HomeMy WebLinkAboutOrdinance CMO 7/16/2007
ORDINANCE NO. 6201
(General)
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).
, THE COMMON COUNCIL OF THE CITY OF SPRINGFIELD FINDS THAT:
1. Article 12 of the Springfield Development Code sets forth procedures for Springfield
Zoning Map amendments; and
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2. . On March 161h, 2007 the appiicant/<;>wner 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 ZON20,07-000l2, for propeliy identified as Lane County As-
sessor's Map 17-02-32-00, Tax lots 400 and 402; and
3, ' Oil June 41", 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 \Yritten 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"", 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 Springfield Zoning .
Map.
NOW THEREFORE, bascd upon the foregoing findings the City of Springfield ordains
as follows: .
Section ]. 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 Coinmunity Commercial.
Section 2. If any section, subsection, sentence, clause, phrase, or portion bf this Ordi-
nance is for any reason held invalid or unconstitutional by any court of competent juris-
diction, that portion shall be deemed.a separate, distinct, a~d independent provision and '
. thai holdinwshall 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-
I plicable Statewide Planning Goals, and is attached as Exhibit A. '
Date Received; 1 II (0 I rn ' , . .
Planner: DR ~9 ORDINANCE NO 6201
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ADOPTED by the Comlllon Council oftheCity of Springfield this ] 6th day of
July, 2007 by a vote of ~for and ~ against.
APPROVED by'the Mayor of the City of Springfield this16thday of
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July
Mayor, !
ATTEST:
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. City Recorded, ~
REVIEWED 8, APPROVED
.~ TO FORM '\' .
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DATE: -'~"l. 7'6~rTJ
OFFICE OF CITY ATTORNEY
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,ORDINANCE NO. 6201'
PAGE 2 OF 2
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Type'lI Metro Pliin Map Amef19rnent:.
& Zoning MapAmendment,;. ...,'
Staff ReRort and Findings
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Hearing Date: '.
June 41n, 2007 -Planning
Commissio'n'
June 18111, 2007 -.'
Planning Commission
july 2nd, 2007 - City
Council, ' . "
'Aoolicant
Case Number:
ZON 2007-00012 .
LRP 2007-00013
Owner
, Aoolicant's'
Representative" ,:' ."
Philip Farrington,AICP'
, ,Director, Land use ,.
. Planning & Development
Peace Health Oregon
,Region ,',
. 123 International Way
, Springfield, OR 97477
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PeaceH~alth Oregon Region,
,1'23 International Way
Springfield, OR 97477.' . ,
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Hyland BUSiness Park, LLC (TL 400) .
Attn:Stiaun Hyland
,1941 - A Laura Street
Springfield, OR 97477 ,
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Andrew Head (TL 402) ,
1616 Ardendale Ln.
Eugene, OR 97405
Date Submitted: M.arch 16th, 2007
EXECUTiVE SUMMARY:
The applicant is seeking approval ora Metro Pian Amendment I Refinement Plan ·
Amendment and a concurrent Zoning Map Amendment from Light Me'dium 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 ifno new Refinement Plan ,text is:'needed or proposed. The
applicant is requesting these amendments in order to pursue 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 44111 and Maih Street (Highway 126). The sit~. 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 of the site 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 '
mixed-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
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LRP2007-0001J & lON2007-000/2
ATTACHMENT
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COrllmercialLands Study, there is a shortfall otcommerciallands within city limits. The
1992 Industrial Land Inventory and the City's adopted Goal 5 analysis support the fact '
that there is a s'urplus of industrial land in the Metro area. The Metro Plan allows ,
'amendments'such as that which is proposed to allow City's to modify land use patterns
as dema.nd and the community's vision change over time: The proposed Metro Plan
Amendment is a Type II Amendment, meaning it is, site specific and is located within the
city limits. ' ' '
In order to approve these applications, the applicant must.d~monstrate compliance with,
the Statewide Planning Goals, Metro Pla'n, Oregon Administrative.Rul'es, State Statutes'
and demonstrate the ability to. service the site with adequate public facilities and' '
',' services.' ' . " ' .'
This Staff Report provides findings of fact relevani to each of the applicable c~iteria of
approval. and recpmmendations to the Planning Cornmission. 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 Metro Plan /
Refinement Plan Amendment and concurrent Zoning Map Amendment from LMI to CC
is appropriate for the subject property and recommends the Planning Commission
approve the attached Order and forward the proposaltothe City Council with a,"
recommendation for aaoption. ' '
REQUEST: . ' " .
The applicant is requesting approval to change the map designation on the Metropolitan.
Area General Plan ("Metro Plan") diagram from Light Medium Industrial (LMI) to .'
Commercial for approximately 5.24 acres located near Main Street and 44th Street.. A
Metro Plan Amendment at this time (not during Periodic Review) is known as a Post
Acknowledgement Plan Amen'dments (PAPA). This .same acreage on the site is being'
proposed for a concurrent amendment to the Springfield zoning map from LMI to
Community Commercial (CC), as allowed in Springfield Development Code (SDC)
12.020 (1)(a)1 ' ;
Pursuant to SD(;7.11O'(4); approval oithe requested Metro Pla~ diagram amendm~nt
automatically amends the refinement plan diagram ,and is processed concurrently.
Findings of fact addressing the criteria of approval in SDC 7 .070(3) are included in the
, applicant's narrative 'statement and in this report.. '
SITE. DESCRIPTION:
The subject site is located on approximately 5.24 acres identifiedasTax Lots 400 and
402 on Assessor's ~ap No. 17-02-32-00.
The s~bject properties include a vacant, flat parcel (Tax Lot400) and eXisting ,,' .'
'commer,cial development (Tax Lot 402) east of 44th Streetalong Main Street in east
Springfie'ld.' The site is bordered on the south by Main Street, on 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
o,ther small-scale commercial 'enterprises (e.g., a cabinet shop and karate school)',
'fronting Main Street and residential homes along 44th Street west of Tax Lot400
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lRP2007,OOOlJ & ZON1007.00012 --
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. Commercial 'enterprises are located immediately south of the site across Main Street'
(e.g,; Gray's Garden Center). . . . . .
. While historically'iilVolved in agricultural uses, since around 1990 Tax Lot 400 w~s us~d
, 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 c9ncrete form plywood. Tax Lot 402 has had various
commercial seriticeson site since the 1950s. \,
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.The properties have no jurisdictional 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 ~o the east is designated Light/Mediurri 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 in the EMRP, and
are all zoned Commullity Commercial. Property to the west of Tax Lot 400 along 44'h
, Street is zoned and designated Medium Density Residential. .
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Metro Plan Designation .
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D Lo\Y Den, Res.
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E~isting Site Conditions:
Existing commercial uses on TL 402
'. Existing .empty structures on TL 400
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Existing modular units located on TL 400
Existing business park on pro perry located east of TL
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LRP2007-000/3 & ZON2007-000/2
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. . REVIEW PROCESS:
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The proposed Metro Plan Amendment is aType II Amendment because it i~ located .-.
inside the city limits and is site specific. The applicant has requested that application
ZON2007-00012 (Zoning Map Amendment) be raised to a Type IV review procedure'
and be reviewed concurrently with.the Type II Metr.o Plan I Refinement Plan Amendme'nt '
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'corisistency with the Metro Plan,and other similar criteria. Rather than
repeat these criteria for each application, they will be addressed only once 'and then.
referenced where appropriate. Criteria that are different will be addressed separately; ,
the end result will be that.all applicable criteria will have'been addressed. .
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This application'was s~bmitted to the Development,S~rvices Department on March .16th:'
2007, and dei~med as complete on April 11th, 2007. Notice for both applications was' '" '.
mailed to Department of Land Con~ervation and Development (DLCD) on April 16th,
2007. Notice of the public hearing date was mailed out on Thu-rsday, April 19, 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 Guaidjon May 17'h,)007, as required in SeC,tion 14.030 (2) of the SDC.No
, written comments were submitted atthe time of iss'uing this report, ' -
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METRO PLAN DESIGNA nON:
The subject property is designated LMI.. as shown in ~he' Metro Plan diagram. The
subject property is part of the East Main Refinement Plan (EMRP), :which provides a
more localized scope related to Plan Designaticin,.The subject property is designated
LMI on the Refinement Plan Diagram. $pecific Findings related to. the Metro Plan and
EMRP Street' Refinement Plan Designation are written in this report, ' ,:',
METRO PLAN DIAGRAM AMENDMENT
CRITERIA OF A,PPROVAL -SDC7.Q70(3}(a)-(b).
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"The following criteria s'hail beapplied'bythe 9iiy 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 LaQd Conservation and Development
Commission; and . .
(b) Adoption of the amendment must not make the Metro Plan internally
, inconsistent:" ' " '~,' !' ' . , '. .,' . ,
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. C.RITERIA'OF APPROVAL ~ SDC 7.070 (3)(a)
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. APPLICANT'S NARRATIVE:
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Consistency with Statewide Planning Goals: '
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lRPZOOY,OOOl3 & ZONZOOY-OOOIZ'
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The followi~g findings address compliance with Metro Plan criteria in SOC 7.070 (3)(a).
'Approval of a Metro Plan diagrani, amendment also,correspondingly changes the '
applicable refinement plan diagram, as established in SOC 7.110 (4). .
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APPLICANT'S NARRATIVE RELATED TQ GOAL 1:
"Goal 1'~ Citizenlnvolvement: To develop a citizen in;~/vem~nt p-'~gram that insures'
the opportunity for citizens to be invo/~ed in all phllses of the planning process.
Goal1 addresses the need to develop a citizen involvement 'progran'- 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, citiz'ens 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. Noti.ce of the public hearings will also be .'
given in accordance with SOC requirements to ne'arliy property owners, interested parties
requesting notice, and any es\ablished neighborhood organization. Since the ,
amendments comply with the City's citizen involvement. program ,,'nd citizens have :
opportunities to be involved in the procedure, the proposed amendments are consistent
INith Goal 1. ' .'
STAFF'S FIr:mINGS RELATED 1:0 COMPLIANCE WITH GOAL 1 :
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Finding 1: These applications comply with Goal 1 because they are 'being 'reviewed
under an acknowledged citizen involvement program.
As previously mentioned in this report, notice for both applications' was mailed to
Department of Land Conservation and Development (OLCO) on April 161h, 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 SOC public notice of the hearing was published in the local newspaper
. (Register Guard) on May 17th, 2007, as required..in Section ,14.030 (2) of the SOC. '.
Staff concurs with the applicant's written statement related to Goal 1.
APPLlCA'NT'SNARRATIVE RELATED TO GOAL 2:
'" Goal 2: land Use Planning: To establish a land use ptanning proce~s 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. Go'al i also requires that land
use decisions be coordina'ted with affected jurisdictions and that-they be supported by
an adequate factua(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 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 Oepartmentof Land Conservation' and
Development, ensuring that they are given opportunity for,comment and review
conformity to applicable statewide planning goals. '
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'LRP2.o07.000 13 & ZON2007,OOO/2
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The Metro Plan and theSDC, as well a,,?'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 ~mendmentssatisfy the' ,
consistency element of Goal 2.. ,.'
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STAFF'S FINDINGS'RELATED TO COMPLlANCEWIIH GOA'i..2: .
Finding' 2: These applications comply with Goal 2 because theSDC ;equires '
consistency between the Statewide Planning Goals, the acknowledged Metro Plan,
adopted refinement plans, and special' area plans and the zoning. .
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Staff con'~urs with the applicant's ~ritten statement rel~ted to'Goal 2. . . '
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APPLICANT'S NARRATIVE RELATED TO GOAL 3:' ". .
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,Goal3 -Ag;iF'iltural Lafld: To preserve and maintai'; agricultural lands.
