HomeMy WebLinkAboutAIS PLANNER 7/16/2007
.r;
r ~..
AGENDA ITEM SUMMARY Meeting Date: July 16"',2007
Meeting Type: Regular Session
'! Department: Development Services
Staff Contact: David Reesor~ (v\ ~
S P R I N G FIE L D Staff Phone No: 726-3783 4\k~
C IT Y C 0 U N C I L Estimated Time: Consent Calendar . "(7v
ITEM TITLE: CONCURRENT METRO PLAN / REFINEMENT PLAN MAP AMENDMENT AND
ZONING MAP AMENDMENT REGARDING PROPERTY NEAR 44TH & MAIN
STREET.
ACTION
REQUESTED:
ISSUE
STATEMENT:
ATTACHMENTS:
DlSCUSSION/
FINANCIAL
IMP ACT:
Date Received:! ~I 07
Planner: DR . I
~ 7,~llN
Conduct a second reading and adopt/not adopt on the following ordinances:
AN ORDINANCE AMENDING THE METRO PLAN DESIGNATION OF
APPROXIMATELY 5.24 ACRES OF LAND, IDENTIFIED AS LANE COUNTY
ASSESSOR'S MAP 17-02-32-00, TAX LOTS 400 & 402 FROM LIGHT MEDIUM
INDUSTRIAL (LMl), TO COMMERCIAL WITH AN AUTOMATIC REDESIGNA TION
TO THE EAST MAIN REFINEMENT PLAN FROM LMI TO COMMUNITY
COMMERCIAL (CC). (SECOND READING)
AN ORDINANCE AMENDING THE SPRINGFIELD ZONING MAP BY REZONING
APPROXIMA TEL Y 5.24 ACRES OF LAND IDENTIFIED AS LANE COUNTY
ASSESSOR'S MAP 17-02-32-00, TAX LOTS 400 & 402, FROM LIGHT MEDIUM
INDUSTRIAL (LMI) TO COMMUNITY COMMERCIAL (CC). (SECOND READING)
The applicant requests approval of a Metro Plan / Refinement Plan Map Amendment to the
Ea'st Main Refinement Plan and a concurrent Zoning Map Amendment. The request
involves property identified as Tax Lots 400 and 402 on Assessor's Map No. 17-02-32-00.
Specifically, the applicant proposes to change the Metro Plan designation from Light
Medium Industrial (LMl) to Commercial and a concurrent Refinement Plan Amendment
and Zoning Map Amendment from LMI to CC.
Attachment I: Staff Response .to issues raised during July 2"" hearing
Attachment 2: Ordinance Amending the Metro Plan & East Main Refinement Plan
Attachment 3: Ordinance Amending the Springfield Zoning Map
Attachment 4: Planning Commission Order & Recommendation
Attachment 5: Staff Report with exhibits
On June 5th, 2007, the Planning Commission held a work session and public hearing on the
subject applications (LRP2007-000I3 & ZON2007-00012). After reviewing all verbal and
written testimony, the Planning Commission deliberated on the applications on June 19th,
2007, and voted unanimously (5-0) to recommend that both applications be sent to the City
Council for consideration and approval.
On July 2"d, 2007, the City Council held a work session and public hearing on the subject
applications. Four people testified: three in favor; one in opposition. Staff concludes that the
testimony has no material effect on the conclusions, findings or recommendations by the
Planning Commission. Staff response and applicant's rebuttal to the issues raised at the July
2"d, 2007 hearing are included in the attached packet. No new evidence is presented in the
attachment; only reference to information which already exists in the record. Based upon
the findings of fact and evidence in the record, Staff requests the Planning Commission
recommendation of approval be acknowledged by Council adoption of the attached
ordinances. .
Staff Response to issues raised during July 2nd, 2007
hearing regarding Applications ZON 2007-00012 /
( LRP2007-00013 .
EXECUTIVE SUMMARY:
On July 2"', 2007, the City Council held a work session and public hearing on the subject
applications (LRP2007-00013 & lON2007-000l2). One person, Geoffrey Aguirre, Goal One
Coalition, testified that Goal One Coalition had several procedural concerns about the proposal.
Mr. Aguirre indicated that he is a resident living in Springfield and a 3'" year law student at the
University of Oregon School of Law. He was speaking on behalf of Goal One Coalition. Mr.
Aguirre's testimony focused on issues related to Metro.Plan and Refinement Plan policies;
initiation of the application; and existing commercial uses on TL 402. Three additional people
testified in support of the application: Philip f'arrington, John Hyland, and Andy Head.
Pursuant to ORS 197"763(6)(e), the applicant"provided a written rebuttal to verbal testimony on
July 3'", 2007. The following are provided in this document: a summary of ML Aguirre's issues;
applicant's written rebuttal; and Staff Response to" issues raised by Mr. Aguirre and applicant's
. .
rebuttal.
Mr. A!!uirre's Testimonv - Issue #1: The proposed plan 'amendment didn't comply"
with provisions of the Metro Plan and Springfield's De~elopment Code for the initiation
o.fMetro Plan amendments. Stafffailed to require the applicant to address the plan
review policies of the Metro Plan and had erred in finding that the applicant's choice of
applicable Metro Plan policies and elements was sufficient. "
Aoolicant's Rebuttal to Issue #1: The proposal is for a Metro Plan diagram
. amendment on(v (no text amendment; the East At/ain Refinement Plan diagram changes
automatically corresponding to the approval of the Metro Plan diagram request). on a
site entirely within the Springfield city Iimtis and UGH, As such. the amendment is a
Type II amendmel1tas defined in SDC rmo (2)(a). SDC 7"080 (1) authorizes such Type
II amendments to be processed by a single jurisdiction:. the home City. Springfield.
,
SDCI040 (1) (b) I. identifies rhat a Type 11 Plan diagram amendmentfor sites wirhin the
City limits can be initiated by the home city "and citizens." SDC 7.040 (2) (b) Slates."
"Citizen initiated Type II Metro Plan amendments maybe appliedfor ar any time."
Therefore, Mr. Aguirre was incorrect in suggesting that the proper procedure was "no/
followed for filing the Plan diagram amendment (or zone change). The proper
procedures werefollowed according. to the Springfield Development Code, which follows
procedures outlined in the Metro Plan (pp" IV-I through IV-4)
STAFF RESPONSE: The issue of which Metro Plan policies to address was addressed
in the document entitled Staff Response to Writ/en Comments..., which was included in
the June 19th, 2007 Planning Commission packet and also provided to both Goa! One
Coalition and to the applicant. Stal/Response to Written Comments along with copies of
the Applicant's Rebuttal and Lauri Segeh comments were all included in the Council
ATTACHMENT
1-?
(
packet for' the July 2,d, 2007 hearing and are included in the Council packet for the July
16th, 2007 second reading. As noted in Staff Response to Written Comments, policies in
the Metro Plan are sometimes conflicting t6 one another. As stated on page 1-4 of the
Metro Plan, "The respective jurisdictions recognize that there are apparent conflicts and
inconsistencies"between and among some goals, objectives, and policies. When making
decisions based on the Plan, not all the goals, objectives,' and policies can be met to the
. same degree in every instance. Use of the Plan requires a 'balancing' of its various
components on a case-by-case basis, as well as a selection of those goals, objectives, and
policies most pertinent to the issue at hand." The applicant submitted written statements
relative to the policies which supported the proposal. As noted in the original Staff
Report, Staff concurred" with the applicant's narrative related to the referenced Metro
Plan policies which support the proposal, given the relationship'ofthose stated Metro
Plan policies as reviewed concurrentlv with the referenced commercial and industrial
adopted inventories. Staff concurs with the applicarlt's rebuttal as included.in this
document.
Mr. A!'uirre's Testimonv - Issue #2: PeaceHealth Oregon should not have,been
allowed to propose the subject plan amendment or zone change. Because they were not
the owner of the subject properties, such a proposal was inconsistent with the proper
initiatioll o.f proposed Metro Plan amendments explained in Section 7.010 and 7.03.0 of
the Springfield Development Code. Metro Plan Amendment Policy 4, Initiation o.f
Metropolitan Plan Amendments. establishes that a Type II amendment may be initiared at
the discretion of anyone of the three governing bodies or by any citizen who owns
property that was subject of the proposed amendments. PeaceHealth Oregon was rhe
applicant. but not the owner of the p,:operty, thus the initiation of these amendments did
not comply with the requirements of the Metro PIWL
"Aoolicant's Rebuttal to Issue #2: SDC 7.010 establishes the Purpose of Metro Plan
amendments. and states that the Metro Plan "allows citizen initiated Type II Metro Plan
amendments to be initiated at any time"" Section 7.020 addresses review of Metro Plan
amendments and 7.030 includes definitions.
Metro Plan Policy 4"b. under the Plan Review element states"' "A]ype II amendment
may be initiated at the discretion a.fany one of the three governing bodies or by any
citizen 'who owns property that is subject of the proposed amendment."" [emphasis
added J
But thefilct is thar the application forms for the zone change and Metro Plan diagram
amendment were sig,led by both Andy Head (owner ofTclX Lot 402) and Shc",n Hyland
(owner of Tax Lot 400). as well as myself as rhe applicant's representative.
ST AFF RESPONSE: The property owner's signature was included on the original
application, which indicates their "initiation" of the application. Staff concurs with the
applicant's rebuttal as included in this document.
1-1
,
I
(
Mr. A!7uirre's Testimonv - Issue,#3:" :rhe <,Zpplic.anl incorrecrly r~ferred to the
sabject properties as being subject to Mixed Use "Area 2 policies" The subjecl properties
were zoned Light MediumIndustrial(LMI)~'Si~ce.the proposed development lot was not"
within the Mixed Use area. no Mixed ,Use area argumenls were applicable and the
properly was not subject to EMRP Mixed Use' Elements Policy 2, which was specific 10
Area 2. The policy did 110t sa): l1nything;l}bo.uticr:iteria,for ,:ezoning or redesignatiul1s, but
merely established what uses were alfowell u~der CC zoning in Area 2 on(1'. The EMRP
d~finition ofCC neilher allowed nor encapsulated medical facilities, offices, clinics or
hospitals.
Aoolicant's Rebuttal to Issue #3:" The EMRP diagram identifies the subject
property as being designated Light/Medium Industrial. The applicants seek CC
land use designations and zoning. Insofar as the area immediately west and south
of the subject property is identified as being in Area #2, our narrative and
jindings addressed EMRP Mixed Use Element Policy #2A which specifically
relates to Area #2. If this policy is not applicable, .then the findings relating to
this Element is superj/;/Ous. But it does not invalidate th/City's 'ability to approve
the applications based upon other policies and elements of the EMRP and other
applicable approvai'criteria. .
STAFF RESPONSE: Finding 23 of the original Staff Report discussed the Applicant's
reference of Mixed Use Area 2 policies. Staff already noted in the Staff Report that the
subject properties are not within the Mixed use area.' '
Mr. Aguirre's testimony stating, "The EMRP definition ofce neither allowed nor
encapsulated medical facilities, offices, clinics or hospitals... " is inaccurate in that the
Springfield Development Code is the implementing ordinance for the Metro Plan (and
therefore the EMRP as well, as the Refinement Plan is part of the Metro Plan). Article IS
provides the list of specific uses allowed in the CC Zone. The list includes "medical
office" as a specific permitted use in the CC zone. Stilff concurs with the applicant's
rebuttal as included in this document. . .
Mr. A!7uirre's Testimonv - Issue #4: the EMRP's commercial element uhder
crileriafor a commercial R~finement Plan designation at1.d, specified thai the CC
Refinement Plan designation shall be applied under the following circumstances - where
legally crealed commercial tIses exisl. The tax recordsior tax lot 402 did not reflect the .
three existing businesses actually condtlcring business on tax lot 402 The City slaff had .
not been able to locate any recent permits for the three exisring businesses," therefore. the
three existing businesses did not appear to -be legal and were not legally created
'commercial uses.
,
Aoolicant's Rebuttal to Issue #4: The applica'tionnarrative andjindings
addressed each of the criteria/or Commercial Rejinement Plan designation
established on page 12 of the EivlRP (see pp. 17, 18 of the 3/15/07 application
narrative; alsofound on pp. 3-17and 3-18 in the attachment to the Planning
Commission's June 5. 2007 hearing packet). Criterion I.D) states that the
Commercial designation can be applied "where legally created commercial uses
1-4
" ,':-l-
"'---."
exist." As noted in testimony at last night's heahngfi'oin Andy Head. owner of
Tax Lot 402. commercial "i,ses have:been locate.d all the site since the 1950s. and
the building has been in its current 'co'hfigui'dti9n since at least 1960 (as the air
photo he presented to the Council illustrated).~ Its unclear what tax records Mr.
Aguirre researched or was referring to. butrecor.dsfi'om Lane County
Assessment and Taxation 'donotpuip'oi'("t()'be'complete'Or identify whim a given
use _ particularly commercial uses that go back niore than a half-century - was
established; the legality of the use. or whether the use is a conforming or non-
l
conforming use. The applicant recognizes that the long-standing and existing
commercial uses on Tax Lot 402 are on a site that is zoned and designated LM1
prior to approval of the requested redesignation/zone change. As such. prior to
approval of the request. such uses are considered pre-existing non-conforming
uses" There was no evidence submitted into the record to indicate thatthf!
commercial uses on-site were not legally established.
ST AFF RESPONSE:. Mr. Aguirre's testimony related to EMRP Commercial Element
I.d is accurate in stating that: CC Refinement Pian designation shall be applied where
legally created commercial uses exist. However, his testimony indicati~g that the
commercial uses on Tax Lot 402 are illegal is not accurate; Information already in the
record (both written and verbal testimony) indicate that commercial uses on TL 402 have
, been in existence for several decades. Thus, these are non-confonning uses that were
most likely established in the 1950's when the property was under County jurisdiction.
Staff concurs with the applicant's rebuttal as included in this document.
1-,
,
.
ORDL1'lANCE NO.
,
..~ ,I.
.,. :' (General)
~ . - -....,...:.:.......,
AN ORDINANCE AMENDING THE METRO PEANDESIQ!'IA TION OF APPROXl-
MA TEL Y 5.24 ACRES OF LAND, IDENTIFIED"AS LAJ,lE COUNTY ASSESSOR'S MAP 17-
02-32-00, TAX LOTS 400 & 402 FROM LIGHT MEDIUM INDUSTRIAL (LMl), TO COM-
MERCIAL WITH AN AUTOMATIC REDESIGN A TION'~T6THE EAST MAIN REFINE-
".' .-.. : ~ i.-..- -",," r''"' '. - -.
MENT PLAN FROM LMI TO COMMUNITY COMMERGIAL (CC).
THE COMMON COUNCIL OF THE CITY OF SPRINGFIELD FINDS THAT:
1. Article 7 of the Springfield Development Code sets forth. procedures for Metro Plan dia-
gram amendments; and
2. Springfield Development Code Section 7.110(4) states:
"When a Metro Plan amendment is enacted that requires an amendme~tto a refinement
pian or functional plan diagram or map for consistency, the Metro Pian diagram
amendment automatically amends the refinement plan or functional pian diagram or map
ifno amendment to the refinement pian or functional pian text is involved... "; and
3. Article 8'ofthe Springfield Development Code sets forth procedures for Refinernent Plan
diagram amendments; and
4. On March 16th, 2007 the applicant/owner of the subject property .initiated the following
Metro Plan Diagram amendment with"automatic amendment to the East Main Refinement Plan:
Redesignate approximately 5.24 acres of land on the Metro Plan Diagram from Light
Medium Industrial to Commercial with automatic redesignation of said property on the
East Main Refinement Plan diagramfrom LMI to Community Commercial (CC), Case
Number LRP2007-00013, for property identified as Lane County Assessor's Map 17-02-
32-00, Tax lots 400 & 402; and ' .
5.. On June 4th, 2007; the Springfield Planning Commission held a work session and public
hearing to receive testimony and hear comments on this proposal. A second public hearing was
held on June 18th, 2007 after the written record was left open for seven additional days and after
reviewing additional written testirnony. The Planning Commission deliberated and voted unani-
mously (5-0) to forward a recommendation of approval to the City Council; and
6" On July"2"d, 2007 the Springfield City Council held a work session and a pUblic'hearing
to consider and to receive testimony and hear comments on this proposal. The City Council is
now ready to take action on this proposal based upon the above recommendation and the evi-
dence and testimony already in the record as well as the evidence and testimony presented at this
public hearing held in the matter of adopting this Ordinance amending the Metro Plan Diagram
and East Main Refinement Plan Map.
NOW THEREFORE, based upon the foregoing findings 1-6 the City of Springfield or-
dains as follows:
Section I. The Metro Plan designation of the subject property, more particularly de-
scribed in Exhibit A attached hereto and incorporated herein by reference, is hereby
amended from Light 0edium Industrial to Commercial.
ORDINANCE NO.
A TtA~~ENT
2-1
Section 2. The East Main Refinement Plan designatiop of the subject property is hereby
amended from Light Medium Industrial to CommunitY:Commercial.
. .
Section 3. If any section,' subsection, sentence, ,!a\!s~, phrase, or portion of this Ordi-
nance is for any reason held invalid or uncqnstittJti9.n'al;by any court of competent juris-
diction, that portion shall be deemed a separate,'distinct, and independent provision' and
that holding shall not affect the validity of the 'remainin,g portion of this Ordinance.
"
..1, .. ....
FURTHER, although not part of this Ordinance, the, Springfield City Council adopts
findings 1-6 herein above, and the findings set forth in the Staff Report which demonstrate con-
formance of this amendment to the Metro Plan, applicable State statutes and applicable State-
wide Planning Goals and Administrative Rules, and is attached as Exhibit A.
ADOPTED by the Common Council of the City of Springfield this
, 2007 by a vote of _ for and _ against.
day of
APPROVED by the Mayor of the City of Springfield this ~ day of.
Mayor
A TIEST:
City Recorder
REVIE'NED & flPPROVEIJ
AS TO FORI\/J
~<.:J">l"J''''_~ \..<l;ll\\~
DATE kZ~-n"'-
OFFICE OFCITY ATTORNEY
ORDINANCE NO.
PAGE 2 OF 2
2-2
,2007.
,--",
ORDINANCE NO.
(General)
AN ORDINANCE AMENDING THE SPRINGFIELD"ZONh'lG MAP BY REZONING
APPROXlMA TEL Y 5.24 ACRES OF LAND IDENTIFIED A'.rLANE COUNTY ASSESSOR'S
MAP 17-02-32"00, TAX LOTS 400 & 402, FROM LIGHT MEDIUM INDUSTRIAL (LMI) TO
COMMUNITY COMMERCIAL (CC). ',' -. ';.~ . ~-h' ~;>~, _ '" .'_.. ,
THE COMMON COUNCIL OF THE CITY OF SPRINGFIELD FINDS THAT:
I. Article 12 of the Springfield Development Code sets forth procedures for Springfield
Zoning Map ~mendments; and .
2. On March 16'h, 2007 the applicant/owner of the subject property initiated the following
Springfield Zoning amendment:
Rezone approximately 5.24 acres of land from Light Medium Industrial ,to Community
Commercial, Case Number' ZON2007-000 12, for property identified as Lane County As-
sessor's Map 17-02-32-00, Tax lots 400 and 402; and
3. On June 4''', 2007, the Springfield Planning Commission held a work session and public
hearing to receive testimony, and hear comments on. this proposal. A second public hearing was
held on June lSth, 2007 after the written record was left open for seven additional days and after
reviewing additional written testimony. The Planning Commission deliberated and voted unani-
mously (5-0) to forward a recommendation of approval to the City Council; and
4. On July 2"d, 2007 the Springfield City Council held a work session and a publi~ hearing
to consider and to receive testimony and hear comments on this proposal. The City Council is
"now ready to take action on this proposal based upon the above recommendation and the evi-
dence and testimony already in the record as well as the evidence and testimony presented at this
publlc hearing held in the matter of adopting this Ordinance amending the Springfield Zoning
Map.
NOW THEREFORE, based upon the foregoing findings the City of Springfield ordains
as follows:.
Section 1. The Springfield Zoning Map, more particularly described in Exhibit A at-
tached hereto and incorporated herein by reference, is hereby.amended from Light Me-
dium Industrial to Community Commercial.
. Section 2" If any section, subsection, sentence, clause, phrase, or portion of this Ordi-
. nance is for any reason held invalid or unconslitution'al by any court of competent juris-
diction, that portion shall be deemed a separate, distihct, and independent provision and
that holding shall not affect the validity of the remaining portion of this Ordinance.
FURTHER, although not part of this Ordinance, the Springfield City Council adopts
findings 1-4 herein above, and the findings set forth in the Staff Report which demonstrate con-.
formance of this amendment to Section 12.030 of the Springfield Development Code and to ap-
plicable Statewide Planning Goals, and is attached as Exhibit A.
ORDINANCE NO"
AmCH~ENT
3-1
ADOPTED by the Common Council of the City of Springfield this
, 2007 by a vote of _ for and _ against.
day of ,
APPROVED by the Mayor of the City ofSpri~gfield:'t~is~day of
~:.
''''',r;.\_.;'
..~';!~ .1H'i:~. .'l'l.A _ ~~ '_'. !'. .: :-t. ..
Mayor
ATTEST:
(
City Recorder
REVIEWED & iiPPROVED
AS TO FORM \
~~~""~
DATE: Jp::-2t:>-fTJ
OFFICE OF CITY ATTORNEY
ORDINANCE NO:
PAGE 2 OF 2
3-2
,2007.
i.
j
BEFORE THE PLANNING COMMISSION
OF THE CITY OF SPRINGFIELD
ORDER A1"1D RECOMMENDATION
FOR A METRO PLA1"1 / EAST MAIN
, STREET REFINEMENT PLA1"1 MAP
AMENDMENT AND A ZONL"IG MAP
AMEN"DMENT
+
+
+"
+
. ~A.SE NO. LRP2007-00013
CASE NO.ZON2007-00012
.. FINDING, CONCLUSIONS
AND RECOMMENDATIONS
. .~ . .}: ..:. - ~""
RE<::OMMENDATION TO CITY COUNCIL
. NATURE OF THE APPLICATION
This is a consolidated application for the above referenced case numbers" The applicant requests approval
of a Metro Plan / East Main Refinement Plan Map Amendment and a concurrent Z<?ni~g Map "
Amendment on properties identified as Lane County Assessor's Map No. 17-02-32-00, Tax Lots 400 and
402.. The request involves two contiguous properties near 44'h and Main Street. Specifically, the applicant
proposes to change Metro Plan' designation from Light Medium Industrial to Conunercial and a
concurrent Refinement Plan Map and a Zoning Map Amendment from LMI to Cc.
1. The subject applications for a Metro Plan / Refmement Plan map amendment and Zoning Map
Amendment were submitted to the Development Services Department dn March" 16'",2007, and
deemed as complete on April t I 'h, 2007.
2" The application was submitted in accordance with Section 3.050 of the Springfield Development
Code" Timely and sufficient notice'of the public hearing, pursuant to Section \4.030 of the
Springfield Development Code, has been provided.
3." On June 5~, 2007 a public hearing o'n the zone change request was held. The Development
Services Department staff notes including "riteria of approval, findings and recommendations,
together with the testimony and submittals of the persons testlfying at that hearing have'been
considered and are part of the record of this proceeding"
4" On June 19"', 2007 the Planning Commission considered additional information submitted into
the record as of June 13'h, 2007.
.
CONCLUSION
On the basis of this record, the proposed amendments are consistent with the criteria of Sections 7.070,
8 "030 and 12"030 of the Springfield Development Code" This general flUding is supported by the specific
findings of fact and conclusions in the attached staff report and attached hereto"
ORDER
It is ORDERED by the Plimning Commission of Springfield that approval of CaseNumber LRP2007-
000.13 and lON2007-000 12, be GRA1'iTED and a RECOMMErpA 1;10N for approval forwarded to the
Spnngfield City CounciL This ORDER was presented. to a. PtOvf'd by the Planning Commission on
Ju~e 19'h, 2007.. ~:; I .
. ' . Pia -nl Co~:ission Chairoerson "
ATTEST: . ( - '
A YES. 5
NOES J:L
i\BSENT: Jc
ABSTAIN L
ATTACHMENT.
4-1
BPRINaPIBLD
Type II Metro Plan Map Amendment
& Zoning Map Amendment
Staff Report ar,ld Findings
. ~J ,
....- .'
Hearina Date:
June 4i", 2007 - Planning
Commi~sion
June 18th, 2007 -
Planning Commission
July 2nd, 2007 - City
Council
ADDlicant
Case Number:
ZON 2007-00012
LRP 2007-00013
. PeaceHealth Oregon Region
123 International Way
Springfield, OR 97477
Hyland Business Park, LLC (TL 400)
Attn: Shaun Hyland
.1941 - A Laura Street
Springfield, OR 97477
Andrew Head (TL 402)
1616 Ardendale Ln"
Eugene, OR 97405
Aoolicant's
Rel)resentative
Philip Farrington, AICP
Director: Land use
Planning & Development
PeaceHealth Oregon
Region
. 123 International Way
Springfield, OR '97477
. Owner
Date Submitted:. March 16th; 2007
EXECUTIVE SUMMARY: .
The applicani is seeking approval of a Metro Plan Amendment I Refinement Plan
Amendment and a concurrent Zoning Map Amendment from lightMedium Industrial
(LMI) to Community Commercial' (CG). As described in the Springfield Development
Code, a Refinement Plan Amendment automatically occurs on a site concurrently with a
Metro Plan Amendment if no new Refinement Plan text is needed or proposed""The .
.applicantis requesting these amendments in order to pu~sue'a future Medical Office.
building on the subject site. The subject site is located within the East Main Refinement
Plan area. ' ! . .
The subject site is located near 44th and'Main Street (Highway 126). The site consists of
two parcels, and is located on approximately 5.24 acres identified as Tax Lots 400 and
402 on Assessor's Map No. 17-02-32-00 The majority o{thesite is vacant (TL 400), with
some small vacant buildings on site. The smaller of the two subject lots, TL 402, has an
existing commercial development on-site Properties located to the north are zoned and
designated heavy industrial. Parcels located west of the subject site are designated
niixed-use on the East Main Refinement Plan" Property located east of the subject site is
designated LMI. Properties located south of the subject site, across Main Street, are
zoned and designated Community. Commercial. .
As mentioned in findings in this report, Staff supports the proposed Metro Plan I
Refinement Plan and Zoning Map Amendment. As noted in the City of Springfield's 2000
lRP2007-000 /3 & ZON2007,OOOI2
ATTACHMENT
.~_1
Commercial enterprises are located immediately south of the site across Main Street
. (e.g", Gray's Garden Center). '
While historically involved in agricultural uses, since 'around 1990 Tax Lot 400 was used
as a ,storage and sales yard for landscape organics and forest by-products. The current
property owners also used the site to store 1T10dula~ construGtion offices, tool trailers,
construGtion equipment and concrete form plywood,. Tax Lot 402 has had various
commercial serVices on site. since the 1950s' .
The properties have no jurisdiGtional wetlands or inventoried Goal 5 natural or historic
resources" The site is within the Springfield Urban Growth Boundary, and both parcels
were annexed into the City of Springfield in 1960. The East Main Refinement Plan
(EMRP) diagram (adopted in 1988) currently designates, the subject property for
industrial uses. "
The abutting property to the east ,is designated LighUMedium Industrial in the EMRP
diagram and zoned LMI. The areas immediately to the west and south of the site
fronting Main Street are identified as being within Mixed-Use Area #2 inthe EMRP, and
are all zoned Community Commercial. Property' to the west of Tax Lot 400 along44lh
Street is zoned and de'signated Medium Density Residential.
J
LRP2007-000J 3 &"ZONl007-000/2
0:-3 _
.
3
Existing & Proposed Metro Plan Designation:
~
-I
J I
I !
~ Change from Light Medium Industrial to Commercial
Metro Plan Designation
. Commercial MU
o Light Med. Indus!.
o Low Den. Res.
D Med. Den. Res.
_ Heavy Industrial
w;::~
~Q~""""rraM",IhaIOO:Onptnythhf"'OducL
lMfJ<WJj,,",uJJ'/l:'ipuMibllJlyponyJ.wOl'da~{rirt"g
jrwrt01'l)'ff'TIX,O"'_""UpnlOonaI/na(:Ql.fUCYO!IhupnxJ>.ct
..
""'....
,
June, 2007
lRP2007~0013 & ZON2007,OOO/2
4
Existing & Proposed Refinement Plan Designation:
"""ST
In
r
~
~
~
J
I I I I
I r-.. .
~ Olange from Light Medium Industrial (LMI) to Commlllity Commercial (CC)
Refinement PI",
_ Community Commercial
Low Dens,y Residential
_ Medium Density Residential
- Ught-Medium l!'dustrial
_ Heavy l!'dustrial
_ Mixed Use 2 & 3
,
l.\LiIi
v.,...,QI"I'IIO..a...../ieJdw;u""""",....,ydwproJuct
lMn_QiJr8pOMlb'htyfr...Y"..".......IffQg<tDnnltJ:
fmm<UlY_. omwlOll<l p>>jllum/lnat:cwrx:yoflill'prodwct
'"
""'''''
,
June, 2007
LRP1007-000/3 & ZON1007-000/1
5
l
Existing & Proposed Zoning:
~
I
I
EII/I-j-A-
.
--
~ Olange from Light Medium Induslrial (LMI) to CommlA'lity Commercial (CC)
Zonirg
_ Medum Density Residential
LDw Dens~y Residential
_ Community Canmercial
Ughl Medilrn Industrial
_ Heavy Irdustrial
Wi.:~
Thertarr"""_/le:I'thtJl~)llhuprotAlcl
lMn 4U1UItt'flO rnp"nn"'lityp""y loDorJa.ogransl1f8
fro",..., 1'7'01'. omwiOlftr t-I/iDftoJ ..acamryofdtuproJuu
""
"'....
June, 2007
l1lP200HJ0013 & ZON2007.{)0012
6
Existing Site Conditions:
Existing commercial uses on TL 402
"I"'
1":/
}i1h"'
r'i'.l'/
\'~ '\.' I .'-"
~.~.~ r"',,/J .;'.1'
~~~,I,. ..,\ 'il rl' If"'"
: i,IIO' I ~'I'I. '
~" "\: ~," · {~:(~iN .'.
~!~~~" i, Y'.if.f
-.r.G~L ~.,~~'!,~'i' .~t
LIf.i~. ----lllLi.. ~ i I ',~>;' i\ . .
.~fll WI": n -rP ~;"~, ".
/: .~~;;' n i i1, t.J I'" ".~ . .:
.
.....L~...
J!' ,
..-~..-....- -
~
I Existing modular units located on TL 400
LRP2007.{)0013 & ZON2007,OOOl2
Existing empty structures on TL 400
Existing business park on property located east of TL
400
7
REVIEW PROCESS:
The p;oposed Metro Plan Amendment is a Type II,Amend;;'ent because it is located
inside the city limits and is site specific. The applicant has requested that application
ZO~2007-00012 (Zoning Map Amendment) be.raised 1.oaType IV review procedure .
and be reviewed concurrently with the Type II Metro Plan I Refinemen\Plan Amendment
Application lRP2007 -00013. These two applications use similar criteria of approval and
have been combined into one staff report for ease of review. Both applications have
criteria requiring' consistency with the Metro Plan and other similar criteria. Rather than
repeat these crite~ia for each application, they will be addressed only once and then
referenced where appropriate. Criteria that are different win be addressed separately;
the end result will be that all applicable criteria will have been addressed.
," .. - -. ..
. ,
This application was submitted to the Development,Services Department on March 16th,
2007, and deemed as complete on April1,1'h, 2007." Notice for both applications.was ."
mailed toDepartment of land Conservation and Development (DlCD) on April 16'h; : .
2007. Notice of the public hearing date was mailed out on Thursday, April 19, .2007 to
property owners within 300 feet ofthe proposed zone change per Section 14.030 (1).(a)-
(n) of the SOC. Public notice of the hearing was published in the local newspaper
(Register Guard) on May 17111, 2007, as required in Section 14.030 (2) of the SDC" No
written comments were submitted at the time of issuing tilis report.
METRO PLAN DESIGNATION:
The subject property is designated LMI as shown in the Metro Plan diagram" The
subject property is part, of the East Main Refinement Plan (EMRP), which provides a
more localized scope related to Plan Designation. The subject prope.rty is designated
lMI on the Refinement Plan Diagram" Specific Findings related to the Metro Plan and
EMRP Street Refinement Plan Designation are written in this report.
METRO PLAN DIAGRAM AMENDMENT
CRITERIA OF APPROVAL - SDC 7.070(3)(a)-(b)
"The following criteria shall be applied by the City Council 'in approving or denying a
Metro Plan amendment application' . .
(a) The amendment must,be consistent with the relevant Statewide."
" planning goals adopted by the Land ConsefYation and Oevelopment
Commission; and .
(b) Adoption of the amendment must not make the Metro Plan internally
inconsistent. " .
CRITERIA OF APPROVAL - SDC 7.070 (3)(3).
APPLICANT'S NARRATIVE:
'.
Consistency with' Statewide Planning Goals:
LRP2007.0001J & ZON2007~0011
.5-9
s.
8
The following findings address compliance with Metro Plan criteria in SDC 7.070 (3)(a).
Approval of a Metro Plan diagrani,amendment also corresp,?ndingly changes the
applicable refinement plan diagram, as established.inSQQ"7.).10 (4). "
APPLICANT'S NARRATIVE RELATED TO GOAL 1:
_ . '. t" ",". ."....,'.',:,., '
Goal 1- Citizen Involvement: To.develop~ citiieninvCilvii'ni~ntprogram that insures
the opportunity for Citizens to be involved in a/l phases of the planning process.
"
Goal1 addresses the need to develop a citizen involvement program to ensure citizen'
involvement in all phases of the land use planning process. The Planning Commission
and the'City Council will hold 'public hearings and accept testimony on the proposal. .
