HomeMy WebLinkAboutCorrespondence APPLICANT 3/28/2007
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Propei 'J 'Planning & Develop~ent
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March 28, 2007
11 PeaceHealth
David Reesor,Planner II
City of Springfield
. Development Services Department
225 Fifth Street
Springfield, OR 97477
. Date ReceiVed:.~.l1.Q)6 7
Planner: DR
Re: Plan Amendment (LRP2007-00013), Zone Change (ZON2007-00012)
Mr. Reesor,
The following and attached is supplemental information for the above-referenced
applications for proposed Metro Plan diagram amendment and zone change in east
Springfield,
The proposal seeks to redesignate and rezone approximately 5,24 acres on two parcels
from Light-Medium Industrial (LMI) to OJmmercial. As noted in the application
findings submitted last week, the Springfield Commercial Lands Study demonstrates that
the City has a deficiency in needed conimercially designat~d and zoned land, so
approving the proposal would help reduce the identified deficit in that land use category.
(
The Metropolitan Industrial Lands Study (July 1993) was adopted by the local
jurisdictions and acknowledged by LCDCas being consistent with statewide planning
goals and the Metro P'lan, specifically 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 1,172 acres." (pg. 73) The Inventory Report also stated: "The 1,688
constraint-free acres may be the best suited to meet short-term industrial demand. This
portion of the' supply also exceeds the twenty year demand'projection."
The City performed subsequent analysis of industrial land 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.
Staff s GoalS work also calculated the changes in industrial land 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) 335-2593
Fax: (541) 335-2595
RiverBend Annex 123 International Way Springfiefd. OR 97477
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suggesting that there is still an ample supply of available industrial lands to meet existing
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 was added to the inventory ofLMI
zoned and designated land due to City Council approval in April 1997 for land east of the
28th/31st 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 enough acreage to the inventory ofLMI designated and zoned land to
off-set the proposal to remove only about? 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 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 apIllications 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 notice to DLCD for my files.
Thanks for your consideration of the above. If you need additional information, please
contact me at your convenience.
.
:~&: ~
Director, Land Use Planning & Development
PeaceHealth Oregon Region
Attachments
Date Received: :1 J16/ 07
Planner: DR I '
. A TT ACHMENT A
11.0 Impact of the Proposed P~otections on Buildable Land
Inventories
This section estimates the impact of the recommended program for protecting
Springfield's resource areas on the inventory of buildable residential, commercial and
industrial land. The administrative rule 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 sumlus of buildable land that was determined at the adoption of
the inventory. Case law supports subtracting the protected acreage from the surplus of
buildable land.
Tables I 1 -I, 11-2, and I I -3 below summanze the amount ofIand 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. Analysis of Maximum Possible Impact on Supply of Residential
Lands within the Eugene-Springfield Metropolitan Area
I Residential Land Supply
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
Sprinefield Goal 5 Protection Measures
Remaining Surplus
-14.18
1265.12
or
193.12 .
Date Received'
Planner: DR .
3(;)j)0/
J
Table 11-2. Analysis of Maximum Possible Impact on Supply of
Commercial Lands within the Springfield Urban Growth Boundary
I Commercial Land Supply
I 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
GoalS Protection Measures
I Remaining Surplus (Deficit)
Acres
-158 acres
-2.8 acres
-11.56 acres
( -172.36 acres)
Table 11-3. Analysis of Maximum Possible Impact on Supply of Industrial
Lands within the Eugene-Springfield Metropolitan Area
I Industrial Land Supply
Metropolitan Industrial Lands Inventory Report Surplus Acres
Low Demand Assumption
or
High Demand Assumption
Acres Removed from Industrial Designation by Previous Plan
Amendments*
Eugene
Springfield
Acres
2954.28
or
2432.28
Total
Maximum Possible Industrial Acres Impacted by Eugene Goal 5
Protection Measures
-642.30
-90.80
-732.80
-44.73
Maximum Possible Industrial Acres Impacted by Springfield
Goal 5 Protection Measures
Remaining Surplus
-54.43
2122.01
or
1600.01
* 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 inventrry. The list of constraints included:
. Floodways' Date Received: 8/:2t1 rJ7
, Planner: DR )
o Wetlands listed on the Springfield Local Wetlands Inventory larger than .25
acres;
o Land within the easement of230 KV power lines;
o Land within 75 feet of a Class A stream or pond;
o Land within 50 feet of a Class B stream or pond; and
o 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 is assumed that protecting these wetland
sites from conflicting residential development will 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.