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This goal is in~pplicable because ~s provided in OAR 660-15-000(3); 'Goal3 applies only to
rural, agricultural lands. The subject properties ar~ located within an acknowledged urban
growth boundary, are inside Springfield's corporate limits, and hav'e nQt been in
agricultural use for decades. . , .
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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 orwithin 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:..
Goal.4.,. Forest Land: To conserve forestlands by maintaining the forestland base
and to protect the state's forest economy by making possible economically efficient
. -forest practices that assure the c,?ntinuous growing and harvesting of forest tree .
species as the le~ding use on forest land consistent with sound management of soil,
, air, water, and fi~h and wildlife resources and to provide for recreational opportunities,
.'and'agriculture.' ' .
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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 ac.knowledged UGB.
STAFF'S FIN[)INGS RELATED TO COMPLIANCE WITH GOAL 4:
Finding 5: 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 related to Goal 4. ,I
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lRP2007,00013 & ZON2007,OOO/2.
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, APPLICANT'S NARRATIVE RELATED TO GOAL 5:
Goa/ 5 _ Open Spaces, 'Scenic and Histo~ic Ar~a; and Natur~/ Resources: To conse;"e
. ope0 space and protect natura/ and scenic resources. '
GoalS requires local governments to protect a variety of open space; scenic, historic, and
',natur'al resource values. GoalS 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, q'uaritity, and location; , c,
(3) identify conflicting uses; ,
(4), examine the economic, social, environmental, and energy (ESEE)
consequences thatcould result fro'm allowi.ng, limiting, or prohibiting
the conflicting uses; and . '. ' ' . ,'. -.
(5).. develop programs to resolve th.e conflicts. . '
The subject properties are not on Springfield's acknowledged Metro Plan GoalS inventory.
,No threatened or endangered species have been)nventoried on tlie 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 y!etlands located on the site. Therefore, the
proposed amendment does not alter the City's compliance with Goai 5.
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STAFF'S FIN'DINGS RELATED TO COMPLIANCE WITH GOAL 5:
Finding 6: Goal 5 does not apply to these appiications because there are no
inventorie'd resources on the subject property. Oregon Administrative Rule 660-023-
0250 establishes the applicability of Goal 5 rules to Post Acknowledgement Plan
Amendments (PAPA). the requested Refinement PlanAmendment and Zoning Map
'Amendment do not affect the Metro Plan's adopted Goal 5 inventory, Staff concurs
, 'with the applicant's narrative related toGoal 5 compliance.
APPLICANT'S NARRATIVE RELATED TO GOAL6:
Goal 6 _ Air, Water and Land Resources Qualiiy: To maintaiil 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 expect that applicable state and federal environmen.tal quality .
standards can be met. .
Tho'ugh 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 10cy) 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 deve1o'pment on the site
will be able to demonstrate compliance with City standards for water quality protection
LRP2007,OOOIJ & ZON2007.00012
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,through the site plan review process, thereby complying with applicable state and federal, '
environmental quality standards.;" ,:' . ',', '.' "'" '... .", '. .' "
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ST AFF'.S FINDINGS RELATED TO COMPLlANCEWITH GOAL 6:
Finding 7: The ~Jroposed Metro Plan I.RefinemenfPlan Amendment or Zoning Map'
Amendment does not modify any of the Goal 5 related policies of the Metro Plan, nor'
do they amend the Regional Transportation Plan, the Springfield Development Code'
other applicable Goal 5 policies, or any regulations imple'menting those policies. '
Th~ subject property is located in the Zone of Contributi6nand outside a'ny of the
" Time of Travel Zones, which is regulated by the Drinking Water Protection Overlay
District.:. Article !7 Any new development onthe,subjectproperty is subject to
compliance with Article 17 and other applicable,regulations related to Goal 5.. Staff
concurs with the applicant's narrative related tei Goal 5' compliance
.' . ' _:~ ~. ;"... . o' .::
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APPLICANT'S NARRATIVE RELATED TO GOAL 7:
"
Goal 7 _ Areas Subject to Natural Disasters arid Haz~rd~: To prated /ife and property
from natura(disa~ters and hazards. :,,' '. .' ,--....' .
. . . '
Goal7 requires that development subjectlodamage from natural hazards and'
, disasters be planned and/orconstructed with appropriate safeguards and mitigation: '.
The goal also requires that plans be based on an inventory of'known areas of natural
disaster and hazards, such as areas prone to landslides, flooding, etc.'
. ~', '
. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 7:
Finding 8: Slaff has' reviewed the natural constraints map and the 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 applicanFs narrative related to Goa(T compliance: "
The site is flat and not subject to landslide hazards, and is located well' outside of any
established FEMA flooo 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. '
.. .01 .
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APPLICANT'S NARRATIVE RELATED TO GOAL 8:
. I.
Goal B _ Reaea'tion Needs: To satisfy. the recreationa/needs of the citizens ofthe state
and visitors and, where appropriate, to provide for the siting of necessary recreational
facilities including destination resorts;' "
Goal Brequires local governments to plan andprovide 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 induded in an inventory of recreational sites',
and the proposeda'mendments will not have an impact on the community's recreatian'al
facilities or needs; therefore, the proposal does not implic,ate Goal B.
I
. ,LRP2007,OOO 13, & ZON2007-00011
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STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 8:
. :Finding 9: Staff has consulted theWillamafane 20-year Parks a~d Recreation
ComprehensivePfan in relation to Goal 8 compliance. The Wi/lamalane 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 thevarious'studies, ',,'
inventories, and fa.cilities plans regarding. recreational facilities in tl:1e adopted .
Wi/lamalane 20--year Parks andRecreation Comprehensive Plan have designated
the subject site forparks 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,' , ,
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APPLICANT'S NARRATivE RELATED TO GOAL 9:
Goal 9 -Economic Development: To provide adequa!e opportunities throughout the'
, state for a variety of economic activities vital to tne health, welfare, and prosperity of
Oregon's citizens. ' ' . '
Goal9 requires the city to provide adequate opportunities for a variety of economic
activities vital tothe 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 consistentwith commercial
zoning is consistent with numerous policies in the,Clty's adopted plan.for compliance with
Goal 9, the Springfield Commercial Lands Study (SCLS). ' .
c
Specifically, ~he following SCLSpolicies are applicable to th~ proposal:
, ~ , ,~ .
Policy'1-A: "Maintain a mixed supply of large and small commercial sites through .
strategies such as rezoning or annexation to serve Sprirgfield's future populati~n:'
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 maintaining. existing employment and commercial use
in Tax Lot 402 and providing the' ability for growth in,medical sector employment by
, allo"(ing 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 (UGB) t~at 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
support existing commercial development on Tax Lot 402, and future development, on Tax
Lot 400. The SCLSidentifies (pg. 33) a need to support "employment in population-
dependent sectors such as retail sales and health,services" to meet 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 services sectors. Approving the proposed
redesignation and.zone change would,help meet Springfield's demonstrated need for
, employment and commercial services: ' . ," ' '
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LRP2007,OOOI] & ZQN200 7-000 I 1
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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 Are'a." :Thereforeithe
proposed'redesignation (and corresponding rezoning) would not result in a deficit of ,
needed industrially designated and zoned land, but if would help reduce.thecommercial
lal)ds deficit, identified in,theSCLS. Therefore, 'approving the proposal would be " ,
consistent with SL~S implementation Strategy 3-A (1): "Ev'aluate inventories based' on
demonstrated need for the planning 'period. Initiate rezoning or redesignation of s'urplus
land uses where more appropriate for commercial, consistent with the Metro Plan.'''
The proposal in fact consistentwith inventories for c'()mmer.cial 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 (OAR660-009-0010(4))
cali for amendments to land use designations "in excess o/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., SCLSror be,consistent.with an' . '. . ..
e"onomic opportunities analysis. The City--can find that the, proposal complies with.
relevant local plan policies by converting one form or employment-generating land us'e to'
another, without negatively impacting the supply of buildable lands for either category of
uses. The proposal enables continued use of the existing a'nd long-standing, commercial
center to continue to oper~te and provide employment opportunities, whiie also allowing'
higher-value employment associated with future development' on' Tax Lot 400. These
. types of employmentcgeneiating uses are arQ,Ong those identified in OAR 660-009-0005(6),'
as eligible non-industrial employ'ment activities that can justify' approval of the proposed
Plan diagram amendment without the need for an economic opportunities analysis ap'art .'
from the SCLS, ";hich DLCD acknowledged as fulfilling the C.ity's obligations under Goal 9. '.'
'.
Because the'requested,redesignation and con'currentzone change implements SCLS
, policies and does notresult 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 City's compliance with Goal 9 and applicable administrative rules
regarding Goal 9 implementation.
Additional Goal'9 information su'bmitted by applicant on 'March 281l1. 2007;;
The Metropolitan Industrial 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, 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
acr,es." (pg. 73) The Inventory Report also stated; "The 1,6?8 c'onstraint-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 ~upply. 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 betw,een 1,600 and. 2,122 acres metro-wide. .
Staff's Goal 5 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,
Ii
LRP200Y,OOO I J & ZON200Y,OOO/2
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.s~ggestingthat there is stiH an ample supply'of a~ailable iitdu~trlalland's to meet existing ,
and future developmenlneeds," ,... . " ". " .... ,:' ~. ,. ' '. " '.;, '. "".'
'. '. ,',
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This analysis may also not reflect other changes within ind[!strially designated.land
categories that would further ciff:set the proposed chang'e to'thesite's'LMI Plan
designation and zoning. For example, 11.5 acres was' added .to the inventory of LMI zoned
and designated land due.to City Council approval in April 19'97 for land east of the 28'h/31"
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 of LMI designated and zoned land to off-set the
. , proposal to remove only about 5 acres from the LMI inv~nt6ry..'
We therefore respectfully s'ubmitthat the proposed Metro Plan diagr.am 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. ' .
STAFF'S FINDINGS RELA't~DTO COMPlIANCE'WITH GOAL 9:
Finding 10: The City of Springfield has two adopted'in~entories "';'hich support the'
proposed Metro Plan Amendment I Refinement Plan Amendment and concurrent zone
. change request _ the 1992 Industrial Land Study and the 2000 Commercial land Study.
, The applicant references both ofthese adopted inventories and sites sp'ecific polices
which support the proposal. As rioted by the applicant, Finding 3 in the Springfield . ,
. ' ,
Commercial Land Study (SCLS) cited the acknowledged 1992 Industrial land Study as
demonstrating that "a surplus of industrial sites exists in the Metro Area," The applicant
, " also references Strategy 3-A(1) o(the SLCS which states: "Evaluated 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:" 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 industriallands in the Metro area..As noted in the City of Springfield Goa\ 5
analysis, even with a reduction of inventoried industrial land affected by Goal 5, there is
a still a surplus of between 1,600 and 2,122 acres metro~wide"
As noted by the applicant, Oregon Administrative Rules concerning Goal9
implemen.tation (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 polic:ies
(i.e. SCLS) or new consistent with an economic opportunities analysis (EOA). OAR 660- '
009-0010.states that a reviewing aiJthority can find that the proposal complies wit(1.
relevant local plan policies by converting one form or employment-generating land use to
another, without negatively impacting the supply of buildable la'nds 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 property, Additionally, the applicant is seeking to develop
future commercial use's on the property which will maintain the property' for employment-
generating acti0ity
lRP2007:000 /J & ZON2007,OOO/2
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G,iven the irifbrrilation provided in the adopted commercial and industrial lands
inventories (a shortfall ot'commeicial and an inventoried excess of Industrial land) "
compared with the size of the proposed Plan Amendment and Zone Change, staff find
that the proposal is consistent y{ith Goal 9 requirements. Staff finds that the proposal
. does not.represent a "signific;ant change" to the adopted EOA., ' . ,
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APPLICANT'S NARRATIVE RELATED TO GOAL 10:.
Goal 1 0 _ Housing: To provide for the housing needs of citizens of the state.