Through the procedures established by the city, citizens will receive notice of hearings in
gener.ally published local papers and have the opportunity to be heard regarding the
proposed diagram amendment and zone change. Notice of the public hearings.will also be
given in accordance with SDC requirements to nearl5y property owners, interested parties
requesting notice, and any establish.ed neighborhood organization. Since the.
amendmen'ts comply with the City's citizen involvement program a"nd citizens have "
opporturiities to be involved in the procedure, the proposed amendments are consistent
with Goal 1. ." ." . "
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 1:
Finding 1: These applications comply with Goal 1 because they are being reviewed
under an acknowledged citizen involvement p'rogram.
. Aspreviously mentioned in this repor:!, notice for both applications was mailed"to
. Departmentof Land Cons'ervation and Development (DL:CD) on April 16'h, 2007.
"Notice of the public hearing date was mailed out on Friday, May 11th, 2007 to
property owners .within 300 feet-of the proposed zone change per Section 14"030 (1)
(a)-(n) of the SDC Public notice of the hearing was published in the local newspaper
. (Register Guard) on May 17'h, 2007, as required in Section.14.030 (2) of the SOC.
Staff concurs with the applicant's written statement related to Goal 1.
APPLICANT'S NARRATIVE RELATED TO GOAL 2:'
Goal 2: Land Use Planning: To establish a land use planning process and policy
framework as a basis for all decision and actions related to use of land and to assure
an adequate factual base for such decisions and actions.
Goal 2 requires that local comprehensive plans be consistent with the Goals, that local
comprehensive plans be internally "consistent, and that implementing ordinances be "
consistent with acknowledged comprehensive plans. Goal2 also requires that land
use decisions be coordinated with affected jurisdictions and that they be supported by
an adequate factual base. As required in SDC 7.050, the City is required to give
referral notice of the proposed Type II Metro Plan diagram a~endment to the City of
Eugene and Lane County so they may determine if there are grounds to participate as
parties to the hearing. The City also sends the statutorily required notice of the initial
public hearing 45 days in advance to the state Department of Land Conservation and
Development, ensuring that they are given opportunity for comment and review
conformity to applicable statewide planning goals. . .
LR?2007-000 I J & lON2007-00012
9
F:-H\
The Metro Plan and theSDC, as well "as the Statewide Planl)ing Goals and applicable
. . statutes, provide policies and,:criteria for the evaluation:d comprehensive plan
"amendments. Compliance with these measures assur"es an adequate factual base for
. approval of the proposed Metro Plan diagram amendment. As discussed elsewhere in
this document, the amendments are consistent with the ,Metro Plan and the Goals.'
Consequently, bydemonstrating such compliance, the amendments satisfy the
consistency element of Goal 2. . '"<.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 2:
Finding 2: These applications comply with Goal 2 because the SDC requires
consistency between the Statewide Planning Goals, the acknowledged Metro Plan,
adopted refinement plans and special area plans and the zoning.
Staff concurs with t.he applicant's written statemenrrelated to Goal 2.
APPLICANT'S NARRATIVE RELATED To GOAL3: ,"
Goal 3 _ Agriculiural uirid: To preserv.e and maintain agriculturalla~ds. "
This goal is inapplicable because as provided in OAR 660-15-000(3), Goal 3 applies only to
rural agricultural lands. The subject properties are located within an acknowledged urban.
growth boundary, are inside Springfield's corporate limits, and have not been in
agricultural use for decades. .
J
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 3:
" , Finding 3: The 'subject property is located within the city limits on land planned and
zoned for urban use" The City does not' have any agricultural zoning districts, either
within its city limits or within the urban growth boundary. .
Finding 4: Goal 3 does not apply to these applications because the subject property
is' within Springfield's city limits.
APPLICANT'S NARRATIVE RELATED"TO GOAL 4:
~
Goal4 _ Forest Land: To conserve forest lands by maintaining the forest land base
and to protect the state's forest economy by making possible economically efficient
forest practices that assure the continuous growing and harvesting of forest tree
species as the leading,use on forest land consistent with sound management of soil,
air, water, and fish and wildlife resources and to provide for recreational opp.ortunWes
and agriculture. . " .
Goal 4 does not apply within urban growth boundaries', per OAR 660-06-0020, and the
" areas affected by the Plan amendments are inside Springfield's acknowledged UGB.
. ,
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 4:
FindingS: The subject property is located within an acknowledged urban growth.
boundary. Goal 4 does not apply within urban growth' boundaries" Staff concur with
. the applicant's written statement rela,ted to Go'al 4
lRP2007:000 /3 & ZON2007,OOOJ 2
/0.
,~-11
APP.L1CANT'S NARRATIVE RELATED TO GOAL.5:
Goal 5 -Open Spaces, Scenic and Historic Area, and Natural Resources: To conserve
open space and protect natural and scenic resources.
GoalS requires local governments to protlictii\va.riety1of open"space, scenic, historic, and
natural resOurce values. GoalS and its implementilig"rlJle, OAR Ch. 660, Division 16, .
require planning jurisdictions, at acknowledgment and as a part of periodic review, to
(1) identify such' resources; .
(2) determine their quality, quantity', and location; .
(3) identify conflicting uses;
(4) examine the economic, social, environment"l, and energy (ESEE)
consequences that could result frqm allowing, limiting, or prohibiting
the conflicting uses; and
(5) develop programs to resolve the conflicts.
, "
The subject properties are not on Springfield's acknowledged Metro Plan Goal 5 inventory.
No threatened or endangered species have been inventoried on the site, and no "
archeological or significant histo.ricalinventoriedresources are iocated on the site. The
National Wetland Inventory and Springfield Local Wetland Inventory maps have been
consulted and there are no jurisdictional wetlands located on the site. Thenifore, the
proposed amendment does not alter the Ci!y's compliance with Goal 5.
STAFF'S FINDINGS RELATED TO COMPLlANCE,WITH GOAL 5:
Finding.6: GoalS does not apply to these applications because there are no
inventoried resources on the subject property. Oregon Admini'strative Rule 660-023-
0250 establishes the applicability of Goal 5 rules toPost Acknowledgement Plan
Amendments (PAPA), the requested Refinement Plan Amendment and Zoning Map
Amendment do not affect the Metro Plan's adopted Goal 5 inventory. Staff concurs
with the applicant's na'rrative related to GoalS compliance"
APPLICANT'S NARRATIVE RELATED TO GOALS:
Goal 6 _ Air, Water and Land Resources Quality: To maintain and improve the quality
of the air, water and land'resources of the state.
The purpose of GOal 6 is. to maintain and improve the quality of the air, water and land
resources of the state. Generally, Goal 6 requires that development comply with
applicable state and federal air and water quality standards. In the context of the
proposed Metro Plan diagram amendment, Goal 6 requires that the applicant demonstrate"
that it. is reasonable to 'expecUhat applicable state and federal environmental quality
standards can be met. -
Though Tax Lot 400 has been" used for low-value storage and quasi-industrial uses, the
site is not listed on any state or local environmental clean-up list. A Phase 1
environmental assessment on the subject property was conducted and recommended
additional analysis. Upon recommendations through the Phase 2 environmental.
assessment a nominal quantity of soil (less than 10 cy) impacted by earlierlhistoric use
was removed from the site and properly disposed. Given the nominal impact generated by
historic uses on the site, it is reasonable to conclude that future development on the site
will be able to demonstrate compliance with City standards for water quality protection
LRP2007-00013 & ZON2007,OOO/2
II
5-12
J---<.,
th.rough the site plan review process, the'reby complying with applicable state and federal
environmentaJ'quality standards.", "
J . . , "
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 6:
. "
Finding 7: The proposed Metro Plan / Refinement PI~n.Amendment or Zoning Map
Amendment does not modify any of the Goal 6 related policies of the Metro Plan nor
. do they amend the Regional Transportation Plan, the Springfield Development Code,
other applicable Goal 6 policies, or any regulations implementing those policies.
The subject property I:; located in the Zone of Contribution and outside any of the
Time of Travel Zones, which is regulated by the Drinking Water Protection Overlay
District _ Article 17. Any new development on the subject property is subject to
compliance with Article 17 and other applicable regulations related to Goal 6" 'Staff
concurs'with the applicant's narrative,related to,Goal 6 compliance.
APPLICANT'S NARRATIVE RELATED TO GOAL 7:
Goal 1 _ Areas Subject to Natural Disaster~ and Hazards: To protect life and"property
from natural disasters and hazards.' .
Goal 1 requires that development subject to damage from na~ural hazards and
disasters be pla"nned andlor constructed with appropriate safeguards and mitigation.
The goal also requires that plans be based on an inventory of known areas of natural
disaster and hazards, such as ~reas prone to landslid~s, flo?ding, 'etc. .
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 7:
Finding 8: Staff has reviewed the natural constraints map and th"e FEMA Floodplain
Map in relation to the subject property. As noted by the applicant, the subject site is
. .not included in the City's inventory of known areas of natural hazards. Staff concurs
with the applicant's narrative related to Goal7 compliance. .
. The site is flat and ~ot'subject to landslide hazard~, and is located well outside of ~ny
. established FEMA flood hazard area. . Therefore, approvaL of the proposed Plan
amendment and Zoning Map Amendment will not alter the City's acknowledged
compliance with Goal 7 through its adopted plans, codes and 'procedures.
APPLICANT'S NARRATIVE RELATED TO GOAL 8:
. .
Goal 8 _ Recreation Needs: To saiisfy the recreatibnal needs of the citizens of the state
and visitors and, where appropriate, to provide for the siting of necessary rec~eational
facilities including destination resorts. " ," .
, , .
Goal 8 requires local governments to plan and provide for the siting of necessary
recreational facilities to "satisfy the recreational needs of the citizens of the state and
visitors," and where "appropriate, provide for the.siting of recreational facilities including
destination resorts. The subject site is not included in an inventory of recreational sites,
and the proposed amendments will not have an impact on the community's recreational
facilities or needs; therefore, the proposal does not implicate. Goal 8. .
l
LRP2007.0001J & ZON2007.000/2
12
5~13
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 8:
Finding 9: Staff has consulted the Wi/lama/a(je2.0~yea.r F:arks and Recreation
Comprehensive Plan in relation to Goal 8 compliancEi'. the Wi/lama/ane 20-year
Parks and Recreation Comprehensive Plan was adopted by the City of Springfield as
. part of the Metro Plan's compliance with Goal 8. None of the various studies
inventories, and facilities plans regardlng're.cfeational facilities in the adopted
Wi/lama/ane 20-year Parks and Recreation Comprehensive Plan have designated
the subject site for parks and open space in an adopted inventory, declared it a
significant resource, ,or slated it for acquisition. Staff concurs with the applicant's
narrative related to Goal 8 compliance.
L
APPLICANT'S NARRATIVE RELATED TO GOAL 9:
\ . .
GoJI 9 _ Economic Development: To provide adequate opportunities throughout the
"state for a variety of economic adivities vital tei the health, welfare, and prosperity of
Oregon's citizens.
Goal9 requires 'the city to provide adequate opportunities for a variety of economic
" activities vital to the health, welfare, and prosperity of the citizens. The proposed
amendment to the Metro Plan diagram will increase the city's capacity for economic
development by adding 5 acres' of CC in place of the existing industrial designation.
Permitting the construction of future clinic facilities and allowing long-standing
commercial uses on Tax Lot.402 to become conforming uses consistent with commercial
zoning is consistent with.numerous policies in the City's adopted plan for compliance with
Goal 9, the Springfield Commercial Lands Study (SCLS).
Specifically, the following SCLS policies are applicable to the proposal:
Policy"1-A: ,"Maintain a mixed supply of large and small commercial sites through
strategies such as rezoning or annexation to serve Springfield's future population."
The proposal fulfills this policy objective by redesignating and - through accompanying"
zone change _ rezoning land from industrial to commercial, for tWo tax,lots of varying
"sizes and commercial uses, thereby m~intaining"existing employment and commercial use
in Tax Lot 402 and providing the ability for growth in medical sector employment by
allowing future clinic uses on Tax Lot 400. '
, .
Policy 1-C: ."Maintain at least a five-year supply of commercial land within the Urban
Growth Boundary (UGS) that is currently served or readily serviceable with a'full range of
urban public facilities and services." .
The SCLS (see Table 3-8, pg. 32) found there to be a deficit of 158 acres in the supply of
commercial land over demand projected through the year 2015. The proposal would allow
for redesignation, and rezoning, of five acres thereby reducing the deficit.of commercial
land. The subject site has a full range of urban public facilities and services available to
s"upport existing commercial development on Tax Lot 402, and future. development on Tax
Lot 400. The SCLS identifies (pg. 33) a need to support "employment in population-
dependent sectors such as retail sales and health services" to meet Springfield's growing
comIT!unity. The SCLS also noted (pp. 27 -29) state and local trends in greater em'ployment
in retail trade and well-paying health services sectors. Approving the proposed
redesignation and zone change would help meelSpringfield's demonstrated need for
employment and commercial services.
lRP2007,OOO/] & lON2007-00012
I]
S-14 !
J
Finding 3'in the SCLS (pg. 36) cited theacknbwledged 1992 Industrial Land Study as
demenstrating that "a surplus of industrial sites exists in the Metre Area." Therefere, the
" prepesed redesignatien (and cerrespending rezening) weuld net result in a deficit .of
need'ed industrially designated and zened land, butitweuld help reduce the cemmercial
lands deficit identified in the SCLS. Therefere, appreving'the prepesal weuld be
censistentwilh SLCS Implementatian Strategy 3-A (1): "Evaluate inventeries based"an
demenstrated need fer the planning peried. Initiate rezeni~g.ar redesignatian .of surplus
land uses w~ere ri)are apprapriate far cemmercial, cansistent with the Metro Plan:"
The propasal in f~ct censistentwith inventaries far cammercial and industrial lands
adapted by the City Ceuncil and acknawledged by DLCD as being censistent with Gaal 9.
Oregan Administrative Rules cencerning Gaal.9 implementatian (OAR 660-009-0010(4))
call for amendments te land use designatiens "in excess .of twa acres within an existing
urban grewthbaundary frem an industrial land use,designatien ta a nen-industrial use
designatien'; to have to'address applicable planning requirements':' such as censistency
with the Metre Plan and ather lecal plan palicies (i.e., SCLS) .or becensistent with an
ecenemic appartunities analysis. The City can find that the prapasal cemplies with
relevant lecal plan palicies by cenverting .one farm .or empleyment-generating land use te
anather, witheut negatively impacting the supply .of buildable lands fer either categery .of
uses. The prepasal enables centinued use .of the" existing 'and lang-'standing cemmercial .
center ta cantinue ta .operate and prevideemplaym"nteppertunities, while alse allewing
higher-value emplayment assaciated with"futuredevelapment en Tax Let 400. These
types .of empleyinent,generating uses are,ameng these identified in OAR 660-009-0005(6)
as eligible nen-industrial emplayment activities that can justify approval .of the prepesed
Plan diagr'am amendment withe!!t the need far an econemic appertunities analysis apart
frem the"SCLS, which DLCD acknawledged as fulfilling the City's abligatiens under Geal 9.
I
" Because the' requested redesignation and cencurrent zene change implements SCLS
pelicies and dees nat result in a deficiency .of needed industrial lands, and is .otherwise
demenstratedta be censistent with relevant Metro Plan policies, appreval efthe request is
censistent with the City's cempliance with Geal 9 and applicable administrative rules
regarding Gaal 9 implementatian. "
Additian~l Geal 9 infermatien submitted by applicant an March 28th, 2007:"
The Metrepalitan Industrial Lands Study (July 1993) was adepted by the local j~risdictiens"
and acknewledged by LCDC as being 'censis'tent with statewide planning geals and the"
Metro Plan, specifically fulfilling the Eugene-Springfield a(ea's ebligatiens under Gaal 9
(Ecenemic Develepment). The Metropelitan Industrial Lands Inventery Repert asseciated
with the MILS identified "abeut 1,688 censtraint-free industrial acres....This supply
exceeds the prejected demand aver the next twenty years, which'is between 650 te 1,H2
acres." (pg.. 73) The Inventery Repert alse stated: "The 1,688 censtraint-free acres may be
the best suited te meet shert-termindustrial demand: This pertion .of the supply alsa
exceeds the tv,ienty year de,;,and prejectien." . . .
The City"perfermed sUbsequent"analysis .of industrial land' supply as part .of periedic
review requirements te demenstrate cemplian,ce witJi statewide planning Geal 5(Natur~1
Reseurces). As shawn in Attachment A, that analysis indicated that even remeving the
pessible industrial acreage affected by Geal5 "pretectienmeasures (abeut100 acres
debited frem th"e Eugene and Springfield inventeries) weuld leave a surplus .of industrial
lands .of between 1,600 and 2,122 acres metre-wide. " .
Staff's Geal 5 werk alse calculated th.e changes in industr'ialla'nd supplies since 1991 as'a
censequence .of Metre Plan diagram changes (see Attachment B). This analysis
demonstrated a reductien in less than 90 acres efindustrialland ever the pa~t 15 years,
ii'
LRP200 7.000 I J & ZON2007.ooo12
/4
5':'15,
s\lggesting that there is still an ample supply of available industriallands to meet existing
and future development needs." . . ," ". . .
This analysis may also not reflect other changes~ithinindustriallY designat~d land
categories that ~ould further off-set the proposed change.to the site's LMI Plan .
designation and zoning. For example, 11.5 acres~,^,~"s.ad~edto the inventory of LMI zoned
and designated land due to City Council appr'o'v'a(in'!l:p"riI1997,for land east of the 28'"/31"
Street connecto'rand north of Marcola Road (Ordinance No.,5851). Insofar as the City and
metropolitan area continue to enjoy a surplus of needed Industrial land, and specifically
Heavy Industrial zoned and designated land, the above-referenced change added more
than enough acreage to the inventory of LMI designated and zoned land to off-set the
proposal to remove only about 5 acres from the LMI inventory. .
We therefore 'respectfully submit that the proposed Metro Plan diagram amendment and
zone change,will not materially affect'the inventory of needed Indus~rialland and will not'
alter the City's continued compliance with Goal 9. .
STAFF'S FINDINGS RELATED TO COMPLiANCE WITH GOAL g:
Finding 10: The City of Springfield has two adopted inventories which support the
proposed Metro Plan Amendment'; Refinement Plan Amendment and concurrent zone
change request _ the 1992 Industrial Land Study and the 2000 Commercial Land Study.
. The applicant references both of these adopted inventories and sites specific polices
which support the proposal. As noted by the applicant,' Finding 3 in the Springfield
Commercial Land Study (SCLS) cjted the acknowledged 1992 Industrial Land Study as
demonstrating that "a surplus of industrial sites ex'lsts in the Metro Area"" The appl'icant
also references Strategy 3-A(1) of the SlCS which states: "Evaluated inventories based
on demonstrated needJor the planning period. Initiate rezoning or redesignat,ion of
surplus land uses where more appropriate for commercial, consistent with the Metro
Plan." Staff finds that these referenced policies and adopted strategies support the
applicant's proposal.' .
In addition to referencing the SCLS and the 1992 Industrial Land Study, the applicant
also references the adopted Goal 5 inventory work, which provides a more up-to-date
analysis of industrial lands in the,Metro area. As noted in the City of Springfield Goal 5
analysis, even with a reduction of inventoried ind~strialland .affected by Goal 5, there ,is
a still a surplus of between 1 ,600.and 2,122 acres metro-wide. .
As no!ed by the applicant, Oregon Administrative RUles:concerning Goal 9 .
implementation (OAR 660;009:0010) call for amendments to land use designations "in
excess of two acres within an existing urban groWth boundary from an industrial land use
designation.to a non-industrial use designation" to have to address applicable planning
requirements _ such as consistency with the .Metro Plan and other local plan policies
(i.e. SCLS) or new consistent with an economic opportunities analysis (EOA). OAR 660-
009-0010 states that a reviewing authority can find that the proposal complies with
relevant local plan policies by converting one form or employment-generating land use to
another, without negatively impacting the supply of buildable landS for either category of
uses" As noted by the applicant, there are existing commercial uses located on TL 400
which are part of the subject pr9perty Additionally, the applicant is seeking to develop
future commercial uses on the property which will maintain the property for"employment-
generating activity" .,'
LRP2007.000 /] & lON2007-000/2
/5
. ii-1R
!......-
Given the information provided in the adopted commercial and industrial lands
inventories (a shortfall of commercial and an inventoried, excess of Industrial land)
compared with the size of the proposed i;'lan AmendmenCand Zone Change; staff find
that the proposal is consistent with Goal 9 requirements. Staff finds.that the proposal
does not represent a "significant change' to the adopted EOA. '
APPLlCANT;S NARRATIVE RELATED TO GOAL 10:
Goal 10 _ Housing: To provide for the housing needs of citizens of the state.
LCDC's'Housing goal requires cities to maintain adequate supplies of buildable lands for
needed housing, based on an acknowledged inventory of buildable lands. The proposal
does,not affect the City's inventory of residential lands.
In fact, approval of the requested redesignation for Tax Lo~ 400would enable
redevelopment of an industrial site abutting existing residential development. Through:
the site plan "review pr9cess, future development on that property will provide a superior
buffer and a higtier use that will benefit the adjoining residentialll.ropertie~. Because the
proposal involves redesignation from industrial to commercial land use?, it does not affect"
Springfield's continued compliance with Goal 10.
'. ..
I
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 10:
. Finding 11: The' proposed Metro Plan I Refinement Plan Amendment.and Zoning
M?p Amendment does not affect the Metro Plan's residential buildable lands "
inventory because no residentially designated properties are involved in this
. proposaL .' '
The City of Springfield is currently working with a consulting company on a
residential land inventory and land supply analysis" When complete, this study will
update the City's inventory and provide a clear picture of residential land supply.
Staff concurs .with the applicant's 'response to Goal 1 0 compliance.
APPLICANT'S NARRNIVE RELATED TO GOAL11:
Goa111- Public Facilities and Services: To plan and develop a tim~/y, orderly and efficient
"" arrangement of public facilities and services as a framework for urban and rural
development. ',' . . ,
. "
OAR 660'011-0005(7)(a)-(d) Definition of Public Facilities:'.
I a) Water
Ib) Sanitary Sewer
Ic) Storm sewer
Id) Transportation
This goal requires the provision of a timely, orderly and e'fficient arrangement of public
facilities and services. The ~ubject property is located within the Springfield UGB and city
limits, and is already designated for urban levels of use. 'The proposed amendment to the
Plan map designations fro"m LMI to CC will not affect the ability to provide needed services
sjnce alUhe required urban services are available to support existing or future commercial
uses ~:m" the subject site. ,. " '
LRP2007-0001 J & ZON2007-000/2
/6
5-17
"
STAFF'S FINDINGS RELATED to COMPLIANCE WITH GOAL 11:
, .' .
Finding 12: As noted by the applicant, the MelroPlan and associated facility plans
have been acknowledged to conform to Goal 11 ensuring that public facilities and
services are currently available t.o the subjEl~ct.~A~:;,(J~~lP,1Cl,P~,sed Metro Plan I
Refinement Plan Amendment and ZOning Map.amendment IS "on "Infill" property,
which currently has city services available to the site" The proposal does not affect
the Metro Plan's compliance with Goa111. ..
Finding 13: The subject Metro Plan I Refineme'nt Plan Amendrnent and Zoning Map
Amendment applications have been reviewed by Public Works and Planning Staff to
assure that there are adequate public services to serve the site. These applications
comply with Goal 11 because there' are urban level public services available to the'
subject property. .'
APPLICANT'S NARRATIVE RELATED TO GOAL:"12:
Goal "12 _ Transportation: To provide and encourag,e a safe, cOflvenient,and economic
transportation system. "
Goal 12 requires local governments to provide and encourage'a safe, convenient and .
economical transportation system. The proposed map amendments involve
approximately 5.24 acres Of property, though existing and long-standing commercial uses
occur on Tax Lot 402 "such that approval of the proposal will not result in any change"s'to
the type or intensity of uses on the site, and will not increase the trip generation for that
parcel. As the attached Traffic Impact Analysis' (TIA) demonstrates, future development of
medical office facilities on TL 400 will not degrade mobility standards below acceptable
levels and' allow for adequate queuing lengths at applicable intersections. Therefore, the
proposal will not have a "significant effect" on transportation facilities as defin<id in the
Transportation Planning Rule (OAR 660-012'060). . .
Existing development at Tax Lot 402 is not'affected by the proposal, and is assumed to
retain its current access points off Main Street. It is further assumed that future
development on Tax Lot 400 will result in some access changes as will be reviewed
through the site plan review process, thereby consolidating two existing curb cuts located
on Tax Lot 400 into a single access point located approximately in the center of the parcel.
The TIA demonstrates that these access points will not result in any degradation of
mobility standards below acceptable levels, and that safe and efficient circulation can be
real,ized through approval of the requested land use redesignation "(and companion zone
change~ .
Furthermore, reducing the number of access points for future deyelopment on Tax Lot 400
is consistent with policy objectives found in East Main Refinement Plan (EMRP) Acc.ess,
Circulation & Parking Element policy 1B (pg: 17) and Commercial Element policy 3 (pg.
1~. .
Because the proposal, as demonstrated in the TIA, is consistent with the requirements of
the TPR and with applicable policies in the EMRP, it is consistent with Goal12 and
applicable local implementing policies.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 12:
Finding'14: The proposed Metro Plan Amendment is from LMI tciCommercial, and
'Refinement Plan Amendment I Zoning Map Amendment is from LMI to CC. The
applicant indicates in the submitted narrative that approval of the proposal will not result
LRP2007,00013 &< ZON2007.00012
5..18
II
I
,.
.
17
inany changes to the type or intensity of uses on thesite,;and"will not increase the trip
generation for that parcel. Staff does not concur with this statement in reviewing all of
the" potential CC uses on the site. Staff does concur, however, with the applicant's
statement if the future medical office use is in fact develo~ed on the site, and not other
potential "reasonable y;orse case" CC uses. '. .
Pages 18-19 of the applicant's TIA list Peak Hour'Trip GenerationfoLboth the existing
zone (LMI) and the proposed zone (CC). The applicant's TIA listed Peak Hour Trip
Generation for Medical Office Building. While this is a permitted use in the CC zone and
is the primary use that the applicant is seeking to use the, property for, it is not the
"reasonable worse case" scenario for traffic generation given other allowable uses'in the
CC zone. During Staff's review of the proposal, staff researched potential vehicle trips
per day for potential uses in the CCzone. There are soine other potential uses in the CC
zone which are much more intensive uses than Medical Office. In considering what a
"reasonable worst case" development scenario might be for the re-zoned condition it is
clear that a 30,000 square foot Medical Office"Building is much less intense than other
uses that would be permitted in the CC zone. On a per-square-Ioot basis.the Medical
Office is estimated to generate 2.47 vehicle tips/1 ,000 SF and 3"~\3 vehicle tips/1 ,000 SF
during the AM and PM peak hours respectively" For comparison.tlie'average rates for a
"Fast-Food Restaurant with Drive-Through Window" are 53.11 vehicle tips/1 ,000 SF and
34.64 vehicle tips/1 ,000 SF" These calculations are taken from the Institute for Traffic
Engineers (ITE) Manual.' , ' '." .
"
,
As shown on Table 6 of the TIA, a 'reasonable worse case traffic.generation. scenario for
" .
the existing zoning (LMI) is 243 trips The proposed use of Medical Office Building is .
shown in Table 7 as 177 trips. While the Medical Office use trip generation is less than
the reasonable worse case scenario for the existing zoning, it does not take into account
other more intensive commercial uses (i.e. drive thru restaurants, banks, etc.). Planning
Staff met multiple times with City Traffic Engineering Staff and ODOT Staff to review the
submitted.TIA. ODOTs review of the submitted TIA indicated thanhere were multiple .
issues.that were not adequately addressed in the submitted TIA to justify compliance
with Goal 12 (see.attached memo from ODOT): Based upon the information provided in
the submitted TIA, all reviewin"g parties (i.e" City Planning Staff, City Traffic Engineering
Staff, and ODOT Staff) agreed on a recommended "condition of approval (see attached
emails from ODOT and City Traffic Engineering Staff). In' order to preserve the existing
and future road system, staff recommends that a trip cap"be required as a condition of
approval norto exceed the reasonable worse case scenario for the existing zoning (243
trips). Because ttiese numbers of trips are already allowed with th~ existing zoning, the
application complies with Goal 12"
Recommended Condition of Approval:
1. Trip generation .from development on the subject property shall be limited to a
maximum of 243 PM Peak-hour vehicle trips, which is based on a "reasonable worse
, case development scenario" under the existing zoning (LMI)" as submitted by the
applica'nt'in the Traffic Impact Analysis for the subject property.
LRP2007-000 /3 &. ZON2007-iJ0012
18
.5-19 _
APPLICANT'S NARRATIVE RELATEEl TO GOAL 13:
, . .
Goal 13 _ Energy Conservatio~:' To conserve energy. Land and uses developed on the
land shall be managed and controlled so as to maximize the, conservation of all forms
of energy, based upon sound economic principles. "
The Energy goal is a general planning goal a[1~ P~?,~~~ll~;Ji,m!l~~~uidance for site-specific
map amendments. The proposed amendment lias no"dlrectiinpact on ,energy
conservation, though it would in fact will promote greater en"ergy efficiency by enabling
needed clinical services available to growing residential areas in east Springfield.
Therefore, the proposed amendment is consistent with, and does not alter the City's
continued complia,nce with Goal 13.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 13:
Finding 15: The proposed Metro Plan / Refinement Plan Amendment and Zoning
Map Amendment do not affect the Metro Plan's,compliance with Goal 13. The
,applicant is not proposing to amend any regulation pursuant to Goal 13 compliance
of the Metro Plan.
APPLICANT'S NARRATIVE RELATED TO GOAL 14: .
Goal .14 -Urbanization: To provide for an orderly and efficient transition from rural to
urban land use. .
Goal 14 requires local jurisdictions to provide for an "orderly and efficient transition from
rural to urban land use." 'The subject property is within the UGB and the city limits of
Springfield, and within an existing urbanized area of the community. Therefore, Goal 14 is
not applicable to this application. .
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 14:
Finding 16: As noted by the applicant, all of the parcels affected by this application
are' currently within the Urban Growth Boundary and were annexed into the City of
Springfield. All annexations are reviewed for compliance with the Metro Plan and the
Springfield Development Code. As previously mentioned, urban facilities are
available to the subject site The proposed Refinement Plan and Zoning Map
Amendment are in compliance with Goal 13.
APPLICANT'S NARRATIVE RELATED TO GOAL 15:
Goal 15 _ Willamette River Greenway: To protect, conserve, enhance and maintain the
natural, scenic, historical, agricultural, economic and recreational qualities of lands
along the Willamette River as the Willamette River Greenway..
This goal is inapplicable because the subject property is not within the boundaries of the
Willamette River Greenway.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 15:
Finding 17: As noted by the applicant, the subject property is not located within the
Willamette River Greenway. Goal 15 does not apply to the subject Refinement Plan
and Zoning Map Amendment applications' ..
lR~2007-0001J & ZON2007-000/2
5.,.20
.
/9
APPLICANT'S NARRATIVE RELATED TO GOALS 16-19:
Goal 16 through 19: (Estuarine Resources,"Co,!stal Shore/ands, Beaches and Dunes,
and Ocean Resources): .
The coastal goals are not applicable to this application.
,.',
STAFF'S FINDINGS RELATED TO COMPLIANCE ~ITH GOALS16~19:
Finding 18: As noted by.the applicant, the subject site is not located within any
coastal ocean estu'arine, or beach and 'dune resources related area. Goals 16-19 do
". ,
. not apply to these Refinement Plan and Zoning Map /lmendment'applications"
CRITERIA OF APPROVAL.: - SDC 7.070 (3)(b)
APPLICANT'S NARRATIVE RELATED TO SDC 7.070(3)(b):
The application req~ests amendment of the Metro Plan diagram from LMi'to CC for
approximately 5.24 'acres. This section oUre application narrative addresses the
c'onsistency of the amendment with the applicable policie~ of the Metro Plan, to
demonstrate that adoption. of the amendment will not make the Metro Plan internally
inconsiste"nt (as required by the approval criteria in SDC 7..070(3)(b)) .
" "
This narrative only addresses those policies that apply to the proposal, and does not .
discuss' those portions of the Metro Plan that: (1) apply only to rural or other lands outside
of the"jrban growth boundary, (2) apply to land uses other than the"current or proposed
designations for the site and will not be affect!"d by the proposed Plan diagram and text
amendments, or (3) clearly apply only to specific development applkations (e.g., site plan
review submittals or subdivisions). In many instances the goals, policies and
implementation measures apply to specific development proposals that will be addressed
through compliance with applicable City regulations.during site plan review of a,given
future development proposal.
The Metro Plan Introduction, Section D provides the following definitions:
. A goai' as a broadstatement of philos'ophy thai Clescribes the h"op~s of the
people of the commun"ity for the future of the comm"unity. A goaL may never be
completely attainable, but is used as"a point tei strive for.
An objective is an attainable target that the communitY attempts .to reach in'
striving to meet a goal. An objective may also be considered as an "
"intermediate point that will help fulfill the overall goal.
A policy is a statement adopted as part of the Plan to provide a consistent
cours'e of action moving the commu"nity towards attainment of its goals.,
Except for the Growth Management Goals, which are addressed b!"low, each of the Metro
Plan policies are addressed in the order in which they appear ;'n the Plan Element section
of the Metro Plan. .
"'
Metro Pla~ Eiements
1. Growth Management
LRP2007"000 13 & lON2007,OOOl2
20 .
~-21
Policies
1. The urban growth boundary and sequential developmentshal1.continue to be
implemented as an essential means to achieve compact urban growth. Provision of all.
urban services shall be concentrated inside th"e urban "growth boundary.