Wetland Setbacks
As noted in Table 11-4 below, about 9.95 acres of low-density residential (LDR) and.59
acres of medium density residential (MDR) land will be removed from the residential.
lands inventory 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 facilities within the recommended
setbacks and that subdivision design cannot arrange for the yard 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 setbacks will also result in the
removal of vacant acreage from the inventory of buildable residential lands. As noted in
Table II -4, about 3.42 acres oflow-density residential (LDR) and ,22 acres of medium
density residential (MDR) land will be removed from the residential lands inventory 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.
The combined impact of the proposed 25-foot setbacks for wetlands and riparian areas is
14.18 acres, This represents .45% of the 3,087 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 development through 2003. The report estimated
that at the end of 2003 there was 1,361 acres ofremaining buildable residential land in
Springfield. The amount ofland removed from the buildable inventory by the 25-foot
wetland and riparian setbacks proposed bX this report represents about 1 % of remaining
1,361 acres. / j
Date Received: -6 <)/(;67
Planner: DR .
Table 11-4. Vacant Residential Land within Proposed Protection Setbacks
Setback Distance Vacant Vacant Total Acres
LDR MDR
Acres Acres
I Wetland Setbacks I
I 25 foot 9.95 .59 10.54 I
I 50 foot 9.4 2.73 12.13 I
I 75 foot 4.97 4.15 9.12 I
I Total 24.32 7.47 31.79 I
I Riparian Setbacks I
I 25 foot 3.42 22 3.64/
I 50 foot 6.06 2.73 8.79
I 75 foot 4.97 4.15 9.12
I Total 14.45 7.1 21.55
I Grand Total 38.77 14.57 53.34
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 inadequate access;
Hydric soils;
Unstable soils;
Willamette Greenway and Greenway setbacks;
Floodwayand 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 PlartlZone conflicts.
The Commercial Lands Study classified sites on the on the Springfield 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 which 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.
Date Received; 3/0 () I/)7
Planner; DR ~
Since the Springfield Commercial Lands Study did not remove wetlands and riparian
sites, protection measures proposed by this study will have an impact on the inventoried
acreage of vacant commercial lands. The development setbacks recommended for
significant wetland and riparian sites will further reduce the inventoried acreage of vacant
buildable commercial land 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 15,8 acre deficit of buildable commercial land.
Wetland hnpacts
Table 11-5 shows that .07 acres of vacant commercial land would be removed from the
Commercial Lands Inventory if wetland sites zoned for commercial development were
fully protected. The 25- foot wetland setback recommended by this study would remove
an additional 1.47 acres of vacant commercial land from development. This figure
assumes that the developer is unable to locate required stormwater facilities or required
landscaping within the recommended setbacks, thus reducing or eliminating lost
. development area.
The total impact on the Commercial Lands Inventory would be a reduction of 1,54 acres
if wetland sites and their setbacks were fully protected.
Riparian Site hnpacts
Table 11-5 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 commercial land will be removed from the inventory by the
proposed 25-foot setbacks.
The total impact on the Commercial Lands Inventory would be a reduction of I .54 acres
if wetland and riparian sites and their setbacks were fully 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 District Site
Acreaee
I Wetlands
I Community
125 ft.
Setback
I
1 .07 1 1.47 I
Date ReceiVed:,J..! ~p I {J 7
Planner: DR .
150 ft.
Setback
I
175 ft.
Setback
I
,11 1
I Total
Acres
I
01
I
1
1.65 I
I Zoning District Site 25 ft. 50 ft. 75 ft. Total
Acreae;e Setback Setback Setback Acres
1 Commercial
I Neighborhood 0 01 0 01 0
Commercial
1 General Office 0 01 0 01 0
I Major Retail I 0 01 0 01 0
Commercial
1 Wetland Total 0.071 1.471 0.11 01 1.65
I Riparian Areas I I I
I Community 2.781 01 0 2.61 5.38
Commercial
I Neighborhood 01 01 0 01 0
Commercial
General Office 01 01 0 01 0
Major Retail 01 01 :24 01 .241
Commercial
Riparian Total 2.781 01 0.24 2.6 1 5.621
Grand Total 1 2.851 1.471 .35 2.6 1 7.271
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 inventory,
For that reason, protection of wetland and riparian lands under the policies proposed by
this study will reduce the inventory of buildable industrial lands. The extent of this
impact is discussed below.