LCDc's Housing goal requires cities to maintain'adequat~ supplies of buildable lands for
needed housing, cased on an acknowledg~d inventory of buildable lands: The proposal .
. does not affectthe City's'inventory of residential'lands. ,'., --' , ".',
In fact, approval of the requested redesignation for Tax Lot400,would enable,
redevelopm'ent of an industrial site abutting existing residential development. Throug'h,
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 uses, it-does not affect
SP.ring'field's continued:compliance with Goal 10. . '
,'i.
STAFF'S FINDINGS RELAT.EDTO COMPLIANCE WITH GOAL 10:
. -' .-
.Finding 11: The proposed Metro Plan I Refinement Plan Amendment and Zoning
Map 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 10 compliance.
, ,
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APPLICANT'S NARRATIVE RELATED TO GOAL 11:
.' .' 1.
Goa111- Public Facilities and Services: To plan and develop a-timely, orderly and efficient
arrangement of public facilities and services as a framework Jor urban and rural .
development. .' " ,
OAR 660.011.0005(7)(a)-(d) Definition 'of Public Facilities: ..
(a) Water
(b) Sanitary Sewer
'(c) Storm sewer
(d) Transportation
This goal requires the provision of a timely, orderly and efficient arrangement of public
facilities and services. The subject property'is located within the SpringfieldU.GB and city
limits, and is already designated for urban levels of use. The proposed amendment to the
Plan map designations from LMl to CC will not affect the ability to provide needed services
since all the required urban services are available to support existing or future commerciai
uses on the'subject site.' '
.LRP2007-000 13 & lON2007-000/2
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STAFF'S FINDINGS'RELATED TO COMPLIANCE WITH GOAL 11: ...
Finding 12: As noted by the applicant, the,Metr~Plan and associated facility pl~ns
have been acknowledged to conform to Goal 11 ensuring that public facilities and
services are currently available to the subject site. The proposed Metro Plan I
. Refinement Plan Amendment arid 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 Refinement'Plan Amendment and Zoning Map
,'Amendment applicatio,ns 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 NAR,RATIVE RELATED TO GOAL'12:'
. Goa/12 _ Transportation: To provide and encou;age a safe, co.rv'enient and e~onomic .
. transportation system. '. . .-
. . '
'Goal 12 requires local governments to provide and encourag'e a,safe, convenient ~nd
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 changes'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 develop'me'n't 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 "S,igni.ficant effect" on transportation facilities as defined in the
Transportation Pla'nning Rule (OAR 660_012-060). '
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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 thatfuture
development on Tax Lot 400 will result in some access changes as will be reviewed
through the site plan review 'process, thereby consolida~ing two existing curb cuts located
on'Tax Lot.400 into a single access point located approximately in the center of the parcel.
The TIA dem'onstrates that these access points will no! result in any degradation of
mobility standardsbel6w acceptable levels, and that safe an<! efficient circulation can be
realized through approval olthe r~quested land use redesignation (and companion zone
change)." ' ,
Furthermore, reducing the number of access pointsfor future development on Tax Lot 400,
is consistent with policy objectives found in East Main Refinement Plan (EMRP) Access,
Circulation & Parking Element policy 1B (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 Goal12 and
applicable ,local implementing policies.
. '
STAFF'SFINDINGS RELATED TO COMPLIANCE WITH GOAL12: .
Finding 14: The proposed,Metro Plan Amendment is from LMI to Commercial,' and
RefineinentPlan 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
/7
LRP1007,OOO /3 & ZQN1007.000/1
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'" . in, any changes to the type 'or intensity of uses on the site,' ~nd will not increase the trip'
generation for that parcel. Staff does not concur with this statement in reviewing all of .'
the potenl/a! CC uses on the site. Staff does concur,however,with the applicant's, ' .'
statement if the future medical office use is in fact developed on the site, and not other,
potential "reasonable worse case': CC uses. .
Pages 18-19 of the applicant's TIA list Peak Hour Trip Generation for both the existing.
. zone (LMI) <)nd 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 gen'eration given other allowable uses in the .
CC zone During Staffs review of the proposal, staff researched. potential vehicle trips'. .
per ,day for potential uses in the CC zone, There are some 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 condi,tion 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-f09t basis the Medical'
Office is estimated to generate 2.47 vehicle tips/1 ,000 SF and 3.43 vehicle tips/1 ,000 ,sF
. during the AM and,PM peak hours respectively. For comparison the average rates for' a '.
"Fast-Food Restaurant with Drive-Thro'ugn 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 60i the TIA, a reasomible worse case traffic generatio~ scenario f~r
the existing zoning (LM1) is 243 trips. The proposed use of Medical Office Building is'
show'n in Table 7 as 177 trips, While the MedicalOffice use trip generation is less than
the reasonable worse case scenario for th'e 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 that there 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 reviewing parties (i.e, City Planning Staff, C~ty 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 not to exceed the reasonable worse case scenariO for the existing zoning (243
, trips), Because these numbers of trips, are already allowed with the 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
applicant in the Traffic Impact Analysis' for the subject property.
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APPLICANT'S NARRATIVE RELATED T() GOAL 13:
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Goa/13 _ Energy Conservation: To cons'erve energy. Land and uses de~~lcJpedon the
land shall be managed and,controlled so as to maximize the con,servation of all forms '
. of en~rg}', :based upon sound economic principle~.. .'., '. ' . '
The.Energy goal is a general planning goal and provides Iimited.guidancefor site-specific
map amendments. The proposed amendment has no direct impact on energy' ,
~onsel"lation, though it would in fact will promote greater energy efficiency by enabling
, needed clinical sel"lices 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. ' , . " , .
"
: STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 13: .'
Finding 15: The proposed Metro Plan I 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 pursuantto 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 ~ural 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 UGBand the city limits of
Springfield, and within an existing urbanized a(ea 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 wer,eahnexed.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 Goa113. ' '
. .
APPLICANT'S NARRATIVE RELATED TO GOAL 15: ..
. Goa115- Willamette River Greenway: To protect, conserve, enhance' and maintain the
natural, scenic, historical, agricuJtural, economic and recreational qualities of lands .
along the Wiilamette 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 TOCOMPLlANCE WITH GOAL 15:
. Finding 17: As noted by the applicant, the subject property is not located within t'he
Willamette River Greenway. Goal 15 does not apply to the subject Refinement Plan
and Zoning Map Amendment applications.
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lRP2007,OOO I J & ZON2007-!JOO/2
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'APPLlCAN'T'S 'NARRATIVE RELATED TO'G'6ALS 16-19:
" . . - ., . . . .
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,'. Go~1 16 through 19: (Estuarine Resources, Coastal Shorelands, Beaches and Dunes, ...'
and Ocean 'Resources): ,,' , '., "" " .. . .....
'. ' . ,..." . . ~ - .
,The coastal goab are notap'plicable to this 'appli~aiion.:' ..' '
. ,STAFF'S FINDINGS RELATED TO COMPLIANCE WiTH GOALS 16'19: '
: ',-,' I.'; ,,' ..' :' ' . .
.. ,Finding 18: As noted by ,the applicant, ihe subject 'site is not. located within any. ..
. coastal, ocean, estuarine, or beachand dune resources related area. Goals 16-19 do
not apply to these Refinement Plan and Zoning Map Amendment applications. ,
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CRITERIA OF APPROVAL ~ SDC 7.070 (3)(b)
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APPLICANT'S Nt'RRATIVE RELATEDT() spc 7.070(3)(b):
.'
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Theap'plication requests amendment of the Metro Plan diagram from LMI to 'CC for
approximately 5:24 acres: ,This section o'f the application,narrative addresses the .
c'onsistency of the amendment with the applicable policies of,the Metro Plan, to '
derrionstrate 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)) , .
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This narrative'~rilyadd~essesthose policies that apply to the proposal, and does not
, discuss those portions of the Metro Plan that: (1) apply only to rural or other la(ldsoutside
. of the urban growth ~,oundary, (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 applicatiolls (e.g., site'plan
, review submittals or subdivisions). In many instances the goals, policies and' .
implementation measures apply to specific development pr,pposals that will be addressed'
thr<:lUghcompliance with applicable City regulations duringsite plan review of a given
future development proposal.' ' .. ",
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The Metro Plan Introduction, Section 0 provides the following definitions:
. , .. .' " . - I'"
A goal as a broad statement of philosophy that describes the hopes of the
people ofthe commun'ity for the.futureof the community. A goal.may never be'
completely attainable, but is used as a point to ?trive fOL ' . ' ,
An objeCtive is an attainable target that the co'mmunity attemptstci reach in'
striving to meet a goal. An objective may also be. considered as an
,intermediate point that will help fulfill the overall' goal.
A policy is a statement adopted as part of the Plan to provide a consistent
course of aCtion moiling the community towards attainment of its goals. '
. ._ ." - . " ...... '..1
.. . .' ',.' .,-.
Except for the Growth'Management Goals, which are addr,essed 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. '. .. ",' . ""'", ,
, . '.
-; ~.' ,., .,.
.i
','
.. '
'.' I"
M~iro Plan EleJl)en!s .
~ .,.
1. ~rowth'Management
LRP2007,000/3 & ZON2007-00012
20
.j
-'i
S...,21
.".
"
....
. ". ....
Policies. ' ", .. "
,1. The urban growth boundary and sequential development shall con'tinueto be
implemented as an essential means to achieve compact urban growth. Provision of all
'urban selVices shall be concentrated inside the, urban g~owth Qoundary. . . "
. .
The proposed amendments satisfy this P?licybecause the subject 'property i~ inside the
UGB and city limits an'd 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 this application. The City's site plan review processes ensure,,'
that the appropriate level of services is .available to serve future development. ..
2. Residential Land Use and Housing Eiement .
....
Policies .'
A.11 Generally locate higher density residential dev.,"lopment near employment or .
commercial selVices, in proximity to major transportatior] systems or within '. ;.
transportation-efficient nodes.:., ".-
. . - ..
The proposed red~signation does not affect the inveritoryor avail~bility of re~identially
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, approvai of the requ'ested redesignation to Community Commercial would allow
for residential areas proximate to the subject area to have close and efficient'a'ccess to .
existing com'mercial services 'on Tax Lot 402 and to future, medical facilities proposed for
Tax Lot'400, consistent with the above policy. The areas proposed 'tor redesignation offer
existing and future employment opportunities and providecomm~rciai services a.long' a
major transportation system that can support the needs,of nearby residential'.' . ,
.development. . . " .
A.22 Expand opp~rtui1ities fo~ a mix df uses in ne":-Iy de~eloping areas a~d 'existing :
neighborhoods through local zoning and development regulations. . ,.'
..t
The map:ameridment and concurrently proposed zone change will allow for existing
.. commerciai 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.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 ourexisting 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 job"
('
2/
LRP2007-0001J & ZON2007.000/2
,H2
.....,
. -.
opportunities with higher thanav~rag~ wages thereby helping'rai~e the ~tandardof living:
. arid meet the needs of Springfield,citizens, consistent with the above policy: ,. '.
B.2 Encourage economic development which utilizes locat and imported capital, ' '
entrepreneurial skills, and the resident laborrorc;,." , .:' '
.' 1 .: . , '.. . - .. .. . I~ , " .
.. . ." . .-.'
The construction of and the use of commercial and medical uses wili utilize both local'and
. imported capital and wili employ the 10caUaborfcirce in a'variety of skilled,semi-skilled,
and unskilled positions, consistent with this policy. '
B.6 Increase the amount of undeveloped land zoned for light industry and commercia{
uses correlating the effective supply in terms of suitability and availability with .the
, projections of demand.
,"
. ,.
. .