" . "" .
The proposed amendments satisfy this policy Decaiiiiertti~if~ubject,property is inside the
UGB and city limits and as such, encourages compact urban growth. Also, urban services
are available at sufficient levels to,accoinmodate the existing and future infill development
resulting approval of from this application. The City's site plan review processes ensure
that the appropria~e level of service~ is,available to serve future development.
2. Residential Land Use and Housing Element
Policies
A.11 G.enerally locate higher density' residential dev!,/opment near employment or
commercial services, in proximity to major transportation systems or within
transportation-efficient nodes..
" .
The proposed redesignation does not affect the inventory or availability of residentially
designated or zoned land, including the single-family residential area abutting Tax Lot 400
that is zoned and designated for Medium DensitY Residential, or higher density residential
developments located east of the site along Main Street.
However, approval of the requested redesignation to Community Commercial would allow
for residential areas proximate to the subject area to have close and efficient access to
existing commercial. services on Tax Lot 402 and to future medical facilities prop"osed for
Tax Lot 400, consistent with the above policy. The areas proposed for redesignation offer
existing and future employnient opportunities and provide commercial services alol]g:a
major transportation system that can support'the needs of nearby residential
development. '
, .
A.22 Expand opportunities for a mix'of uses in newly developing areas and, existing
. neighborhoods through local zoning and development regulations.
The inap amendment and concurrently proposed zone change will allow for existing
commercial uses on Tax Lot 402 to continue to serve. existing neighborhoods in the mid-
and east-Springfield area, and for fut~re clinical facilities to be developed"to serve this
rapidly growing area of the community. Approving the requested redesignation and zone
change would expand commercial opportunities to serve these neighborhoods consistent
with the above policy.
3. Economic Element"
Policies
S.1" Demonstrate a positive interest in existing and neW industries, especially those
providing above-above wage and salary levels, and increased variety of job opportunities,
a rise in the standard of living, and utilization of our existing comparative advantage in the
level of education and skill of the resident labor force.
The proposed amendment is consistent with this policy because it will allow medical clinic
uses to be developed to serve growing areas in east and south Springfield. As is
observed in the Springfield Commercial Lands Study (pp. 27,.29), employment in health
services is growing and approving the requested redesignation will enable increased iob
LRP2007.000 /3 & ZON2007.00012
21
5-':22
. '"'~
opportu'nities with higher than average wages thereby helping raise the standard of living
and meet the needs. of Springfield citizens, consistent with the above policy. . .
B.2, Encourage economic development wliicliutilizes:Joca,,:and imported capital,
entrepreneurial skills, and tlie resident labor force. .
. .
The construction of and the use of commercial and medical uses will utilize both local and
imported capital and will employ. the local labor force in a~ariety of skilled, semi-skilled,
and unskilled positions, consistent with th.is policy. "
8.6 Increase the amount of undeveloped land zoned for light industry and commercial
uses correlating the effective supply in terms of suitability 'and availability with the
projections of demand.' ,.
The proposal will add appro."imately 5.24 acres of Community Commercial land;
consistent with recommendations to increase the cO,mmerciallands inventory made in the
Springfield Commercial Lands Study. The SCLS and acknowledged met'ropolitan
Industrial Lands Study concluded that there is a deficit of needed commercial land, and a
surplus of industrially zon~d and designated'land. Approval of tti~.requested
redesignation will not cause'the inventory of needed industrial land to go into a deficit, but.
in fact would, consistent with the above policy. The proposal correlates the need'and
suitability, and availability of the subject site for commercial uses with the need for such
uses as demonstrated in the adopted SCLS.
B.11 Encourage economic activities which strengthen tlie. metropolitan area's position as
a regional distribution, trade,health, and service cente(. .
The amendment will facilitate the development of medical uses that will serve the needs of
the growing residential areas in east, south and southeast:Springfield, and strengthen the
metropolitan area's position as a premier ,locale for healthcare services, consistent with
this policy objective.
6. ,Environmental Design Element
Policies
E.1 In order to promote the greate;;t possible"'degree of diversity, a broad"variety of
commercial, residential, and recreationa/'land uses shall be ellcouraged when consistent
with oth~rplann'ing policies. .
.
Approval of the proposed' map amendments will addjust over 5 acres into,the City's
inventory of commercially designated and zoned land, thereby allowing for a variety of
needed commercial uses to o<;cur on the subject property. Long-standing existing
commercial services on Tax Lot 402 would be allowed to continue without the specter of
. being considered non-conforming uses, and Tax Lot 400 <:ould be developed with medical
services that will serve .the needs of the growing residential areas east and south of the
subject site, consistent with the above' policy. . '
7. Transportation Element
Land Use Policies
"
F.3 Provide for transit-supportive land use patterns and development, including higher"
intensity, transit-oriented development along major transit corridors and near transit
stations; medium- and high-d.ensity residential developmen't within one:quarter mile of
transit stations, major transit corridors," employment centers, and downtown areas; and
LRP1007,OOOl3 & ZON2007-iJ0012
22
J
--fi=? ~
II
development and redevelopment in designated areas tl1at are or could be well served by
existing or planned transit. ..., ' ". " '.
The proposed "map amendment and co.ncurrent zone change will enable land use patterns
and development consistent with the above policy. Approyal of the proposal will allow for
higher intensity development along Main Street, a major transit corridor. An existing L TD
stop is located on the frontage of Tax Lot 400 (se-e ph-6todig."':Z;.Appendix A of the TIA),
and will provide convenient access to existing and projected employment on the subject
site, as well as access for patients to future out-patient medical facilities projected on Tax
Lot 400.
Transportation System Improvements: Roadways Policies
"\
F.15 Motor vehicle level of service policy:
a. Use motor vehicle level of service standards to maintain acceptable
and reliable performance on .the roadway system. These standards
shall be used for: .
(1) Identifying capacity deficiencies on the roadway system.
(2) Evaluating the impacts on roadways of am!!ndri1ents to -
.transporta"tion plans, acknowledged comprehensive plans and
.land-use regulations, pursuant to the TPR (OflR 660-012-0060).
(3) Evaluating development applications for consistency with the land-
" use regulations of the applicable local government jurisdiction. .
b. Acceptable and reliable performance is defined by the following
levels of service under peak hour traffic conditions: LOS E within
Eugene's Central Area Transportation Study (CA TS) area, and LOS
D elsewhere. .
c. Performance standards from the OHP shall be applied on state
facilities in the Eugene-Springfield metropolitan area. .
In some cases, the level of service may be substandard. The local government
jurisdiction may find that transportation system improvements to bring performance
up to standard within the planning horizon may not be feasible, and safety will not be
compromised, and broader community goals would be better served by allowing a
substandard level of service. The limitation on thefeasibi/ity of a transportation
system improvement may arise from severe constraints, including but not limited to
environmental conditions,' lack of public agency financia/.resources, or land use
constraint factors. It is not the intent of TS/Baodway Policy #2: Motor Vehicle Level
of Service to require deferral of development in such cases. The intent is to defer
motor vehicle capacity increasing transportation improvements until existing
,-constraints can be overcome or develop an alternative mix of strategies (such as:
land use measures, TOM, short-term safety improvements) to address the problem.
Subsection a.(2) in the above policy requires an evaluation of the prop,?sal pursuant to the
state Transportation Planning Rule (TPR). The accompanying Traffic Impact Analysis
provides the factual basis to determine that the proposed,redesignatiori would not result
in a "significant' effect" as defined under the TPR (OAR 660-012-0060(1)).
Specifically, the proposal does not change the functional classification of Main Street or
any other nearby roadway, and it does not change the standards for implementing' the
City's functional classification system of roadways, as identified in the Regional.
Transportation Plan. As demonstrated in the TIA, the proposal also does not:
. _ Result in types or levels of traffic or access that are inconsistent with the
functional classification of Main Street o~ any othe.r nearby roadway;
23
LRP2007-000 / 3 & ZON2007'OOO 12
.:;~?4
]
. Reduce performance of traffic on Main Street or other affected
intersections to a I,evel that,is below acceptable established performance
standards; or . ,
. Make performance of existing facilities w'orse (Le., below acceptable
. mobility standards) than would be the case'other uses permitted under
existing designations, or zoping. ' . .
Specific TPR findings are further located in the TIA, see pp, 31-32. "Because"the proposal
does not result in a "significant effect" as established by applicable OARs, no further TPR
analysis is re'quired:'The request is therefore consistent with the above policy.
8. Public' Facilities and Service Element
G.1 Extend the minimum level and fu/l range of key urban facilities and seivices in an
orderly and'efficient manner consistent with the growth management policies in
Chapter /I-B, relevant pglicies in this chapter and ot/ler Metro Plan policies.
The subject property is located in Springfield's city limits UGB. All necessary
infrastructure and key urban facilities/services are present to serve existing development
(Tax Lot 402) or are available to serve future infill development on Tax Lot 400. Therefore,
the proposal is consistent with the above policy. ' .
9. Parks and Recreation Facilities Element Policies
Policies in this element of the Metro Plan are not relevant to the requested diagram
amend'm'!nt. . . .
10. Historic Preservation Element Policies .
: Policies in this element of the Metro Plan are ,not relevant to the requested diagram
I . "
amendment. "'. '. " .
11. Energy Element policies ",' .
" Policies in this element of the Metro Plan are not relevant to the requested diagram
amendment.
STAFFS FINDINGS RELATED TO SDC 7.070(3)(b):
Finding 19: The requirement of this criterion thah3doption of these propo~ed
. applications not make the Metro Plan intermilly inconsistent does not mean that every
goal, objective, finding and policy of the'Metro Plan must support these applications:
B~cause of recognized confiicts in the Metro Plan, the proper inquiry is whether on
balance the most relevant of the Plan polices support the Metro Plan Diagram
Amendment The applicant's narrative discusses numerous Metro Plan Policies and'
Elements related to the proposal. '
Staff has reviewed the applicant's choice of applicable Metro Plan.Poiicies and Elements
and concur that the noted Policies and Elements are applicable to the proposal.' Findings
addressed regarding ~oal 9 and Goal 12 in this report also support the stated Metro
Plan policies. Specifically, as conditioned in this report related to Goal "12 compliance,
the Metro Plan Transportation Element.and TranspOrtation Policy F" 15 are satisfied.
lRP2007~OOO I J & lON2007-000 12
24
. ~.5~25
1;he stated Policies and "Elements have been reviewed by staff and are found to be
applicable and consistent with the proposal.
REFINEMENT PLAN MAP AMENDMENT
CRITERIA OF APPROVAL - SDC8.030.,"~t.~.~q..
In reachifig a decision on these actions, the Planning Commission and the City
Council shall adopt findings which demonstrate conformance to the following:
(1) The Metro Plan;
(2) Applicable State statutes.
(3) Applicable State-wide Planriing Goals and Administrative Rules.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH SDC 8.030 (1 H3):
. .
.Finding 20: SDC 8.030(1)-(3) indicates that a Refinement Plan Amendment must be
consistent with (1).The Metro Plan (2) Applicable State Statues; and (3) Applicable
Statewide Planning Goals and Administrative'Rules. Each of these' criteria are
addressed in this report as part of the Metro plan Amendment Criteria and the Zoning
. . Map Afl1endment Criteria. As noted in the applicant:s narrative, SDC'7.11 0"(4) states:
"When a Metro Plan amendment is enacted that requires an amendment to a refinement
plan or functional plan diagram or map for consistency, the Metro Plan diagram
, amendment automatically amends the refinement plan or functional plan diagram or map
" if no amendment to the refinement plan or functional plan text is involved".." .
There is no refinement plan text amendment proposed as part of this application.
therefore, no separate refinement plan application is required" As stated in'the above
referenced section of the SDC, the refinement plan is automatically amended upon
approval. of the MetroPlan amendment
. .. " .
The applicant's narrative related to consistency with. specific refinement plan policies is . "
most. appropriately addressed as part of the Zoning Map Amendment criteria, later in this
report
METRO PLAN MAP & REFINEMENT PLAN AMENDMENT (LRP2007-00013)
CONCLuSION AND RECOMMENDATION
Staff finds that the request meets the ,criteria of SDC 7030(a) - (b) and SDC 8.030.
Upon review of the evidence provided. by the applicant, site visits, existing
structuresluses and review of the applicable criteria of approval, staff finds thafthe
<jlpplicant's request for a Metro Plan &. Refinement Plan Map Amendment is, appropriate
for. the subject property with the. following recommended condition of approval:
1. Trip g'eneration from development on the subject property shall be limited to a
maximum of 243-PM Peak~hour vehicle trips, which is based on a "reasonable worse
case development scenario" under the existing zoning (LMI) as submitted by the
applicant in the Traffic Impact Analysis for the subject property.
lRP2007,OOO 13 & ZON2007-000/2
25
.5-26
~
I
"
40NING MAP AMENDMENT,
CRITERIA OF .APPROV AL - SDC 12.030 et seq.
SDC 12.030 (1) _ Quasi-judicial Zoning Map Amendments - The Planning Commission or
Hearings Official may approve, approve with conditions or deny a quasi-judicial Zoning Map
amendment based upon approval criteria (3)(a)-(c) below. The Planning Commission or Hearings
Official shalf make the final local aecision on alf quasi-judicial Zoning map amendments that do
noUn elude a Metro Plan diagram amendment.
SDC 12.030(3) Zoning Map amendment criteria of approval:.'
(a) Consistency with applicable Metro Plan policies and the Metro Plan diagram
(b)' Consistency with applicable Refinement Plans, PIElIj District maps, Conceptual
Development Plans and functional plans; and .
(c) The properly is presently provided with adequate public facilities, selYices and
transportation networks to support the use, or these facilities, services and transportation
networks are planned to be provided concurrently with the development of the property.
NOTE FROM STAFF REGARDING APPLICANT'S ZONING MAP AMENDMENT
" NARRA T1VE: The applicant's narrative for the Zoning Map Amendment is similar
to the narrative for the Metro Plan & Refinement Plan Amendment, addressing
many of the same criteria. The portion of the Applicant's Narrative related to
Refinement Plan policies is included below. Rather than be duplicative in this
report, and for ease of review, Staff has attached the remaining portions of the
. applicant's written narrative in its entirety for 'reference. "
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH SDC 12.030(3)(a):
, . . .
Finding 21: This criterion is also found in SDC Section7.070(b) under the Metro Plan
Amendment criteria. Specific findings related to compliance with Metro Plan policies and
the Metro Plan diagram has been addressed in this report. The applicant is proposing a
Metro Plan Map Amendment as part of this application from LMI to Commercial. Upon
approval of the Metro Plan Amendment application (LRP2007-00013), the proposed
zone change will be consistent with the Metro Plan diagram.' .
Conclusion: The proposed rezone request is consistent with Metro Plan policies and
the Metro Plan Diagram"
APPLICANT'S NARRATIVE RELATED TO COMPLIANCE WITH SDC 12.030(3)(b):
The following demonstrates how.the proposal is consistent with applicable policies in
the East Main Refinement Plan (EMRP).
1. Mixed-Use EI<~ment
LRP2007.000/J & ZON2007-iJOO/2
26
1-:21.
Policy 2) Area #2
A) The following land uses are allowed under Community Commercial zoning:
All Communitv Commercial uses subject to Article 18 of the Springfield
Development Code. " .
..
The proposal requests redesignating the subject properties to Community
Commercial, and concurrently rezoning the properties to CC, as is allowed by the
above policy and consistent with other EMRP policies. Approval of the request would
allow long-standing existing commercial uses on Tax Lot 402 to continue as permitted
under Article 18, and consistent with neighboring uses to the west and south, which
are also zoned and designated fo'r commercial uses. .
2. Commercial Element
Criteria for Commercial Refinement Plan Desicnation ~
1. Generally, the Community Commercial refinement plan designation shall be
applied under the following circumstances: '
A) where it is not an intrusion into well-maintained residential
neighborhoods;
The proposed redesignation does not intrude into the existing residential area west of
the subject site along 44th Street, and is therefore consistent with the above criterion.
B) where it does not increase conflict between Low Density 'Residential
and Commercial;
Although the abutting residential area is zoned Medium Density Residential, it is
developed in low density residential uses. Approval of the proposed redesignation of
the subject sites would actually' result in a decrease of conflicts between abutting
residential and non-residential land uses by allowing future infill development on Tax
Lot 400, and through the site plan review process establishing improved landscaped
buffers and a use more compatible than the industrial uses that historically abutting
this residential area. " ""
,
cj where criteria for designating Medium Density Residential land does
not apply; , "
"Criteria for designating MDR land does not apply to the subject site."
D) where legally created commercial uses exist;
Tax Lot 402 has existing, long-standing commercial uses that were legally created
prior to development of the Metro Plan or EMRP. '
E) where adequate customer and service access to an arterial street can
be provided; ... and
The subject site has adequate legal access onto Main Street, which is classified as an
arterial street. .
LRP2007,OOO I] 0:. ZON2007.o00/1
27
li-i28
F) where designated Commercial on the Metro Plan Diagram.
Approval of this application would result in a Commercial designation on the Metro
Plan diagram, which would also automatically modify the designation on the EMRP
diagram. .
Policy 2) Apply site-specific Commercial refinement plan designations to clearly define .
the limits of new commercial uses where there is not an' existing, legally established, and
beneficial mixing of uses. "
Approval of the requested redesignation would apply Commercial plan designations to
the subject properties, allowing the existing, legally established commercial uses on "
Tax Lot 402 to continue. It would also enable commercial uses to be established on
Tax Lot 400: thereby defining the limits of new commercial uses between the pre-
existing commercial uses on Tax Lot 402 and others to the west, and the developed
industrial business park to the east. Tax Lot 400 does not .have an existing or
beneficial mix of uses, but has historically housed industrial yard-type operations.
Therefore, approval of the proposal would define. the limits of new commercial uses as"
called fo'r in the above policy, and also provide the ability to make superior buffering
and other improvements associated with future development on Tax Lot 400 through
the site plan review process.
Policy 3) Reduce the number of vehicular access points and require the rebuildirig of
curbs and installation of sidewalks and street trees along Main Street, through the Site
Plan Review process and in public improvement projects.
The proposai would result in reducing the number of existing access points as
required above. Through the Site Plan Review process, future development on Tax Lot
400 will have a single driveway access onto Main Street, eliminating one of the two
existing curb cuts on this site. Sidewalks and street trees are already located along its
Main Street frontage, consistent with the above policy. "
Policy 4) Provide buffering between commercial and residential uses through Article 31 of
the Springfield Development Code, Site Plan Review process.
Existing residential uses along the east side' of 44'h Street' have had no real buffer from
pre-existing industrial uses on Tax Lot 400." Approval of the proposal would allow for
attractive infill development of future medical facilities that would provide (through the
SPR process) improved landscaped buffers between the future use and existing
residential area to the west - as required by Code, and consistent with the above
policy.
3. Industrial Element
Policy 1) The City shaliencourage efforts of various agencies to attract new and retain
existing jobs and businesses.
Imo/ementation
. The City shall maintain a current inventory of vacant commercial and industrial land and,
structures within the East Main area.
Consistent with the above policy, approval of the requested redesignation will enable
existing, long-standing jobs and businesses on Tax Lot 402 to remain as legal,
conforming land uses, and allow future development of new employment on Tax Lot
LRP2007-000/J & ZON2007.o00/2
28
~-~a
400 with highedhan average'wages and employment densities than the current
designation and zoning allows.
'"
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH SDC 12.030(3)(b):
Finding 22: As previously mentioned in this report, the subject property is located within
the East Main Street Refinement Plan area. The applicant's narrative above discusses
refinement plan Elements and Policies. .
Finding 23: The applicant references policies in the Mixed Use Element, Area 2. This
area (Area 2) is located south of the subject property" (across Main Street); and is not
part of the subject property. Reference to this policy is not applicable to this application.
Finding 24: The applicant discusses specific criteria listed in the refinement plan for
commercial arid industrial uses. Staff concurs with the applicant's narrative related to the
commercial criteria.
Finding 25: Criteria 6f approval for consistency with all applicable City of Springfield
functional plans have been previously addressed in this report. As noted in the findings.
in this report, the proposal is in compliance with all applicable functional plans.
. Conclusion: Based on the above findings, the proposed zone change is in compliance
with SDC 12.030 (2)
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH SDC 12.03.0(3)(c):
Finding 26: As previously noted in this report and as stated by the applicant, the subject.
properties are currently served by sanitary sewer systems and storm drain systems .
Springfield Utility Board (SUB) has sufficient capacity to provide electrical and water
service to the site. .
Finding 27: The property is served by Springfield Fire and Life Safety.
Finding 28: The site is within Springfield SchoolDistrict 19.
Finding 29: The site is within the Willamalane Parks and Recreation District.
Finding 30: Transportation systems currently provide access to the property. . The
subject site takes access from 44'" Street which is under City of Springfield jurisdiction
and Main Street, which is under ODOT jurisdiction.
Finding 31: The proposed zone change is from LMI to CC. The subject lot has existing
development on all sides, and is located on 18'" and MainStre"et. As. previously
discussed in findings in this report, and as conditioned" the proposed zone change will
not significantly affect the existing transportation network. The proposed zone change
will notnegatively affect" existing public transit service. .
LRP2007-000/3 &. ZON2007-000/2
29
o_~n
"
Finding 32: Solid waste management service is available at the subject property. The
City and Sanipac have an exclusive franchise arrangement for garbage service inside
the city limits.
Finding 33: The site receives police protection from the City of Springfield,consistent
with service provision throughout the city and with service that is now provided to
adjacent properties. .
Finding 34: The City of Springfield Development Services Department provides land
. use control for property within the City's jurisdiction.
Finding 35: Owest and Comcast currently provide telephone and cable communication
service in this area for and an array of wireless companies provide a number of different
communication services. The City has no exclusive franchise arrangements with
telecommunication or wireless companies. The field is competitive and therefore
guarantees a wide selection currently.' "
Conclusion: All key urban facilities and serVices required for the proposed rezone are
available to the site. Any specific public and private improvement requirements and
utility connection points will be determined when the property is developed. The proposal
meets 12.030(3)(c).
ZONING MAP AMENDMENT CONDTIONS OF APPROVAL:
SDC12.040
SDC Article 12 allows for the Approval Authority to attach conditions of.approval to a
Zone Change request to ensure that the application fully meets the criteria of approval.
The specific language from the code section is listed below:
12.040 Condifions of Approval
The Approval Authority may attach conditions as may be reasonable necessary in order
to allow the Zoning Map amendment to be granted.
Staff have reviewed the Zone Change request and supporting information provided by
the applicant and do not recommend any conditions of approval other than the condition
already stated for the Metro Plan / Refinement Plan Map Amendment related to trip cap
requirements.
The Planning Commission may choose to apply conditions of approval as necessary to
comply with the Zone Change criteria"
LRP2007.000/3 & ZON2007.000/2
30
~_?1
ZONING MAP AMENDMENT (ZON2007-00012) CONCLUSION AND
RECOMMENDATION
Staff finds that the request meets the criteria of SOC, 12.030. Upon review of the
evidence provided by the applicant, site visits, existing structures/uses and review of the
applicable criteria of approval," staff finds that the applicant's request for a zone change
from LMI to CC is appropriate for the subject property and recommends the Planning
Commission approve the attached Order and forward the proposed Zoning Map
Amendment Application ZON2007-00012 to the City Council with a recommendation for
adoption.
" .
,
\
3/
LRP2007-000/3 & ZON2007-000/2
t::: 1)1'}
. ...'.!..
EXHIBIT A-1
.
5,0 TRIP GENERATION AND DISTRIBU1ION
5.0 TRlr GENEP-ATION
To determine the traffic impacts of a development on'a roadway system, the number of
vehicle movements resulting from the development must be' estimated. These
movements are referred to as "trips'"'. Trip generation IS the estimated volume of trips
resulting from the develo'pmenL. " .
The amount of trips expected to be generated by thepropQsed development was
. determined using the information contained in the ITE. T riD Generation Manuat 7'h
Edition. The equations.in the manual predict the nunlber oftrips generated based on the
gross square feet of t1oorarea. Separate trip generation analyses were performed for the
AM and PM peak hours for the development. . "
Under the current Light-M~dium Industrial zoning th';:development site can be built out
~' ..'- -,- .
to incllldea variety of land uses specitied in Springtield Development Code Article 20. .
The maximum trip 'generation of the development was determined for the allowed land
uses under the current zoning. Tables 5 and 6 ,illustrate the maximum development
. potential and subsequently the maximum trips generated by the development site using
thefollowing ITE Land Use Codes:
i
I
.
Land Use Code '760 - Research and Development
Land Use Code 714 - Corporate Headquarters'
Land Use Code 492 - Health/Fitness Club,
Land Use Code 565 - Daycare Center
.
..
.
,", Research and 760 8.0," Ln(T),,088'Ln(x}~D.88 ':114' .0.8,3 ',.017.'"95 .,: 19:
. Deyelopment . -
Illi];~~4~(j~~j~II_I;rIl'Jti.
Health Fitness Club 492 4 T=L21'x" 5 0.42 0.58' '2 "3"
Total Trips 1 229
,::~~~~~i~t
168 61
-'
IR.H TRANsrOi>.TATION ENGINEEI'JNG I EastS2":f3'''etdReZOne" Springfield" Oregon I March 6. 2007[18
.
Research and
De~elopm~nt .,
760
80.
Ln(T)=0.83'Ln(xltL06 ..110 . 0.15 ". 0.85
t\';:,\J'C"':"''''''''''''~'~;' "":"-H~"".-"~":"-"'''''''''~.''~l'''';''~''':' 'fR!;." ,'" :,;;.r. ~:t'.B:~'" --"i::r.:"~ ~~~i.pr~('T)"'-"'.-O':'8-:i:;['-~'(!'~".
".~" "orporate eadquarters"':"1""f14"::':1),,"ZOy):,,"'~:':n, .=, 'I, 'n x "
1~~~~~;r:'1>.;.:~}~~',',~~~:-,~P:1{r,~",~~:\:','~:k:';i";~'~~~;'; '- .. ~~~~ttl,':~~:Q'\~-:'5~f1;J f1t1;~4~!S~:~;~!ii":';:1J:::':0"~t., , ,'.
;'f;,;;,lsl~"~-",I~..;;~~,,,,;;;14;;.!"~r'r4fi<::l1:~1f.)~."0':"! .~-l:c ;i'?~~i'j',l?j~;*j '~i~~,Ljj,',E!' :l;!.l:,{~" ; dh. 'f"
a.i~iii.'?",,~~:;'~l:.~,k~-;:';'~i.:Ml',~ci''{f~~'t!:. t: ~';~g i~::.+~li&.-J;~~f~ :~i/,:::~~~::;:,!~l,.!t'!rUzfE.4
"" Health Fitness Club ." 492 " '4 T=4.05'x
"'D'~"~:~',"~''''-':~''C'~'~,' - ~t'~""':->'.' ;:i~~~;~' ~".
: ' aycare; .. en e~'-"f~,~"~~~!l:
~l~t~1t~I~l1if~l ".
With the zone change the development"site will be b,uilt to include an approximately
30,000 square foot medical office building. The land use codefor a fully developed
. medical otIice building was 720 - Medical-Dental Oftlce Building. This was used in
place of Land Use Code 630- Medical Clinic because,.after close inspectlon of the Trip
. Generation Manual. it was detemlined that the sample size forthis category ofland use
v';as too small to create a reliable estimate of trips generated. Table 7 illustrates the traffic
generated by the proposed 30,000 square foot medical oftlce building. Tax Lot 402 is.
currently occupied by a commercial/specialty retail center. With the proposed zone
change, the building will remain on the property and will continue to operate as a
specialty retail center. Vehicle trips using this site have already been' accounted for on the
roadway in the background traftlc volumes: therefore, no new development trips were
assigried to this Tax Lot. .
Table 7: Peak Hour Trip Ge.neration-Medical Office Buildin9 "
, j:,"" .~' h::r..:.... . '
.:Ji\"
;!I'J~0)~(i~:~&~t~li~I~~~~t~}i~~~Oi"',H"i~;J,;T0ii
AM.
, T =2.48'x
74
79% 21%58
There are 155 fewer AM and 140 fewer PM vehicle trips generated by the medical oftlce
building when compared to the niaximum potential of the site under the current zoning.
]RH TP-ANSrORTATION ENGINEERIHG I E;'t Spnngfleld Re:one. Springfield Oregon I March 6, 2007119
5-3f
I
EXHltll1 'A-:~
,
16
-.
5.1 HUr DISTIZIBUT10N AND ASSIGNM.ENT
- After detennining the trip genera'tion, the next stepin the "analysis requires distributing
and assigning the trips to the existing traftic network. Trip distriblltion allocates the trips
generated from, the developments to generalized destinations" Trip assignment routes
trips to these generalized destlnationsvia the actual street network. The trip distribution
for this project was based on the exiiting distribution pattern of the study area roadway
network; where applicable" A~cess to Tax Lot 400 is assumed to be limited"to a single
full~movement access from Main Street. Figlires 9 and 10 shows the assigned vehicle
trips generated by the 30,000 squar~ foot medical office buil<.!i'ng forth~AM and PM
peak period respectively. . - - .. .
52 BUILD WAFFle VOLUMES
To determine the Build tral1ic volumes the development trips assig~~d.throl.lghout the
study area were added to the background traftic data, The year 2008 AM and PM Build
year trat1ic volumes are illustrated in Figures II and 12, respectively" The year 2023 Atvl"
and PM Build year traftic volumes are illustrated in Figures 13 and 14, respectively
JRH TRANSrOItTATlm~ ENGINEEItING I East Springfield Reoone" Springfield. Oregon I March 6. 2007120
5-,.35
t::AHltlll "'-.j
1
I
~
i
~
I
I
~
I
,
!
i
,
J
I.
I
!
I
EXHIBIT A-~
.
I
7.0 TPR FINDINGS
I
The follo\ving discusses the Oregon Administrative Ruling 660-0 l2'o'OOO the
"'''' .... ,..... 1
Transportation Planning Rule, and the effect ofthe prop6'sed'Cl~~ei'opment on the
transportation fa'cilities as it applies to the ruling.
'1
660-012-0060
I
1
Plan and Land Use Regulation Amendments
(l)JVhere an amendmenl 10 ajimclional plan, an ackno"wledged comprehensive plan, or
'a land use regulUlion would significantly. ajJect an existing or planned transportation
. fdcilily, the 'iocal governmenl'siwll put in place meastires as provided in'seClion (2) of
this rule 10 cissure that allowed land uses are consistent wilh the identifiedfimclion,
capacily, and performance standards (e.g. level of service, volume"'IO capaciiy ratio,etc)
of the facility. A plan or land use regulation amendment significantly affects a
transportationfaciliiy ifit would: .
(a)' Chdng'e Ihe fiiilctioilal classification of em existing or planned Iransportation facility
(exclusive ofcorreclion of map errors in an adopted plan). .
"The addition of development traffic on the adj<lcent" roadways does not cause the
change in functional classitication of any of the transportation facilities.
(b) Change standards implementing afimclionalclassijicution system: or
I
I
I
I
I
The standards implementing a functional classitication system within the project
study area are not changed by the proposed development.
1
(e) As meClsured at th~ end of the planning period idenlified in the adopted transportCltion
system plan""
I
I
(A) AllOlv'land Lrses or levels ofdevelopmentthClt would resull in types or levels of travel
. or access that are inconsistent wilh the jimctional classijication of an exisling or planned
trClnsportatiol1 ji/cilit)/,"
The proposed development does not result in types 01 levels of travel or access
that are inconsistent with the functional classitication of the studied transportation
facilities"
(E) Reduce the perjurmance of an existing or phmned transponalion facilif.V below Ihe
minirmrnj Clcceplable pelformcmce swndurd idenlijied in the TSP or comprehensive plan.
or
The addition of development trJftic does not reduce the performance of an
existing or planned transportation facility below the minimum acceptable
. performance standard. '
JR.H TRANSPOR.TATION ENGINEER.ING I East Springfield Rezone" Springfield, Oregon.1 March 6, 2007[31
5~36-" " "
.
EXHIBIT A-5 ']
,f
~
(C) Worsen the perforrrwnce of an e.~isting or p/unned tramporlCltion fa~ility.that is
othenvise projected to perjorm beloH' the minimum acceptable pelformcince standard
identiJled in the TSP or comprehensive plan. " .
,
The ~ddition of d'evelopment traffic does not further'degrade the perfom1a~ce of
intersections projected to perform below the minimum acceptable performance
stand~Hd.
~
1
~
t~
~1
'i
i~
~'1
,',j
~i
:1
~1
~
~
j::
;~
N
~i
~
~
'i~
~
~~
~1
,~
p
~~
~
JJ
~l
t~
I:,;
~
,'J
'I
',1
:~ '
~
~
. H
?!'
~l
'.1
"
.1
11
!'.:~
~5
I
:4
As shown, the proposed redesignation of Tax Lot 400 and402 does not result in a
"significant etTect" on thetransportation facilities as defined in the TPR. .
8.0 SUMMARY AND RECOMMENDATIONS
This report provides an analysis of potentiaItraffic impacts resulting from the proposed
redesignationlzone.change and nlture development of the subject site in Springfield, .
Oregon. This development will include approximately 30,000 square feet of medical.
office space. The parcel proposed for development is \ocatedeast cif 44th Street and west
of 48th Street on Main Street.. A single unsignalized full-movement access point on Tax
Lot 400 and existing driveway acce'ss to Ta,< Lot 402 is assumed. ' .
,ee
Completion of the proposed development is anticipated for the year 2008. This report
includes year of completion analysis, year 2008, for the'roadway network ~vithin the
study area. [n addition, a horizon year analysis was performed t~r the year2023..
A performance analysis was completed for the intersections of Main Street and 42nd
Street, Main Street and 48th Street, Main Street at 44th Street. and Niain Street at 46th
Street. The operatioiml analysjs of all intersections within the study area shows tlpt
under the Bllild condition no degradation in volume-to-capacity ratio in comparison to
the No-Build condition occurs due to the additional trips. produced by this development.