Wetland Impacts
GIS analysis shows that about 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 wetlands are recommended for protection by a 25-
foot development setback under the Springfield natural Resources Study. These setbacks
add another 6.82 acres to the amount of industrial zoned land that would be removed
from 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 37.46 acres. Table 11-6 shows the total acreage for land
affected by wetlands and the acreage protected by setbacks from both this program and
the existing SQM program.
Date ReceiVed: 3) :;{[j JIJ7
Planner: DR ~ ,...
Riparian Impacts
GIS analysis shows that 13.70 acres of vacant industrial land are affected by riparian
areas are that not already protected by the Springfield Stormwater 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 of industrial zoned land that would be removed from 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 I I -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
The total impact on the Industrial Lands Inventory 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 % of the 709 acres of buildable industrial land for
Springfield in the Industrial Lands Study.
Table 11-6. Vacant Industrial Land within Proposed Protection Setbacks
Zoning
District
Total
Wetland
Site
Acreage
Site
Acres not
Protected
by SQM
I Wetlands
Light-
Medium
Industrial
1 Heavy
Industrial
Campus
Industrial
Special
Heavy
Industrial
I Quarry
Mining
I ~th Kelly
I Wetland I
Total
Riparian Total Site
Areas Riparian Acres not
Site Protected
Acreage by SQM
Date Received:
Planner: DR
28.20
(27,76)
13.16/
.351
o
(2.88)
o
.13
41.84
(30.64)
25 ft.
Setback
50 ft.
Setback
75 ft.
Setback
4.81
.82
o
2.01 I
01
o
o
J9.15
1.28
o
o
o
o
o
o
.47
6.82
21.72
25 ft.
Setback
50 ft.
Setback
75 ft.
Setback
I 1
jj.9Jj I oj
,
Total
Acres
o
33.83
o
34.321
1.63
o
o
o
o
01
0.60
o
o
70.38
Total
Acres
Zoning Total Site 25 ft. 50 ft. 75 ft. Total
District Wetland Acres not Setback Setback Setback Acres
Site Protected
Acreaj!e by SQM
Light- 16.48 (10,89) 2.05 4.72 L26 24.51
Medium
Industrial
I Heavy 68.31 1 (2.81) L22 8.93 0 78.461
Industrial
1 Campus 3.221 0 0 2.83 .03 6.081
Industrial
Special 0 0 0 0 0 0
Heavy
Industrial
1 Quarry 01 0 0 0 01 01
Mining
1 ~th Kelly .21 0 0 .82 01 1.031
1 Riparian 88.22 (13. 70) 3.27 17.3 1.291 110.081
Total
I Grand Total 130.06 (44.34) 10.09 39.02 1.29 I 180.46 I
Date Received'
Planner: DR
3/~;;1{j/
.' .. ':" ':
Metro Plan Dia!lram Ch""ges Affecting the Suoolv of Residential, Commercial and Industrial Land
Chan!les in Metro Plan Desirnations
NC CI ILMI IHI Ipos G&E NR AG
lIIIliIillli l1li11\1
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1
1
ILocal File Number
190-04-058
190-12-201
192-04-77
193-01-33
193-01-12
193-06-087
194-10-0194
195-02-036
195-02-036
195-02-036
a) 195-02-036
~195-02-036
~ 195-08-0157
, __ 197-05-101
~ 199-02-038
'J 199-02-041
199-09-230
102-03"0062
102-03-0063
102-07 -200
102-08-243
ILRP-2002-12431
1 LRP-2004-00031
ILRP-2005-00015
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0.0
0.0
3.0
0.9
5.3
0.5
3.7
-3.7
6.5
9.2
72.0
18.0
16.5
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LOR Low Density Residential
MeR Medium Density Residential
CC Commercial Center
NC Neighborhood Commercial
CI Campus Industrial
LMI Light Medium Industrial
HI Heavy Industrial
POS Public Open Space
G&E Government and Education
NR Natural Resource
AG Agriculture
MU Mixed Use