. The proposal will add approximately 5.2.4 acres of Community Commercial land,
consistent with recommendations to increase the co.mmerciallands inventory made in the'
Springfield C~mmercial Lands Study. l:he SCLS and acknowledged metropolitan
Industrial Lands Study concluded that there is a deficit'of needed:commercialland, and'a'
surplus of industrially zoned"and de~ignated lan.d. Approval of th!'requested .
redesignation will not cause' the inventory .'if needed"industrialland to go into a deficit, but
in fact would, c'onsistent with the above poticy. 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 activitie; which strengthen the metropolitan area's position 'as
a regional distribution, trade,health, and service center. '
,--'
The amendment wili 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 positi.on as a premier locale for healthcare services,consistent with
this policy objective. . .
6. Environmental Design Element
l'
.'-
Policies
E.1 In order to promote the greatest possible degree of diversity, a broad variety of
commercial, residential, andrecfeationalland uses shall be encouraged whfw consistent
with other planning policies. ,', - '
Approval of the proposed map amendments wili add just over 5 acres intoJhe 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
services that will serve the, needs of the growing residential areas .e~st and south of the
subject site, consistent with the above policy.," ,: '. .. '" "
7. T(ansportation Element'
.'
Land Use Policies
F.3 Provide for transitcsupportive land use patterns and development, including higher'
intensity, transit-oriented development along major transit corridors and near transit
stations; medium- and high-density resid,ential development within one-quarter mile of
: transit stations, major transit corridors, ef!1ployment ,centers, and downtown areas; and'
".,
lRP2007'OOOI3 & ZON2007-00012
.22
,~-?~
~ j
development 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 iand use p'att~rns '
. and development consistent with the above, policy. 'Approval'of the proposal will allow for
" . higher intensity development along Main S'treet, a major 'transit corridor. An existing L TO
stop is located on the frontage ofT ax 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 as access for patients to future out-patient medical facilities projected on Tax
Lot 400. .' . '
Transportation System Improvements: Roadways Policies
.F.1S 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
; shali be used for; .. _ . - ',' .
" '_. (1) Identifying capacity deficien'cies on the roadway'system. ,
(2) Evaluating the impacts on,roadways of am~ndnients to
. transportation plans, acknqwledged comprehensive plans and.
land-use regulations, pu.rsuant to the TPR (OAR 660-012-0060).
. ' '" (3) Evaluating development applications for consistency with the land-
, use regulations of the appticable 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
.' '_ - I '
D elsewhere. . . ".".: " ,,' .
c. ' Performance standards from- the OHP shall be applied on state
facilitiesin 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 goats 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
c.onsiraint'tactors. ltis not the intent of TSI Raodway Policy #2: Motor, Vehicie 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 proposal pursuant to the'
state Transportation Planning Rule (TPRl: The accompanying Traffic Impact,Analysis
provides the factual basis to determine that the proposed redesignation:would not result
in a "significant effect" as defined under the TP.R (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 sta'ndardsfor 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 o'r 'access that are inconsistent with the
. functional classification of Main Street or any other riearby roadway;
"
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LRP1007-000 /3 & ZON2007-000 12
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I
Reduce performance of traffic' on Main Street or oth'er affected:
'intersections to a level that is below acceptable established performance'
standards; or . "
,.
Make performance of existing facilities v;orse (I.e., below acceptable
mobility standards) than would be the case other uses permitted under.: . ,
,existing designations or zoning'.' .
SpecificTPR 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 required. The request is therefore consistent with the above policy.
0,'
o
8. Public Facilities and Service Element
G.1 Extend the minimum -/~vel and fu/l range o(key urban 'facilities and services in an
orderly and efficient manner consistent witli the growth management policies in
. Chapter /I-B, relevant policies in this chapter and other Metro Plan policies.
. , j,... .' ,. . ;:; .. .,. ~ . ..' : . .,.
The subject property is located in Springfield'scity limits UGB. AU micessary .
infrastructure and key urban facilities/services are present to serve, existing development
,(Tax Lot402) or are available to serve futureinfill development ori,Tax Lot 400.. Therefore,
the proposal is consistent with the abov'e p'olicy. '-. .
..-,' l ',' - .
.,.
. ,
9. P~rks and RecreatiOll Facilities Element Policies ". .' ,
Policies in this element of the Metro Plan are not relevant ts> the requested diagram
amendment. " . '. ' ' . '
;, ~
10. Historic Preservation Element Policies .', , '.
Policies in this element of the Metro Plan are not relevarit to the requested diagram
amendment. ' '
11. Energy Element policies
Policies in this element of the Metro Plan are not' relevant to the requested diagram
a~endment.
STAFFS FINDINGS RELATED TO SDC 7.070(3}(b):,
Finding 19: The requiremelit of this criterion that adoptiof) of these proposed
applications not make the Metro Plan internally inconsistent does not mean that every
goal, objective, finding and policy of the Metro Plan must support these applications.
Because of recognized conflicts 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 r.elated to the proposal.
Staff has reviewed the' applicant's choice of applicable Metro Plan Policies and Elements
and concur that the' noted Policies and Elements are applicable to the proposal. Findings
addressed regarding Goal 9 and Goal! 2 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.
LRP2007-000 /3 & lON2007-00011
24
..!i-25
~
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:, The stated policies and Elemel'1ts have been re:;iewedby staff and are found to be
. applicable and'consistent with.the proposal. '" --, '--,'.: . ,." . ", '.
" . ' .
.. . .
REFINEMENT PLAN MAP AMENDMENT--
'. CRITERIA OF APPROVAL -sot 8.03Qet seq.: .
in reaching a decision on thes~' actfons, ihe Planning Commission and the City
Council shall adopt findings which demonstrate conformance to the following:
, .
. .' . -. . -
, (1) The MetraPlan;..
.. (2) Applicable State'statutes. .
.: (3) Applicable State-wide planning Goals and AdministrativeRules.
.' . , .
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STAFFS' FINDINGS RELATED TO COMPLlAN,CE WITHSDC 8.030 (1H3): .
, , ... .,- '. .. ;.
.. "
. " . Finding'20:'SDC 80'30(1)-(3) indicates that a Refi'nement Plan Amendment~ust be
consistent with (1) The Metro PJan (2) Applicable State Statues; arid (3) Applicable. .
, Statewige 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 Amendment Cnteria. As noted in the applicant's narrative, SOC 7:1,10(4) states',
" "When a Metra Plan amendment is enacted that req'uires an amendment to a refinenient
plan or functional plan diagram or map for consistency, the Metra 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 applicatiof) is required. As stated in the above
'.referenced section of the SOC, the refinement plan is automatically amended upon .
approval of the Metro Plan amendment. .
The applicant's narrative related to consistency with~pecific refinement plan policies is
, most appropriately addressed as part of the Zoning Map Amendment criteria, later'in this
re~~ ' .
"
METRO PLAN MAP &. REFINEMENT PLAN AMENDMENT (LRP2007-00013)
CONCLUSION AND RECOMMENDATION' .
Staff finds that the request ~eets the criteria of.SOC 7.030(a) :.. (b) and SOC 8.030.
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
applical'1t'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 generation from development on the subject property shali be limited to' a
maximum of 243 PM Peak-h()ur vehicle trips,'which is based on a "reasonable worse
case'development scenario" under the existing zoning (LMI) as submitted 9Y the, .
. ,applicant in the Traffic Impact Analysis for the subjeCt property.
!:
25
LRP2007,OOOl3 & ZON200rooo/ 2 .
5-26
ZONING MAP AMENDMENT '-',
CRITERIA OF APPROVAL -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
,Offi.cial shall make.the,flnal local decision on all quasi-judicial Zoning map amendments that do
not include a Metro Plan diagram amendment:
, .
SDC 12.030(3) Zoning Map amendment criteria of approval:
, ,
(a) Consistency withapplicable Metro Plan policies and the Metro Plan diagram
(b) Consistency ...:ith applicable Refinement Plans, Plan. c;Jstrict maps, . Conceptual
Development Plans'andiunctionalplans; and .'
,"
, . (c) 'The property is presently provided with .adequate public' facilities, services and
transportation'networks to support the use, or these facilities, services and transportation
networks ar9 planned to be provided concurrently with ,the developl1)e~t 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 PlanAmendment, addressing
many of the same criteria. The portion of the Applicant's Narrative relatr:;d to '
Refinement Plan policies is included below. Rather than be duplicative in this
report, ~nd for ease of review, Staff has attached the remaining portions ofthe
applicant's written parrative in its entirety for reference.
"
STAFF'S FINDINGS RELATED TO COMPLIANCE WIT,H SDC 12.030(3)(a):
FindiI1g 21: This criterion is also found in SDC Section 7.070(b) under the Metro Plan
Amendment cntena 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.,
'.
APPLICANTS NARRATIVE REL~TED TO COMPLlA~CE 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 Element
"
, ,
26
lRP2007-000 13 & lON2007-000 12
5-:21..
.,r,_
Policy 2) Area #2 .
" A) The following land,uses are all5JWed under Community Commercial z'oning:
. '
. . .
All Commimit'( Commercial uses subjeci to Article 18 of the Springfield
Development Code. . , . '
The proposal requests redesignating the subject prop~rties 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 Desicnatio~ '
1. . Generally, the Community'Commercial refinement plan designation shanbe
. 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 residenti'al area west of
the subject site along 44th Street, and is therefore consistent with the above criterion.
B) where it does hot increase conflict between LbW 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 o'f
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. '
"
C) where criteria for designating Medium Density Residential land does
. not apply; . .'
Criteria for designating MDR land does not a'pply 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 str~etcan
be provided; ... and
The subject site has adequate legal access onto Main Street, which is'classified as an
arterial street. ' . ,
LRP2007-000 J 3 & ZON2007-000J 2
27
;;-'28
.1
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, .. .. ..
Fj . where 'designated Co'mm~rCial on the'Metro Plan Diagram. " " ,
,Approval of this app'lication ,wouldreslllt in a Commerciai design-ation on the Metro:
.. Plan diagram, which would also_automatically modify the designation on the EMRP
diagram. .,' . " , ' ' " .
Policy 2), Apply site-speCific Commercial iefinemerit plan designations to clearly define "
the.limits of new commercial useswherethere is not an existing, legally established, and
beneficial mixing of uses.. ,'.. .' '
"
Approval of the requested redesignation would apply Commercial'pl.an designations to
the subject properties, allowing the existing, legally established commercial uses on."
Tax Lot 4'02 to continue. It would also enable commercial uses to be established on'
Tax Lot 400, therebydefining.the limits of new commercial use's betweenthe'pre-
existing commercial uses on Tax Lot 402 and others to the west, and the developed
industrial business park to the east. 'fax Lot 400 does not have an existing or '
beneficial mix of uses, but has historically housed industrial yard-type operations.
, Therefore, approvalofthe proposal wouid define, the limits of new commercial uses as,
called for in the above policy, and also provide the ability,to.make superior buffering'
~nd other improvements associated with future development on Tax Lot 400 thro'ugh
the site plan review process.
..,
Policy 3) Reduce the numberaf vel1icula; '(cces5 points arid require the rebuilding of
curbs and installation of sidewalks and street trees along Main Street, through the Site
Plan Review process,and in public improve;ne,:,t projects..' .
The proposai would result in reducing the number of existing access points as'
required above. Th'rough 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 co';'me!~i;t and residential uses through Article 31 af'
the Springfield Development Code, SiteP/~n Revie,w'process.
Existing residential ~ses along the east side' o( 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 shall encourage efforts 9f various agenCies to attract new and retain
existing jobs and businesses. I.,
'J
Imolementation
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 oi the requ~sted 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,OOOlJ & ZON2007,OOOl2
18
"-29
"
400 with higherthan average'wages and employment densities than the current
designation and zoning allows. . "
. '" ,
'," j."
, ~
,...'
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH SDC 12.030(3)(b):
Finding 22: As previousiy mentioned in' this report, \tie 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 2j'is located south of the subject property (across Main Street), an'd is not
part of the subject property. 'Reference to this policy is not'applicable .to this application.
r. " '
Finding 24: The applicant discusses specific criteria listed inthe refinement plan for
. commercial and 'industriaL uses. Staff concurs with,the applicant's narrative related to the
commercial criteria. .'.