All study ::treas meet the mobility stand::trd for the Bl:ild condition. .
A"queulng analysis was performed for the intersection within the study area. The queuing
::tnalysis, which assumes the current lane configuration throughout the planning horizon,
was performed to determine the amount of required storage' length due to the construction
of the project. The results of the queuing analysis indicate th::tt all existing storage lengths
will facilitate the lpeuing anticipated for the traffic demand, including the proposed .. .
development. . .
.,
I'
.:
l'
I
i".
According to the tinding under Oregon Administrative Ruling 660-012-0000, the
" Transportation Planning Rule, the proposed redesignation of Tax Lot 400 and 402 does
not result in a "significant effect" on the transportation facilities as defined in the TPR.
I
JRH TRANSPORTATION ENGINEERING IEasl Springfield Rezone - Springfield. Oregon I March 6, 2007 I 32
5-37
EXHIBIT !~-6
Memorandum
City of Springfield
Date: . April 4, 2007
To: , David Reesor; Planner III
From: Gary McKenney, P :E., Transportation Plarullng'En'gineer
Subject: LRP2007-000 12 Peace Health PAPA
The following comments and recommendations are based on my preliminary review of the
assumptions used in the traffic analysis report (TIA) and. other materials provided with the
subject application. Pertinent pages of the TIA are attached for reference.
Traffic Impacts' Analysis
In estimating the trip-making potential of site development under existing LMI.
designation/zoning the TIA assume the la,nd uses as depicted in Table 5 (Page 18).
. Recommendation: Confirm that the uses assumed in the "existing-designation" .
development scenario are permitted, and that they represent a "reasonable worst case."
In estimating'the trip-making potential of site development under proposed CC
" designation/zoning the TIA assumed a single la'nd use (Medical Office Building) as depicted in
Table 7 (Page 19).
Recom~endation: Confirm that the use assumed in the "proposed-designation';
development scenario represents a "reasonable worst case." If not;'we' need to decide
whether limiting allowed development to the level assumed in the TIA would be an
acceptable means of ensuring that future development would not generate traffic in
excess of what is estimated in the TIA. Ifwe find that the assumed Medical Office use
would under-utilize the land, then we will want the TIA revised to reflect the impact of a
true "reasonabte worst case." ..".
.
Goal 12 TPR AnalysislFindings
The PAPA application refers to the Goal 12 tindings contained in the TIA. These are presented
on pages 31 and 32. The validity of these finds'will depend on the details of the technical
analysis and supporting assumptions.
5-38
- -0- - -- -.
EXHIBIT A-7
REESOR David
"..
From:" . MCKENNEY Gary
Sent: . Thursday, April 05, 2007 9:23 AM
. To: REESOR David
Subject: PeaceHealth PAPA Traffic Analysis
Follow Up Flag: Follow up
Flag Status: Red
David,
In considering what a "reasonable worst case" development scenario might lie for the re-zoned condition
it is clear that a 30 KSF Medical Office Building is much less intense than other uses that would be
. permitted in the CC zone. On a per-square-foot basis the MO is estimated to generate 2.47 vehicle
tipsll ,000 SF and 3.43 vehicle tips/I ,000 SF durillg the.AM and PM peak hours respectively. For
comparison the average rates for a "Fast-Food Restaurant'with Drive-Thi;ough Window" are 53.11
vehicle tips/I ,000 SF and 34.64 vehicle tips/I,OOO SF.' .
In considering the Goal 12 "insurance policy" issue some more I thought of another possible way to deal
with it, which we did not discuss yesterday. We might choose to limit the trip g~neration for the ..
rezoned land' to be no greater than what would be expected from development under a reasonable worst
case with existing zoning. .
I'd like to discuss these ideas further.in our meeting with Ed Moore.
Gary
5-39
5/25/2007
CAMltll1 J.'. 'j
-Oregon
Department of Transportation
'Region 2 Tech Center
455 Airport. Road SE . Building A
Salem, Oregon 97301-5397
Telephone (563) 986-2990
Fax (503) 986-2839
. Theodore R. Kulongoski, Governor
DATE:
May 10,2007
File: T15-2
TO:
Ed Moore
Area 5 - Senior Planner
FROi\'l:
Stephen B. Wilson, PE
Region 2 Senior Traffic Analys
---
East Springfield Rezone
Traffic Impact Analysis Review ""
Highland Business Park- Peacehealth Medical Office Building"
McKenzie Highway - OR 126 Bus. (Highway #15) "
Milepost 4.61- 5.00
City of Springfield
Lan,e County
SUBJECT:
"
These are review comments for the EU1it Springfield Retone Traffic Impact Analysis (IIA), prepared by
JRH T"illsportation Engineers. The focus of this review is the amilysis methodologies and assumptions.
The results and conclusions of this study are in question, due to lloted inconsistencies. Itis recoinmen,dcd
this study be revised,' taking 'into "account these comments. Region.2 TniJftc .will ne"d to, review any
revised traffic study, to ensure it complies with OOOT requirements, before ;~dlfi be deemed aceeptable.
.Page Paragraph.
7 Table 1
8 Seasonal
Adjustment
8 Peak Hours
II
Figure 4
12
Section 3.1
Theclas~i~~~;;~~Of M~in Str~;t~~;rilt26;:~~;t;~IS~::li;;;d~;;he \
OOOT highwa~ classification. .
This study needs to demonstrate how the Seasonal Adjustment factors
were applied to the raw traffic data. A graphic showing .the "raw
traffic volumes should also be included. ' .
The peak hours "assumed for this study seem}e~sotlable;" assuming the
Peak Hour Factors were calculated off data from these assumed hours, "
and were the same for all intersections. ". '
The 2006 Existing PM Pealc traffic volumeS do not seem correct. As
part of this review, calculations were made " using the raw traffic data
and the assumed Seasonal Adjustment factors, presented in this study.
The review calculations were unable to confirm. the traffic volumes
1?resented in Figure 4. See related comment for Page 8.
OOOT does not have a standard from which you can compare an
. Intersection Crash Rate. This study cites a crash rate threshold of 1.0.
This is not an OOOT standard, and it is unclear where this standard
may have originated. The only ODOT standard for comparison is a
Segment Crash Rate, which should be calcUlated for the crashedn at
least a mile of the study area roadway.
.
5-40
.Page
. 13
18
18
Paragraph
Grov.:ih Factors
Existing,
Zoning Trip
Generation
TableS
19
Proposed
Zoning Trip
Generation"
IlIa
" Future.
Build-Out
Traffic
Volumes
n/a
Section 6.0
'rJa
Manual COUIlt
Data
nla
S ynchro
Analysis
31
Section 7.0
EXHIBIT A-9,
Comment
This study m"st demonstrate how the Historical Growlh Rates were
applied to the 2006 30'h Highest Hour tramc volumes. Calculations to
confirm the 2008 and 2023 data were unable to duplicate the future
volumes clted in this repOlt.
This report states the maximum. development potential was
determined for the property, given its current zoning of Light-MediLlm
Indus/rial. For this scenario; how was the maximum allowable
develo~ment determined?
The trip generation assumptions and output in this" table are accurate.'
This study's trip generation analysis for the propos cd zoning, assumed
a 30,000 sf Medical CJfJice BLli/ding would be the only deveiopment
on this site. To satisfy the requirements for a TPR.!evel analysis. the
trip generation study for the proposed, zoning must be for the
maximum allowable develoomen;' on that site, given .'the City's
development codes and regulatio"ns.
The trafflc volumes for all Future Build-Out data sets will need to be
revised to account. for corrections made 'to address the previous
comments.
The traffic data for this study is in question. Any analysis made from
these data sets is also questionable and niust be revised; taking into
,account the previous comments. This comment can also be applied to
the queuing analysis developed for thls study"
The scope of wOl'k for this TlA required 3-houJ' ManLlal Classification
COLln!s for all study-are<! intersections. However, a review "of the
manual count data was unable to determtne any tlUck volumes or
percentages" The tlUck traffic 111 this study area IS Slgmficant, and
must be taken into account.
A review of the Synchro output has noted several inconsistencies
throughout the analysis:
" An [deal Saturation Flow rate of 1900 pcphpl was assumed
for both signalized intersections (42'" & 48'''), whlle1800
pcphpl. was assumed for the two unsignahzed intersections.
The ODOT Analysis Procedut'es Manual requires a saturation
flow rate of 1800 pcphpl for all intersection analySts.
. The truck percentages must be based on real-world data. The
Synchro default of 2 % is not acceptable.'
.. Unless the Yellow Time (s) entered into Synchro fot' the
. .
signalized intersectlons is based on either an 000'1' or. City
_ tlming sheets, this analysis should assume 4.5 seconds of
yellow for the OR 126 approaches, and 4.0,seconds of yellow
for the City-street approa'ches. The 5.0 seconds of yellow is'
generally reserved for highways with an 85'h Percentile Speed
equal to, or greater than 45 mph" "
The TPR findings from this study are in question, due to the
inconsistencies noted in this review. It is very likely. they wlll need to
" be revised, based on the r.ecommendations in this review.
. 5~41
':'p'a2e\' ~)'~'Pa;radraDh
32
Section 8.0
- CAntOl1 1-\-11'
.'
on the previous comments in this review,".the conclusions
drawn and recommendations" proposed are in ,question. It is very
likely they will ,need to berevi,sed,based on the recommendations in
this review. '
If you havcany quesiions regarding my comments, please conta~l'me'by phone at (503) 986-2857 orby
e-mail at stenhen"b wi!son(@odoUlatenru.\. " '
C c: Jim Hanks - JR}\
" David Warren
Jane Lee
Mike Spaeth
Dennis Santos
File,"
\-,
o
'H
5-42
FW: Springfield - East Springtield Kezone ll'l< f\IlalY:;l' I\.CVlCW
" . .
,- -'Q- - .-.
EXHIBIT A-11
REESOR David
From: MCKENNEY Gary
Sent: Tuesday, May 15, 20074:28 PM
To: REESOR David
Subject: RE: Springfield - East Springfield Rezone TPR Analysis Review
. I:
Attachments: lRP2007-00012 Trans mem01.DOC
David __c
I believe Steve Wilson is thinking in the context of an unconditioned 'approval of the PAP NZC.
Given the approach we planned to take in conditioning this approval, I think only Item #18 ofhis noted
issues is relevant to ensuring Goal 12 compliance, "
. . This issue was discussed in my April 4, 2007 memo to you (copy attache,d). I assume you can respond
to Steve's question on how we conclude that the assumed' existing-zoning development scenario is no
more intense than "worst case."
If we condition the PAPA to limit trips to less than or equal to what would be generated by the "worst
case," all the othet issues appear moot.' ' '
:Gary
v.
-------~--~_.- .
------------
.'
From: REESOR David
Sent: Monday, May 14, 2007 10:34 AM
To: MCKENNEY. Gary. .
Subject: FW: Springfield - East Springfield Rezone TPR Analysis Review
Gary-
What are y?ur thoughts on the attached memo?
-DR
-~-,-------.,..---
---_._---.,._._------_.__.._--,-----..,.--------'---------""--~------
From: MOORE Ed W [mailto:Ed.W.MOORE@odot.state.or.us]
Sent: Monday, May 14,20078:06 AM
To: REESOR David; MCKENNEY Gary
Subject: FW:' Springfield - East Springfield Rezone TPR AnalysiS Review
",
FYI
5-43
5/25/2007
... ....b... ............
EXHIBIT A- 3
REESOR David
From: MOORE Ed W [EdWMOORE@odot.state.or.us] .:,..
Sent: Monday, May 21,20073:14 PM
To: REES,OR David
Subject: ~E: PeaceHealth Plan and Zoning Map Am"endment". .<"""'
Dave, that is what we agreed to at our meeting and it still hold for us. Ed
-----Original Message-----
From': REESOR David [mailto:dreesor@Ci.springfield.or.us]
'Sent: Monday, May 21, 2007 11:49 AM
To: MOORE Ed W (OR)
Cc: MCKENNEY Gary .
Subject: PeaceHealth Plan and Zoning Map Amendment.
Hi Ed-
I just wanted to clarify with you ODOT's position on the PeaceHealth proposal (LRP2007-Q0013 &.
ZON2007-00012).Based upon the meeting you and I had with Gary McKenney, weare all.in agreement
that the 'most appropriate way to address Goal 12 compliance' on this proposal is by conditioning a trip
cap to what the worse case scenario would be under existing zoning (LMI). Does this sound correct to
you? "
Thanks,
David Reesor
Planner III
City of Springfield"
541.726.3783
5~44
5/25/2007
FW: Springfield - East Springfield Rezone Tl'K A.Ii.alysls KeV1CW
.... ....5... J... V,L_
EXHIBIT A-12
-.-.;Original MeS5age~---
From: WILSON Stephen B
Sent, Friday, May 11, 2007 10:03 AM
To: MOORE Ed W "
Cc: . jimhanks@jrl1web.cami WARREN David; LEE Jane ?; SPAETH Michael. A; SANTOS Dennis N
.Subject: Springfield. East Springfield Rezone TPR Analysis Review
Ed...
This is my technical review of this TIA submitted by JRH. I apologize for the delay in
getting this review out.
<<East Springfield Rezone TPRAnalysis Review.pdf>>
,.
Stepfz.en $, Wil6o.n, PE
Senior Transportation Analyst
ODOT - Region 2 Tech Center
455. Aiq:~ort Road SE - Building' A'
Salem, OR 97301-5397
(503) 986-2857
5-45
5/25/2007
"'"
.m,Peac~Health
March 15,2007
> . ;f;i ,~':' .3::t~<< "
Type II Metro Plan/East Main Refinement Plan'
Diagram Amendments
Written Explanation of the Proposal
Applicant:
PeaceHealth Oregon Region
. 770 E. II th Avenue ,
P.O. Box 1479
Eugene, Oregon 97440
Property Owners:
Hyland Business Park, LLC (Ta'{ Lot 400)
1941-A Laura Street .
Springfield, OR 97477
. Attn: Shaun Hyland
(241) 726-8081
Andrew Head (Tax Lot 402)
1616 Ardendale Ln.
Eugene, OR 97405
(541) 521-3403
Applicant's
Representative:
Philip Farrington, AICP
Director, Land Use Planning & Development
. PeaceHealth Oregon Region
123 International Way
Springfield, Oregon 97477
(541) 686-3828' Fa'{ (541) 335-2595
pfarrington@peacehealth.org "
1.0 Land Use Request
PeaceHealth Oregon Region (the "Applicant") requests approval to change the map
designation on the Metropolitan Area General Plan ("Metro Plan") diagram from Light
Medium Industrial ("LMI") to Community Commercial ("CC") for approximately 5.24
acres identified as Ta". Lots 400 and 402 on Assessor's Map No. 17-02-32-00. This same
acreage on the site is being proposed for a concurrent amendment to the'S pringfield
zoning map from LMI to CC, as allo\ved in Springfield Development Code CSDC")
12.020 (1)(a)l.
5-46
Metro PlarrlEMRP Diagram Amendment
. PeaceHealth Oregon Region
Mar,,, 1).2007
Page 2
The area subject to the proposed land use designation changes is mapped on Attachment
A, and is referred to collectively in this application as the "subject properties" or "site."
Pursuant to SDC"7 .11 0 (4), approval ofthe requested Metro Plan diagram amendment
automatically amends the refinement plan diagram and is proc'essed concurrently.
Findings of fact addressing the criteria of approval in SDC 7.070(3) are included in this
narrative statement (see Section 5 below). .
. .
. "
2.0 Project Purpose, Relationship to East Main Re!inemeht Plan
The Applicant seeks to redesignate and rezone the subject properties to CC so they may
be'developed for 'commercial uses (i.e.', Tax Lot 409), including a possible future medical
clinic which could sen;e residents in the growing east Springfield area, and to be allowed
to continue long-standing commercial operations (i.e., Tax Lot 402). Approval of this
land use request would preserve employment and existing viable' commercial op~rations
on Tax Lot 402, and create stable family:wage employment opportunities on Tax LotAOO
_ a vacant and underused industrial site. The proposal would also help beautify this
portion of Main Street from its traditional industrial yard:uses, and future development
would provide a superior buffer for residential uses to the west than currently exists.
The proposahs also consistent with the East Main Refinement Plan (EMRP) criteria for
designating property.as Commercial within the refinement plan (EMRP, pg. 12) since:
a) The propos.a! would not be an intrusion into a well-maintained residential
neighborhood." The proposal would allow for higher quality development than has
historically existed on the vacant industrial site (Tax Lot 400), th'erefore providing
opportunity for improved buffering between abutting residential and non-
residential uses" Tax Lot 402 borders only Tax Lot 400 and two commercially
zoned parcels, so legitimizing the pre-existing commercial uses on.that property
would not affect the existing residential area nearby.
b)" It does not increase conflict between Low Density Residential and Commercial
uses, but in fact can provide for uses and development far superior to those that
have traditionally been located adjacent to the abutting residential area.
Moreover, the area abutting Tax Lot 400 to the ';"est is zoned Medium Density.
Residentlal, though in primarily low density residential use.
c) The criteria for designating Medium Density Residential land does.not apply
because the subject properties are not currently developed, nor have they ever
bee~ designated, for MDR uses,.
d) Legally created commercial uses have existed on the properties, and the proposal
would facilitate higher quality commercial "uses (such as medical offices) than
have existed before on Tax Lot400, and allow for Plan designations and zoning
to correspond with long-standing legally established commercial uses on Tax Lot
402.
. e) Adequate access exists to an arterial street, with existing curb cuts directly onto'
Main Street.
5-47
Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March'15 2007
Page 3
3.0 Site Context
"The subject properties inclu~e avaca'nt; flat parcel (Tax I:.~t 400) a'nd existing
commercial development (Tax Lot 402) east of-44th Street along- Main Street in east
Springfield. The site is b(]rdered on the south'by Main Street, o~ the east by the Hyland
, Business Park, on the north by an open area south of the Weyerhaeuser mill site (Tax Lot
400) or an existing 'commercially zoned parcel (Tax Lot 402), and on the west by other
small-scale commercial enterprises (e.g., a cabinet shop and karate school) fronting Main
. Street and residential homes along 44th Street,west of Tax Lot 400. Commercial.'
enterprises are located immediately south of the site across Main Street (e.g., Gray's
. Garden Center). . .
While historically invol ved in agricultural' uses, since around 1990 Tax Lot 400 'was used
as a storage and sales yard for landscape organics and forest by-products. The current
property owners also used the site to store modular construction offices, tool trailers,
construction equipment and concrete form plywood. Tax Lot 402 has had various
"commercial services on site. since the 1950s.
The properties have no jurisdictional. wetlands or inventoried GoalS n"atUral or historic
resources. The site is within the Springfield Urban Growth Boundary, and both parcels
were annexed into the City of Springfield in 1960. The EMRP diagram (adopted in
1988) currently designates the subject property for industrial uses.
The abuttlngproperty tO,theeast is designated Li'ght/Medium Industrial in the EMRP
diagram and zoned LMl The areas immediately to the west and south of the site"fronting
1viain Street are identified as being within Mixed-Use Area #2 in the EMRP, 'and are all
zoned Community Commercial. Property.to the west of Tax Lot 400 along 44th Street is
zoned and designated Medium Density Residential.
, 5~48
Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15 7007 "-
Page 4
4.0 Type II Metro Plan Diagram Amendment
Amendments to the Metro Plan are classified as Type"! orJype II amendments,'
. depending upon the speciftc changes sought. The proposed Metro Plan and EMRP .
amendments are "site specific" and relate to property solely within the corporate limits of
the City of Springfield. The Metro Plan defines Type II amendments as> . .
"[A]ny change to the Plan diagram or Plan text thdt'is site specific
and not otherwise a Type]. category amendment."
, The proposed amendment is aTYRe lI,site-speciftc amendment because.it:'
. . Involves a specific geographically identi;fiable'pr~perty;
. " Does not change the metropolitan Urban 'Growth Bou.ndary;"
'.' . Does not change the Metro Plan Jurisdictional boundary; .
. Does not require a goal exception;
. Does not include a non-site-specific amendm~nt of the Metro Plan text; and
. Applies only to property located within the Springfield City.limits,
Accordingly, the current proposal is prop'erly chara,cterized as a Type II amendment (as
defined in SDC 7.030) that must be reviewed and aRproved by the City of Springfield,
consistent. with SDC 7.070 (2)( a). . Per SDC 7.040 (2)(b), this citizen-initiated Type II
Metro Plan amendment can be, initiated at any time.
. .
5.0 Applicable Approval Criteria
Type II Metro Plan amendments are evaluated according to the criteria of approval
contained within SDC 7.0~O (3), which provides:
"The following criteria shall be applied by the City Cquncil in
approving or denying a Metro Plan amendment applic~tion: '
(a) The amendment must be consistent with the relevant
Statewide planning goals adopted by the Land
Conservation and Development Commission; and
(b) Adoption of the amendment must not make the Metro
Plan internally lnconsistent."
Findings demonstrating consistency with the approval criteria are outlined below.
5-'49 .
Metro Plan7EMRP Diagram Amendment
PeaceHealth Oregon Region
March 1 \, 7007
Page 5
5.1 Consistency With Statewide Planning G~als
The following findings address compliance with Metro Plan criteria in SDC 7.070 (3)(a).
Approval of a Metro Plan diagram amendment also corresl1~ndingly changes the. .
applicable refinement plan diagram, as established in SDC'7:IIO (4).
Goal 1 - Citizen Involvement
Goal 1 addresses the need to develop a citizen involvement program to ensure citizen
involvement in all phases of the land use planning process. The Planning Commission
and the City Council will hold public hearings and accept testimony on the proposal.
Through the procedures'established by the city, citizens.will receive notice of hearings in
generally published local papers and have the opportunity to be heard regarding the
proposed diagram amendment and zone change. Notice of the public hearings will also
be given in accordance with SDC requirements to nearby property owners, interested
parties requesting nqtice; and any established neighborhood organization. Since the
amendments comply with the City's citizen involvement program and citizens have
opportunities to be involved in the procedure, the proposed amendments are consistent
with Goal I:
Goal2 - Land Use Planning
Goal 2 requires that local comprehensive plans be consistent with'the Goals; that local .
comprehensive plans'be internally consistent, and that implementing ordinances be
consistent with acknowledged comprehensive plans. Goal 2 also requires that land use'
decisions be coordinated with affected ju.risdictions and that they be supported by an
adequate factual base. As required in SDC 7.050, the City is required to give referral
notice of the proposed Type II Metro Plan diagram amendment to the Cit{of'Eugene and
Lane County so they may determine if there are grounds to participate as parties to the
hearing. The City also sends the statutorily required notice of the initial public hearing
45 days in advance to the state Department of Land Conservation and Development,
ensuring that they are given opportunity for comment al}d review conformity to
applicable state\vide planning goals. .
The Metro Plan and the SDC, as well as the Statewide Planning Goals and applicable
statutes, provide policies and criteria for the evaluation of comprehensive plan
amendments. Compliance with these"measures assures an adequate factual base for
approval of the proposed Metro Plan diagram amendment. As'discussed elsewhere in
this document, the amendments are consistent with the Metro Plan and the Goals.
. Consequently, by demonstrating such compliance"the amendments satisfy the
consistency element of Goal 2.
.'
Goal3 - Agricultural Lands
This goal is inapplicable because as provided in OAR 660-15,000(3), Goal 3 applies only
to rural agricultural lands. The subject properties are located within an acknowledged
urban gro'wth boundary, are inSIde Springfield's corporate limits, and have not been in
agricultural use for decades.
5-50
Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March I.)' 20Q7
Page 6
Goal 4 - Forest Lands
Goal 4 does not apply within urban growth boundaries, per OAR 660-06-0020, and the
areas affected by the Plan amendments are inside Springfield's acknowledged UGB.
Goal 5 .:.. Natural Resources
Goal 5 requin;s local governments to protect a variety of open space, scenic, historic, and
. natural resource values. Goal 5 and its implementing rule, OAR Ch. 660, Division 16
, '
require planning jurisdictions, at acknowledgment and as a part of periodic review, to
(1) identify such resources;
(2) determine their quality, quanti~, and location;
(3) . identify conflicting uses;
".
c
(4) . examine the economic, social, environmental, and energy
(ESEE) consequences that could result from allowing,
limiting, or prohibiting the conflicting uses; and
(5) develop programs to resolve the conflicts.
I
The subject properties are not on Springfield's acknowledged Metro Plan Goal 5
inventory. No threatened or endangered species have been inventoried on the site, and no
archeological or significant historical inventoried resources are located on the site. The "
National Wetland Inventory and Springfield Local Wetland. Inventory maps have been
consulted and there are no jurisdictional wetlands located on the site. Therefore,' the
proposed amendment does not alter the City's compliance with Goal 5. . '
Goal 6 _ Air, Water, rind Land Resources Quality
The purpose of Goal 6 is to maintain and improve the quality of the air, water and land
resources of the state. Generally, Goal 6 requires. that development comply with
applicable state and federal air and water quality standards" In the context of the .
proposed Metro Plan diagram amendment, Goal 6 requires .that the applicant demonstrate
that it is reasonable to expect that applicable state and federal environmental quality
standards can be met.
Though Tax Lot 400 has been used for low-value storage and quasi-industrial uses, the
site is not listed on any state or local environmental clean-up list. A Phase I
environmental assessment on the subject property was conducted and recommended
"additional analysis. Upon recommendations through the Phase 2 environmental'
assessment a nominal quantity of soil (less than 10 cy) impacted by earlier/historic use
was removed from the site and properly disposed. Given the nominal impact generated
by historic uses on the site, it is reasonable to conclude that future development on the.
site will be able to demonstrate compliance with City standards for water quality
protection through the site plan review process, thereby complying with applicable state
and federal environmental quality standards.
5-51
".'
Metro PlanlEMRP Diagram Amendment
Peace Health Oregon Region
March 1 S ?007
Page 7
Goal7 - Areas Subject to Natural Hazards
Goal 7 requires that development subject to damage from natural. hazards and disasters be
planned and/or constructed with appropriate safeguards and mitigation. The goal also.
requires that plans be based on an inventory of known areas Of natural disaster and
hazards, such as areas prone to landslides, flooding, etc. .
The site is flat and not subject to landslide hazards, and is located well outside of any
established FEMA flood hazard area. Therefore, approval of the proposed Plan
amenaments will not alter the City's acknowledged compliance with Goal 7 through its
adopted plans, codes and procedures. .
GoalS - Recreational Needs
Goal 8 requires local governments to plan and provide for the siting of necessary
recreational facilities to ,"satisfy the recreational needs of the citizens of the state and
visitors," and where appropriate, provide for the siting of recreational facilities including
destination resortS. The subject site is not included in an inventory of recreational sites,
and the propo'sed amendments will not have an impact on the community's recreational
facilities or needs; therefore, the proposal does not lmplicate Goal 8.
Goal 9 - Economic Development
Goal 9 requires the city to provide adequate opportunities for a variety of economic
activities vital to the health, welfare, and' prosperity of the citizens. The proposed.
amendment to the Metro Plan diagram will increase the city's capacity for economic
development by adding 5 acres ofCCin place of the existing industrial designation.
Permitting the construction of future clinic facilities and allowing long-standing
commercial uses on Tax Lot 402 to become conforming uses consistent with commercial
zoning is consistent with nurnerous policies in the City's adopted plan for compliance
with Goal 9, the Springfield Commercial Lands Study (SCLS).
Specifically, the following SCLS policies are applicable to the proposal:
Policy l'A: "Maintain a mixed supply of large and small commercial sites'
through strategies such as rezoning or annexation to serve Springfield's
future population."
Theyroposal fulfills this policy objective by redesignating and - through accompanying
zone change _ rezoning land from industrial to commercial, for two tax lots of varying
sizes and commercial uses, thereby maintaining existing employment andcommercirrl
use in Tax Lot 402 and providing" the ability for growth in medical sector employment by
allowing future clinic uses on Tax Lot 400.
Policy I-C:. "Maintain at least a five-year supply of commercial land
within the Urban Growth Boundary (UGB) that is currently served or
readily serviceable with a full range of urban public facilities and
services."
5-'52
Metro PlanlEMRP Diagram tIlTlendment .
PeaceHealth Oregon Region
March \ 5.- 2007
Page 8
The scq (see Table 3-8, pg" 32) found there to be a deficit of 158 acres in the supply of
commercial "!and over demand projected through the year 201 S. The proposal would
allow for redesignation, and rezoning, of five acres thereby reducing the deficit of .
commercial land. The subject site has a full range of urban public facilities and services
available to support existing commercial deyelopment on Tax Lot 402, and future .
development on Tax Lot 400. TheSCLS identifies (pg. 33) a need to support .
"employment in population-dependent sectors such as retail sales and health services" to
me,et Springfield's growing community. The SCLS also noted (pp. 27-29) state and local
trends in greater employment in retail trade and well-paying health servic"es sectors.:
'Approving the proposed redesignation-and zone change would help meet Springfield's
demonstrated need for employment and commercial services. .
Findi[lg 3 in the SCLS (pg. 36) cited the acknowled,ged 1992 Industrial Land Study as
demonstrating that "'a surplus of industrial sites exists in the Metro Area." Therefore, the
proposed redesignation (and corresponding rezoning) would nor-result in a deficit of
needed industrially designated.and zoned lahd,but it would help reduce.the commercial
lands deficit identified in the SCLS. Therefore, approving the proposal would be .
consistent with SLCS Implementation Strategy 3-A (I): "Evaluate inventories basedon
demonstrated need for the planning period. Initiate rezoning or redesignation of surplus
land uses where more appropriate for commercial, consistent with the Metro Plan."
,
The proposal in fact 'consistent with inventories for c'omm,ercial' and industrial lands
adopted by the City Council and acknowledged by DLCD as being consistent with Goal
9. Oregon Administrative Rules concerning Goal 9 implementation (OAR 660-009-
0010(4)) call for amendments to land use designations "in excess oftwo acres within ,an
existing urban growth boundary from an industrialla1)d use designation to a non:
. industrial use designation'"to have to address applicable,planning requirements - such as
consistency with the Metro Plan and other local plan policies (i.e., SCLS) or be consistent
. with an economic opportunities analysis. The City can find that,the proposal complies
with relevanf local plan policies by converting one fOrID or employment_generating land.
use to another, without negatively impacting thesupply'ofbuildable lands for either
categoryof uses. The proposal enables continued use of the existing and long-standing
commer,cial'center to continue to operate and provide employment opportunities, while
al~o allowing h'igher-value employment associated with future development on Tax Lot
"400. These types of employment-generating uses are amongthose identified in OAR .
660-009-0005(6) as eligible non-industrial employment activities that can justify
approval of the proposed Plan diagram amendment without the need for an economic
opportunities analysis apart from the SCLS, \~hich DLCD acknowledged as fulfilling the
City's obligatIons under Goal 9.
. Because the requested redesign,ition and concurrent zone change implements SCLS
policies and does not result in a deficiency of needed industrial lands, and is otherwise'
demonstrated to be consistent with relevant Metro Plan policies, approval of the request
is consistent with the Citv's compliance with Goal 9 and applicable administrative rules
. .
regarding Goal 9 implementation.
5-53
-
Metro PlanlEMRP Diagram Amendment
PeaceHeallh Oregon Region
March J 5, ?007
Pa_ge 9
Goal 10 - Housing
LCDC's Housing'goal requires cities to maintain adequate supplies of buildable lands for
needed housing, based on an acknowledged inventory of buildable lands. The proposal
does not affect the City's inventory of residential Iands.
In fact, approval of the requested" redesignation for Tax Lot 400 would enable
redevelopment of an industrial site abutting existing residential development. Through
the site plan review process, future development on that property will provide a superior
buffer and a higher use that will benefit the adjoining residential properties. Because the
proposal involves redesignation 'from industrial to commercial land ust;S, it does riot
affect Springfield's continued compliance with Goal'l O.
Goal.ll.-,: Public Facilities and Services
This goal requires the provision of a timely, orderly and efflcient..arrangement of public.
facilities,and services. The subject property is located within the Spnngfield UGB and
city limits,' and is already designatedJor urban ievels of use. The proposed amendment to
the Plan map designations from LMI to CC will not affect the ability to provide needed
services since all the required urban services are available to support existing or future
COmmercial uses on, the subjeetsite.
Goall2 - Transportation
Goal 12 requires local governments to provide and encourage a safe, convenient and
economical transportation system. The proposed map "amendments involve . .
approximately 5.24 acres of property, though existing and long-standing commercial uses
occur on Tax Lot402 such that approval of the proposal will not result in any changes to
the type or intensity of uses on the site, and will not increase t)"le trip generation for that
parcel. As the attached Traffic Impact AnalYSIS (TIA) demonstrates, future development
of medical office facilities on TL400 will not degrade mobility standards"be\ow
acceptable levels and allow'for adequate queuing lengths a\ applicable intersections.
" Therefore, the proposal will not have a "significant effect" on transportation facilities as I
defined in the Transportation Planning Rule (OAR 660-012-060).
Existing development at Tax Lot 402 is not affected by the proposal, and is assumed to
retain its current access points off Main Street It is further assumed that future
development on Tax Lot 400 will result in some access changes as will be reviewed
through the site plan review process, thereby consolidating two existing curb cuts located
.on Tax Lot 400 into a single access point located approximately in the center of the
parcel. The TIA demonstrates that these access points will not result in any degradation
of mobihty standards below acceptable levels, and that safe and efficient circulation can
be real1zed through approval of the requested land use redesignation (and companion
zone change).
Furthermore, reducing the number of access points for future development on Tax Lot
400 is consistent WIth policy objectives found in East Main Refinement Plan (EMRP)
5"':54-
Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15. i00.7
Page 10
Access, Circulation & Parking Element policy IB (pg. 17) and Commercial Element
policy 3 (pg. 12).
