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Home My WebLink AboutCorrespondence Miscellaneous 6/12/2007 GOAL ONE COALITION .'~ i.~ ~...'\~ . Goal One is Citizen Involvement City of Springfield Planning Commission David Reesor City of Springfield 225 Fifth Street . Springfield, OR 97444 Date Received' Planner: DR' ~( vL-fOl (YN-L~ RECEIVED- JUN 1 2 2007 BY: j/;':::' June 12,2007 RE: ZON 2007.()00121LRP 2007.()0013, Plan Amendment & Zone Change Dear Members of the Commission: (', .' . 'The Goal One C6alition (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 the request of and on behalf of its membership residing in Lane County. This testimony is presented on behalf of Goal One and its membership, including Nancy Falk, 2567 Marcola Road, Springfield Oregon 97477, as an individual. I. Introduction This proposal is for a site-specific Metro PlanAmendment( Refinement Plan Amendment and a concurrent Zoning Map Amendment from Light Medium Industrial (LMI) to, Community Commercial (CC) within the Springfield city limits. . The subject site is located near 44th and Main Street (Highway 126). The site cOnsists of two parcels under separate 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, includiAil portable trailer type structures. The smaller of the. two subject lots, TL 402 (.24 acres), has an existing commercial development on-site, although the plan designation and zone are LMI. 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. Property located east and adjacent to TL #402 is built out as a business park, and, designated LMI. T wp".l;es located south of the subject site,across Main Street, are zoned and designated Community 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 I 97.1 75(2)(a). Applicable goals include Goal 1, Citizen Involvement, Goal 2, Land Use Planning; Goal 9, Economy of the State; and Goal 12, Transportation. The Eugene office:' 642 Chamelton Suite 100. Eugene OR 97401 . 541-431-7059' Fax 541-431-7078 Lebanon office: 39625 A1men Drive' Lebanon OR 97355 . 541-258-6074 . Fax 541-258-6810 wwW.goaI1.org GOAL ONE COALITION proposed plan amendment must also coll)ply with administrative rules implementing applicable statewide planning goals: '" III. Analysis COMPREHENSIVE PLAN CONSISTENCY AND COMPLIANCE WITH STATEWIDE GOALS " All comprehensive plan amendments"'are-revi~~~lri'il):?fO'r'j60mpliance with the statewide .. .. Oar" '~I=jr.(1(.W.' planrung goals. Residents ofRosemont v. Metro, ~173 or lXpp 321 (2001); 1000 Friends of Oregon v. Jackson County, 79 Or App 93, 97, 718 P2d 753 (1986), rev den 301 Or 445 (1987); Opus Development Corp. v. City of Eugene, 141 Or App 249, 254, 918P2d 116 (1996). . Goal 2 - Land Use Planning is: "To establish a land use planning process and policy framework as a basis for all decisions and actions related to use of land and to assure an . adequate factUal base for decisions and actions." Specifically, local land use actions "shall be consistent with the comprehensive plans." Goal 2, Part L . Further, the infoI1Jlation upon which land use decisions are made "shall be contained in the plan document or supporting documents." Goal I, Part L In this case, the applicant relies heavily on the acknowledged 2000 Sprillgfield Cominercial Lands Study (SCLS), which does not address the :entire Metro UGB area, and is not a refinement plan of the Metro Plan. It is the, 1992 Metropolitan Industrial Lands Study, that does address the entire Metro UGB area, is part of the Metro Plan, and is reflected in the Economic Element of the Plan, : 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 rather 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 iI].v!lntories pursuant to Ordinance #6 I 50 that adopted the Springfield NatUral.Resource StUdy, staff's position is that inventories established pursuant to GoalS are relevant considerations in considering availability of commercial and industrial land. However, that analysis (applicant's Attachment "A" - tables 11-1, 11-2 .and 11-3) actUally show little or no impact on the commercial. lands inventory from GoalS protection measures, and provide little if any analyses of land availability within the entire Metro UGB area, rather than just the Springfield UGB area. Table 11-2, Analysis of Maximum Possible Impact 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) commerciaUand supply. ' .' . , Metro Plan/East Main Refinement Plan, ZON 2007-00012 - LRP 2007-00013 - 2 .~~~ ~:~~,fj-.. n;" GOAL ONE COALITION Additionally, the analysis pursuant to Ordinance #6 1'50 fails to account for lands ADDED TO . the commercial inventory since 2000,'including but not limited to the Gateway MDR site's 100 acres, provi~ing a skewed picture '?fthe.actual commercial land inventory: To skew the picture even further, the analysis of maximum possible iinpact 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 Springfield portion of the UGB,and does not pto\ide a breakdown of number of industrially zoned acres in Springfield vs. Eugene. The 2000 SC,"S, however (Table 3-2) shows that the number oflight medium industrial (LMI) acres by plan designation. 