, Finding 25: Critena of approval for consistency with all applicable City of Springfield
functional ,plans have been previously addressed in this report. As noted il) the findings.
in this report, the proposal is in .compliance with all applicable functional plans..
. Conclusion: Based on the above fif1dif1gs, the proposed zone change is if1 compliance.'
with SDC 12.030 (2). .
, !
STAFF'S FINDINGS RELATED TO COMPLIANCE W,'TH SDC 12.030(3)(c):.
, ' '
, "
Findif1g 26: As previously f10ted in this report and as stated by the applicaf1t, the subject'
properties are currently served by sanitary sewer systems af1d storm drain systems
Sprif1gfield Utility Board (SUB) has sufficient capacity to provide electrical and water.
service to the site. ,
Finding 27.: The property is served by $pringfield Fire af1d Life Safety.
. '
Findif1g 28: The site is within Springfield School District' 19.
'Finding 29: The site is withif1 the Willamalane Parks and Recreation District. ,
Finding 30: Traf1sportatiof1 systems curref1tly. provide access to the property. The
subject site takes access from 44'h Street which is under City of Sprif1gfield 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'" af1d Main Street: As previously
discussed if1 findings in this report, and as conditioned, the' proposed zone change will
not significantly affect the existing transportation network.. The proposed zone chaf1ge
will not negatively affect existing public'transit service.
.' r.
29
'lRP2007-000 I J'& ZON2007.000J 2
t;-~n
,
, ,
>.~
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)' ,
, Finding 32: Solid waste manageme'nt service is available' at the subjec(property.The
City and Sanipac have an excl.usive franchise arrangement for garbage service inside
'I' . - - .
the city limits. '. .... ,:.' . . '.
~ ., . . , .
Finding 33: Thesitereceives 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 Se'rvices Department provides land,
use control for property within the City's jurisdiction.
. ' "
'"
, .' Finding 35: Q.:vest and Com cas! 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." .
.'
, .
. C'o~clusio'n: Ail key urban facilities and. services required for the propose.d 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:.
SOC12.040
SDC Article 12 allows' for the Approval Authority to attach conditions of.approval to a
, Lone Change request to ensure that the application fully meets the criteria of approval.'
The.specific language from the code section is listed b~,low:
12,040 Conditions of Approval
.,.:,
The Appro~al Authority may attach conditions as may be reasonable necessaryiri order'
to allow the Zoning Map amendment to be granted. '
Staff have revie"":ed the Zcine 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 I 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.
.. '
'..
.!,
lRP2007,00013.& ZON2007,OOO/2
'. 30
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ZONING MAP AMENDMENT (ZON2007 -00012) CONCLUSION AND
RECOMMENDATION
......
Staff finds that the request meets the criteria of SDC'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 .arid forward .the proposed Zoning:Map ,
Amendment Application lON2007-00012 to the.City Council with a recommendation for.
adoption: , . . '
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tRP2007-000/3 & lON2007-000/ i
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'5.0 TRCP'GENERATION AND> DISTRIBUTION
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5.0 TRIP GENERATION
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To determine the triffic impac;~ of a d~vei~pineht ~na road\~ay system, the Iiu~ber 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 development. . . .
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The amount of trips expected'to'be generated by theproP2sed development was' '.'
determined usino the infomiation contained in the ITE T riD Generation Manual, 7'h
'=' .: .
. Edition. The equations in the manual predict th~ number of triPsgenerated based on ,the
gross square' feet ofl1oor area. Separate trip generation analyses were performed for the ""
AM and PM peak hours for the developmeht. " : ' .
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Under the current I.:ight :MedluIn Industrial zoning tlie.deveiopn)ent site ~an be built out ",
to inclllde a variety of l::md llses'specilied in Springfield D,evelopment CodeArticle 20.
The maximum ,trip generation of the cievelopment was determined for the allowed land
uses under the'c'ur'rent zoning. Tables 5 and 6 illLlstrate the maximllm development.
potential and sLlb'sequently the 'maximum trips generated by the develqpment site using
the following ITELand Use, Codes:' .'
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. Land Use Code 760, Research and Development,
. Land Use Code 714, Corporate Headquaiters
. LandUse Code 492 '.Heal~hJFitness Club.
. Land Use Code 565 - Daycare Center ,
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<' Research and,
" Development'
, 760 .
80,. Ln(T)~0.88'Ln(x)+0:88 . '114'- 0.83,. ,
0.17 .';:95 ,; 19'
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Health Fitness C'lub . 492 . 4' T=1.21'x '5 0.42,0.58
'2
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61
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JR.H TMNSrOR. TA TIONENGIN EER.iNG I E'asi 5::rf'eld~e:one:,.?~rlngfleld. Oregon I March 6. 2007 i 18
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EXHII::lII A-:
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T=4.05'x
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TotalTrips' 243,it:o, ,:':H;,6?{fj!U
With the zone change'tl~e developme~tsite will be bllilt t~ include an approximately,
30,000 square foot medical office building. The land use code for a fully developed
, medical oHice bt;ilding was no -Medical-Dental Oftice Building. This was used in
.. place of Land Use Code 630 - Medical Clinic because, after' close inspection ofthe Trip
'" Generation ManuaL it was detemlined that the sample size for this' category .of land use'
vias too small to create a reliable estimate of trips generated. Table 7 illustrates the traffic,
generated by the proposed 30,000 square foot medIcal oftice building. Tax Lot 402 is .
currently' occupied by a conunercialispecialty retail center. With the proposed zone
change, the building wiUremain on the property and will continue to operate as a,,' . .
special tv retail center. Vehick trips using this site have 'already been accounted for on the
roadway in the background traffic volumes: therefore, no ,new development trips were
assigned to this Tax. Lot ' '
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Table 7: Peak' Hour Trio Geneiation,Medical Office Building',
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.'ii)~~c~i~,f;~rkt~l\~~~l~ 11~00~.l)}~~~21~;~j
AM
T~2.48'x ' '
74
79% 21%
58
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'In(T)=093'1~(x)+ nT; ';i,f63';;* ''27%:- _'I:j'~;ijii;'!28:'i'i.m:ij
i;.'~~;!.<:. . ..,', ..:~:;":'-:..: ...: ::'\ ,:~,:-:~::~ Nh~~~~ :-~}~2~~0 ':.1~~~fI}:~~ ;~'itj1~.;.~;fl1{~ti5:)~
. There are 155 fewer ANI and 140 fewer PM vehicle trips generated by the medical office,
building when compared to the'maximumpotential of the site under the current zoning,
,.IIlH TP_,NsrOIlTATION ENGINEEIlING 1 East Springfield Rezone, Springfield. Oregon I March 6.'2007119
. 5-34 .
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5.1 TRJr DISTIZIBUTION AND ASSIGNMENT'
Afte; dete'rmining the t;ip generation, the ne~t step in the aI1alysis re'quires distribt;tirig
: and assigning the trips to the existing traffic network. Trip distribution allocates the triPs
generated from the developments to generalized destinations. Trip.assignment routes.
trips to these generalized destinations via the actual street network. The trip distribution,
for this project was based on the existing distribution pattern of the study area roadwiy
network, where applicable. Access to Tax Lot 400 is assumed to be limited'to a single'
, . full-movement access from Main Street. Figures 9 and 10 shows the assigned vehicle
. trips generated by the 30,000. square foot medical office buiLding for the AM and PM
peak period respectively. :, ...' .' ", ','
.,.,',.
"52 Bl)iLD TRAFFICVOLUMES"
.T 0 determine the Build tniftl~ volumes the development trips assignedihraughout the
study area were added t~ the background traflic data. The'year 20o'sAM and PM Build ,
, year traflic volumes are illustrated in Figures 11 and 12, respectively. The year 2023 AM' .
,and PM Build year traffic volumes are illustrated in Figures 13 and 14, respectively ,
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jR.HTRANSrOlnATlON E~GINEE~ING I East Springfield Rezone ',Spr!ngf!eld"Or~gon I March 6. Z007 I 20
5~35
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" EXHIBIT A-I
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, '7.0 TPR FINDINGS
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.' The follo\ving discusses the Orego~ Administrative Rllli~g660-012-0000, the
'Transportation Planning Rule, and the effect 6fthe proposed development on the
transportation. facilities as it applies to the rulipg.
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660-012:0060
Plan and Land Use Regulation Amendments'
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'(J)JVher~ an amendment to ajimclional plw1, an acknowledged comprehensive plan, or '
"ci land use regulation would significantly ajfect an existing or planned transportation'
':facility, the local government shall put in place measi'tres as provided in section (2) of
this rule io (lSsure that allowed land uses are consistent with the identified function, ,',
'capadty, and performcmce standc/rds (e.g. level of service, Vollll71e'to capacity ratio, etc.)'
of the facility, A plan 'or land use regulation amendment significantly affeCts a
tramportation facility if it would'
. (ciy'Chd71ge, the fwictional clCtssification of cm existing or pla~n~d trahsportalionjilCility
}exclusive ofcorrectio'n of map errors in an adopted plw1): '
" The addition of development traffic on the adjacent' roadways does not cause the
change in functional classilication of any of the transportation facilities.
(b) Change slclnda;ds implementing afunctionttlclassifica/ion system.: or
The standards implementing a functional classilication system within the project.
. study area are not changed by the proposed development. . .
(c) As measured at the end of the planning periiJd iden/ifled in the adopled Irclf/sportCltion,
,systempla71: ' . .
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, (A) Allow land uses or levels of develop men I I hat would result in types or levels'oftruvel
'or access thai Clre inconsistenl with Ihe fimclional classiJicalionof an existing or planned
transportation facility;,
. The proposed development does not result in types or levels of travel or access.
that are inconsistent with the ti.mctional classific'ation of the studied transportation
t~1cilities.
(B) Reduce the performance of Cm exiSling or planned Iransportution jilcilir,v below the
minimum acceplUble peljormance standard idenllfied in the TSP or comprehensive plan:
or
The addition of development traftic does not redllce the performance of an
existing or planned transportation facility below the minimum acceptable
performance standard.
I
, JR.H TI\ANSrOR.T.~TlON ENGINEER.ING I Eas'.Sp~l~gfield Rezone:, Springfield. Oregon I March 6.' 20071.31
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EXHIBIT A-5 ~
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(C) FVorsen'th:'perforriwnce of an 'e);islingorplcmi-ied transportqti;'nfii~iri&'that is '
othenvise projected (Q perform below the rriinilrnlln acceplcible pe,jorl)'/cince standard' ,
, identified inlheTSP or comprehensive plan. ""
The addition of development traffic does not further degr<lde the perf~mlance of
, '.int;,:rsections projected to perform below the minimum acceptable performance'
. standard. "
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, As sho\Yn, the proposed redesignation of Tax Lot 400 and 402 does not result ina
"significant effect" on ,the transporption facilities as defined in the TPR.
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, C~inpletion' of the proposed development is anticipated for the year 2008. This report
.includes year of completion analysis, year 2008, for the roadway network within the
study area. In addition, a horizon year analysis waS performed for,th'e year2023.
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.",8.0 SUMMARYAND'RECOMMiNDATIONS.'
This report 'provides an analysis of potential traffic impacts resulting from theprciposed
. redesignation/zone change and ti.lture development of the subjec! site in Springfield,
,Oregon. This developn1ent \Yill include approximately 30,000 square feet of medical
office space. The parcel proposed for development'is iocated east <if 44th Street and west'
of 48th Street on Main Street. A single unsignalized full-movement access point on Tax
Lot 400 and existing driveway access to 'Tax J-,Qt 402)s assumed. '
. A performance analysis \Yas completed tor the intersections of Main Street and 42nd
Street, MainStreet' and 48th Street, Main Street at 44th Street, and Main Street at 46th.