Because the proposal, as demonstrated in the TIA, is consistent with the requirements of
the TPR and with applicable policies in the EMRP, it is consistent with Goal 12 and.
applicable local implementing policies.
Goal 13 - Energy ,Conservation
The Energy goal is a general planning goal and provides limited guidance for
site-specific map amendme'nts. The proposed amendment has no direct impact on energy
conservation, though it would in fact.will promote greater energy efficiency by enabling
needed clinical services available to growing residential areas in east Springfield.
Therefore, the proposed amendment is consistent with, and does not alter the City's
continued compliance with Goal 13.
. Goal 14 - Urbanization
Goall4 requires local jurisdictions to provide for an "orderly and efficient transition
from rural to urban land use." The subject property is within the UGB and the city limits
of Springfield, and within an existing urbanized area of the community. Therefore, Goal
14 is not applicable to this application.
Goal 15 _ Willamette River Greenway
This goal is inapplicable because the subject property is not within the boundaries of the
Willamette River Greenway. .
Goals 16-19 - Coastal Goals
The coastal goals are not applicable to this application.
5.2 Metro Plan Consistency .
The application requests amendment of the Metro Plan diagram from LMI to CC for
. approximately 5.24 acres. This section of the application narrative addresses the
consistency of the amendment with the applicable policies of the Metro Plan, to
demonstrate that adoption of the amendment will not make the Metro Plan internally
inconsistent (as required by the approval criteria in SDC 7.070(3)(b))
This narrative only addresses those policies that apply to the proposal, and"does not
discuss those' portions of the Metro Plan that: (I) apply only to rural or other lands
outside of the urban growth boundary, (2) apply to land uses other than the current or
proposed designations for the site and will not be affected by the proposed Plan diagram
and text amendments, or (3) clearly apply only to specific development applications (e.g.,
site plan review submittals or subdivisions). In many instances the goals, policies and
implementation measures apply to specific development proposals thatwill "be addressed
5-55
Metro PlaniEMRP Diagram Amendment
PeaceHealth Oregon Region
March 1) 2007
Page II
through compliance with applicable City. regulations during site plan review of a given
future development proposal. .
The Metro Plan Introduction, Section D provid~s ih~'f~llo~ing definitions:
A goal as a broad statement of philosophy that describes the
hopes of the people of the community forthe future of the
community. A goal may never be completely attainable, but.
is used as a point to strive for.
An objective is an attainable target that the community
attempts to reach in striving to meet a goal. An objective may
also be considered as ari,interrnediate point that will help
fulfill the overall goal. .
A policy is a statement adopted as part of the Plan to provide
" a consistent course of action moving the community towards
attainment orits goals.
Except for the Growth Management Goals, which are addressed below, ellch of the Metro
Plan policies are addressed in the order in which they appear in the Plan Element section
. of the Metro Plan.
S.2.A.
Metro Plan Elements
1. Growth Management
,
Policies
1. The urban growth boundary and sequential development shall '
continue to be implemented as an essential means to achieve
compact urban growth. Provision of allllrbllll services shall be
concentrated inside the IIrban growth bOIl!ldary.
The proposed amendments satisfy this policy because the subject property is inside the
UGB and city limits and as such, encourages compact urban growth. Also, urban
services are available at sufficient levels to accommodate the existing and future inftll
development resulting approval of from this application. The City's site plan review
processes ensure that the appropriate level of services is available to serve future.
. development.
5":56
Metro PlaniEMRP Diagram Amendment
PeaceHealth Oregon Region
Marcn 15 ~Q0'
Page 12
2. Residential Land Use and Housing Eiement
Policies
A.II Gimerally locate higher density residential development near
eniploymen't or commercial services, in proximity to major
transportation systems or within transportation-efficient nodes.
The proposed redesignation does not affect the inventory or availability of residentially
designated or zoned land, including the single-family residential area abutting Ta~ Lot
400 that is zoned and designated for Medium Density Residential, or higher density
residential developments located east of the site along Main Street.
However, approval of the requested redesignation to Community Commercial would
allow for residential areas' proximate to t~e subject area to have close and efficient access
to existing COmmercial services on Tqx Lot 402 and to future medical facilities proposed
for Tax Lot 400, consistent with tht;: above policy. The areas proposed for redesignation
offer existing and future employment opportunities and provide commercial services
along a major transportation system that can support the' needs of nearby residentiaL
development. .
A.22 Expand.opportunitiesfor a mix of uses in newly developing areas
and existing neighborhoods through local zoning and development
regulations.
The ma'p amendment and concurrently propos'ed zone change will allow for existing
commercial uses on Tax Lot 402 to continue to serve existing neighborhoods in the mid-
and east-Springfield area, and for future clinical facilities to be developed to serve this
rapidly growing area of the community. Approving the requested redesignation and zone
change would expand commercial opportunities to serve these neighborhoods consistent
with the above policy.
3. Economic Element
Policies
B.] Demonstrate a positive interest in existing and new imiListries,
especially those providing above-above wage and salary levels, and
increased variety of job opportllnities, a rise in tlte standard of living,
andlltilization of ollr existing comparative advantage in the level of
edllcation and skill of the res.ident labor force.
5-57
Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March i 5. 2007
Page 13
The proposed amendment is consistent with this policy because it will allow medical
clinic uses to be developed to serve growing areas "in east and south Springfield. As is
observed in the Springfleld Commercial Lands Study (pp. 27, 29), employment in health
services is growing and approvirig the requested rede;ignation will enable increased job
opportunities with higher than average wages thereby helping raise the standard of living
and meet the needs of Springfield citizens, consistent with the above policy.
B.2 Encourage economic development which utilizes local and imported
capital, entrepreneurial skills, and the resident labor force.
The The construction of and the use of commercial and medical use's will utilize both
local and imported capital and will employ the 10caJ labor force in a variety of skilled,
semi-skilled, and unskilled positions, "consistent with this 'policy.
B. 6 Incre~se tile atrlqunt of undeveloped land zoned for light industry
and commercial uses.correlating the effective supply in . terms of .
suitability and availability with the projections of demand.
The proposal will add approx.imately 5.24 acres ofCommunityCommerciallahd,
consistent with recommendations to increase the commercial lands inventory made in the
Springfield commercial Lands Study. The SCLS and acknowledged metropolitan
Industrial Lands Study concluded that there is a deficit of needed commercial land, and a
surplus of industrially zoned and designated land. Approval of the requested
redesignation will not cause the inventory of needed industrial land to go into a deficit, .
but in fact would, consistent with the above policy. The proposal correlates the need and
suitability, and availability of the subject site for commercial uses with the need for such
uses as demonstrated in the adopted SCLS.
B.ll Encourage economic activities which strengthen the metropolitan
area's position as a regional distribution, trade, health, and service
center.
,
The amendment will facilitate the development of medical uses that will serve the needs
of the growing residential areas in east, south and southeast Springfield, and strengthen
the metropolitan area's position as a premier locale for healthcare services, consistent
with this policy objective. .
6. Environmental Design Element
policies
E.l In order to promote the greatest possible degree of diversity, a broad
variety of commercial, residential, and recreational land uses shall be
encouraged when consistent with 'other planning policies.
5':58. .
Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March IS. 2007
Page 14
Approval of the prop'osed map amendments will add just over 5 acres into the City's
inventory of commercially designated and zoned land, thereby allowing for a variety of
_ needed commercial uses to .occur on the subject property. Long-standing existing
commercial services on Tax Lot 402 would be allowed to continue without the specter of
being considered non-conforming uses, and Tax Lot 400 could be developed with
medical s"ervices that will serve the needs of the growing residential areas east and south
of the subject si,te, consistent with the above policy.
7. Transportation Element
Land Use policies
. " .
F.3 Provide for transit-supportive land use pattems aid development,
including higher intensity, transit-oriented developmen~ along major
transit corridors and near transit stations; medium- and high-density
residential development within one-quarter mile oJ transit station's,
major transit corridors, employment centers, and downtown areas; atlll
developmeryt and redevelopment in designated areas that are 'or could be
well served by existing or planned transit.
,
The proposed map amendment and concurrent zone change will enable land use patterns
and development consistent with the above policy: Approval of the proposal will allow.
for higher intensity development along Main Street, a major transit corridoL An existing
L TO stop is located on the frontage ofTax Lot 400 (see photo, pg" 2, Appendix A of the
TIA), and will provide convenient access to existing and projected employment on the
subject site, as well us access for patients to future out-patient medical fac{liti~s projected
on Tax Lot 400. '
5~8
Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15 2007
Page 15
Transportation System Improvements: RoadwaysPolicies
F.15 Motor vehicle level of service policy:
"a. Use motor vehicle level of service standards to maintain acceptable
and reliable performance on the roadway system. These standards
shall be used for:
(1) Identifying capacity deficiencies on the roadway system.
(2) Evaluating the impacts on roadways of amendments to
transportation plans, acknowledged comprehensive plans and
land-use regulations, pursuant to.the TPR (OAR 660-012-
0060). ' '
(3) Evaluating development applications for consistency with the
land-use regulations of the applicable local government
jurisdiction.
b. Acceptable and reliable perfonnance is defined by the following
levels of service under peak hour traffic conditions: LOS E within
Eugene's Central Area Transportation Study (CA TS) area, and
LOS D elsewhere.
c. Performance standards from the OHP shall be applied on state
facilities in the Eugene-Springfield metropolitan area.
In some cases, the level of service may be SLlbstandard. The local
government jurisdiction may find that transportation system
improvements to bring performance up to standard within the planning
horizon may not beIeasible, and safety will not be compromised, amI
broader community goals would be better served by allowing a "
substandard level of service. The limitation on the feasibility of a
.transportation system improvement may arise from severe constraints,
including but not limited to environmental conditions, lack of public
agency financial resources, or land use constraint factors. It is not the
intent of TSI Raodway Policy #2: irIotor Vehicle Level of Service to
require defenal of developmellt ill such 'cases. The illtellt is to defer
motor vehicle capacity increasillg transportation'improvements until
existing consiraints can be overcome or develop an alternative mL-<: of
strategies (such as: land use measures, TDM, short-term safety
improvements) to address the problem.
SubsectlOn a.(2) in the above policy requires an evaluation of the proposal pursuant to the
state Transportation Planning Rule (TPR). The accompanying Traffic Impact Analysis
5-60
" Metro PlanJEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15. 2007 '
Page 16
provides the factual basis to determine that the proposed redesignati~n would not result in '
.a "~igniflcant effect" as defined under the TPR (OAR 660-012-0060(1)).
Specifically, the proposal does not change the functional ~lassiflcation of Main Street or
any other nearby roadway, and it does not change the standards for implementing the
City's functional classification system ofroadways, as identified in the Regional
Transportation Plan, As demonstrated in the TIA, the proposal also does not:
. Result in types or levels oftraffic or access that are inconsistent with the functional
classification of Main Street or any other nearby roadway;
. Reduce performanc'e of traffic on Main Street or other affected intersections to a level
that is below acceptable established performance standards; or
.. Make performance of existing facilities worse (i.e., b~low acceptable mobility
standards) than would be the case other uses permitted under.existing designations or
'. .
zonmg.
Specific TPR findings are,further located in the TIA, see pp. 31-32. Becmis~the proposal
does not result in a "significant effect" as established'by applicable OARs, no further
TPR analysis is required. The request is' therefore consistent with the above policy.
S. Public Facilities and Servic~ Element
G.] Extend the ,ninimum level and full range of key urban facilities alii/. )
services in an orderly and efficient manner consistent with the growth
management policies in Chapter II-B, relevant policies irdhis chapter and other
lvI etro Plan policies.' .
The subject property is located in Springfield's city limits UGB. All necessary
infrastructure and key urban facilities/services are presenrto serve existing development
(Tax Lot 402) or are available to serve 'future infill.development onTax L,ot400.
Therefore, the propo'sal is consistent with the ~bove policy.
. 9. Parks and Recreation Facilities Element P9licies
Policies in this element of the Metro Plan are not relevant to the requested diagram
amendment
10. Historic Preservation Element policies
Policies in this element of the Metro Plan are not relevant to the requested di:!gram
amendment . .
5-61
Melro"PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
Mar<:" ". 20i\7
Page 17
n. Energy Element Policies
. Policies in this element of the Metro Plan are not relevant to the requested diagram
amendment.
,
S.D East Main Refinement Plan Consistency
The folio wing demonstrates how the proposal is consistent with applicable policies in the
East Main Refinement Plan (EMRP).
1. Mixed-Use Element
Policy 2) A rea #2
A) Thefollowing land uses are allowed under Community COfflmercial"
zoning: .
, All Comniunitv Con;mercialuses subject to Article 18. of the
Springfield Development Co.de. .
The proposal requests redesignating the subject properties to Community Commercial, .
and concurrently rezoning the properties to CC, as is allowed by the above policy and
consistent with other. EMRP policies. Approval of the request would allow long-standing
existing commercial uses on Tax Lot 402 to. continue as permitted under Article 18, and
consistent with neighboring uses to the west and south, which are also zoned and
designated for commercial uses.
2. Commercial Element
.
Criteria for Commercial Refinement Plan Desirznation.
1. Generally, the Co;nmunity Commercial.rejinement plan design~tion
shall be applied under the following circumstances:
A) where it is not an intrusion into well-maintained residential
neighborhoods;
The proposed redesignution does not intrude into the existing residential area west.
of the subject site along 44th Street, and is therefore consistent with the above
criterion.
. 5-62
Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
. March 15 ?DO' "
Page, 18
-B) where it does not increase conflict between Low Density, .
Residential and Commercial; :1
'--
Although the abutting residential areais zoned Medium 'Density Residential,it is
developed in low density residential uses. Approval of the proposed, '
. . . . 1
redesignation of the subject sites would actually result in a decrease of conflicts
between abutting residential and non'residentialland uses by allowing future infill
development on Tax Lot 400, an'd through the site plan review process ..
establishing improved landscaped buffers and a use more compatible than the
industrial uses that histori'cally abutting this residential area'-
C) !Vhere criteria for designating JHediitmDensity Residential
Idnd does not apply; .
, ~ . '
Criteria for designatingMDR land does not apply to the subject site.
'. ....1
. D) where legally created eomrilereiatuses exist;
Tax Lot 402 has existing, long-standing commercial uses that were legally created
prior to development of the Metro Plan or EMRP.
....
]::)_where adequate customer and serviee,access to an art~rial' ,
street ea,! be provided; ..... and .
. The subject site has adequate legal access onto Main Street, which is Classified as
an arterial street.
. J , .
F) where' designated Commercial on the i'yJetro Plan Diagram.
Approval of this application would result in a Com~ercial desi'gnation on the .)
Metro Plan diagram, which would also automatically modify the designaiion on
the EMRP diagram.
Policy 2), Apply' site-specijic Commercial...ejinement plan designations
to clearly define the limits of new commercial uses whel'i!'thel'e is 'not'ari
existing, legally'established, and beneficial mixing 0/ uses. '
Approval of the requested redesignationwould apply Commercial plan designations to
the subject properties, allowing the existing, legally established commercial uses onTax
Lot 402 to continue. It would also enable commerciai uses to be established on Tax Lot
400, thereby defining the.\imits of new commercial uses between the pre-existing
commercial uses on Tax Lot 402 and others to the west, and the developed industrial
business park to the east. Tax Lot 400 does not have an existing or beneficial mix of '
Llses, but hashistorically housed industrial yard-type operations. Therefore, approval of
t 5-63
Metro PlaniEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15, 200' .
Page 19
the proposal would define the limits of new commercial uses'as called for in the above
policy, and also provide the ability to make superior buffering and :other improvements'
associated with future development on Tax Lot 400' through the site plan review process.
, . .., ~ . ." . 0,. , _ ,.' : ...~.,., ':, '.
Policy 3) Reduce the number of vehicular access points atldrequire the
rebuilding of curbs and installation of sidewalks and street trees along
'N!ain Street, through the Site Plan Review process" and in public
improvement projects. '
The proposal would result in reducing the number of ~xisting access points as required
above: Through the Site Plan Review process, "future development on Tax Lot 400 will
have a single driveway access onto Main Street, eliminating one of the two existing curb
cuts on this site. Sidewalks and street trees are already located along its Main Street
frontage, consistent with the above policy.
Policy 4) Provide buffering between commercial and residential uses
through Article 31 of the Springfield Development Code, Site'Plan
Review process. .
Existing residential uses along the east side of 44th Street have had no real buffer from
pre-existing industrial uses on Tax Lot 400. Approval of the proposal would.allow for
attractive infill development of future medical facilities that would provide (through the
SPR process) improved landscaped buffers between the future use and existing
residential area to thewest - as required by Code, and consistent with the above policy.
3. .. Industrial Element
Policy 1) The City shall encourage efforts of various agencies to attract
new and retain existing jobs"(/lId business~s. . .
.
Imolementation
The City.shalln;wintaina currerlt inventory of vaCllnt commercial and
industrial land and'Stmctures within the Ea.st N!ainarea.
Consistent with the above p'olicy, approval of. the requested redesignation will enable
existing, long-standing jobs and businesses on Tax Lot 402 to remain as legal,
conforming' land uses, and allow future development of new employment on Tax Lot 400
'with higher than average wages and employment densities than the current designation
and zoning allows
5-64
~SI,ct.44"e ~
.~.]_:~:.:.c. '.;~.':......i";,:f~Jj_;;;~;;,';i;.,i~%'.'1;i.i,:..,".':~;9a '~.1'76?::'~;~~'; !
~ _. _ - - - - - " ". ".;~:,~~f{t. :
,
/.JS/, 02"
,
. ',7"'19"8.':;?'
I
I
I
I
I
I
I
I
I
I
I:
I
:~I
lei
't
~
I
77..9C-?_ ':;-/-4.14~
SOO.2'
401
501
02 32 2 4'
'n
OJ
.2
~
CIJ
I
'\I
.
l\.
,'t
~
I .
.0 ~
Cl !:i
~"' -
t!
t..;
~
~
~
I /3~i<o'
.
I'l
irI' "-..
~ ~
...
,
. - ....
" ,
. ~
~ '1'
T)I>.
~
~"5.+ .
.r.J'" ~ i/;f9"U'p.r~
r- .', .'
"y-
EXISTH 3
. r~1
/ . tJ,'f9Ch! L
so/' /~-.L..?93 '/ ~ _
NE COR./' NW COR. . ;:
TD EDWARDS AWHAMMIl ~
D.L.C. 55 D.LC. 36
100
.
~
.~
.~~
'<)
~
co
t<)
N
~ d
~ z
,
.. 0
" c:r
0
n:
>-
I-
Z
::>
0
0
.""'-'::-",',"
,,': : ':. . : -;~J~\:~~,:{. '.
. :. ':" ,..,.<:'.::}~j.;:~a;}~*;';?, I
III Community Commercial
Light Medium Industrial
~~:,j Medium Density
Residential
02 32 2 4
/..:;>S/. 02
/. 7...9C....,.~ S/~,14' SOO.2 , I ,;>4 9.8.R . I
401 501 I I
, I I
.'(\
OJ I I
.2
I
. I , I
fY) I
'<I il)' \. I
, ~ ,
l\ l- I
~ .... . '~I
~ ,
I ' . - 1'\ t--
-8 ~ .... .
. ~ 'll Iq"
~~ ~ \l' ~ ll-
t! ....'" ~ . ~
...= ~ '\
fII -- I /3.5/.3$0' I
SMITH -:J.
\c-
~g
. -u
~,
"'"
""
PROPOSED '11
, $0/' /YJ..' (...?6'3T""('
1;:"1- - ,.
NE COR.. NW COR. ::
TD EDWARDS AW HAMMIl ~
. D.L.C. .55 DLC. 36
100
~
, ~
~~ .
1(\ <l)
-.: ~
0:. ....
" II,
<;~"'44'e -,.."
00
to
N
....,
Z
0
c:r
0
0::
>-
t-
:z
;:)
.' 0
0
.. ...~:.. .' .......:\.,.;...,- ...'600-. .,.~
,.-. ":';""'-:''-''~'o':' '.,':'.: .:..-:..7'fTo;I'
. ,;~"';:' . ,
~ '-:'.',:l<_:~
. """.t
... -'102" i";
..,;.....
..-,,,
:. " ,~,.....:;::, :',,,-'....,.
. '"':":" -',i:!,;-,::;:;c
':';:h},~lm~j.~;..
.11 Community Commercial
Light Medium Industrial
Medium Density
Residential ,
Metro Plan I Refinement Plan
Amendment Application
#LRP2007 .00013
Rezone Application
#ZQN2007.00012
Metro Plan Amendment from LMI to
Commercial and concurrent Zoning
Map Amendment from LMI to CC
,
~~~i.'" (~J:~:"'I~' ",".;. ':" t\~ - <'l,\\:"!!"~:'-r;,,
:""~1' ."'Ol,,,VIClnIW Map'-"',!:;~;':':'~;~"f"
!.:;~:::~~~':~~ ~.:o:A;}~~'iJE:~~l~~
,_ ,.._, .---~..~'0" ,.,
~ ~f~~~~[~f~%~~~~ ~~~~;~::~~\
t,11 1:3:-:::'''" ~r <'''::~'~" _,.' ,...l_ _I~,,:,l,. 1"'1:'.:L.O~. ...,...!.... '-1''':;- .--" ",(~
~~;~:;~~
./
-'
~ie.!~;::.: --.,-..-<.-.
........~-,.-
-g..<.
-~"'"
--,,_.~.
;f!~{ '~,
~i~~;;".
. .."~:
".....';O.0"!,...,...\
,...--.--..-."
1
5-67.
"-~;;;~;;~i1;~: "(1 ~~~~~~~1~
~ETL'oo-.".",", !:'l'~, ~~' '. ~ ,.. _",
~~:"~ ,)\;;;,:,:~S~'_~,x:;" ~~~.':
5-68
5-69
"
.
3
'..
".'
..'
tt
o
r--
I
U')
C',
UJ
C
o
:c
UJ
<IJ
:::J
o
'.
Propet~,~Planning & Development
~ Peace Health'
March 28; 2007
David Reesor, Planner II
City of Springfield
Development Services Department
225 Fifth Street
Springfield, OR 97477
Re: '. Plan Amendment (LRP2007-00013), Zone Change (ZON2007-00012)
. Mr. Reesor, .
The following and attached is supplemental illformation for the above-referenced
applications, for proposed Metro Plan diagram amendment and zone change in east
Springfield, .
The proposal seeks to re'designate and rezone approximately 5.24 acres' on two' parcels
from Light-Medium Industrial (LMI) to Commercial. As noted in the application
findings submitted. last week, the Springfield Commercial Lands Study demonstrates that
the City has a deficiency in needed corrimercially designated and zoned land, so .
approving the proposal would help reduce the' identified deficit in that .land use category,
The Metropolitan Indttstrial.Lands Study (July 1993) was adopted by the local
jurisdictions and acknowledged by LCDC as being consistent with statewide planning
goals and the Metro Plan, specifica\ly fulfilling the Eugene-Springfield area's obligations
under Goal 9 (Economic Development). The Metropolitan Industrial Lands Inventory
Report associated with the MILS identified "about 1,688 constraint-free industrial '
acres,. ..This supply exceeds the projected demand over the next twenty years, which is.
between 650 to l,ln acres," (pg. 73) The Inventory Report also stated: "The 1,688
constraint-free acres may be the bestsuited to meet short-term industrial demand. This
portion of the supply also exceeds the twenty year demand projection."
The City performed subsequent analysis of industriallavd supply as part of periodic
review requirements to demonstrate compliance with statewide planning GoalS (Natural
. Resources). As shown in Attachment A, that analysis indicated that even removing the'
possible industrial acreage affected by GoalS protection measures (about 100 acres
debited from the Eugene and Springfield inventories) would leave a surplus' of industrial
lands of between 1,600 and 2,122 acres metro-wide,
Staffs GoalS work also calculated the changes in indusirialland supplies since 1991 as a
consequence of Metro Plan diagram changes (see Attachment B). This analysis .
demonstrated a reduction in less than 90 acres of industrial land over the past 15 years,
Phone: .(541)'3:~5-2593
FE: (541) 335-2595
Ri'ler8end Annex 123 International Way Springfield OR 97477
wwwpeacehealth.org/oregon" . 5-':7r..
Dedicored ro.Exccprional A/edicil7l!
and Compos.~i()l7u(e Core
,
suggesting that there is still an ample supply of available industri:illands to meetexistina
. ". . Q
and future development needs,
This analysis may also not reflect other changes within industrially designated land
categories that would further off-set.the proposed ,change to the site's LMI Plan
designation and zoning. For example, 11.5 acres ~as added to the inventory of LMI
zoned and designated land due to City Council approval in April 1997 for land.east of the
28th!31 st Street connector and north of Marcola Road (Ordinance No, 5851). Insofar as
the City and metropolitan area continue to enjoy a surplus of needed Industrial land, and
specifically Heavy Industrial zoned and designated land, the above:referenced change
added more than enol1gh acreage to the inventory of LMI .designated and zoned land to
off-set the proposal to remove only about 5 acres from the UvlI inventory. ..
We therefore respectfully submitthat the proposed Metro Plan diagram amendment and
zone change will not materially affect the inventory of needed Industrial land and will not
alter the City's continued compliance with Goal 9, . .
With acceptance of the above findings and earlier findings and narrative in the prior
submitted applications, we believe the applications are complete and ready to be set for
Planning Commission hearing. Please notify me when the hearing is set, and send me a
copy of the required hearing n~tice to DLCD for my files.
Thanks for your consideration of the above. If you need additional information, please
contact me at your'convenience.
.
. :rtk~ticP p-:.
Director,-Land Use Planning& Development
PeaceHealth Oregon Region
:
Attachments
. ., ~
5~72
A TT ACHMENT A
1J ,0 Impact of the Proposed Protections on Buildable Umd
Inventories .
This section estimates the impact of the recommended program for protecting
Springfield's resource areas on the inventory ofbuildabJe residential, commercial and
industrial land, The administrative mle quoted above is somewhat vague about how to
compute the impact. Some contend that the protected acreage should be subtracted from'
the current inventory of buildable land. Others contend that the protected acreage should
be subtracted from the surulilS of buildable land that was detennined at the adoption of
the inventory. Case law supports subtracting the protected acreage from the surplus 'of
buildable land.
Tables ll-l, 11-2, and 11-3 below summarize the amount ofland that would be
subtracted from the Eugene-Springfield inventories 'of surplus of buildable residential:
commercial and industrial lands that were' identified when each inventory was adopted.
Table 11-1, An'alysis of Maximum Possible Impact on Supply of Residential
Lands within the Eugene-Springfield Metropolitan. Area
, .
I Residential Land Supoly
Eugene-Springfield Metropolitan Area Residential Lands
and Housing Study Surplus Acres
Low Demand Assumption
or
High Demand Assumption
Acres Removed from Residential Designation by Previous
Plan Amendments'
Eugene '
Springfield
,Acres I
. 1862.00
or
790.00
Total
-84.90
-52.03
-136,93
Maximum Possible Residential Acres impacted by
Eugene Goal 5 Protection Measures
-.445.77
Maximum Possible'Residential Acres Impacted by
Springfield Goal5 Protection Measures
Remaining Surplus
-14.18
1265,12
or
193,12 J
5-73
Table 11-2. Analysis of Maximum Possible Impact on 'Supply of .
C'ommercial Lands within the Springfield Urban _Gr~wth B~undary
I Commercial Land Supply ,
'\ SpringfIeld Commercial Lands Study (2000) projects a deficit of
commercial land, ' '
\ Acres Removed from Commercial Designation by. Previous Plan
Amendments' . . .
\ Maximum Possible Commercial Acres Impacted.by Springfield's
Goal 5 Protection Measures .
I Remaining Surplus (Deficit)
Acres \'
. -158 acres
-2.8 acres 1
-11.56 acre~ 1
I
(-172.36 acres) j
Table 11-3. Analysis of.Maximum Possible Impact on Supply of Industrial
Lands within the Eugene-Springfield Metropolitan Area
I Industriall and Supply
Metropolita~ Industrial Lands Inventory Report Surplus Acres
Low Demand AssurriptiOll
or
Hie-h Demand Assumption
Acres Removed from Industrial Designation by Previous Plan
Amendments'" .
, Eugene
Springfield
.Acres
2954.28
or
2432.28
-642.30
-90.80
-732,80
Total
Maximum Possible Industrial Acres Impacted by Eugene Goal 5
Protection Measures
-44.73
Maximum Possible Industrial Acres Impacted by Springfield
Goal 5 Protection Measures
Remaining Surplus
-54.43
2122.01
or
1600.01 I
'" Does not consider actions taken by Eugene to add additional lands to the surplus. .
11.1 Impact on the Residential Lands Inventory
'In 1999, the Eugene-Springfield Metropolitan Area Residential Land and Housing Study
(Residential Lands Study) estimated the amount of vacant buildable residential land in
the area. In Springfield, a total of 3,087 acres of buildable lands were identified. The
Study classified wetlands listed on the Springfield Local Wetland Inventory as
unbuildable and were not included. in the estimated supply of buildable residential lands.
Other types of constraints were also considered and classified as unbuildable and were
not counted in the buildable residential land inventory. The list of constraints included:
. Floodways;
5-74
. ,
. Wetlands listed on th~ Sp~ingfield Local Wetlands Inventory larger than .25
acres; .
Land ,yithinthe easement of 230 KV power lines;
Land within 75 feet ora Class A stream or pond;
. Land within 50 feet of a Class B stream or pond; a~d
Small irregularly shaped lots;
Since the Residential Lands Study did not include wetlands listed on the Local Wetlands
Inventory in the buildable lands inventory, it'isassumed that protecting these wetland
sites from conflicting residentialdevelopm'ent W}1l not reduce that inventory. The
development'setbacks recommended for significant wetland sites in'this study will
slightly reduce the inventoried acreage of vacant buildable land adjacent to wetland
features, .' '
'.
.
..
.
Wethind Setbacks
'.
As noted in Table 11'-4 belovi, about 9.9S:acres oflow-density residential (LDR) and .59 '
acres of medium density residential (NIDR) land"vill be remqved from the residential
lands inventbry by the 25-foot setback 'recommended for those wetlands not already
protected by the 50 and 75 foot setbacks required by Springfield's stormwater quality
protection policies, Keep in mind that this is a worst case,scenario and assumes that the
developer'is unable to locate required stormwater facilitie_s within the. recommended
setbacks and that subdivision design cannot arrange for'th, yaid areas of affected
dwelling units to be placed adjacent to the wetland, thus reducing or eliminating lost
development area.
Riparian Setbacks
In addition to wetland setbacks, recommended riparian se.tbacks will also result in the
. -. .
. removal of vacant acreage from the inventory of buildable residential lands. 'As noted in
- . . . . -
Table 11-4, about 3.42 acres oflo\v-density residential (LDR) and ,22 acres of medium
density residential (NIDR) land will be remo,ved.from the residential lands inventory by
the 25-foot setback recommended for those wetlands not.already protected by the.sO and
75 foot setbacks required by Springfield:s stormwater quality protection policies.
The combined impact of the proposed 25-foot setbacks for wetlands and ripari~n areas is
14,1 S acres. This represents .45% of tne3,OS7 acres' of buildable residential land
described in the 1999 Residential Lands Study.
In May 2004, a Residential Lands Study. Monitoring Report was published, updating the
'residential'lands inventory to reflect dev.eIopment through 2003. The report estimated
that ill the end of2003 there was 1,361 acres o'fremaining buildable residentiallandin
Sp'ringfield. The amount of land removed from the buildable inventory by the 25-foot
"vetl~nd and riparian setbacks proposed by this report represents about I % of remaining
1 ,361 acres. . .
5-75
. '
Table 11-4. Vacant Residential Land within Pr,oposed Prot~ction Setbacks
. .' ,., "".,
. '
Setback Distance y.acant Vacan.t Totai Acres
LDR lVLDR ' ,
. . ,.... '. .~
Acres Acres" ' 1
. I Wetland Setbacks
I 25 foot 9.95 ,59 10.541
\ 50 foot 9.4 2.73 12.13 I
75 foot 4.97 4.15 9.12]
I Total 24.32 7.47 '31.79
'I Riparian Setbacks
25 foot 3.42 .22 3.64,
-
50 foot 6,06 2.73 8.791
I 75 foot' 4,97 . 4.15 9.121
I Total 14.45 7,1 21.55 j
I Grand Total 38.77 14.57 53.34 j
11.2 Impact on the Commercial Lands Inventory
The Springfield Commercial Lands Study (2000) listed several types of development
constraints that affected commercial'properties. These development constraints included:
Major transmission lines;'
Hazardous waste sites;
Slopes'greater than 15%;
Lots less' than 6,000 square feet in size;
Lots with poor visibility;
Lots with i,nadequate access;
Hydric soils;
. Unstable soils;
Willamette Greenway and Greenway setbacks;
Floodway and floodway fringe;
Wellhead zone of influence;
Wetlands listed on the Springfield Local Wetland Inventory;
Other potentially regulated natural resource sites [Natural Resources Study
. Inventory]; , . .
Sites with Plan/Zone conflicts.
. .
The Commercial Lands Study c\assilied sites on the on the Springtield Local Wetland'
Inventory as constrained. The presence of these wetlands was noted and the inventory of
vacant commercial lands was noted to reflect the constraint. The riparian sites \vhich are
part of this study were also included as constrained', since they were part of the draft
Springfield Inventory of Natural Resource Sites at the time Commercial Lands Study was
conducted.