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 o{these tables to the current PAPA and zone change proposal, considering that orily 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 sta.te for a vll[iety of economic activities Vital to the health, welfare, and prosperity of Oregon's' citizens." .. . The Staff Report's Goal 9 findings arebas~ upon the 1992 Industrial.Land Study and the 2000 Commercial Land Study. Goal 2 requires that information upon which land n:;e 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 rylated 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-acknpwledgement plan amendment under OAR chapter 660, division 18, that changes the plan designation ofland in excess oftwo acres within an existing urban growth boundary from an industrial use designation. to a non-industrial use designation, 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 plan which address the requirements of this division; - ,. .. The applicant appears ,to rely hea\ily on inventory. and policy statements. 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 Metn)politan General Plan, Chapter III, B- I - B-7 is insufficient and does not address the most significant policies that must be considered. The proposal would decrease the City~s campus industrial land inventory by yet another 5.24 acres. The applicant has not justified the conversion of scarce, shovel ready industrial land, Metro Plan/East Main Refinement Plan, ZON 2007-00012 -LRP 2007-00013. 3 ." GOAL ONE COALITION. especially land designated and zoned light medium industrial inside the Metro UGB, even though Me\(:0 PI'!ll (comprehensive plan) EconOl:nic Elementpolicy #12 establishes that the cities are to "discourage future Metropolitan Area General Plan amendm,ents 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 inipactS the short-term supply ofLMI designated land. ' I -;;. The applicant makes the argument that the proposed plan amendment and zone change would have the effect ~f correcting exi~ting 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. It appears that the existing nonconforming uses were actually established AFTER adoption of the 2000 SCLS, indicating that tjie 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 Commercial 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 lIGB, 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 own 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 establis1\ Goal 9 compliance is that in analyzing supply and deinand, the study fails to consider or otherwise account for lands added to the commercialinventory",viaapplicant initiated and city approved zone changes and plan 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 of residential land to commercial: The applicant provides a spreadsheet (their Attachment B) that supposedly accounts for all Metro Plan diagram changes affecting the supply of residential, commercial and industrial Lands in the City of Springfield between 1991 and the present, but has failed to account for or otherwis( address the addition of cominercial land to the SCLS, even though.it is clear that more than I 00. acres of commercial land has been add~ to the inventory since the year 2000. This omission raises doubt as to the accuracy of applicant's Attachment B,in supposedly accounting 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 for all zoning classifications, the'analysis of maximum possible impact on supply of commercial lands pursuant to the 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 UGS area is necessary to establish an accurate pictUre of the supply of commercial lands. - Metro Plan/East Main Refinement Plan, ZON 2007.,Q0012,-lRP 2007.,Q0013 4 GOAL ONE COALITION ,'~- In any case, the NR Study found t)1at the maximum possible, impact of Goal 5 protection measures on the Springfield Commercial Lands Inventory would be the loss of 11.56 HcommerciaJ. acres~" ' LOSS OF INDUSTRIAL LAND 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 additional 56 a~e ,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 pro\ision of family wage jobs. The applicant has said nothing about the existence of their other 100 acre medical campus located within about ~ miles of the subject properties proposed for plan and zone changes. Given this fact, the applicant has not justified the removal of shovel ready light medium industrial land for commercial uses.' This area within the Springfield city limits is already inundated with coII1lllercial zoning and commercial uses, and approval of this proposal ',Vould contribute even further to over commercialization within the city of Springfield, The applicant cites 4 of the 32 Economic Element policies pursuant to the comprehensive plan (Metro Plan) (Chapter III, Section B) of the Plan as relevant to the proposed PAPA. The four Plan policies considered by the applicant. as relevant to the supply of industrial land are policies I, 2, 6, and I I' . 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@dard of living, and utilization of our. existing comparative advantage in the level. of education and skill of the resident labor force. However, 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 will in fact utilize local and imported capital, skills etc. as no commitment to a use has been established. Policy 6 merely states: "Increase the amount ofun.developed land zoned (emphasis added) for light industrial and commercial uses correlating the effective supply in terms of suitability and, availability with the projections of demalld.'