Street. The operational analy~is of all intersections within the study area shows that
under the Bllild conditionuo degradation in volume-to-capacity ratio in comparison to
. the No-Build condition,oscllisdlie to the additional trips produced by this development.
All study areas meet the inobility standard for the Build condition:
A qlleuing analysis \Yas performed for the intersection within the study area. The queuing
analysis, which assumes the current lane configuration throllghollt.the planning horizon,
was perfomled to determine the amount of required storage length due to the construction
of the project. The results of the qlleuing analysis indicate that all existingstorage lengths
will hicilitate the queuing anticipated for the traffic.demand. including the proposed'
development. . " '
According to the tinding under Oregon Administrative Ruling 660-012-0000, the
Transportation Planning Rule, the proposed redesignation of Tax LotAOO and 402 does
not result in a"signiticant effect" on the transportationfacilities as defined in the TPR.
: .JR.H TMNSrOR.TATION ENGINEER.IHG I East Springfield Rezone. Springfield, Oregan 1 March 6. 2001 132
5~37
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EXHIBIT 1.-6
Memorandum ,..,
City of Springfield
Subject: ., LRP2007 -000'12 PeaceHealth PAPA
. April 4, 2007 '
David Reesor, Planner. III
Garf McKenn.ey, YE., Transportation Planning Engineer
;.
...
'. Date:
'To:
From:
" The following comments and recommendations are based on ~y preliminary r~view' ofthe .
assumptions used in the traffic analysis report (TIA) and other materials provided with the
subject application. Pertinent pages ofthe TlA are attached for reference'. . '
. ,.'
. Traffic Impacts Analysis
In estimating the trip-~aking potentiai'~fsite developme'nt under existing LMI
designation/z~ning theTlA assume the land uses as depicted in Table 5 (Page 18). ~.
Reconunendatiorj: Confirm that the uses ,\~sumed in the "existing-desig~ation"
, 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 TlA assumed a single land use (Medical.Office Building) as depicted in
Table 7 (Page 19). '
, . Recomniendation: 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 theTlA would be an
acceptable means of ensuring that future development would riot generate traffic in
excess of what is estimated in the T1A. If we. find that the assumed Medical Office use
, .
. would under-utilize the land, then we will want the TlA revised to reflect the impact of a
true "reasonable worst case." .' ,
Goal 12 TPR Analysis/Findings
The PAPA application refers to the Goal 12 findings contained in the TlA. 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
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. EXHIBIT A-7
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REESOR David:. :.
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,From: ,MCKENNEY Gary' ' .. ",
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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,
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In' considering what a "reasonable worst case'" devel~pment scenario might be 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 GC zone. On a per-square-foot basis the MO is. estimated to generate 2.47 vehicle':. ,
,tips/l,OOO SF and 3.43 vehicle tipsll,OOO SF during the.AM arid PM peak hours respectively. For
comparison the average rates for a "Fast-Food Restaur,ant with Drive-'fhi;ough Window" are 53.11.
. 'vehicle tipsll,OOO SF and 34,64 vehicle tips/l,OOO SF. ': : ',. . ' , .
In considering the Goal 12 "insurance policy" issue some more I thought of anoth~r possible way to deal
with it, which we did not discuss yesterday. We might choose to limit the trip generation for the "
rezoned land to be no greater than what would be expected.from development under a reasonable worst
case with existIng zoning. .' '. '
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I'd like to discuss these idea,s further'in our meeting with.Ed M~oie.
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Gary
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-:Oregon
. 'Theodore R. Kulongoski, Go'vernor
Department of Transportation ,"
, "Re'gion 2 Tech Center
455 Airport Road SE Building A
., Salem, Oregon 97301-5397
Telephone (503) 986-2990
. " Fax (503)986-2839 "
. :'
DATE:
.,TO:
FROM:
. SUBJECT:
.
File: T15~2
May 10,2007
.Ed Moore
Area 5 - SeniorPlan'1er
Stephen B. Wilson, PE' "
, Region 2 Senior Traffic Analys
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. East Springfield Rezone ~ ",
. Traffic ImpactAnalysis Review ".,
Highland Business Park - Peacehealth Medical Office Building
, McKenzie Highway'- OR 126 Bus; (Highway #15), '
Milepost 4.61- 5.00
dty of Springfield
Lane County
. .
These are review corrunents for the East Springfield ~e"one Trafftc'lmpacf Analysis (TIA), prep~ed by
JRH Transportation Engineers. The focus of this review is the analysis methodologies and assumptions. '
The results and conclusions of this study an; i!1 question, due to noted inconsistencies: ltisrecotnmendcd
this study be revised, taking into ,account these comments. Region,2 Tr,,"ffic.will need to review any
revisedtrafftc study, to' ensure it complies with ODOTrequirements, before :~eanbe deetned acceptable.
11
.Figure 4
',,' Cillnineni'-.':":'..-':J . :,,," ,.... j'
The classification of Main Street (OR 126) must also be listed by the I
ODOT high\Yay classification. ' ' '
This study needs to. demonstrate ho\Y the Seasonal Adjustment factors'
were applied to the raw trafflc data. A graphic showing ,the .raw
traffic volumes should also be included, .
The peak hours assumed for this study seem reasonable; assuming the
Peak.Hour Factors were calculated off data from these assumed hours,
and were the same for all intersections.
The 2006 Existing PM Peale t",mC volumes <10 not seem cimect. 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 confi.rm the traffic volumes
~resented in Figure 4. See related corrunent for Page 8.
ODOT 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 'ODOT standard, and it is unclear where this standard
may have originated. The only ODOT standard for comparison is a
Segment Crash Rate, which should becalcwated'for the crashes in at
least a mile of the study area road\Yay.' I
I rag~ Paragraph.
\ 7 Table 1
8 Seasonal' .
Adjustment,
8 Peak Hours
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Paragraph
Growth Factors
Existing
Zoning Trip
, Generation
Table 5
19
Proposed
Zoning Trip
, Generation
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Future
Build-Out
Traffic
VOlulnes
Section 6.0
nla
Manual Count'
Data
nla
S ynchro
Analysis
31
Section 7.0
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, EXHIBIT A-9.
. Comment
This study must demonstrate how the Historical: Growth Rates were
applied to the 200630'" Highest Hour trafflc volumes. Calculations to
confllm the 2008 and 2023 data were. unable to duplicate the future
volumes cited in this report. - ---- '
This report states the, maximum development potential was
determined for the pr.operty, given its current zoning of Light-Medium
Indus/rial. For this scenario, ho\Y ,\Yas the maximum allowable
development determined"
The trip generation assumptions and output in this table are accurate.
ThiS study's trip generation analysis for the proposcd zoning, assumed
a 30,000 sf Medical Office Building would be the only development
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 develoomerJ on that site, given ,the CitY's
. development codes and regulittio'ns.
The traffic 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 questionablc and must be revised; taking into
account the previous comments. This comment can also be applied to
the queuing analysis developed for this study. ,- -- - -
:rhe scope of work for this TIA rcquired 3-hvur Manual Classification
COLlnts .for all study-area intersections. However, a review .of the
manual count data was unable to determine allY tluck volumes or
peroentages, The lluck traffic in this study area is significant, and ,
must be taken into account.
A review of the Synchro output has noted several inconsistencies
throughout the an"lysis:
. An Ideal S<lturation Flow rate of 1900 pcphpl was assumed
for both signalized inlcrsections(42'" & 4S'''), wllitetSOO
pcphpl was assumed for the two unsignalized intersections.
The ODOT Analysis Procedures Manual requircs a saturatlon
flow rate of 1800 pcphpl for all intersection analysis.
. The truck percent8ges must be based on real.world data. - The
Syncllro default of2 % is not acceptable. .
Unless the Yellow Time (s) entered into, Synchro for the
signalized intersections is based on either an ODOT or City
timing 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 approaches. The 5,0 seconds of yellow is
generally reserved for high\Yays with an 85'" 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 ver; likely they will need to
be revised, based on the recommendations in this review.
..........-....
,5-41
c'^nIOII M~I J'
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Basedont~e pr~viouscomments, in this review, the conclusions
drawn and recomrriendations 'proposed. are in ,question.'. It' is very
likely they will need to be revised, based on therecommendations in
this review.' . .\
32 .Section 8.0
If you havc any"questions regarding my comments, please contact me by phone at (503)986-2857 or by
.e-mail at ~ten"en,h wilson(ciJodot,stuteoru-,.. ... '
Cc: Jirri Hanks - JRH
David Warren
.J ane Lee
Mike Spaeth
'Dennis.Santos
. File
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5-42
: ',I,'W:.Springfield- East Springti,.q Kezone lrK'M'ilYS1~ "'''VI''''''
"
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_ EXHIBIT A-H
REESOR David' .,':
From: ,
Sent: .
. To:'
Subject: RE: Springfield. East Springfield Rezone TPR Analysis ~Review
,Attachments: LRP2007-00012 Trans mem01.DOC
: MCKENNEY Gary ,
. Tuesday, May 15, 20074:28 PM
REESOR David:
David -~-'
I believe Steve Wils~n is thiclcing in the context of an unconditi~n~d approval of_the PAP NZC.
Given the approach we planned to take in conditioning this approval, lthink onlyltem #18 ofhis noted
. issues is relevant to ensuring Goal 12 compliance." "
This issue was di~cussed in my April 4,2007 men;o to you (copy attache,d). I assume you can respond
to Steve's question on how wecilnclude that t~eassumedexisting-zoning development scenario is no .
moreintense.than "worst case." . ' . '
. . . - ~ . , . . ' '
. If we condition the PAPA to limit trips to less than orequal to what would b~ generated by the "wors't .
case," all the other issues appear moot. .
Gary
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,---,-~,~_.__._----
From: REESOR David,
Sent: Monday, May 14, 200710:34 AM
To: MCKENNEY Gary . ,
Subject: PN: Springfield" East Springfield Rezone TPR Analysis Revie:-v
Gary-
..-'.,
What are your thoughts on the attached memo?
. '
-DR
-.-------.-.---.---
From: ~100RE Ed W [mailto:Ed.W.MOORE@odot.state.or.us]
Sent: Monday, May 14, 2007 8:06 AM
To: REESOR David; MCKENNEY .Gary
Subject: PN: Springfield - East Springfield Rezone TPR AnalysiS Review
FYI
,5-43
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EXHIBIT A'~- 3
"
, REESOR David
__ From: MOORE Ed W [EdW.MOORE@6dot.state.or.us] .
Sent:' Monday, May21', 2007 3:14 PM'':
. To: ,REESOR David
Subje,,!: RE:PeaceHealth Plan and Zoning MapAmendment'
Dave, that is what we agreed to at our meeting and it still hold for us. Ed
--'--Original Message----- .
. From: REESOR David [mailto:dreesoc@ci.springfield.or.usj .
Sent: Monday, May 21, 200711:49 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 -00013&' ..
ZON2007-00012). Based upon the meeting you and I had with Gary McKenney, we are 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.underexisting zoning (LMI). Does this sound correct to
you? " .
Thanks, "
David Reesor
Planner III
City of Springfield
541.726.3783
5-44
: . FW: Springfield ;Eas( Spring!; "Kezone TI'K.1\IlalY~l~ MV1CW ,
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_ '~d-Original Message:......
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From: .WIL?qN Stephen.S .:. '.'
.. S~nt: Friday, May 11,2007 10:03,AM' .'
" '. To: MOORE EdW .. . . , .
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. Cc: jimhanks@jrhweb.com' WARREN O.avld; LEE Jane 5; SPAETH Mic.1ael. A; SANTOS Dennis N
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'.Subject:. Spring.field : East Springfield,Rezone TPR Analysis Re....iew'
,Ed... '
This is my technical review ~f this TIA submitted by JRH:
, '
: getting this revi.ewout.