5""76
\
Since theSpringfieldCotru;lercial Lands Study did not remove wetlands and riparian-
sites, protection measures proposed by this study wilIhave.an impact.on,the inventoried
acreage o(vacanfcortimerciallands. The development setbacks recommended for
'significant wetland and riparian sites will further reduce the inventoried acreage of vacant
buildable coinmefcialland adjacent to these resource sites. The extent of this impact is ,
discussed below. . '
The Commercial Lands Study concluded that there was about 85 acres of vacant'
buildable commercial land in Springfield. An additional 12 acres was projected for
redevelopment by the Study bringing the total to 97 buildable acres.. Demand for vacant
commercial land for the planning horizon 2015 was 255 acres. The 2000 Commercial
Lands Study concluded that there was a 158 ~cre deficit of buildable commerciaLland,
Wetland Impacts
Table 11-5 shoWs that .07 acres of vac'ant commercial land would be removed from .the
. Commercial Lands Inventory i['wetland sites zoned for commercial development were
fully protected, The 25.foot wetland setback recommended by this study would remove
an additional L47.acres of vacant commercial land from development: This.figure
assumes that the developer is unable' to loca!erequired stOrrTIwater facilities or required
landscaping within the recommended setbacks, thus reducIng or elimin~tinglost
development area,
The total irripact on the Corninercial Lands Inventory.wouid be a reduction of 1.54 acres
if wetland sites arid their setbacks 'were fully protected,
Riparian Site Impacts
Table n-5 shows that about acres 2.78 of vacant 'commercial land lies within inventoried
riparian sites that are protected by the Springfield's Stormwater Quality Management
program. Therefore, no commercial acreage is removed from the Commercial Lands.
Inventory'by the implementation of proposed protections in this study. As noted in
Table 11-5, no vacant coriunercialland will be removed from the inventory by the
proposed 25-foot setbacks.
The total impact on the'Commercial Lands lnv~ntorYwould'be a reduction of 1.54 acres
if wetland and riparian sites and their setbacks were fi.illy protected, This represents 1.8%
of the 85 acres of buildable commercial land described in the Springfield Commercial
Lands Study.
Table 11.5, Vacant Commercial Land within Proposed Protection Setbacks
-
I Zoning Dislri~t - Site
Acrea~e
I -,. -.----
Wetlands
I Community
\25 ft.
. Setback
I
.07 I 1.47
'So ft.
Setback
75 ft..
Setback
Total
Acres
I
I
I
1.65 !
.ll
o
5~77 '
\ Zoning District . Site . 25 ft. .50 ft. 75ft, . Total 1
Acreage Setback Setback Setback Acres. I
I Commercial
\ Neighborhood 0 0 0 0 0\
Commercial 01
I General Office 0 0 ",~o . 0
Major Retail. 0 0 "0 0 0
Commercial I
I Wetland Total 0.'07 1.47 0.11 0 1.651
\ Ripa:ian Areas
'1 Community 2.78 , 0 0 2.6 5.381
Commercial
Neighborhood 0 0 0 0 0
Commercial
General Office 0 0 0 0 1.
0
\ Major Retail 0 0 ,,24 0 .24
Commercial 5.62 j
r Riparian Total 2.78 0 0.24 2.6
I Grand Total. 2.85 1.47 .35 2.6 7.27 I
11.3 Impact on the Industrial Lands Inventory
The 1992 Metro Area Industrial Lands Study assessed the supply and demand for
,industrial land in the greater Eugene-Springfield area, The study concluded that there
was about 709 acres of buildable industrial land within Springfield's UGB,' Like the
. Springfield Commercial Lands Study, the Industrial Lands Study noted those industrial
sites with wetland and riparian constraints but did not exclude them from the inve'ntory.
For that reason, protection of wetland and riparian lands under the policies proposed.by
this study will reduce the inventory ofbuildalJle indlistriallands. The extent of this . .
impact'is discussed below, '
Wetland Impacts
GIS analysis shows that abollt 30.64 acres of vacant industrial land are affected by
wetlands that are not already protected by the Springfield Stormwater Quality
Management (SQM) program, These wetland's are recorrunended for protection by a 25-
foot development setback under the Springfield natural Resources Study. These setbacks
add another 6.32 acres to the amount of industrial zoned land that would be removed:
from the Industrial Land Inventory if wetland sites and the setbacks were fuliy protected
under the policies recommended by this siudy. The total impact. to the in,ventory of
industrial lands would be 37.46 acres. Table 11-6 shows the total acreage,for land
affected by wetlands and the acreage protected bysetbacks from both. this program and
the existing,SQM program.
, Riparian Impacts
5-78
GIS analysis shows that 13.70 acres of vacant industrial land are affected by riparian
areas are that not already'protected by the SpringfieldStorrnwater Quality Management
(SQM) program" These riparian areas are recommended for protection by a 25-foot
development,setback under the Springfield Natural Resources Study. These setbacks add
another 3,27 acres to the amount o'findustrial zoned land'thai would be removed fro'm the
Industrial land Inventory if wetland sites and the setbacks were fully protected under the
policies recommended by this study. The total impact to the inventory of industrial lands
would be 16.97 acres. Table 11-6 shows the total acreage for land affected by riparian
corridors and the acreage 'protected by setbacks from both this program and the existing
SQM program,
Total Impact
Thetotaltmpact on the Industrial lands In~entory would be a reduction of 54.43 acres if
all wetland and riparian sites protected by this program and their 25-ft setbacks were fully
. protected. This represents less than 1% ofthe)09 acres of buildable industrial land for
Springfield in the Industrial lands Study.
Table 11-6. Vacant Industrial Land within Proposed Protection Setbacks
Zoning Total. . . Site ,25 ft. 50 ft. 75 ft. Total
'District Wetland Acres !!Q! Setback Setback Setback Acres
Site Protected
Acreage by SQM
Wetlands
Light- 28,20 (27J6) A.81 .82 0 33.83
Medium
Industrial !
\ Heavy 13,16 (2.88) 2,01 .19.15 01 34,32 I
Industrial
I Campus ,35' 0 0 1.28 . 0 1.63
Industrial
Special 0 0 0 0 0 0
Heavy
Industrial o j
\ Quarry . 0\ 0\ 0 0 01
Mining 0,60 I
\ BoothKelly .13 \ 0\ 0 .47 0
MU .'
\Vetland 41.84 \ (30.64) \ 6,82 21.72 0 70.38
, .Total. I
Riparian Total Site 25 ft. 50 ft, 75 ft. Total
Areas Riparian Acres not Setback Setback Setback Acres
Site Protected
Acrea2e . by SQi'Y1
5-79
Zoning Total Site 25 ft. ' 50 ft. 75 ft- . Total.
District Wetland Acres !!2! Setback Setback Setback Acres
Site Protected
Acreage by SQM
Light- 16.48 (10,89) 2,05 4.72 1.26 24.51
Medium
Industrial
\ Heavy 68.31 (2,81) 1.22 . 8,93 0 78.461,
Industrial 6.08 \
, \ Campus 3.22 0 0 2.83 .03
. Industrial
Special 0 0 0 0 0 0
Heavy ~
Industrial 01
\ Quarry . 0 0 0 0: 0
Mining 1.03\
.\ Booth Kelly' ,21 0 0 ,82 0
Nill . "
Riparian 88.22 (13.70) 3.27 17.3 1.29 110.08
. Total
Grand Total 130.06 ( 44.34) 10.09 39.02 l.7.9 180.46\
.
,5-80
Metro Plan .Diagram Changes Affecting the Supply of Residential, Commercial and Industrial Land
Changes in Metro Plan Desirnation.e
---------
<.n
I
co
~
I
I
ILocal File Number
190-04-058
90-12-201
192-04-77
193-01-33
\93-01-12
93-06-087
\94-10-0194
. 95-02-036
95-02-036
95-02-036
95-02-036
95-02-036
95-08-0157
97-05-101
199-02-038
99-02-041
99-09-230
02-03-0062
02-03-0063
02-07 -200 '
02-08-243
LRP-2002-12431
LRP-2004-00031
LRP-2005-00015 ~,,~;1:6 Wclf~l\!
Res idential'lotalsisince1rt S95$1j~ ~.Wf7:5':n ~l1;2:l!O
,.,
MOR CC
-0.1
35.0
-5.3
0.0
0,0
-3.0
--
-0.9
LOR
5.3
0.5'
3.7
AG
MU
0.1
5.0
0.0
0.0
0,0
3.0
0.9
NC CI LMI HI PDS G&E NR
"."'.."""'" e'".".""" .;>;.."."~""!,,,,,-
~w~" ,};!~1! ,-4~:m'1
~ ~1.91O f,59)0 =
~~~.~~ ~~~!t~
"'.......Zc"I"~1!~0'5 ~""\'1""
'Jima\"4l~...",,,,,,_' ~\1ii'!.ml
rtl;tg-"!~~.;ry;:,tloit:;':1.ti~;;! ~iJ%;~!f; -----:- - --
. ,,,:-,~O(~,,",,, ,4...(],~'l5)j.')J'@i; ,",f7.J<nr,,~,
. '!~~W:ll.1"~\, ~~~...,,~lf.0-'i~': !:!liit,1'J(:~';:' -
"_{"~l.fii.\tfu.:-ffi."f~Jt'~\_:,.,....1";,rNI,1
~W~ ~~~~~ ~i:.~~r-
-- ---.-,.-,- - --
i;i'};38':r7f ~X;~ ~li~W{; .
",:'''."'6'5 '~~"."~" l-..t"\'i~;.'-
"L;;rc.~ . ~fN,~-<- _>';ft..;~"
-",-",,,1'i""~";<~"'\'" ~
~~~~-
j~'f$,"f:4 'llFllfM$ .~.~~
i\!"'~5'::) ~"""~",,,}\ "'",OI1l0 - -
"')J~ " .)G.~W<'d, ~.,)A:".~.:1
."""".,~ ."....8'0 """"'0' - -'-
~~$1i!~f>', Fs'~. !.i:1~~'"
- i;!~'Yti'Sf1~ i1!Y~;i~'l<l.'i 'd!>m\'(~;:,Xf.; 72 0
~ ~~".,;ii'J,:,~eJ. ~1iI!~ _ .
-"'\""~"! "\"'6'.'6 ,.,"""" ,
___~"I~_.. P,..~, _ ,~.>~J1'-
. ~.,il~i.\!r~~i!tl11! 18.0-
~O&~ itt~~.'
l~22:0 [fi~~,Ii\~~" -22.0
-~-
~1&~J::tt35!O i!.\r~ 6.0
~[.\l!lJ~'!lf~J~I~\1l
~iffii1j@\~~~J!ii~!~~
~.~ ~~~I~;~
I1!'A\1;~itl !ii!$i!iF2j,'1l1~~>('!ii.
tJ\\,!;f;1':6~:'f,jii) ,
'~flHt~j ~j}t~~~&; '~~1RM~~ TqraTrd.~tiitS(fQ'~Fi;Si~e~tlii~~ ~f1~~~Z~,Q,
'~~~f~]ttl\q,@;}&i:ff;iY~R~~~i~-l . '. 11- to." ' t,.I 'i
,ffi,t1~~ ~if28~5 ~f2;3-~3 j~;59H) troiaird'lh)its':fo'~lntiustHar~~trf~ ~~~.(ttf90~6
:Do
-l
-l
:Do
()
::r:
:s:
m
z
-l
OJ
-3.7
\
i'\!'~~J\t;~;,~Mi.::Ji'~3 8 9,
;t~~~,if" :..*;t;'~~.om
'!.~~?!~_9;:2 :;}~~8,!$~,
:~1~4)B:~irri'5 ;:&ilf_?~;5
~H~.5'~~'-~~~,~~~1
:8;[~~;8:0 ~f~~1
'"i7,2.0'
!f't~~~~~~ff.fi
~?'1~~~~t~t;;~-m}1.K~~
;i~~:';W{~O:2 ',~1iJ~'t~UWf,;
~~4~_~tf.@.1; '~\;M~~~~ .
~~~~'-~:t~~Jj
. _ l~~~{gii4~~~J~
'~~i~~;;~~S~ ~~m.~'~jf2
,,;(..t'5i&ijt:\).~jf&' I rid us trial: totals1s InceiMarch:\~ 99;1
6.5
16.5
-34.5
1
\
1
0)
33.0
LOR Low Density Residential
MDR Medium Density Residential
CC Commercial Center
NC Neigh,borhood Commercial
CI Campus Industrial
LMI Light Medium Industrial
HI Heavy'lndustrlal
pas Public Open Space
G&E Government and Education
NR Natural Resource
AG Ag'rlculture .'
MU Mixed Use
. m PeaceHealth
. March 15,2007
. .~,
Zone Change Application
Written Explanation of the Proposal
Applicant:
peaceHealth Oregon Region
. h
. 770 E, \1' Avenue
P.O, Box 1479
Eugene, Oregon 97440
i'
,
Property 'Owners:
Hyland Business Park, LLC (Tax Lot 400) ,
1941-A Laura S,treet
Springfield, OR 97477
Attn: Shaun Hyland
(541) 726-8081
Andrew Head (Tax Lot 402) .
1616 Ardendale Ln.
Eugene, OR 97405
'(541) 521-3403
Applicant's
Representative:
Philip Farrington, A.ICP
Director, Land Use Planning' & Development
peaceHealth Oregon Region
123 International Way
. Springfield, Oregon 97477
. (541) 686-3828 * Fax (541)335-2595
pfarrington@peacehealth.org .'
1.0 Land Use Request
PeaceHealth Oregon Region (the" Applicant") requests approval to.change the zoning
classification on the City's zoning map from light Medium Industrial ("lMI") to .
Community Commercial (HCe") for approximately 5.24 acres identified as Ta:'( Lots 400
and 402 on. Assessor's Map No. 17-02-32-00. This same acreage on the site is being
. proposed for a concurrent amendment to the Metro Plan diagram (which automatically
also amends the East Main Refinement Plan diagram) from lM\ to CC, as allowed in
Springfield Development Code ("SDC") \2.020 (I)(a)l.
5-82
Zone Change Application
PeaceHealth :Oregon Region
. March 15. 2007
Page 2
The area subject to the proposed rezoning is mapped on Attachment A, and is referred to
collectively in this application as the "subject properties" or "site." ,
,
2.0 Project Purpose .
The Applicant seeks to rezone (and through concurrent application, redesignate) the
subject properties to CC so they may be developed for cOmrllercial uses (i.e., Tax Lot
400), including a possible future medical clinic which CQuld serve residents in the
growing east Springfield area, and to be allowed to continue long-standing commerc'ial
operations (i.e., Tax Lot 402). Approval of this land use request would preserve
employment and existing viable commercial operations on Tax Lot 402, and create stable
family-wage employment opportunities on Tax Lot 400 - a vacant and underused
industrial site. The proposal would also help beautify this.portion of Main Street from its
.' traditional industrial yard-uses, and future development would provide a superior buffer
for residential uses to the west than currently exists,
.I-
As described iri later sections ,of this narrative the proposal is consistent'with East Main
Refinement Plan (EMRP) and the Metro Plan as required by approval criteria in SDC
12.030. In particular, this request~. when considered' with the concurrently submitted
Metro Plan diagram amendment (and automatic EMRP diagram amendment) - complies
with EMRP'Policy 2: "Apply'site-specific C0r11mercialrefinement plan designations to
clearly define the limits of new commercial uses where there is not an existing, legally
established, and beI}eficial mixing of uses." :(pg, 12) The proposal to aliow for a broader, '.
more beneficial range of commercial and employment-generating uses on the subject
properties. It would also improve the area and better distinguish and buffer adjacent
residential and industrial business park uses. . ..
3.0 Site Context .
The subject properties include a currently vacant, nat parcel (Tax Lot 400) and existing
commercial development (Tax Lot 402) east of 44th'Street along Main Street in east
Springfield. The site is bord,red on the south by Main Street, on the east by th~ Hyland
Business Park, on th~ nortli by an open area south of the Weyerhaeuser mill site (Tax Lot
. 400) or an existing commercially zoned parcel (Tax Lot 402), and on the west by other
small-scale commercial enterprises (e.g., a cabinet shop and kar.ate school) fronting Main
Street and residential horries along 44th Street west of Tax Lot 400. Corninercial
enterprises are located immediately south of the site across Main Street (e.g., Gray's:
Garden Center): ' ,
\Vhlle historically involved in agricultural uses, since around 1990 Tax Lot 400 was used
as a storage and sales yard for landscape-organics and fo~est by-products.. The'current
property owners also used the site to store modular const.[1.lction offices, tool trailers;"
construction equipment and concrete form plywood. ,Tax "Lot 402 has had various
commercial services on site since the 1950s.
5~83
Page 3
Zone Change0Pplicalion
PeaceHealth Oregon Region.
March 15 2007
The properties have no juri?dictional wetlands or inventoried Goal Smi.tural or historic
resources, The site is within the SpringfIeld Urban Growth Boundary, and both pa,rcels
were annexed into the City of Springfield in 1960. . The EMRP diagram (adopted in
1988)currently designates the subject property for industriatus~s. . .
. The abutting property to the east is designatedLightlMedium Industrial in the EMRP ,
. diagram and zoned LM!. The areas immediately to tlie west and south 'of the site fronting .
Main Street are identified as being within Mixed-Use Area #2 in the EMRF, and are all
zoned Conununity Commercial. Property to the west ofTa)'.. Lot 400 along 44th Street is
. zoned and designated Medium Density ResidentiaL" . . .
4.0 Applicable Approval Criteria .
Zone change proposals are evaluated according to the criteria cif approval contained
withinSDC 12.030 (3), which requires: '
. 1. Consistencywith applicable Metro Plan policies and the Plan
. Diagram;
2. Consistency with applicable Refinement Plans, Plan District maps,
Conceptual Development Plans and functional plans; and .
3, That the property is provided with adequate public facilities, s'ervices
and transportation networks to support the use, or will be provided
concurrent with property development.
Legislative zone map amendments are also.requi'red to show that'they 'meet the.
, criteria for Plan ameridments outlined in SDC Midi: 7; and that it complies with
the state Transportation Planning Rule (OAR 660-012-0060), where applicable.
Findings demonstrating consistency with the approv~l criteria are outlined below,
,
4,1 Consistency with Metro Plan Text and Diagram
Consistent with SDC 12.03'0 (3)(a), this narrative only.addresses those policies that apply.
to the proposal, and does not discuss those portions.of the Metro Plan that: (1) apply only
to rural or other lands outside of the urban growth boundary, (2) apply to land uses other
than the current or proposed designations for the site and will not be affected by the
proposed Plan diagram and tex.t amendments, or (3) clearly apply only to specific
development. applications (e.g, site' plan review submittals or subdivisions). In many
instances the goals, poiicies and implementation measures apply to specific dev'elopmem
proposals that w'ill be addressed through compliance with applicable City regulations
during site plan review of a given future development proposal.
Ex.cept for the Growth Management Goals, which are addressed below, each of the Metro
. Plan policies are addressed in the order in which they appear in the Plan Element section
of the Metro Plan.
5-84
Page-4
Zone Change Application
PeaceHealth Bregon Region
March IS. 2007
4.1.1 Metro Plan Elements
1. Growth Management.
Policies
1. The urban growth boundary and sequential development shall
. continue to be implemented as an essehtial means to achieve
compact urban growth. Provision of all urban services shall be
concentrated iliside the urban growth boundary.
The proposal satisfies this policy because the subject property is inside the UGB and city
limits and as such, encourages compact urban growth, Also, urban services are available
at sufficient levels to accommodate the existing and future infill development resulting
approval of from th\s application. The City's site plan review processe~ensure that the
appropriate level of services is available tO,serve future development.
2. ResidelltialLand Use a~d Housing Element
Policies
A,lJ Generally locate higher density residential development near
employment or commercial services, in proximity to major"
transportation systems or within tramportation-eJJi~ient nodes,
The proposed redesignation does not affect the inventory or availability of residentially
design'ated or zoned land, including the single-family residential area abutting Tax Lot.
400 that is zoned and deSignated for Medium Density Residential, or higher density
'residential developments located east of the site along Main Street.
However, approval of tl~e requested redesignation to Community Commercial w~uld
allow for residential areas proximate to the subject area to have close and efficient access
to existing comrriercial serviceson Tax Lot 402 and to future medical facilities proposed
for Tax Lot 400, consistent with the above policy. The areas proposed for redesignation '
offer existing and future employment opportunities and provide cortunercial serVices
along a major tr~\D.sportation system that can support the needs of nearby residential
development.
.'
A,22 Expand opportllnitiesJor a mix oJ uses in newly developing areas
and existing neighborhoods through local zoning and development
regulations.
-The proposed map amendment and zone change will allow for existing commercial uses
on Tax' Lot 402'10 continue to serve existing neighborhoods in the mid- and east-
Springfield area,'and for future clinical facilities to be' developed to serve this rapidly
growing area of the community. Approving the request would expand 'commercial
. opportunities to serle these neighborhoods consistent with the above policy.
5-85,
Page 5
Zone Change ;t.pplication .
PeaceHealth Oregon Region
March 15 Z007
3. Econom.ic Element
Policies
B.l Demonstrate a positive interest in existing and>new industries,
especially those providing above-above wage and salary-levels, and
increased variety of jOb opportunities, a rise in the standard of living,
and utilization of our existing comparative advantage in the level of
education and skill of the resident labor force. '
. The proposal is consistent with this policy because it will allow medical clinic uses 'to be
developed to serve growing areas in east and south Springfield, As is observed in the
Springfield Commercial Lands Study (pp, 27,29), employment in health services is
growing and approving the requested redesignation arid zone change will enable
increased job opportunities with higher than average wages thereby raising the standard
oflivingandineeting the needs of Springfield citizens,~6nsistent with the above policy,
.'
B.2 Encourage economic development which utili~es local and imported
capital, entrepreneurial skills, and the resident labor for,ce: .
, The construction of and the use of commercial and medical uses will utilize both local'
.and imported capital and will employ the local labor force in a variety of skilled,
semi-skilled and unskilled positions, consistent with this policy,
, . .
. .. ." .
B.6 Increase the amount of tll1develope;lland zoned for light industry
and commercial ases correlating tlte effective supply in terms of
suitability and availability witlt tlteprojections afdemand.
. .
The proposal will add approximately 5.24 acres of Community Commercial land,
consistent with recommendations to increase the commercial lands inventory made in the
. Springfield Commercial Lands Study. The SCLS and ackr10wledged metropolitan
Industrial Lands Study concluded that there is a deficit'of needed commercial land, and a
surplus of industrially zoned and designated land. Approval of the requested
redesignation and zone change will not cause the inventory of needed industrial land to
go into a deficit, but in fact would be consist~nt with the above policy. The proposal
correlates the need, suitability, and availability of the subject site for commercial uses
with the need for such uses as demonstrated in the adoptedSCLS.
B,1J Encourage economic activities which srrengthen the,metropolitah
area's position as a regional distribution, trade, health, and service
center.
The amendment will facilitate the development of medical uses that will serve the needs
of the growing residential areas in east, south and southeast Springfield, and strengthen
the metropolitan area's position as a premier locale for healthcare services, consistent
with this policy objective. .
\
I
5~86
Page 6
Zone Change Application
PeaceHealth Oregon Region
March 15 ~~07
6. Environmental Design 'Element
Policies
E.1 In order to promote the greatest possible deg'ree of diversity, a broad
variety of commercial, residential, and recreationatland uses shall be
encouraged whim consistent with other planning policies.
Approval of the proposed map amendments will add j~st over 5 acres into the City's
inventory of commercially designated and zoned land, thereby allowing for a variety of
needed commercial uses' to occur on the subject property. Long-standing existing
, commercial services on Tax Lot 402 would be allowed to continue without the specter of
being considered non-conforming uses, and Tax Lot 400 could b~ developed with
medical services that will serve the needs of the growjng residential areas east and south
of the subject site, consistent with the above policy, -
7. Transportation Element
Land Use policies
F.3 Provide for transit-supportive land use patterns and development,.
including higher intensity, transit-oriented development along major,
transit corridors aild near transit stations; medium- and high-density
residential development within one-q uarter mileof transit stations,
major transit corridors, employment centers, iwd downtown areas; and
development and redevelopment in designated areas that are or could be
well served by e.dsting or planned transit .
The proposal will enable land'use patterns and development consistent with the above
policy. Approval of the requeste'd zone change (and concurrent redesignation) will allow
for higher intensity development along Main Street, a major transit corridor. An existing
L TO stop is located on the frontag~ ofTax Lot 40'0 (see photo, pg, 2; Appendix A of the
TIA), and will provide coiwenient access to existing arid projected employment on the
subject site, as well as access for patients to future out-patient medical facilities projected
on Tax Lot 400. .
Transportation System Improvements: Roadways policies'
F,15 IH%r vehicle level olservice policy:
a: Use maWI' vehicle level oj service standards to maintain acceptable
and reliable performance on the roadway system. These standards
shall be tlsed for: .
(1) IdentiJying capacity deficiencies on the roadway system.
(2) Evaluating the impacts on roadways oj amendments to
transportation plans, acknowledged comprehensive plans and
5-87
page 7
Zone Change.Application
PeaceHealth Oregon Region
March \5. ?007
land-use regulatidns, pursuant to thi;' TPR (OAR 660-012-
, 0060),
(3) Evaluating development applications for consistency with the
land-use regulations of the applicable locai government'
jurisdiction.
b. Acceptable and reliable performance is defined by the following
ievels of service under peak hour traffic conditions: LOS E within
Eugene's Central Area Transportation Study (CA TS) area, and
LOS D elsewhere. .
c. Performance standards from the OHP shall be applied. on state
facilities in the Eugene-Springfield metropolitan arelL .
In some cases, the level of service may be substandard. 'The local
. govem~entjurisdiction may find that transportation system
improvements to bring performance up to standard within the planning
horizon may not be feasible, 'llld safety will not be compromised, and
broader community goals would be better served by allowing a
substandard level of service. The limitation on the feasibility of a
transportation system improvement may arise from severe constraints,
including but not limited to environmental con,ditions, lack, of public
agency financial resources, or land use cOllstraint factors, It is not the
intent ofTSI Raodlvay Policy #2: Motor Vehicle Level of Service to
. re'li,ire deferral of development ill such cases..' The intent is to defer
motor vehicle capacity increasing i1'llnsportatiiin',improvements until
existing constraints can be overcome or de'velop"'all alternative mix of
strategies (such as: land31se measures, TDivI, short-term safety
improveme1lts) to address theproblem,
,
Subsection a.(2) in the above policy requires an evaluation of the proposal pursuant-to.the
state Transportation Planning Rule (TPR). The accompariyingTraffic impact Analysis
provides the factual basis to determine that the proposed redesign at ion would not result in
a "significant effect" as defined under the TPR (OAR 660-012-0060(1)).
Specifically, the proposal does not change the functional classification of Main Street or.
,any other nearby roadway, nor does it change the standards for implementing the City's
functional classification system of roadways, as identified in the Regional Transportation
Plan. As demonstrated in the TIA, the proposal also does not:
. .Result in types or levels 'of trafflc or access that are inconsistent with the functional
classification of Main Street or any other nearby roadway;
. Reduce perfonnan~e of traffic on Main Street or other affected lntersections to a level
that is below acceptable established performance standards; or
5-88
. Page.3
Zone Change Application
PeaceHealth Gregan Region
March 1 5. 2091' -
.
Make performance of existing facilities worse (i.~., below acceptable mobility
standards) than would be the'case otheruses permitted under eXcistiiig designations or
zoning.
Additional TPR fmdings are further located in the TIA, see pp. '31-32, Because the
proposal does not result in a "significant effect" as established by applicable OARs, no
further TPR analysis is required: The request is therefore consistent with the above '
policy.' .
8. Public Facilities and Service Element
Policies
G,] Extend the minimum level and full rr;mge of key urb'an
facilities and services in an orderly and effiCient ma'nner consistent
with the growth management policies in Chapter II-B, relevant
policies, in this chapter and other Metro Plan policies,
'The subject property is located in Springfield's city limits UGB, All necessary ,
infrastructure and key urbanJacilities/services are preseht to serve existing development
(Tax Lot 402) o(are available to serve future infill development on Tax Lot 400.
Therefore, the proposal is consistent with the above policy.,
9, Parks and Recreation Facilities Element poliCies
Policies in this element of the ~etro l'lan are not relevant to the requested zone change.
'10, Historic Preservation Element policies . . '
Policies'in this element QftheMetro Plan'are.not relevant/to the requested zone change.
. ' . .
11. Energy Element policies
policies in this element of the Me\fo Plan are not relevant lo'the requested zone change.
5-89
Zone Changq\pp\ication
PeaceHealth.Qiegon Region
March 15,2007
. Page 9
4,2 Consistency with East Main Refinement Plan' .
The following demOnstrates how .the proposal is consistent with.applicable policies in the
East Main Refinement Plan (EMRP), .'
'1. . Mb;ed-Use Element
Policy 2) (lrea #2
A) Thefollowing land uses are allowed under Community Commercial
zoning: . '
All Communitv Commercial uses subject to Article 18 of the
.. Springfield Development Code. .
The proposal requests rezoning the subject properties from 1M! to ,Community
Commercial (and concurrently redesignating the properties to CC);as the above policy
and other EMRP policies allow. Approval of the request would allow long-standing
existing cOJJlIIlercial uses on Tax Lot 402 to continue as pennitted under Article-l8, and
'consistent with neighboring uses to the west and south; which are also zoned and
designated for. commercial uses. .'
2,
Commercial Element
Criteria for Commercial Refinement Plan Desir:natiol!
, 1. Generally, the Community COl/lme~cial r'!jjhwment plan designation
shall be applied under the following circu/'l,stances:. .
. . .
, A) where it is not an inti'usion into )~eII_maint~iiled residential
neighborhoods;
.
The area proposed for rezoning does not intrude ihto 'the ex:isting residential area
west of the subject site along 44th Street, and is therefore c.onsistent with the
above criterion.
B) where it does not increase conflict between Low Density
Residential and Commercial;
Although the abutting residential area is zoned Medium DensityResidential, it is
developed in low-density residential \lses. Approval of the proposed rezoning of
the subject. sites would actually result in a decrease of conflicts between abutting
residential and non-residential land uses by allowing future inflll development on
Tax: Lot 400, and through the site plan review process establishing improved
landscaped buffers and a use more compatible than the industrial uses that
historically abutting this residential area.
5-90
Page 10
Zone Change Application
PeaceHealth Oregon Region
March \) 7007
C) where criteria for designating i'rledi!lm Density Residential
land does not apply;
Criteria for designating MDR land does not.apply to the subject site,
D) where legally created ~ommercial uses exist;
. Tax Lot 402 has existing, long-standing commercial uses that were legally created
prior to development of the Metro Plan or EMRP. Tax Lot 400 has had a variety
of commercial serVices located on-site over the years.
E) where adequate customer and sen'ice access to an arterial
weet can be provided; ... and .
The subject site has adequate legal access onto Main Street. which is classified as
an arterial street. .
F) where designated Commercial on the Metro Plan Diagram.
.
Approval of the concurrently submitted Plan diagram'amendment application
would result in a Commercial designation on the Metro Plan diagram, which
would also automatically modify the designation on the EMRP diagram.
Policy 2) Apply siie-specific Commercial refinement plan designations
to' clearly dejin~ the limits of new commercial uses where there is /lot an .
existing, legally es'tablished, and beneficial mL-ring of uses,
Approval of the concurrently requested redesignation would apply Commerci~1 plat1
designations to the subject properties. allowing tne existing, legally established
commercial uses on Tax Lot 402 to continue. It would also enable commercial uses to be
. established on Tax Lot 400, thereby defining the limits of new commercial uses between
the pre-existing commercial uses on Tax Lot 402 and others to the west, and the
developed industrial business park to the east. Tax Lot 400 does not have an existing or
beneficial mix 6fuses, but has historically housed industrial yard-type operations.
Therefore, approval of the proposal would deflt1e the limits of new commercial uses as
called for in the above policy. and also provide the ability to make superior buffering and
other improvements associated with future development on Tax Lot 400 through the site
plan review process.
I
I
I
,
Policy 3) Reduce the number ofvehiwlar access points and,require the
rebuilding of curbs and installation of sid~walks and street trees along
iYJain Street, through the Site Plan Review process and in public
improvement projects,
5-91
Page 11
Zone Change.Application
PeaceHealth Oregon Region
March \5 '1007
The proposal would result in reducing the number of existing access points as required
above, Through the Site Plan Review process, future development on Tax Lot 400 will
. have a single driveway access onto Main Street, eliminating one of the two existing curb
, cuts on this site. Sidewalks and streeUrees are already.located along its Main Street
frontage, consistent with the above policy, . .' .
Policy 4) Provide buffering between commercial and residential uses .
through Article 31 of the Springfield Development Code, Site Plan
Review process,
Existing residential uses along the east side of 44th Street have had no real buffer from
pre-existing industrial uses on Tax Lot 400. Approval of the proposal would allow for
attractive infill development of future medical facilities that would provide (through the
SPR process) improved landscaped ,buffers between the future use and existing
residential area to the west - as required by Code, and consistent with the above policy.
3. Industrial Element
Policy 1) The City shall encourage efforts of various agencies to attract
new atid retain e.:cisting jobs and businesses. .
Imolementation
The City shall maintcrin a ClIrrent inventory-of vacant commercial and
industrial land and structures within the East JHain area,'
Consistent with the above policy, approval of the requested.z()ne change and
redesignation will enable existing, long-standing jobS-and businesses on Tax Lot 402 to
remain as legal, confonning land uses, and allow future dev~lopment of new employment
on Tax Lot 400 with higher than average wages and employment densities than the
current designation and zoning allows. .'
5-92
Page 12
Zone Change Appllcation
PeaceHealtil Oregon Region
Nlareil 15. 2007
4,3 'Provision of Adequate Public Facilities
The subject properties were annexed into theSpringfield corporate limits in 1960, and
therefore are provided with City police, fire, and .other government services. Other basic
infrastructure is in place to serve existing development on Tax Lot 402 and any future
development on Tax Lot 400, Specifically, sanitary sewer, stormwater, and water lines
are all located along the site's Main Street frontage - all of which are adequate to serve
the needs of existing and/or future development on the subject site, T~ansportation
services are also readily available to serve existing and future development, as Main
Street is fully improved with curb, gutter, etc.'