~ This policy addresses zoning only, not plan designation, and concems the necessity of having adeqUate supplies of land of both commercial and industrial designations. It says nothing concerning the applicability offavoring one plan designation over the other. Metro Plan/Easl Main RefinementPlan, ZON 2007.{)0012. LRP 2007.{)0013 5 GOAL ONE COALITION Policy II is to encourage economic activities which strengthen the metropolitan area's position as a regional distribution, trade, health, and service center. The applicant asserts that the amendment (sic) will facilitrite the development ofmedicalu,ses 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 medical care 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 marketwithin the city liniits, it has hard to fathom why they think another 5.24 acres will somehow strengthen Springfield's position as a premier locale for healtheare services. , The PAPA proposal must be consistent with the Economic Element of the Comprehensive plan in it's entirety. A major omission found in the application and staff report is an analysis of alltheMetro Plan Economic Element policies other than the four addressed by the applicant, The remaining 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-Springfield Metro UGB area. . 5 - Provide existing industrial activities sufficient adjacent land for future expansion. . ' This Plan. provision is directly applicable because the subject properties. are currently zoned . and designated to take advantage oflight mediuni 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 Econoinic element, and if approved would have the effectoflimiting future growth and expansion of the existing campus industrial uses. 7 - Encourage industrial park development, including areas for warehousing and distributive in,dustries 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 acti\ities which are characterized by low levels of pollution and efficient energy use. Staffhas not discussed efforts to attract and/or encourage expansion of manufacturing acti\ities that could be sited on campus industrial.zoned and designated lands. The only reference to this issue from staff is that there hasn't been much interest in the site from the industrial development sector. 15 - Encourage compatibility between industrially zoned lands and adjacent areas in local planning program. Metro Plan/EaslMain Refinement Plan, ZON 2007-00012 - LRP 2007-00013: 6 GOAL ONE COALITION '\ Neighbors have expressed no concern about their quality oflife from existing industrial uses. The applicant has not addressed why or how the existing light medium industrial zoning and plan designation is inC<?mpatible with the adjacent neighborhood zoning and plan designation. , 16 - Utilize processes and local controls which enCourage retention oflarge parcels or consolidation of small parcels of industrially or commercially zoned lan~ to facilitate their use or reuse in a comprehensive rather than piecemeal ~ashion. The subject properties are adjacent to a large parcel which is zoned and designated LMI. Staff is directed by this policy to encOurage retention of this parcel of industrially zoned and . 'designated land, which is one of the few remaining parcels ofLMI land within the Springfield city limits, . 21 - Reserve several areas within the UGB for large scale, campus typeJight ma!}ufacturing uses. Staff has failed 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 appro\ing land use cOde amendments to the campus industrial zone that established more 'flexibility' for what uses are allowed in the city's campus industrial zones. ' . 28 - Recognize the vital role of neighborhood commercial facilities in providing services and goods to a particular neighborhood. . This P AI> A proposal requests community commercial plan designation and zoning yet has not considered or otherwise addressed the applicability of neighborhood commercial zoning vs. the requested community commercial zoning. Staff and applicant have not addressed the applicability of community commercial zoning within a node, or explained why neighborhood commercial zoning is being ignored for higher intensifY uses in this existing neighborhood. , All the Metro Plan Economic Element policies are applicable to this application, and should have been addressed by the applicant. Ill. Conclusion The proposed plan amendment is not logical and harmonious with the land use pattern for the greater area. The proposed change is not "logical and harmonious" because it is not consistent with the development pattern envisioned in the Metro Plan. As explained above, the proposed amendment is inconsistent with the intent of the Economic Element of the Metro Plan, and does not comply with Metro Plan policies. Therefore it cannot be found to be compatible with these Plans, ' ~ 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. ' Metro Plan/East Main Refinement Plan, ZON 2007-00012 - LRP 2007-00013 7 , GOAL ONE COALITION The requested plan aIlJendment does not. comply with policies of the Metro Plan and Metr9Politan 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 2007~0012,- LRP 2007~0013 " . l I 8