, <<E~st Springfield RezoneTPRAnalysis Review.pdf>':, '
Stephen:J1. WilMJ.tt,P[
. 'Senior Transportation A~alyst
ODOT - Region 2 Tech Center' "
.' 455 Airport Road SE- Building 'A'
Salem, OR 97301-5397 '
. (503) 986-2857
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... ....t:I-........."-.....
'; EXHIBIT A-12
I apologize forthe delay in '
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Maich 15,2007
. Type lI:,Metro PI~mlEast'Main RefineIllent Plan
. .' .
. Diagram Amendments
Written Explanationof the Proposal .
Applicant:
. '.. '"
.' PeaceHealth Oregor Region
Ih '
. .770 E. 11 Avenue
. P..O. Box \479
Eugene, Oregon 97440 '
Property Owners:
, Hyland Business Park, LLC (Tax Lot 400),
\941-A Laura Street'
Springfield, OR 97477
At\n: Shaun Hyland
(541) 726-8081'
'.
Andrew Head (Tax L()t 402)
\616 Ardendale Ln.
Eugene, OR 97405 .
(54\) 521-3403 ",
Applicant's
: . Repr.esentative:
Philip Farrington, A1CP
Director, Land Use Planning & Developm~nt
, PeaceHealth Oregon Region .
123 International Way'
Springfield, Oregon' 97477'
(541) 686-3828' Fax (54\) 335-2595
P farringto n@peacehealth.org
1.0' Land Use Request
PeaceHealth Oregon Region (the "Applicant"i requests approval to change the map
, designation on the Metropolitan Area General Plan ("Metro Plan") diagram from Light
, .Medium Industrial CLMI") to Community Commercial ("CC") for approximately 5.24 ,
acres identified as Tax 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 Springfield
zoning map from LMI to CC, asallowed in Springfield Development Code CSDC")
\2.020(1)(a)1.' '
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, Metro PlanlEMRP Diagram Amendment
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. The area subject to the proposed land use ciesi~ation changes is mapped on Attachment
A, and is referred to collectively in this application as the "subject properties"or "site." .
"Pursuant to SDC 7.110 (4), approval of the' requested Metro Pian 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'S belo\v).: '
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.2.0' Project Purpose, Relationship to East Main Refinement,Plan
The Applicant seeks to redesignate and. rezone the subject,properties to CC so they may
. be developed forcoIlliI1ercial uses (i.e., Tax Lot 409), including a possible future medical
clinic which could serve residents in the growing east Springfield area, and to be allowed
. to continue long-standing commercial operations (Le., Tu'xLot 402). Approval of this
land use request \Yould' preserve employrnent and existing viable' commercial operations
on Tax Lot 402, and create stable family-wage employrnent opportunities on Tax Lot 400
_ a vacant and Ul1derused industrial 'site. The propo'sal would also help beautify this ,
portion of Main Street from its traditional.industrial yard uses, and future development.
would provide a superior buffer forresidential uses to the west than currently exists.,
.0. .. . -
. The proposal is 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 proposal '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), therefore providing
opportunity for improved buffering between abutting residential and non-
residential uses. Tax Lot 402 borders orily Tax' Lot 400 and two commercially
zoned parcels, so legitimizing the pre-existing commercial uses on that property
,\Yould not affect the existing residential area nearby
1 .' .
b). It does not ipcrease conflict between Low Density Residential and Commercial
uses, but in fact can pr'ovide 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 w~st is zoned Medium Density".
Residential, though in primarily 10\Y density residential use. .
c) The criteria fo'r designating Medium Density Residentialland,does not apply
because the subject properties are not currently developed, nor have they ever
been designated, for MD Ruses.
d)' Legally created commercial uses have existed onthe properties, and the proposal.
\Yould facilitate higher quality commercial uses (such as medical offices) than
have existed before on Tax Lot 400, 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, \vith existing curb cuts directly'onto
. Main Street . . '
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'l) Upon approv~l Qf this request, the'site wouldhavea Commercial designation' on
the Metro Plan diagram. .' . .... '
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The proposal is also 'consistent with EMRP Policy 2: "Apply site-specific Commercial
, refinement plan designations' to clearly define the limits Qfnew commer'cial uses where
. .'there is not an existing; legally established, and beneficial I~ixing of uses.': (pg. 12) The
proposal to. allQw for a broader, more beneficial range of commercial and employment-
" generating uses on the subject properties. It would also improve the area arid better
distinguish ,and buffer adjacent residential and industrial business park uses. .
,
3.0 >"Site Coni~xt' .
, The subject properties include a vacant, flat parcel (Tax Lot 400) and existing
'commercial development (Tax LQt 402). east of 44th Street alQ,ng' Main Street in east
Springfield. The site is bQrdered on the south by Main Street, o~ the east by the Hyland
Busines~ Park, on the north by an Qpen area south oftlje Weyerhaeuser mill site (Tax Lot
400) or an existing c'ommercially zoned parcel (TaxLot402), and on the west by other' . .
small.scale commercial enterprises (e.g., a cabinet shop and karate school) franting Main
Street and residential homes along 441h Street west of Tax Lot 400. Commercial'
enterprises are located immediately SQuth of the site across Main Street (e.g., Gray's. '
. Garden Centei'). .
, While historically involved in agricultural ,uses, since arQund ,1990 Tax Lot 400 was us'ed
as a stQrage and sales yard for landscape organics and fQrest by-products.' The current
property owners also. used'the site to stare modular construction offices, taol trailers,
, cQnstruction equipment and concrete form plywood; Tax' LQt 402' has had variQUS
,commercial services Qn site since the 1950s,
The properties have no. jurisdictiQnal \Yetlands or inventoried Goal 5 natural ar historic'
, resaurces. The' site is within the ,Springfield Urban Growth BQundary, and both parcels
" \Yere annexed into. the City af Springfield in 1960. The EMRP diagram (adopted in
'1988) currently designates the subject property for .industrial uses. '
, The abutting propertytQ th'e east is designated Light/Medium Industrial in theEMRP
diagram and zoned LMI. The areas immediately to the west and SQuth of the site fronting
.- Main Street are identified as being within Mixed-Use Area #2 in the EMRP, and are all
zoned Community CQmmercial. Property t~the west of Tax Lot 400 alQng 44th Street is
zoned and designated Medium Density Residential.
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4.0. Type II iYIet~o Phn Diagram Amendment'
Amendments to the rYletroPlan are classified as Type I or TyPe II amendments,
depending upon the specific 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 defmes Type II amendments as: . .
'![A]nychange to the Plan diagram 'or Plan text that is site specific
'andnot otherwise a Type Ccategory amendment.':, .
The proposed amendment is'~ Type IIsite"specific amendment because it:
". .
. Involves'a specific geographically identifiable property;
. Does not change the metropolitan Urban Growth Bou,nd,ary;
, .. Does n~t charigethe Metro Plan'jurisdictional boundary;
. Does not require a goal exception;
.. Does not include a non-site~sp:ecific amendment of the Metro Plan text; and
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. Appliesonly"to property l?cated within the Springfield City limits,
Accordingly, the current proposal is properly characterized as a Type II amendment (as
defined in SDC'7.030) that must be reviewed' and approv~dby 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 caribe.initiated at any time. .' .
5.0 Applicable Approval Criteria "
Type II Metro Plan amendments are evaluated according:to the criteria of approval
contained \vithin SDC 7.070 (3), which provides: .
"The follo\Ying criteria shall be applied by the City'Council i.n
approving or denying a Metro Plan amendment application: .'
(a) The amendment must be cOl1s{stent with the,relevant.
S'tate\Yide planning goals.adopted by the Land
Conservation and Development COm.rrlission; and
(b) Adoption of the amendment must ,not make the Metro
~ . .
Plan internally inconsistent."
Fin~irigs demonstrating consistency with the approval criteria are outlined below.
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, ',5.1 Consistency With Statewide Planning Goals .
The following findings address compliance with Met~o Plan criteria iIi SDC 7.070 (3)(a).
Approval of a Metro Plan diagram amendment also correspondingly changes the
:applicablerefinement plan diagram, as established inSDC 7.110 (4). '.
. Goal'l - Citizen Involvement . .' .
" Goal I 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 \Yill 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 ofthe public hearings will also
be given in accordance with SDC requirements to nearby property ciwners, interested
parties requesting notice, 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 1. ' ".
Goal 3 - Agricultural Lands
This' goal is inapplicable because as provided in OAR 660-IS-OOO(3),GoaI3 applies only
to rural agricultural lands. The subject properties are located within an ackno\Yledged
urban gro\Yth boundary, are inside Springfield's corporate limits, and have not been in '
agricultural use for decades. ' .'
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Goal4 ~ ForestLands' .' '. , '., .'
Goal 4 does n,ot apply' within urban growth boundaries', per OAR 660-06-0020, and ttje
areas affected by the Plan amendments are,inside Springfield's ackIio\vledged DGB.. .'
GoalS - Natural Resources .
. Go.al5requires 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 apart of periodic review to
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(1) .identify such resources;
(2) detennine their quality, quantity, and lo~ation;'
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identify conflicting uses; ,
'(4), examine,the economic, sci~ial, enviro~ental, and energy
(ESEE). consequences thatcould restllt from allowing,
'limiting, or prohibiting the conflicting uses; iui.d
(5).. develop programs to.resolve the conflicts.
The subjeCt properties are not on Springfield's a~kno\Yledged Metro Plan GoalS
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 Springfie'ld Local Wetland Inventory maps have been'
consulted and there are'no jurisdi~tional wetlands'locatedon the-site., Therefore, the
. proposed amendment.does not alter the City's comPliance with GoalS.'
Goal 6 _ Air, Water'; and Land Resources Quality
,
The purpose of Goal' 6 is to maintain and improve the quality of the air, water and land
resources of the state. Generally, Goal 6 requires. that development comply with,
applicable state and federal air and \Yater 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..
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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 corducted and recommended
additional analysis. Upon recommendations through the Phase? environmental .
assessment a nominal. quantity of soil (less than lO cy) impacted by earlier/historic use
. \Yas removed from the site and properly disposed. Given the nominal impact generated'
by historic uses on the Slte, It lS reasonable to conclude that future d~velopment 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.
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Goal7 - Areas Subject to Natural Hazards '. '
Goai 7tequires that development'subject to ~amage 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 ofkno\vn 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, approv'al of the proposed Plan, .
,amendments will not alter the City's acknowledged compliance with Goal 7 through its
adopted plans, codes and procedures. '
., , Goal 8 - Recreation'al Needs. ,c
Goal 8 requires local goverrunents to plan and provide for the siting of necessary
recreational facilities to "satisfv the recreational needs of the citizens of the state and" .
,~ . . " .
visitors," and where appropriate, provide for the siting ofrecreational 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.
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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
developme'nt by adding 5 acres ofCC.in place'oftheexisting industrial designation,
Permitting the construction of future clinic facilities and allo\Ying long-standing"
commercial uses onTax Lot 402 to beco'm'e conforming uses consistent with commercial
zoning is consistent \Yith numerous policies in the City's adopted plan for compliance
with Goal 9, the Springfield Commer~ia1 Lands Study (SCLS)..
Specifically, the following,SCLS policies are applicable 'to the proposal:
Policy I-A: ."Maintain a mixed supply of large' and small commerCialsites
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, fodwo tax lots of varying
sizes and commercial uses, thereby maintaining 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, . , .
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Policy 1-e: "Maintain at least a five-year'supply of commercial land
within the Urban Growth Boundary (UGB) that is currently served or
readily serviceable witll a fullrange'ofurban public facilities and,
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serVices,
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The SCLS (se~ Table 3'-8, pg. 32) found th~re to be a deficitof 158 acres in the supply of
commercial land over ~emandprojected through the year 2015. The proposal would .