As indicated in the TraffiC lmpact A.llalysis accompanying the concurrently submitted
zone change and Metro Plan diagram amendment, approval of the proposal wo~ld not
result in a "significant effect" to the transportation sy~tem, and therefore is consistent.
with the state Transportation Planning Rule, The TIA further demonstrates that existing
and future development under the proposed zone'change has safe and efficient access and
circulatiori for vehicles and also will benefit from the sidewalks, bike lanes, and transit
. '
service existing on Main Street.
Therefore, the proposed zone change complies'with the requirement for having adequate
public facilities and services to serve development, as established in SDC 12:030 (3), '
4.4 Consistency with Approval Criteria in'SDC Article 7
The proposed zone change is submitted concurrently with an application to amend the
Metro Plan diagram. The following findings are contained in the Plan diagram
amendment application, and also demonstrate that this proposal complies with Metro
Plan policies as required in SDC 7.070 (3) and with zone change approval criteria in SDC
12.030, Both the fmdings below relative to Goal 12 and those above pursuant to. Metro
Plan Transportation Element policies address consistency with the state TPR, as called
for in SDC 12.030.
It should also be noted that approval of a Metro Plan diagram amendment also
. correspondingly changes the appiicable refmement plan (East Main Refmemen't Plan)
diagram, as established in SDC 7.110 (4).
Goal 1 - Citizen Involvement
Goall addresses the need to develop a citizen involvement program to ensure citizen
involvement in all phases of the.land use planning process, The Planning Commission
and the City Council will hold public hearings and accept testimony. on the proposal.
Through the procedures established by the city, citizens will receive notice of hearings in
generally published local papers and have the opportunity to be heard regarding the
proposed diaiITam amendment and zone change. Notice of the public hearings will also
be given in accordance with SDC requirements to nearby property owners, interested
parties requesting notice, and any established neighborhood organization. Since the
process complies ;vith the City's citizen involvement program and citizens have
5-93
Zone Change.l,pplication
PeaceHealth Oregon Region
March 15 2007
Page 13
opportunities to be involved in the procedure, the proposed plan and zone map
amendments are consistent with Goal I. .
Goal 2 - Land Use Planning
Goal 2 requires that local comprehensive plans be consistent with the Goals, that local
comprehensive plans be internally consistent, and that implementing ordinances be
consistent with acknowledged comprehensive plans. Goal 2 also requires that land use
decisions be coordinated with affected jurisdictions and that they be supported by an
adequate factual base, As required in SDC 7,050, the City is required to give referral
. notice of the proposed Type II Metro Plan diagram amendment to the City of Eugene and
. Lan'e County so they may determine if there are grounds to participate as parties to the
hearing. The City also sends the statutorily required notice of the initial public hearing
45 days iri advance to the state Department of Land Conservation and Development,
ensuring that they are given opportunity for .cominent and review conformity to
applicable statewide planning goals, '
The Metro Plan and the SDC, as well as the Statewide Planning Goals and applicable
statutes, provide policies and criteria for the evaluation of comprehensive plan
amendment and zone change proposals. Compliance with these measures assures an
. adequate factual base for approval of the proposals. As discussed elsewhere in this
. document, the Plan diagram and zone map amendments are consistent with the Metro
Plan and the Goals. Consequently, by demonstrating such cbmpliance, the proposal
satisfies the consistency element of Goal 2, . ..,
Goal 3 - Aaricultural Lands
~ '
This goal is inapplicable because as provided in OAR 660-15-000(3), Goal 3 applies only
to rural agricultural lands. The subject properties are located within an acknowledged
. urban growth boundary; are inside Springfleld's corporate limits; and have not been in
agricultural use for decades. .
. Goal 4 - Forest Lands
Goal 4 does not apply within urban growth boundaries, per OAR 660-06-0020, and the
areas affected by the Plan amendments are inside Springfield's acknowledged UGB.
,
I
'.
GoalS - Natural Resources .
Goal 5 requires local goverrunents to protect a variety of open space, scenic, historic, and
natural resource values. GoalS and its implementing rule, OAR Ch. 660, Division 16,
. require pl"nning jurisdictions, at acknowledgment and as a part of periodic review, to
(2) determine their quality, quantity, and location;
(3) identify conflicting uses;
I
i
I
I
I
i
I
!
i
.'
. (1) identify such resources;
5-94
Page 14
Zone Change Application
PeaceHealth Oregon Region
March 15 7.007
(4)
examine the economic, social, environmental, and.energy
(ESEE) consequences thatcould result fr'om allowing, .
limiting, or prohibiting the conflicting uses; and
develop programs to resol ve the conflicts.
(5)
The subject properties are not on Springfield"s acknowledged Metro Plan Goal 5
inventory. No threatened or endangered species have been inventoried on the site, and no
archeological or significant historical inventoried resources are located on the site, The
National Wetland Inventory and Springfield Local Wetland Inventory maps have been
. consulted arid there are no jurisdictional wetlands located on the site. Therefore, the
proposal does not alter the City's compliance with Goal 5.
Goal 6 -Air, Water, and Land Resources Quality
The p~rpose of Goal 6 is to maintain and improve. the quality ofth~ air, water and land
resources of the state. Generally, Goal 6 requires that development comply with
applicable state and federal air and water quality standards. In the context of the .
proposed Metro Plan diagra~ amendment a'nd zone change, Goal 6 requires that the
applicant demonstrate that it is reasonable to expect that applicable state and federal
environmental. quality standards can be met.
Though Tax Lot 400 has been used for low-value storage and quasi-industrial uses, the
site is not listed on any state or local environmental clean-up list. A Phase 1
environmental assessment on the subject property was conducted and recommended
additional analysis, Upon recommendations through the Phase 2 environmental
assessment a nominal quantity of soil (less than 10 cy) impacted by earlier/historic use
was removed from tbe site and properly.disposed, Given the nominal impact generated
by historic uses on the site, it is reasonabie to conclude that nlture development on the
site will be able to demonstrate compliance with City standards for water quality
protection through the site plan review process, thereby complying with applicable state
and federal environmental quality standards.
Goal7 _ Areas Subject to Natural Hazards
Goal 7 requires that development subject to damage from natural hazards and disasters be
planned and/or constructed with appropriate safeguards and mitigation. The goal also
requires thm plans be based on an inventory of known areas of natural disaster and
,hazards, such as areas prone to landslides, flooding, etc.
~
The site is flat and not subject to landslide hazards, and is located well outside of any
established FEMA flood hazard area. Therefore, approval of the proposal will not alter
the City's acknowledged compliance witb Goal 7 through its adopted plans, codes and
procedures. . .
5-95
Zone Change,,o.pplication
PeaceHealth Oregon Region
March 15 2007
. Page 15
GoalS - Recreational Needs
Gaal S requires local governments to 'plan and provide for the siting of necessary
recreational facilities to "satisfy the recreational needs af the citizens of the state and
visitors," and where appropriate, pravide far the siting of rec\eational facilities including
destinatian resorts. The subject site is nat included' in an inventory of recreational sites,
and the proposal. will not have an impact on the community's recreational facilities or
needs; therefore, the proposal does not implicate GoalS. '
Goal 9 - Economic Development' .
. Gaal 9 requires the city toprovide adequate opportunities for a variety of economic
acti vities vital to the health, welfare, and prosperity af the citizens. The proposed
amendment to the Metro Plan diagram will increase the city's capacity far economic
development by adding 5 acres ofCC designated/zanea land in place of the existing
industrial designation and zoning, Permitting the construction of future clinic facilities
on Ta.." Lot 400 and allowing long-standing commercial uses on TaX Lot 402 to continue
.and become conforming uses consistent with commercial zoning through approval af the
proposed Plan diagram amendment and zone change is consistent with numerous policies
in the City's adoptei! plan for compliance with Goal 9, the Springfield Commercial Lands
Study (SCLS). .
, . .
Specifically;the following SCLS policies are applicable to the proposal:
Policy I-A: "Maintain a mixed supply of large and small cammercial sites
through strategies such as rezoning or annexatian to. serve Springfield's'
future papulatian."
The prapasal fulfills this palicy abjective by rezoning (and redesignating)larid from'
industrial to commercial use, for two tax lots of varying sizes 'ani! commercial uses;
thereby maintaining existing employment and commercial use inTaxLot 402 and'
providing the ability for growth in medical sector employment by allowing future clinic
uses on Tax Lot 400.
,
Policy.l-C: "Maintain at least a five-year supply of commercial land .'
within the Urban Growth Boutldary (UGB) that is currently served or .
readily serviceable with a li.lll range of urban public facilities atld
serVlces,l1
The SCLS (see Table '3-8, pg. 32) found there to be a deficit of 158 acres in the supply of
cammercialland over demand projected through the year 2015. The proposal would .
allow for redesignatiotl and rezoning of five acres thereby reducing the deficit of
commercial land. The subject site has a full range of urbatl public facilities and services
available to support existing commercial development on Tax Lot 402, and future
development on Tax Lot 400. The SCLS identifies (pg. 33) a need to support .
"employmetlt in population-dependent sectors such as retail sales and health services" to
meet SpringfIeld's growing community. The SCLS also noted (pp. 27-29) stale and local
5-96
Zone Change Application
PeaceHealth'Oregon Region
March '.5 2001
Page 16
trends in greater employment in retail trade and well-paying health services sectors.
Approving the proposed redesignation and zone change would help meet Springfield's.
demonstrated need for employment and commercial services.
. Finding 3 in the SCLS (pg. 36) cited the acknowledged 1992 Industrial Land Study as
demonstrating that "a. surplus of industrial sites exists in the Metro Area," Therefore, the
proposed redesignation (and corresponding rezoning) would not result in a deficit of
needed industrially designated and zoned land, but it would help reduce the commercial
lands deficit identified In the SCLS. Therefore, approving the proposal would be
consistent with SLCS Implementation Strategy 3 -A (I): "Evaluate inventories based on
demonstrated need for the planning period. Initiate rezoning or redesignation of surplus
land uses where more appropriate for commercial, consistent with the Metro Plan."
The proposal in fact consistent with inventories for commercial arid industrial lands
adopted by the City Council and acknowledged by'OLCO as being consistent .with Goal
9. Oregon Administrative Rules concerning Goal 9 implementation (OAR 660-009-
0010(4)) call for amendments to land use designations "in excess of two acres within an.
existing urban growth boundary from an industrial land use designation to a non, .
industrial use designation'.' to have to address applicable planning requirements - such as
consistency with the Metro Plan and other local plan policies (i.e., SCLS) or be consistent
with an economic opportunities analysis. The City can tind that the proposal complies
with relevant local plan policies by converting one form or employment-generating land
use to another, without negatively impacting the supply of buildable lands for either
category 0 f uses, The 'proposal enables continued use of the existing and long-standing
commercial center to continue to operate and provide employment opportunities, while'
also allowing higher-value' employment associated with future develop~ent on Tax Lot
400. These types of employment-generating uses. are among those identified in OAR
660-009-0005(6) as eligible non-industlial employmentrictivities that can justify
approval of the proposed Plan diagram amendment without the need for an economic
opportunities analysis apart from the SCLS, which OLCO acknowledged as fulf1lling the'
City's obligations under Goal 9.
Because the requested redesignation and zone change imple'rrients SeLS policies and
does not result in a deficiency of needed industrial lands, and is otherwise demonstrated
. .
to be consistent with relevant Metro Plan policies, approval of the proposal is consistent
with the City'scompliance with Goal 9 and applicabl~ administrative rules regarding .
. Goal 9 implementation. . .
Goal 10 - Housing
LCDC's Housing goal requires cities to maintain adequate supplies of buildable lands for
needed housing, based on.an acknowledged inventory of buildable bnds. The proposal
does not affect the City's inventory of residentiallands._
In fact, approval of the requested redesignation for Tax Lot 400 would enable
redevelopment of an industrial site abutting existing residential development. Through
5-97
Zone ChangJ:Application
PeaceHealth Oregon Region
March 15. 20Q7
Page 17
the site plan review process, futur~' development on that property can provide a superior
buffer and a higher use that will benefit the adjoining residential properties. Because the
proposal does not involve directly imy change in the amount of residentially designated
or zoned land, it does not affect Springfield's continued compliance with Goal 10.
Goalll _ Public Facilities and Services
. This goal requires the provision of a timely, orderly and efficient arrangement of public
facilities and services. The subject property is located within the Springfield UGB and
city limits, and is already designated for urban levels oruse, The proposed amendment to
the Plan map designations and zone map classifications from LMI to CC will not affect
the ability to provide needed services since all the required urban services are available to
support existing or future commercial.uses on the sub,Ject site.
Goall2 - Transportation.
Goal 12 requires local governments to provide and encourage a safe, convenient and
economical transportation system, The proposed map amendments and zone change
involve approximately 5,24 acres of property, though existing arid long-standing
commercial uses occur on Tax Lot 402 such that approval of the proposal will not result
in any changes to the type or intensity of uses on the site, and will not increase the trip
generation for that fully developed parcel. As the attached Traffic Impact Analysis (TIA)
demonstrates, future development of medical office facilities on TL 400 will not degrade
mobility standards below acceptable levels and allow for adequate queuing lengths'at
applicable intersections. Therefore, the proposal will not have a "significant effect" on
. transportation facilities as defined in the Transportation PlaMing Rule (OAR 660-012-
060) .
'-
Existing development at Tax Lot 402 is not affected by the proposal, and.is.assumed to
retain its current access points off Main Street. lt is further assumed that fu'ture ..
development on Tax Lot 400 will result in some access changes as ,,,ill be reviewed
through the site plan review process, thereby consolidating two existing curb cuts located
on Tax Lot 400 into a single access point located approximatelY in 'the center of the
parcel. The TlA demonstrates that these access points will not result in any degradation
of mobility standards below acceptable levels, and that safe and efticient.circulation can
be realized through approval of the requested land use redesignation' and'zone change.
Furthermore, reducing the number of access points for future development on Tax Lot
400 is consistent with policy objectives found in East Main Refinement Plan (EMRP)
Access, Circulation & Parking Element policy I B (pg. 17) and Commercial Element
policy 3 (pg. 12).
,
Because the proposal, as demonstrated in the TIA, is consistent with the requirements of
the TPR and with applicable policies in the EMRP, it is consistent with Goal 12 and
applicable local implementing policies. .
5-98
Zone Change Application
PeaceHealth Gregon Region
March 1 S. Z007
Page 18
. .
Goal 13- Energy Conse~vation
The Energy goal is a general planning goal and provides limited guidance for
site-specific map amendments. The proposalhas no direct impact on energy
conservation, though it would in fact will promote greater energy efficiency by enabling
needed clinical services available to growing residential areas in east Springfield.
Therefore,-the proposal is consistent with, and does not alter the City's continued
compliance with Goal 13, .
. Goal 14 - Urbanization
Goal 14 requires local jurisdictions to provide for an "orderly and efficient transition
from rural to urban land use." The subject property is within the UGB and the city limits
of Springfield, and within an existing urbanized area of the community. Therefore, Goal
14 is not applicable to this application... .
Goal IS - Willamette River Greenway
This goal is inapplicable because the subject property is not within the boundaries of the
Willamette River Greenway.
Goals 16-19 - Coastal Goals
The coastal goals are not applicable to this application.
. ,
'.
5-99
Staff Respo~se to written comments to Applications
ZON 2007-00012 / LRP2007-00013 .
I
~ I
II
SPRINQprlELD
EXECUTIVE 13UMMARY:
. Staffreceived one written testimony from Lauri Sejiel, Goal One Co'alition Planner. on
June 12th, 2007. A written rebuttal to Ms, Segel's letter was then submitted by the
'applicant the following day, June 13th, 2007, Both letters were received within the
specified deadlines as noted in the Planning Commission public hearing on June 5th,
2007. Excerpts from Ms. Segel's letter and the applicant's rebuttal letter have been
provided in this report (in italics) in order to summarize the issues and to provide ease of
review by the Planning Commission, Copies of the tylo letters in their entirety are
attached for reference and review in addition to the excerpts and Staff responses in this
report,
Ms, S~~el's Submittal- Issue #1,: "Applicant Relies heavily on the acknowledged
2000 Springfield Commercial Lands Swdy (SCLS), which does noraddi-ess the
entire Metro UGB area. and is not a refinement plan of the Metro Plan... The
proposed findings rely on reports and other documents containing inventories.
assumptions. and data/hat have not been established for the entire Metro UGB
area, but rather only for the Springfield portion of the UGB area'... ..
Applicant's Rebuttal: "The cities of Eugene and Springfield have separately
adopted and acknowledged commercial/ands studies fulfilling the requirements
, of Goal 9. As such. the SCLS serves as the City of Springfield's "most recent
. economic opportunities analysis, " as ids, Segal notes above by her own
admission ,.. There is no requirement that the Applicant or the City perform a
metro~wide analysis of commercial lands in order to adopt findings satisfying
compliance with ivletro Plan policies and Goal 9... ..
~T A FF RESPONSE:, TheSCLS was a Period Review Task required by OLCO and was
approved by said agency as part of Springfield's compliance with Goal 9 during the
Periodic Review process. As such, it is a valid document to reference related to this Post
Acknowledgement Plan Amendment (P AP A) proposal. The SCLS was adopted by
Resolution No. 00-13 as the "policy document guiding the provision of commercial lands
within the Springfield Urban Growth Boundary." The SCLS was revie\ved by OLCD and
found to be consistent with the Periodic Review Order and Statewide Planning Goals:
The SCLS was not adopted as a specific amendment to the Metro Plan. The City
undertook a supply and demand analysis to determine if there was adequate commercial
land in the adopted inventory to accommodate projected demand and, based on these
conclusions, identify what the City could do to address these conclusions, Chapter 4 of
the SCLS, which includes policies and implementation strategies, all recommended
actions are already in the Metro Plan or TransPlan; are a recommendation to amend the
. Code; or are suggestions to improve business practices. The City and DLCO concluded
5-100
it was not necessary to adopt the SCLS as an amendment to the Metro Plan because'all
nicommendations regarding inventory adjustments contained in the Study could be
implemented through th~ PAPA process as increases in the commercial lands inventory;
the SCLS would be used at that time as part of the findings, reasons and conclusions for
those PAPA actions.
Best available data was used in the analysis of these applications, which included the
SCLS. There are no comprehensive_ studies (i.e, commercial lands inventory) available
for the entire UGB related to commercial lands within one specific time period. Rather,
there is a conglomeration of various studies that are reviewed, For example, the 1992
Industrial Lands stUdy is UGB-wide. The Residential Lands Inventory which is used by
the City is not UGB-wide, Likewise, the SCLS is not Metro-wide.
Ms, Segel's Submittal- Issue #2:. "The adopted Springfield Natural Resource
Study (adopted by Ordinance #6150) shows little or no impact on the commercial
lands inventolY from Goal protection measures, and providdittle if any analyses
of land availability within the entire J\lJetro UGB area, rather than just the
Springfield UGS area. The analysis shows an impact of 11.56 acres on
Springfield's (not the urban growth boundary area in its entirety)... The
referenced sllldies / analyses referenced by'the applicant do not take into account
the 100 acres of new commercial land designated / rezoned to commercial in the
Gateway area. ..
Aoolicant's Rebuttal:. "Considering that the SCLS identified a deficit of 158
acres in the stipply of commercialla,!d over demand, accounting for this
additional redesignated/rezoned land, this would still result in a deficit of more
.ihan 61 acres of needed commercial land. Approving the requested Plan
amendment/zone change would still leave a deficit of approximately 55 acres of
needed commercial land... Therefore. even considering impacts to commercial
lands inventories from other adopted and acknowledged plans. (i.e. the City's plan
for Gpal 5 compliance) and acknowledged Plan amendments / zone changes,
approval of the proposal will not result in there being an exc'ess of needed.
commercially zoned and designated land. . To the contrary, this analysis
demonstrates that there will remain a deficit of approximately 66 acres after
approval of the requested redesignation / rezoning. .. .
STAFF R~SPONSE~ The Springfield Natural Resource Study (SNRS) is referenced by
the applicant and staff as related to this P AP'A because it provides a more updated view
of the city's commercial & industrial lands inventory. It is not meant to be all inclusive in
'and of itself. Reference to the SNRS in conjunction with other referenced documents (i.e.
the SCLS & 1992 Industrial Lands Study) is provided to give the most accurate
information possible given all the available data at this time.
Again, the applicant's report and staffs analysis reference the most recently adopted
documents / inventories available. The City currently does not have an ongoing database
5-101'
,,'
that keeps track of inventories based upon Plan Amendments and/or Zoning Map
Amendments on an ongoing basis: . , '.
The applicant's rebuttal references numbers of acres related to the City's deficit of
commercial land, Staff concurs with the applicant's rebuttal related to number of acres of
commercial lands. The redesignation and rezoning of up, to 99 acres ofreside~tialland
within the Gateway MDR site (as referenced by Ms. Segel) still does riot negate the
deficit of commercial land within Springfield's city limits,
1\'1s, Se~el's Submittal: Issue #3:. "The applicant has not justified tlie . .
conversion of scarce. shovel re}!-dy industrial land, especially land designated a~d
zoned light medium industrial inside the .Metro UGB. even though the Metro Plan
'(comprehensive plan) Economic Element policy #12 establishes that the cities are
'to 'discourage jilwre Metropolitan Area Ge~eral Plan amendments that would
change development ready industrial lands (sites definedas short-term in the
metropolitan Industrial Lands Special Study, 1991) to noh-industrial
desigiwtions,' The applicant and staff findings do not 'address how the loss of
. these 5.24 acres impacts the short-term supply of LMl designated land.., "
Awlir.ant's Rebuttal: "Ms. Segel's citation of Economic Element Policy 12
ignores the fact that the subject site was not included among the sites "defined as
. short-term in the metropolitan Industrial Lands Special Study. 1991). ":..casting
. doubr.on the applicability of Metro Plan Economic Element Policy 12.., Even if
Policy 12 were rel~vant, it's language is clearly not prohibitive to approval of an
application for redesignation/rezoning of an industrial site. particularly when
considering it in the conte:ctofindustrial commercial land inventories. ..,even if
all of the acreage redesignated in Springfield were from the LMI designation - .
which is no, doubt not the case - there would still be a surplus of nearly 50 acres
of LivfI designated land even after approval of the requested Plan amendment.
This does not account for the 11.5 acres of land added to the inventory of LMI
zoned and designated land referenced in my March 28, 2007 supplemental
information. ..' Therefore. the reinovai'of 5.24 acres of LidI zoned and designated
. land will not result in a deficit'of needed land in that industrial designation.
..)v[oreover, although Economic Element Policy 12 "discourages" Plan
amendments for certain indusrriallands. there are countervailing policies in the
L',;{etro flan (i.e., Economic Element Policy 6) and SeLS (i.e.. policies I-A and I-
e) thai are direcrive to providing an adequate supply of needed commercial
lands,.. "
STAFF R_~,,5PONSE:, Staff concurs with the applicant's rebuttal to the. issue raised. The
applicant has cited numerouS acreage calculations based off of adopted inventories which
support the prop'osa!. As noted by the applicant, the subject site was not included among
the sites defined as short-term in the metropolitan Industrial Lands Special Study, 1991.
As noted in the applicant's rebuttal and as previously noted in' this report'and the original
Staff Report, a deficit of cornmercialland and surplus of industrial land will still exist
5~102
even after an approval of the proposed Plan Amendment and concurrent Zoning Map
Amendment. .
Ms, Sr!>'el's Submittal - Issue #4':. "The Applicant's analysis of the proposals; .
consistency with comprehensive plan Economic Element policies found in the
Metropolitan General Plan, Chapter III, B-I - B-7 is insrifficient and does not
address the most significant policies that must be considered, "
Aoolicant's Rebuttal:." ...there are countervailing policies in the Metro Plan
(i,e., Economic Element Policy 6) and SCLS (i.e" policies I-A and I-C) that are
directive to'providing an adequate supply of needed commercial lands. The Metro
Plan recognizes such conflicts: "The respective jurisdictions recognize Ihatthere
are apparent conflicts and inconsistencies berween and among some goals,
objectives, and policies. When making decii.ions based on the Plan, not all the
goals, objectives, and policies can be met to the same degree in every instance.
Use of the Plan requires a 'balancing' of its various components on a case-by-
. case basis, as well as a selection of those goals. objectives. and policies most
pertinent to .the issue at hand. " (pg. 1-4, Metro Plan)... The applicant's original
March 15, 2007 sttbmittal includedfindings addressing relevant Metro Plan
policies (see pg. 5 of the submittal, pg. 4-5 of the Commission 's June 4. 2007
hearing packet). Clearly not all of the 32 Metro Plan Economic Element policies
are relevant to the proposal. .lvIany are aspirational in nature and not directive to
a specific qt;asi-judicial application...
. S1 AFF RESPONSE: As noted in the applicant's rebuttal, policies in the Metro Plan are'
some~imes conflicting to one another. As stated on page 1-4 of the Metro Plan, "The
respective jurisdictions recognize that there are apparent conflicts and inconsistencies
between and among some goals, objectives, and policies. When making decisions based
on the Plan, not all the goals: objectives, and'policies can be met to the same degree in
every instance. Use of the Plan requires a 'balancing' of its various components on a
cas'e-by-case basis, as well as a selection of those goals, objectives, and policies most
pertinent to the issue at hand." The applicant submitted written statements relative to the
policies which supported the proposal. As noted in the original Staff Report, Staff
concurred with the applicant's narrative related to the referenced Metro Plan policies
which support the proposal, given the relationship of those stated Metrp Plan policies as
reviewed concurrentlv with the referenced commercial and industrial adopted inventories.
lVIs, Se?el's Submittal - Issue #5:. "The applicant is not specific about what uses
will be cited should the proposal be approved, and'there is no way to know if in
fact above wage jobs 'and salaries... there, is no way to establish if the applicant
will infact utilize local and imported capitcd'-skills etc. as no commitment to a Lise
has been established... "
Aoolicant's Rebuttal:, "...Ms. Segel's assertion that the application was
unspecific as to the filiure uses on Tax Lot 400 is inaccurate. The application
narrative clearlv states the intended purpose of the redesignationlrezoning is to
5-103
allow for afutt;re medical clinic on Tax Lot 400 and to allow the 10ng-standinc7
~ 0
commercial operations on Tax Lot 402 10 continue (pg. 2. pg.4-2 in the
Commission 's June 4 hearing packet). Such clinical uses are not permitted in any
industrial zoning district. thus promopting the need to rezone (and Redesignate)
Tax lot 400 10 allow a medical clinic, Average wagj?,s and benefits for medical
workers tends 10' be higher than average local wages. a~d further substantiating
data can be entered inlO the record at the City Council level...
ST AFF RESPONSE:, The applicant has noted the intent of the Plan Amendment and
concurrent zone change is for the eventual development of a medical office building. This
is mentioned not only in theapplicant's narrative, but also in the 'applicant's Traffic
Impact Analysis, In fact, the referenced table in the 'fIA (Table 7, pg, 19) specifically
calculates trip generation for the orol)osed medical office buildim;. However,.as noted by
Ms, Segel, there is no certainty as to what the salaries will be, if it will utilize local
capital, etc, With that said, there is no such assurance for any new use that might go on
the properiy with the existing zoning and Plan designation either> Given the fact that the
applicant is a medical service provider (i,e, Peace Health); that they are pursuing these.
applications; and that they have indicated on their application that the purpose of these
applications is to develop a future medical office clinic, it is highly likely (in Staffs
opinion) that they will pursue the medical office use as they've specified. As noted in the
. applicant's rebuttal; average wages and benefits for medical workers .tends to be higher
than average local wages. Staff concurs with the applicant's.rebutta\ statement and' .
affirms the original Staff Report findings indicating that the proposal is in compliance
,with applicable Metro Plan policies,
Ms, Seuel's Submittal-Issue #6:. "The applicant makes the argument that the
proposed plan amendment and zone change would have the effect of correcting
existing non-conforming uses on TL #402. (map 17-02-32); however. the 2000
SCLC. at App~ndi;( C. "Sites with Plan/Zone Conflicts" does not include the
subject property. It appears that the existing nonconforming uses were actually
established AFTER adoption of the 2000 SCLS. indicating that the existing uses
were actually permitteiby the City with the knowledge that these uses would
create plan/zone conflicts,"
.
Aoolica-nt's Rebuttal:. "The applicant does not allege that there is a Plan/zone
conflict on Tax Lot 402;' clearly the existing Plan designatiOns and zoning are
Ud!. Rather. the point made in our application narrative is that commercial uses
have existed for decades. pre-existing the esrablishment of the lVJetro Plan and the
application of the LM1 designation on the subject properties. ids. Segel provides'
no evidence JO back up her accusation that the City wittingly allowed commercial
uses on Tax Lot 402 after adoption of the SCLS. The applicant and owner of Tax
Lot 402 will provide additional evidence and testimony at the City Council
hearino on Julv 2 which willfurther demonstratefactuallv that commercial uses
~. " r . .
and employment have been in the building on Ta;( Lot 402for nearly jO years.....
5-104
STAFF RF:SPONSE: The existine: zoning for TL #402 is Lie:ht Medium Industrial
(LMI), The existine: Plan DesiQl1atioI} for TL #402 is Lie:ht Medium Industrial (LMI).
Therefore, there is no Plan/zone conflict as alleged by Ms. Segel. A non-conforming use
is not the same as a plan/zone conflict. Ms. Segel alleges that the City permitted the.
. existing uses on TL #402 "AFTER adoption of the 2000 SCLS..," and further states that
the uses were ". ..permitted by the City with the knowledge that these uses wouldcreate
plan/zone conflicts," This allegation has not merit for multiple reasons. Article 5 of the
Springfield Development Code provides provisions to allow existing non-conforniing
uses to modify or expand based upon specific criteria, A "non-conforming use" is a use
that was legally created when first established but would not be allowed as a "new use"
under the existing zoning. The existing commercial uses on TL #402 are most likely
considered non-conforming uses (i,e, commercial uses on industrial zoned property). The
2000 SCLS does not list TL #402 as a Plan/Zone conflict because it is not a plan zone
conflict. .
Ms, Set>e!'s Submittal- Issue #7:, "The proposed change is not 'logical and
.harmonious' because it is not consistent with the development pal/ern envisioned
in the Metro Plan ...Compliance with statewide planning goals. including goals
2,6.9,10.12 and 13 has not been established. In particular. it has not. been
established that the Eugene-Springfield Metro UGB area's supply of campus
industrial land will be protected pursuant to the PAPA and zone change
proposal... Staffhasfailed to address the impact that this proposal will have on
the dwindling supply of shovel ready industrial land inside the Springfield city,
limits, including prior actions approving land use code amendments to the
campus industrial zone that established more flexibilit/for what uses are
allowed in the city's campus industrial zones, ..
Aoolicant's Rebuttal: "It shouldfirst be n'oted that the application does not
involve or in any way affect the 'metro area 's supply of campus industrial land. '
Moreover, the applic~tion has no effect upon Goal 1 0 (Housing), and has
. elsewher~ demonstrated compliance with Goal 12 and other applicable statewide
planning goals. !v~v guess is that Ms. Segel and Nancy Falk. who appeared at the
June 4 hearing and requested th'e wril/en record be lefi open for a week. both
vigorously appose the Plan amendment/zone change proposedfor the lyfarcola
Meadows project, and are borrowing arguments to also object to this modest
request before the City... The contention that the proposal would not result in a
'logical and hwmonious ' land use pal/ern is without substance or basis in fact:
and is not an approval criterion. As .noted above and elsewhere in therecord, this
proposal is consislent with policies and provisions in the Metro Plan, its
Economic Element. supporting refinement plans (i.e., the SCLS and lvIILS) 10 the
i,Ietro Plan. and Goal 9 and other applicable statewide planning goalL. "
ST AFF RESPONSE~ Ms. Segel refers to the existing zoning of the subject site as
"Campus Industrial" multiple times in her letter.'The subject property is zoned and
. designated Lie:ht Medium Industrial, not Camous Industrial. As noted in the applicant's
rebuttal, the statement submitted by Ms. Segel indicating that the ". ..proposed 'change is
5-105
not 'logical and hanno~ious".,' isnot a criterion of approval for these applications, Staff
have reviewed the proposal based upon the applicable criteria of approval, and found that
it meets the criteria (with conditions) as written in the' Staff Report, The inventories of
corrunercial and industrial land have been evaluated and balanced with the relevant Metro
Plan policies to formulate the recorrunendation for approval with conditions. Specific
findings related to the Statewide Planning Goals have also been included in the original
Staff Report.
5-106
I
:~.
GOAL ONE COALITION
~
Goal One is Citizen Involvement,
City of Springfield Planning Commission
David Reesor
City of Springfield
225 Fifth Street
Springfield, OR 97444 .
I.....y:i-,-"..-..-:;--\ -- --,--
-' "....... .~:.:I \ c t-I'" "',
"". ".-' .....;/ :.:..,' 'f,. .~/ ,'~ jU!
. lUN 1 2 2007
BY:~):<<
June 12, 2007
RE: ZON 2007-00012fLRP 2007-00013, Plan Amendment'&: Zone Change
DearMembers of the Commission:
The Goal One Coalition (Goal One) is a nonprofit organization whose mission is to provide
assistance and support to Oregonians in matters. affecting their communities. Goal One is
participating in these proceedings at therequest of and on behalf of iis membership residing in .
Lane County. This testimony is presented on behalf of Goal One and its membership,
including Nancy Fall<, 2567 Marcola Road, Springfield Oregon 97477, as an individual.
