The intent of the proposed Metro Plan amendment is to develop safe, efficient solutions to
wastewater infrastructure for the existing Short Mountain Landfill and for urban levels of
industrial development that is already planned for the Goshen area. The proposal is consistent
with Policy 4.
Chapter III-B Economic Element
Policy B.27: Eugene, Springfield, and Lane County shall improve monitoring of economic
development and trends and shall cooperate in studying and protecting other potential
industrial lands outside the urban boundary.
On October 12, 2021, the Lane County Board of Commissioners directed staff to coordinate
with the Metropolitan Wastewater Management Commission (MWMC), the City of Eugene, and
the City of Springfield to pursue amendments to the Metro Plan to facilitate extending
wastewater services to the rural unincorporated community of Goshen as well as a pipeline
extension connection to service Short Mountain Landfill for conveyance of leachate. Although
the economic element no longer applies to Eugene or Springfield, both cities and the County
must jointly adopt any amendments to the Metro Plan.
The industrial development in the unincorporated community of Goshen has been a topic of
significant conversation and action by the Board of Commissioners for more than 10 years. In
2013, the Board adopted the GREAT Plan, which designated lands within Goshen for urban
levels of industrial development. The major remaining barrier to development of that area is the
lack of adequate wastewater infrastructure. The adoption of the proposed Metro Plan
amendment would enable extension of wastewater services by MWMC, which in turn, would
enable the industrial development that has long been planned for this area.
Attachment 2, Page 12 of 13
Likewise, the ability of the Short Mountain Landfill to connect to a piped wastewater system
remains a strong desire of the Lane County Public Works Department. This wastewater is
already truck delivered to the regional wastewater facility at the Glenwood Transfer Station. A
piped connection to the regional wastewater facility would eliminate the high costs,
environmental impacts, and operational challenges of transporting over 25-million gallons of
leachate annually by tanker trucks.
Chapter IV Metro Plan Review, Amendments, and Refinements
Policy 6.b.iii: Type III Text Amendments include: Amendments to a regional
transportation system plan, or a regional public facilities plan, when the participation of
all three governing bodies is required by the amendment provisions of those plans.
Policy 7.c: A Type III amendment may be initiated by any one of the three governing
bodies at any time.
Policy 8.a: The initiating governing body of any Type I, II, or III Metro Plan amendment
shall notify all governing bodies of the intended amendment and the Type of amendment
proposed. If any governing body disagrees with the Type of the proposed amendment that
governing body may refer the matter to the processes provided in 8(d) or (e) as
appropriate.
Policy 8.b: When more than one governing body participates in the decision, the Planning
Commissions of the bodies shall conduct a joint public hearing and forward that record
and their recommendations to their respective elected officials. The elected officials shall
also conduct a joint public hearing prior to making a final decision.
The proposal is a request to amend Chapter II.C, Policy 21; and Chapter III.G, Policy G.26 and
Policy G.28 of the Metro Plan via this Type III Metro Plan Amendment. The amendment was
initiated by Lane County, and Lane County has notified the other jurisdictions. The jurisdictions
agree that the proposal is a Type III amendment. The procedures are consistent with Chapter IV
of the Metro Plan.
2. In cases where Springfield Comprehensive Plan applies, the amendment shall be consistent
with the Springfield Comprehensive Plan.
The proposed amendment does not impact land with Springfield’s urban growth boundary.
Therefore, the Springfield Comprehensive Plan is not applicable.
Conclusion and Recommendation
Based on the applicant’s narrative, the findings above, and the criteria of SDC 5.14.135 for approving
amendments to the Metro Plan, staff finds the proposed Metro Plan amendment to allow wastewater service
to be extended to the unincorporated community of Goshen and Lane County’s Short Mountain Landfill
are not yet consistent with all the criteria.
Questions: Please call Haley Campbell in the Development & Public Works Department at (541) 726-
3647 or email hcampbell@springfield-or.gov if you have any questions regarding this process.
Attachment 2, Page 13 of 13