1. lntr_oduction
This propos~l is for a'site-specific Metro Plim Amendment I Refinement Plan Amendment and
a concurrent Zoning Map Amendment from Light Medium Industrial (LMI) to Community
Corrunercial (CC) within the Springfield city limits,
The subject site is located near 44th and Main Street (Highway 126), The site consists of two
parcels underseparate ownerships, and is located on approximately 5,24 acres identified as
Tax Lots 400 and 402 on Assessor's Map'No, 17-02-32-00: TL 400 (5.01 acres) has several
vacant buildings on site, including portable trailer type structures, The small~r of the two
subj!=ct lots, TL 402 (.24 acres), has an existing corrunercial development on-site, although the
plan designation and zone are LM!. Properties located to the north (Weyerhauser) are zoned
and designated heavy industrial. Parcels located west .of the subject site are designated mixed-
use on the East Main Refinement Plan, Propert): locate.d 'east and adjacent to TL #402 is built
out as a business park,and designated UvlI. Properties located south of the subject site, across
Main Street, are zoned and designated Corrununity Commercial.. . .
..
II, Criteria applicable to the request
Local approval criteria are found in the following documents: Springfield Development
Code, Metro General Plan, and East Main Refinement Plan, as indicated in the staff
report,
. The proposed plan amendment must also be found to be consistent with applicable statewide
planning goals. ORS 197.175(2)(a). Applicable goals include Goall, Citizen Involvement,
Goal 2, Land Use Planning; Goal 9, Economy ofl1'1e State; and Goal 12, Transportltion. The
I
Eugene office: 642 Charnellon Suile 100 . Eugene 01\ 9740 I . 541-431-7059' Fax 541-43 1,7078
Lebanon office: 39625 A1men Drive' Lebanon 01\ 97355 "'541-258-6074 ' Fax.541-258-681 0
WNW .goal1.org
5-t07
GOAL ONECOAUTION
. propqsed plan amendment must also comply with administrative rules implementing
applicable statewide planning,goals,
Ill, Analysis
COMPR:BEN5TVE PLAN CONSISTENCY AND COMPLIANCE WlTH
STATEWIDE GOAL~
" .'-'"'-.' .,
..' .'-.'"
All comprehensive plan amendments are reviewable for compliance with the statewide.
planning goals, Residents of Rosemont v. Metro. 173 Or App 321. (2001); 1000 Friends of
Oregon v. Jackson County, 79 Or App ?3, 97,718 P2d 753 (1986), rev den 301 Or 445
(1987); Opus Development Corp. v. City of Eugene, 141 Or App 249, 254, 918 P2d 116
(1996),
. . The proposed findings rely on reports and other documents containing inventories,
assumptions, and data that have not been established for the entire Metro UGB area, but mther
only for the Springfield portion of the UGB area, This material includes data used to justify
findings of compliance with goal 9, Any decision relying on such findings would not comply
with Goal 2,
GoalS
Concerning .applicability of land' inventories p!-lrsuant to Ordinance #6150 that
adopted the Springfield Natural Resource Study, staff's position is that inveritories
established pursuant to Goal 5 are relevant considerations in considering availability
of commercial and industrial land. However, that analysis (applicant's Attachment
"A" _ tables 11-1, 11-2 and .ll-3) actually show little'or no impact on the commercial
lands inventory from Goal 5 protection measures, and provide little if any analyses of
land availability within the entire Metro UGB area, rather than just the Springlield
UGB area, Table 11-2, Analysis of Maximum 'Possiblelmpact on Supply of
Commercial Lands within the Springfield Urban Growth Boundary shows an impact
of 11.56 acres on SpringfIeld's (not the urban growth boundary area in it's entirety)
commerciallilnd supply. ,.
Metro Plan/East Main Refinement Plan, ZON 2007-00012 -lRP 2007-00013
5-108
,
2
GOAL ONE COALITION
Additionally, the analysis pursuant to Ordinance #6150 fails to account for lands ADDED TO
the commercial inventory since 2000, including but not limited to the Gateway MDR sit~'s
100 acres, providing a skewed picll!re 0 f the actual commercial land inventory, .
To skew the picture even further, the analysis of ma,~imum possible impact frOm Goal 5
protection measures on supply of industrial lands (Ordinance #6150, table II-I) considers
ALL industrial lands within the entire Metro UGB area, rather than just the Springfieldportion'
of the UGB, and does, not provide a breakdown of number of industrially zoned acres in
Springfield vs. Eugene. The 2000 SCLS, however (Table 3-2) shows that the number oflight
medi!lm industrial (LMI) acres by plan desigmition in the Springfield UGB area is 198.77, ,
while the' number of LMI acres within the Eugene UGB is shown to be 1230.78, The
applicant fails to establish the relevancy of these tables to the current PAPA and zone change
proposal, considering that only about 16% of the' Metro area ugb industrial land supply is
within the Springfield city limits,
. .'
~~..::
Goal 9 _ Economic Development is: "To provide adequate opportunities throughout the
. state for a variety. of economic activities vital to the health, weifare, :ind prosperity of Oregon's
citizens."
The Staff Report's Goal 9 findings are based upon the 1992 Industrial Land Study and the
2000 Commercial Land Study, Goal 2 requireS that information upon which land use
decisions are made be contained in the plan document or supporting documents,
. .
OAR 660-015-0000(2), Part I Planning establishes that city, county, state and federal agency
and special district plans and actions related to land use shall be consistent with the
comprehensive plans of cities and counties and regional plans adopted under ORS Chapter
268.
Goal 9 _ 660-009-0010 (4) establishes that for,a post-acknowledgement plan amendmellt
under OAR ch;pter 660, division 18, that changes the plan designation ofland in excess
of two acres within an existing urban growth boundary from an industrial use designation
to a non-industrial usedesignatioll, or an other employment use designation to any other
use designation, a city or county must address all applicable planning requirements, and:
(emphasis added). .
(a) Demonstrate that the proposed amendment is consistent with its most recent economic
opportunities analysis and (emphasis added) the parts of its acknowledged .
comprehensive pi all which address the requirements of this divisioll;
The applicant appears to rely heavily 011 inventory and policY'statemellts established bY the
2000 SCLS in establishing that the proposal is consistent with the Goal 9 rule. However, the
applicant's analysis of the proposals' consistency with, comprehensive. plan Economic
Element policies found in the Merropoliw.n General Plan, Chapter !II, B-1 - B-7 is insufficient
and does not'address the most significant policies that must be cOllsidered.
, '
.The proposal would decrease the City's campus indusmalland inventory by yet another 5.24
acres, The applicant has no't justified the conversion of scarce, shovel ready industrial land,
Metro Plan/East Main Refinement Plan. ZON 2007.()0012 - LRP 2007.00013
5-109
3
GOAL ONE COAUTION
especially land designated and zoned light medium industrial inside the Metro UGB, even
though Metro Plan (comprehensive plan) Economic Element policy # 12 establishes that th~
cities are to "discourage future Metropolitan Area General Plan amendments that would
change development ready industnallands (sites defined as short - term in the metropolitan
Industrial Lands Special Study, 1991) to non-industrial designations." The applicant and staff
fmdings do not address how the loss of these 5,24 acres impacts the short-term supply of LMI
designated land, .
The applicant makes the argument that the proposed plan amendment and zone change would
have the effect of correcting existing non-conforming uses on TL #402. (map 17-02-32);
however, the 2000 SCLC, at Appendix C, "Sites with Plan/Zone Conflicts" does not include
the subject property. [t appears that the existing nonconforming uses were actually established
AFTER adoption of the 2000 SCLS, indicating that the-existing uses were actually permitted
by the City with the knowledge that these uses would create plan/zone conflicts" /
In addressing applicability of the Springfield Cornrhercial Lands StUdy (2000 SCLS), the
applicant appears to try to separate the Metro Area by jurisdictional boundary. However,
Eugene and Springfield have a shared and adopted UGB, Comprehensive Plan, and Industrial
Lands study, The jurisdictionally focused SCLS does not analyze supply and demand for the
entire Metro UGB area and cannot be relied upon on it's o'W!1 to establish consistency with the
requirements of OAR 660-009-0010 (4), which establishes that the proposed PAPA be
consistent with both (emphasis added) the most recent economic opportunities analysis (i.e,
the 2000 SCLS) and the comprehensive plan,
A related problem with placing such heavy reliance on the 2000 SCLS to establish Goal 9
compliance is that in analyzing supply and demand, the study fails to consider or otherwise
.' account for lands added to the commercial inventory via applicant initiated and city approved
, zone changes and p'lan amendments, One very obvious example of an addition to the
Springfield commercial lands inventory was the 2003 plan amendment and zone change (LRP
2003-0013 and ZON 2003-0019) at the 100-acre GatewaY,Medium Density Residential site
that had the effect of rezoning and redesignating 100 acres ofresidentialland to commercial.
The applicant provides a spreadsheet (their Attachment B) that supposedly accounts for all
. Metro Plan' diagram changes affecting the supply of residential, conimercial and industrial
Lands in the city of Springfield between 1991 and the present, but has failed to account for or
otherwise address the addition of commercial land to the SCLS, even though it is clear that
more t.'1an 100 acres' of commercial land has been added to.the inventory since the'year 2000.
This omission raises doubt as .to the accuracy of applicant's Attachment B -in supposedly
accountina for additions to and subtractions from the various land inventories,
'"
The applicant also relies in part on inventories established in conjunction with adoption of
Springfield's Natural Resource (NR) Study, by Ordinance #6150 on November 28, 2005,
While those inventories may be relevant to this proposal in that possible' impacts' resulting
from Goal 5 protection measures were considered focall zoning classifications, the analysis of
. maximum possible impact on supply of commercial lands pursuant to t.'1e study is limited to
the area within the Springfield portion of the Metro UGB (table 11-2). Again, because
Eugene and Springfield share a UGB and a comprehensive plan, an analysis of the entire
UGB area is necessary to establish an accurate picture of the supply of commercial lands.
Metro Plan/East.Main Refinement Plan, ZON 2007-00012 - LRP 2007-00013
5-110
4
GOAL ONE COAUTION
",
In any case, the NR Study found, that the ma'(imum possible impact of Goal 5 protection
measures on the Springfield Commercial Lands Inventory would be the loss of 11.56
"commercial acres," . '.
LOSS OF INDUSTRLA.L LAJ'ID
The proposed plan amendments and zone changes would remove 5.24 acres of shovel ready
light medium industrial land from the Metro UGB area industrial lands inventory. This is. in
addition to an aC\ditio~al 56 acre conversion of campus industrial to community commercial
. land less than 2 miles away which is currently pending approval by the Springfield city
council. The applicant is vague about the purpose of the proposed plan amendment and zone
change, noting that, with approval of the plan amendment and zone change, the uses could
include a possible future medical' clinic, and the provision of family wage jobs~ . The applicant
has said nothing about the existence of their other 100 acre lTledical campus located within
about 5 miles of the subject properties proposed for pl!ill and zone changes, Given.this fact,
the applicant has not justified the removal oLshovel ready light medium industrial land for . .
commercial uses, This area within the Springfield city limits is already inundated with
commercial zoning and commercial uses, and approval of this proposal would contribute even
further to over commercialization within the cit)( of Springfield. '
The applicant cites 4 of the 32 Economic Element policies pursuant to the comprehensive
plan (Metro Plan) (Chapter 1Il, Section B) of tne Plan as relevant tothe proposed PAPA.
The four Plan policies considered tiy the applicant as relevant to the supply of industrial land
are policies 1,2, 6, andl'l .
Policy I is to Demonstrate a positive interest in existing and new industries, especially those,
providing above wage job and salary levels, and increased variety of job opportunities, a rise
in.the St;Jndard of living, and utilization of our existing comparative advantage in the level of
education and skill of the resident labor force. . Ho\vever, the applicant is not specific about
what uses will be cited should the proposal be approved, and there is no way to know if in fact
above wage jobs and salaries.
, .'
Policy 2 is to encourage economic development which utilizes local and imported
capital, entrepreneurial skills, and the resident labor force. Again, there is no way to
establish if the applicant wilfin fact utilize local and imported capital, skills etc, as no
commitment to a use haS been established.
Policy 6 merelv states: "Increase the amount of undeveloped lilI\d :oned(emphasis added) for
light industrial and commercial uses correlating the effective supply in terms ofsuitabilicy and
availabilicy with d'le projections of demand." .
This policy addresses zoning only, not plan designation, and co'ncems the nes:essit'j of having
adequate supplies of lilI\d of both commercial and industrial designations, It says nothing
concerning the applicabilicy of favoring one plan designation over the other.
Metro Plan/East Main Refinement Plan, ZONs2~j f0012 - LRP 2007 -D0013
5
GOAL ONE COAUTION .
Policy 11 is to encourage economic activities which strengthen the metropolitan ru:ea's
position as a regional distribu~ion, trade, health, and service center, The applicant
asserts that the amendment (sic) will facilitate the development of medical uses that
will serve the needs of the growing residential areas in east, south and southeast
. Springfield, and strengthen the metropolitan area's position as a premier locale for
healthcare services, consistent with this policy objective, Considering that their 2003
zone change and plan amendments were based on the assertions that provision of
medicakare pursuant to campuS style medical facility development is the wave of the
future, and that the applicant already has established their dominance in the health care
market within the' city limits, it has hard to fathom why they. think another 5.24 acres
will somehow strengthen Springfield's position as a premier locale for healthcare
services,
The PAP A proposal must be consistent with the Economic Element of the Comprehensive
plan in it's entirety. A major omission found in the application and staffreport is an analysis
of all the Metro.Plan Economic Element policies other than the four addressed by the
applicant, The rem.aining 28 policies should be addressed in some manner, More
specifically, the following policies are directly relevant to the inventory of industrial lands '
throughout the Eugene-Springfi~ld,Metro UGB area,
. ,
5 _ Provide existing industrial activities sufficient adjacent I~d for future expansion,
. - .
This'Plan provision is directly applicable because 'the subject properties are currently zoned
and designated to take advantage oflight medium industrial designation and zoning. This
proposal to eliminate more industrial zoning adjacent to existing and developed industrial
zoning, plan designation, and uses is clearly inconsistent with the Metro Plan Economic
element, and if approved would have the effect of limiting future growth and expansion of the
existing campus industrial uses, .
- .
7 _ Encourage industrial park development, including' areas for warehousing and distributive
industries and research and development activities, .
Economic Element of the Metro Plan, Finding #17 establishes: "Special light industrial firms" ,
"have varied site location requirements, prefer alternative sites.to choose from, and usually
benefit from location of other special light industrial firms within the community and within
the same industrial development." The subject site is located adjacent to an existing light,
medium industrial site.
9 _ Encourage the expansion of existing and the location of new manufacturing activities
which are characterized by low levels of pollution and efficient energy use.
Staffhas not discussed efforts to attract andlorencourage expansion of manufactUring
activities that could be sited on campus industrial zoned and designated lands, The only
reference to this issue from staff is t.J-jat there hasn't been much interest' in the site from the
industrial development sector.
IS-Encourage compatibility between industrially zoned lands and adjacent are:lS in local
planning program. .
Mel;o Plan/East Main Refinement Plan. ZON 2007-00012 - LRP 2007-00013
5-112 '
6 -
GOAL ONE COAUTION
Neighbars have expressed no. cancern abaut their Cjuality aflifefram existing industrial uses,
The applicant has nat addressed why ar haw the existing light medium industrial zaning and
plan designatian is incampatible wi\h the adjacent neighbarhaadzaning and plan designation.
16 _ Utilize pracesses and lacal cantrals which encaurage retentian aflarge parc~\s ar
cansalidatian af small parcels af industrially ar cammercially zaned land to. facilitate their use
ar reuse in a camprehensive rather than piecemeal fashian.
The subject praperties are adjacent to. a large parcel which iS,zaned and designated LMI. Staff
is directed by this policy to. encaurage retentian af this parcel of industrially zaned and
designated land, which is ane af the few remaining parcels af LMI land within the Springfield
city limits. .
,,'
21 _ Reserve several areas within the UGB far large scale, campus type, light manufacturing
uses.
Staffhas failed to. address the impact that this praposal will have an the dwindling supplyaf
shovel ready industrial land inside the Springfield city limits, including priar actians
appraving land use cade amendments to. the campus industrial zane that established mare
'flexibility' far what uses are alia wed in the city's campus industrial zanes. .
28 _ Recagnizethe vital rale afneighbarhoad cammercial facilities in praviding services and
goods to. a particular neighbarhaad.
This PAPA prapasal requests cammunity cammercial plan designatian and zaning yet has not
cansidered ar atherwise addressed the applicability af neighbarhaod cammercial zaning vs.
the requested cammunity cammercial zaning.
Staff and applicant have nat addressed thecapplicabilityof community cammercial zoning
within a nade, ar explained why neighbarhood cammercial Zalung is being ignored for higher
intensity uses in this existing neighbarhaad.
All the Metra Plan Econamic Element policies are applicable to. this applicatian, and shauld
have been addressed by the applicant.
HI. Conclusion
The praposed plan amendment is nat lagical and harmonious with the bnd use pattern far
the greater area. The praposed change is not "logical and harmaniaus" because it is not
consistent with the development pattern envisianed in the Metra Plan.
As explained above, the prapased amendment is incansistent wit.i-] the intent 0.1' the Ecanamic
Element af the Metra Plan, and daes nat camply with Metra Plan palicies. Therefore it cannat
be faund to be campatible with these Plans.
Campliance with stiltewide planning gaals, including gaals 2,6,9, 10, 12, and \3, has nat
been' established. [n particular, it has nat been established that the Eugene-Springfield Metra
UGB area's supply af campus industrial land will be protected pursuant to. the PAP A and zane
change prapasal.
Metra Plan/East Main Refinement Plan, ZON 2007 -00012 - LRf! ,2007 -00013
5"'113
7
GOAL ONE COAUTlON
The requested plan amendment does not comply with policies of the Metro Plan and
Metropolitan Industrial Lands Special Study.
The requested plan amendment and zone change does not benefit the public and are not.
appropriate.
Goal One and other parties whose addresses appear in the first paragraph of this letter request
notice and a copy of any decision and findings regarding this matter.
"-
Respectfully submitted,
Lauri Segel
Community planner
Metro Plan/East Main Refinement Plan, ZON 2007-00012. LRP 2007-00013
5-114
8
. ,
~ Pem:eHealth
June 13, 2007
Springfield Planning Commission
Attn: David Reesor, Planner
City of Springfield
Development Services Department
225 Fifth Street
Springfield, OR 97477
i'y t~:~ ~'-_'~:._
JljAV' '. ':/'(:::-<;.
-/i I 'J :-f }:':.:..";-.
/:Jl ,] )//1 .-......j: /
::!~'&. 'jl]/ I
....' /
,.~ . .
-.....~ .,,'
.---- J
._-~>-
Re: ZON 2007-00012, LRP 2007-00013 - Plan Amendment/Zone Change
Dear Chairman Cross and'Commissioners,
The Commission considered the above-referenced applications on.June 5 at a duly.
noticed work session and public hearing. The following.rebuts written testimony ,
submitted by Lauri Segel of the Goal One Coalition at the close of the extended record
yesterday.
Ms. Segel suggests that the applications do not comply with statewide
planning Goal 9 (Economic Development) - and by extension with Goal 2
(Land Use Planning) - because the 2000 Springfield Commercial Lands
Study (SCLS) "does not address the entire Metro UGB area, and is not a
refinement plan of the Metro Plan." (pg. 2; June 12,2007 Segel letter)
She further states that "Eugene and Springfield have a shared and adopted
UGB, Comprehensive Plan, and Industrial Lands study. The .
jurisdictionally focused SCLS does not analyze supply and demand for the' I
. entire Metro UGB area and cannot be relied upon on it's [sic] own to
establish consistency with the requirements of OAR 660-009-0010 (4),
which establish'es that the proposed PAPA [Plan amendment] be
consistent with both (emphasis added) the most re.cent economic
opportunities analysis (i.e., the 2000 SCLS) and the comprehensive plan."
(pg..4, Segel letter) .
Aoollcant's Resoonse: The SCLS was developed by the City. and adopted by the
Springfield City Council (Resolution No. 00-13 and included in the end pages of the
SCLS) to comply with Goal 9 and applicable OARs pursuant to periodic review
requirements established by the Oregon Land Conservation and Development
Commission. Prior to the SCLS, the City of Eugene had an acknowledged plan for
complying with Goal 9, the 1992 Eugene Commercial Lands Study (EeLS). The ECLS
states: "The study includes solely the Eugene portion of the metropolitan urban growth
boundary." (pg. 1-3, ECLS)
..--... - .-- -. ---
DedicClred 10 Ex.ceprionall'vIedic{111!
and COlllpassirJnare Care
Phone: (541) 686.3660 .
FH: (541) 686-3699
PO Box 1479 Eugene OR 9i....O.1J79
www,peacehealth.org
5-115
Re: ZON 2QOi-00012. LRP '- -00013 - Plan Amendment/Zone Change
Applicant's Rebuttal
Jun, 1.3. 2007
Page 2.
Although there is in fact an ackno\vledged study covering both comrriunities' industrial
lands (the 1993 Metropolitan Industrial Lands Policy Report, and companion Inventory
Report), the cities of Eugene and Springfield have separately adopted and acknowledged
coinmerciallands studiesfulfllling the requirements of Goal 9. As such, the SCLS serves
as the City of Springfield's "most recent economic opportunities analysis," as Ms, Segel
notes above by her own admission. The SCLS also .complies with Metro Plan Policy 31
which called for the City to conduct a commercial lands study, and fulfills the City's
, Goal 9 requirements pursuant to the periodic review work order, now accepted as
. complete by DLCD. There is no. requirement that the Applicant or the City perform a
metro-wide analysis of commercial lands in order to adopt findings satisfying compliance
with Metro Plan policies and Goal 9,
Ms. Segel states that the analysis provided does not account for additions
to the inventory of commercial lands, notably "the Gatew,\y MDR site's
100 acres." (pg, 4, Segel letter) . -
Aoolicant's ReSDonse: The City previously adopted amendments to the Gateway
Refinement Plan (Jo, No. 2002-08-244), including GRP. Implementation Action 12.1,
. which limited redesignation and rezoning of up to 99 acres ofresidentiai land within the
Gateway MDR site, Subsequent Plan diagram amendments and zone changes of96.2
acres and 3.5 acres resulted in redesignationJrei'-oning of96,2 acres to Mixed Use
Commercial or Medical Services of the possible 99 acres available under the GRP.
Considering that the SCLS identifled a deficit of 158 acres in the supply of commercial
land over demand, accounting for this additional redesignated/rezoned land, this would
still result in a deficit of more than 6 I acres of needed commercial land. Approving the
requested Plan amendment/zone change would still leave a deficit of approximately 55
acres of needed commercial land.
The supplemental information submitted into the record by the Applicant included the
City's analysis of impacts to the commercial lands inventory pursuant to the City's .
acknowledged compliance with Goal 5 periodic review requirements. Table I I -2 of this
analysis (see pg, 3-25 in the Commission's June 4, 2007 hearing packet) identifies that as
a consequence of the City's Goal 5 protection measures that approximately I l.s acres
would be removed from the inventory of needed commercial lands, thus further adding to
the commercial lands deficit established in the SCLS.
Therefore, even considering impacts to commercial lands inventories from other adopted
and acknowledged plans (i.e., the City's plan for GoalS compliance) and acknowledged
Plan amendments/zone changes, approval of the proposal will not result in there being an
excess of needed commercially zoned and d'esignated land. To the c'ontrary, this analysis
demonstrates that there will remain a deficit of approximately 66 acres after appro~al of
the requested redesignationlrezonirig.
5-116
. I J '"
Re: ZON 2{)07-00012, U.... _J07-00013 - Plan Amendment/Zone Change
Applicant' ;"Rebuttal
June 13 ~007
Page 3
(vis. Segel states that the application relies "heavily on inventory and
policy statements established by the 2000 SCLS in establishing that the
proposal is consisteI)t with the Goal 9 rule. However, the applicant's
analysis of the proposals' consistency with comprehensive plan Economic
Element policies found in the tyletropolitan General Plan, Chapter III, B-1
_ B-7 is insufficient and does not address the most significant policies that
must be considered," (pg. 3, Segel letter)
She further alleges that the application has'n't "justified the conversion of
. scarce, shovel ready industrial land, especially land designated and zoned
light medium industrial inside the Metro UGB, even though the Metro
Plan (comprehensive plan) Economic Element policy #12 establishes that
the cities are'to 'discourage future Metropoli:tan Area General Platt
amendments that would change development ready industrial lands (sites
defined as short-term in the metropolitan Industrial Lands'Special Study,
. 1991) to non-industrial designations.' The applicant and staff findings do
not address how. the loss of these 5.24 acres impacts theshort-Ierm supply
of LMI designated land." ,
Aoolicant's Resoonse: The Applicant's original March 15, 2007'submittal includ~d'
findings addressing relevant Metro Plan policies (see pg. 5 of the submittal, pg. 4...5 of the
Commission's June 4, 2007 hearing packet). Clearly not all of the 32 Metro Plan
Economic Element policies are relevant to the proposal. Many are aspirational in nature
and not directive to a specific quasi-judicial application, for example Policy 28:
"Recognize the vital role of neighborhood commercial facilities in providing services and
goods to a particular neighborhood." (pg. III'B-6, Metro Plan) Others are directed to
actions that the public sector jurisdictions are to undertake, such as Policy 31, which
Springfield did in conducting in the SCLS: "Conduct a Commercial Lands Study prior to
the next major plan update." (pg. III-B-7, ibid) Nonetheless, to demonstrate that all
policies were considered irrespective oLtheir applicability, the Applicant will provide
supplemental findings and enter them into the record prior to the City Council hearing on
these applications. However, this does not suggest that the Applicant's findings are
presently inadequate or that the Metro Plan policies cited are not on point. .
-
Ms. Segel's citation ofEconon1ic Element Polley 12 ignores the fact that the subject site
was not included among the sites "defined as short-term in the metropolitan Industrial
Lands Special Swdy, 1991)." The adopted and acknowledged Metropolitan Industrial
. Lands Policy and [nventory Reports identify the subject site as being included in
"Subregion #8 _ East Springfield." Maps and tabularinformationin these reports (pp.
42-44, tables pp. 18-26; [993 MIL Policy Report) do not identify the subject site among
the "short-term sites" in the i'ndustriall<inds study, presumably because both were'
considered developed. The abutting property now developed with the Hyland Business
Park was, however, identified in the study as site #7 in this subr,egion. While the Hyland
property was included in. the matrix of"short-terrn sites," it was also identified as being a
"developed" site. The MIL Policy Report states that "sites develop~d during the study
5-117
. Re: ZON 2007-00012, LRP. -00013 -Plan AmendmentlZone Change
Applicant' ,Rebuttal
June \ 3. ?no?
Page 4
were not included in the short-term supply ofsi!es. Staff projected a.five year need for
industrial sites based on development trends in Eugene,Springfield during the previous
two year period, a time of economic growth. This sport term demand was compared to
the existing supply of site~, excluding those already developed. (emphasis in original
report]" (pp. 15, 16) Therefore, the subject site was not included in the inventoriof
short-term industrial sites in the industrial lands study casting doubt on the applicability
,of Metro Plan Economic Element Policy 12.
Even if Policy 12 were relevant, its language is clearly not prohibitive to approval of an
application for redesignationlrezoning of an industrial site, particularly when considering
it in the context of industrial and commercial land inventories. As stated above and
established in the record, there is a demonstrated ne,ed for additional commercial iand
. ' I
which the proposal helps address.
. The record also includes evidence demonstrating that there is a surplus of needed
industrial land. The acknowledged metro industrial lands study identified a surplus of
buildable light medium industrial acreage, and overall industrial acreage, in Eugene,
Springfield, and combined in the metro UGB. Table 5 in the MIL Inventory Report (pg,
47) identifies supplie's of buildable industrial land as follows:
.Eugene
Springfield.
Metro UGB .
LMI Acres
1,230.78
. 19S,77
1,429.55
Total Industrial Acres
2,895.49
70S.80
3,604.29
The report further states that the study "identifies about 1,688 constraint-free industrial
acres.... This supply exceeds the projected demand over the next twenty years, which is
between 650 to 1,172 acres." (pg. 73,-MIL Inventory Report)
AS noted in the City's Goal 5 analysis entered il\to the record, the maximum impact of
industrial acreage from Goal 5 protection measures in Springfield is 54.43 acres (Table
11.3, pg. 3,25 of the Commission's June 4 hearing packet). The analysis also found that
there were 90.S0 acres removed from the industrial designation by prior Plan
amendments in Springfield. Therefore, even if all of the industrial acreage impacted by
Goal S.and all of the acreage redesignated in Spri'ngfield were from the LMI designation
_ which is no doubt not the case - there would still be a surplus of nearly 50 acres ofLM!
designated land even after approval of the requested Plan amendment. This does not
accOllllt for the 11.5 acres of land added to the inventory of LM! zoned and designated
land referenced in my March 2S, 2007 supplemental information.
Therefore, the removal of 524 acres of LM! zoned and designated land will not result in
a deficit of needed land in that industrial designation.
Moreover, although Economic Element Policy \2 "discourages" Plan amendments for
certain industrial lands, there are countervailing policies in the Metro Plan (i.e.,
5-118
, " .,.
Re: ZON 2'007-00012, LRP 2007-00013 - Plan AmendmenrJZone Change
Applicant's Rebuttal
June 13. 2007
. Page 5 .
Economic Element Policy 6) and SCLS (i.e., Policies. I-A and I-C) that are directive to
providing an adequate supply of needed comrnerciallands. The Metro Plan recognizes
such conflicts: "The respective jurisdictions recognize that there are apparent conflicts
and inconsistencies bet\veen and among some goals, objectives, and policies. When
making decisions based on the Plan, not all the goals, objectives, and policies can be met
to the same degree in every instance. Use of the Plan requires a 'balancing' of its various
components on a case-by-case basis, as well as a selection of those goals, objectives, and
policies most pertin'ent to the issue at hand." (pg. 1-4, Metro Plan) The Applicant
contends' that fmdings and evidence in the record from adopted and acknowledged.
sources demonstrate that approval of the requested.redesignation/rezoning is consistent
with applicable policies and fulfllls the City's employment-generating objectives and
requirements under Goal 9.
Ms. Segel's letter states thaf"the applica~t is not specific,about'what'uses,
will be cited should the proposal be approved, and there is no way to know
if in fact [sic] above wage jobs and salaries." (pg. 5, Segel letter)
She also states that.while "the applicant argues that the proposal would
have the effect of correcting existing non-confonning uses on TL 11402"
that the property is not included in the "Sites with Plan/Zone Conflicts" in
the SCLS. She goeson to state that "it appears that the existing
nonconfom1ing uses were actually established AFTER adoption of the
2000 SCLS, indicating, that the existing uses were actually pennitted by
the City with the knowledge that these uses would create plan/zone
conflicts,';'(pg. 4, Segel letter) .
Aoolicant's Re~Donse: The Applicant does not allege that there is a Plan/zone conflict on
Tax Lot 402; clearly the'existing Plan designations and zoning are LMI. Rather, the
point made in our application narrative is that com'mercial uses have existed for decades,
pre-existing the establisqment of the Metro Plan and the application of the LMI
designation on the subject properties. Ms. Segel provides no evidence to back up her
accusation that the City wittingly allowed conunercial uses on Tax Lot 402 after adoption
of the SCLS. The Applicant and owner of Tax Lot 402 will provide additional evidence
and testimony at the City Council hearing on ]LIly 2 which will further demonstrate
factually that commercial uses and employment have been in the building on Tax Lot 402
for nearly 50 years.
Ms. Segel's assertion that the application was.unspecific as to the future uses on Tax Lot
400 is inaccurate. The application narrative clearly states the intended purpose of the
redesignatiorJrezoning is to allow for a future medical clinic on Tax Lot 400 and to allow
the long-standing commercial operations on Tax Lot 402 to continue (pg. 2, pg. 4-2 in the
Commission'slune 4 hearing packet). Such clinical uses are not permitted in any
industrial zoning district, thus prompting the need to rezone (and redesignate) Tax Lot
400 to allow a medical clinic. Average wages and benetits for medical workers tends to
5-119
I
Re: ZON 2007-00012, LRP 2007-00013 - Plan ,';mendmenUZone Chanee
Applicant's Rebunal
June 13,2007.
Page 6
\. . ~ .
'r---
be higher than average local wages, and further substantiating data can be entered into the
record at the City Council level.
Ms. Segel contends that the proposal is not "logical and harmonious" with
'. land use patterns in the greater area, inconsistent with the intent of the
Economic Element of the Metro Plan, doesn't comply with Metro Plan
policies, and hasn't demonstrated compliance with statewide planning
goals 2, 6, 9,10,12, and 13. "In particular, it has not been established that
the Eugene-Springfield metro area's supply of campus industrial land will
be protected pursuant to the PAPA and zone change proposal."
Aoolicant's Resoonse: It should first be noted that the application does not involve or in
any way affect the "metro area's supply of campus industrial land." Moreover, the
application has no effect 'upon Goal 1 0 (Housing), and has elsewhere demonstrated
compliance with Goal 12 and other applicable statewide planning goals. My guess is that
Ms. Segel and Nancy Falk, who appeared at the June 4 hearing and requested the written
'record be.left open for a week, both vigorously oppose the Plan amendment/zone change
proposed for the Marcola Meadows project, and are borrowing arguments to also object
to this modest request before the City.
The contention that the proposal would not result in a "logical and harmonious" land use
pattern is without substance'or basis in fact, and is not an approval criterion. As noted
above and.~lsewhere in the record, this proposal is consistent with policies and provisions
in the Metro Plan, its Economic Element, supportil1g refinement plans (i.e., the SCLS and
MILS) to the Metro Plan, and Goal 9 and other applicable statewide planning goals.
On the basis of the record and arguments before you, we urge you to support the Staff
. recommendation and forw:lrd to the City Council your recommendation approving the
pending applications.
Pnilip Farringt n,. .ICP
Director, Land Use Planning & Development
PeaceHealth Oregon Region
cc: Jim Werfelmann
Andrew Head
S haun Hyland
5-120