'allow for redesignation, and rezoning, cjf 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 development on Tax Lot 402, and future "
development on Tax Lot 490. The SCLS identities (pg33) a need to support
"employment in populatio'n-dependent sectors such as ietail sales and health services" to
meet 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 services, sectors.
Approving the proposed redesignation and zone change would help meet' Springfield's
. demonstrated need for employment and commercial services.
. '
Finding 3 in theSCLS(pg. 36) cited the acknowledged 1992 lridustrial Land Study as
demonstrating that "asurplus of industrial sites exists in the Metro Area." Therefore, the
proposedredesignation (and corresponding rezoning) would no[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 ly!etro Pian."
The proposal in fact consistent with'inventories for commercial' and industrial lands
adopted by the City Council and acknowledged by DLCD as being consiste'nt \Yith Goal
9. Oregon Administrative Rules concerning Goa19 implementation (OAR 660-009-
00 10( 4)) call for amendments 'to land use designations "in~xcess of twq acres within an
existin'g urban gro\Yth boundary from an industrial land Lise designation to a non-'
industrial use designation".to have to address applicable planning requirements - such as
consistency with. the Metro phU1 '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 relevant local plan policies by converting one fonn or emplO'yment,generating land
use to another, \Yithout negatively impacting the supply of buildable lands for either, .'
, category of uses. The proposal enables continued use of the existiriga'nd long-standing
commercial center to continue to operate and provide employment opportunities, while
also allo\Ying higher-value employment associated with future development on Tax Lot
400. These types of employment-generating uses are among tnose identified in OAR
. 660-009-0005(6) as eligible non_industnalemployment activities that can justify
. approval of the proposed Plan diagram amendment \Yithout the need for an economic
opportunities analysis apart from the SCLS, \vhich DLCD acknowledged as fulflllingthe
City's obligations underGoal 9.
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BeC:lUse the requested redesignation and concurrent zone change implements SCLS
policies and do.es not result in a deficiency of needed industrial lands, and is otherwise
demonstrated to be consistent \Yith relevant.Metro Plan policies, approval of the request
is consistent with the Clty'S compliance \Yith Goal 9 and applicable administrative rules
.regarding Goal 9 implementation.
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. , Goal 10 -'Housing
LCDC's Housing 'goal requires cities to maintain adequate supplies of buildable lahds 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 ofth~ requestedredesigfJation for TaxLot 400 would enable
redevelopment of an industrial site abutting existing residential development. Thro~gh
. the site plan revie\Y 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 uses, it does not
affect Springfield's continued compliance'with Goal 10. ' '
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" Goal 1.1'-: Public Facilitil!s 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 SpringfieldUGB and .,'
.' city limits, and is ~lreadydesignated forurbim levels of use. The proposed amendment to"
the Plan map designations from LMl 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 oIl the subject site. ' ,.' '
Goal 12 - Transportation ".
Goal 12 requires local govemments to provide.and.encourage a safe, convenient and
economical transportation system.' The proposed map amendments involve
appro,ximately 5.24 acres of property, though existing and 10ng_standingcOn1mercial uses
occur on Tax Lof402 s~ch tnat appi'ovalof theproposal will not result in any changes to,
the type or intensityof uses on the site, and will not;increase the trip generation for that
.parcel. As the attacheCl Traffic Impact Analysis (TIA) demonstrates, future development
of medical.. office facilities on TL 400 \Yill not degrade mobility standards belo\Y
acceptable levels and allo\Y for adequate queuing lengths at applicable'intersections. .
Therefore, the proposal will not have a "significant effect" on transportation facilities as . ,
defined in the Transportation Planning Rule (OAR 660-012-060).
Existlng 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 revie\Yed
through the site plan review process,therebY'cons~lidating 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 point~.will not result in any degradation
of mobllity standards below acceptable levels, arid tha.t safe and efficient circulation can,
be realized through approval of the requested land'use redesignation (and companion ,
. zone change):
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Furthermore, reducing the number of access points foe future development on Tax Lot
'400 is consistent with policy objectives found in East Main Refinement Plan (EMRP)
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Access, Circulation & Parking Element policy lB (pg. 17) and Commercial Element
policy 3 (pg. 12). ,.' ,
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Because the propos'al, as demonstrated in the TIA"is consistent with the requirements of
the TPR andwitli'applicable policies in the EMRP, it is consistent with Goal 12 and
appllcable local. implementing policies.' ,.
Goall3 - Energy Conservation .. . . '
The Energy goal is a general planning goal and provides limited guidance for
site-specific map amel}dments. The proposed amendment has no direct impact on energy
conservation, though it would in fact will promote greater energy efficiency by enabling
,needed clinical ser:vices available to growing reside;.ntial 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
. Goal 14 requires local jurisdictions to provide for an "orderly and efficient transition'
from rural to urban land use." The subjec't property is within the UGB and the city limits
of Springfield, and within an existing urb~nized area of the community., Therefore, Goal
14 is not applicable to this application. ",
Goans _WiJlamettc River Greenway ,
This goal is inapplicable because the subject property is not within the boundaries ofthe
Willamette River Greenway.' .
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'Goals 16-19 - Coastal Goals
The c~as'tal goals are not applicable to this application.
.'
5.2 Metro Plan Consistency.. . . ' .
The application requests amendment of the' Metro Plan diagram from LMl to CC for
approximately 5,24 acres. This section p'fthe applic'ation narrative addresses the
conslstency of the amendment with the applicable policies of the.Metro Plan, to
demonstrate that adoption of the amendment \Yill not make the Metro Plan intem'ally
inconsistent (as requir.ed by the approval cnteria in SDC7.070(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 speciflc development applications (e,g"
site plan revie\Y submittals or subdivisions). in many instances the goals, policies and
, implementlltlonmeasures apply to specific development proposals that will be addressed
.,
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tlll-ough c~mpliance ';"ith appli~able City regulations during site plan review of a given
future development propo~al.' ' '
The Metro Plan Introduction, Section D provides the follo\Yingdefinitions:' .
A goal as a broad statement of philosophy that des~ribes the
,hopes of the people of the community for the future of the '.
community. A goal may never be completely attainable, but
, isused as a pointto strive for.
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An objective is an attainable target that the ~ommuri.ity , .'
". attempts to reach in striving to meet a goal. An objective may
also be considered as an intermediate point that will help
fulfill the overall goal. . . '
: A policy is a statement adopted as part of the Plan to provide
. a consistent course of action moving the community towards
attainment of its goals. '
, Except for the Gro\Yth 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. .' . .' .
5.2.A.
. Metro plan Elements
1. Growth ,Management
'Policies
1. The urban growth boundary arid seqilentiaI development shall
continue to be implemented as im' 'essentilil means to achieve
compact urban growth. Provision of all urban services shal! be
, concentrated inside the urban growth boundary.
The p\oposedamendments 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 infill
development resulting approval of from this application. The City's site plan review
processes ensure that the appropriate levelof services is available to. serve future
., development. .
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'Metro Pl.niEMRP' DiagramAIDendment
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PeaceHealth Oregon Region,
Marco, 1,5 ?007
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2, Residential J,..and Use a'nd Housing Element" .
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. Policies :.
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A.II . Generally 10C{lie higher density residential d~velopment~iiar;
employment or co~mercinl service~,in proximity to major ", '
trilnsportdtion systems or within trllllsportiztion,-efficient nodes.
., - .1
.' . ," .f
'.The proposed redes,gnation'does not affectthe inventory or availability of residentially
designated orzoned,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 ~long Maip Street.
"
. . . - -
Ho\vever, approval of the requested redesignation to Community Commercial\vould
. allow for residential areas prox\m~te to the subject area' to have close and efficient access
to existing commercial services on Tax Lot 402 and to fut,ire medical facilities proposed
, for Tax Lot 400, consistent with the above policy. 'The are~sproposed for redesignation
offer existing and future employment opp.ortunities and provide commercial services
along a major transportation system that can support the needs of nearby residential'
development. " . , .
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A.22 Expand opportunities for a mix of uses in newly developing are~s'.
ahd existihg heighborhoods thrO!lgh local zoning and development.
regulations.' ,
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The map arriendment'and.concurrently proposed' zone change \Yill allo\Y 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 iequested redesignatio.n and zone
change \Yould expand commercial opportunities to serve.these neighborhoods consistent'.
with the above poli~y.. ." . .
3: Economic Element
,I.
policies
B.] Demonstrate a positive interest in existing and new industries,
especially those providing above-above wage and salary levels, and
increa~'ed variety of job opportl!nities, a rise in the standard of living,
and utilization oj our existing comparative advantage in the l~vel of.
education and skill of the resident laborforce.,'
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PeaceHealt~ Oregon Reglon .
March' 1'5, 2007.
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)'he proposed' amendment is consistent withthis 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
servic'es is growing and approving the requested redesignation will enable in~reased job
opportunities with higher than average wages thereby helpingraise the standard ofliving
and meet the needs of Springfield citizens, consistent with the above policy. ' . :
B.? Encourage economic dev~lop~;ent whiclri,tilizes local and imported,
capital, elitrepreneLlrial skills, and tire resident labor forse. .
". ' ..~
The The construction of and the use of commercial and medical uses will utilIze both
. local and impol1edcapital and will employ the 10caJ labor force in a variety of skilled,
semi:?killed, and unskilled positions,consistent with thispolicyc ' . , . .
'. B.6 Increase the amounl.df lInd~velopd hind zoned jor light'industry,
and commercial uses correiating.the effec,tive sllpply in terms of
suiuibility aM availability with 'tlre projections of demand. ,
The prop6salwilladd approximately 5.24 acres of CommtmityCommercialland:
consistent with recommendations to increase'the commercial lands invento'ry made in the
. Springfield Commercial Lands Study. The SCLS ~nd acknowledged metropolitan
Industrial Lands Study concluded that there is a deficit of needed commercial land, and a
surplus'of ind1.1strially zoned and designated land. Approval of the requested
redesig;lation will not cause the inventory of needed industrial land to go into a deficit, '
.but in fact \vould,:consistent with the above policy. The proposal correlates theneed 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 eClmomic aciivitieswhich strengthen the metropolitan
area is position as a regional distributiqn; trade,. health, qnd service
-.'.
center.
The amendment will facilitat'e the development of medical uses that will serve the needs
of the gro\Ying 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 objectJve. ' ' ,
6. Environmental Design Element,
policies
E.l In ;Jrder to promote the greateSt pos;ible degree of diver;ity, ,a broad
'variety of commercial, residential, al1drecreationalland uses shali be
encouraged whet! consistent with other planning policies. . '
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"r,larch 15,2007 .
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, Approval oftheproposed 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 subje'ct property. Long-standing existing
commercial services on Tax Lot 402 \Yould be allowed to continue without the specter of
being considered non-conforming uses, and Tax Lot 400 could be developed with
medical services tha't will serve the needs of the grov-:ing residential areas east and south
of the subject site, consistent .with the above policy. '
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7. Transport~tion Element
Land Use policies
'j "
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F.J.' Providefor transit~supportive land use patterns a~d development,
including higher Intensity, transit-oriented developmen( along major'
. transit corridors and near transit stations; medium- and high-density
residential development within one-qilarter mile of transit stations,
major transit corridors, employment centers, and downtown areas; and
. development and redevelopment in designated areas that are or could be
well s~rved 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 \Yill allow"
for higher intenSIty development along Main Street, a major transit corridor., An existing
L TD stop is located on the frontage ofTax Lot 400 (see pb.oto, pg. 2, Appendix A of the
TIA), and \Yill 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. . .
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Metro'PlanlErV!RP Diagram Amendmen( .
PeaceHealth Oregon Region
March \5 2007 .,
Page \5
'Tran~por'tation Systemlmproveinents: Roadways Policies
,F.15 Motor vehiclelevei Ofservicepoli~y: ,
a. Use motar vehicle level af service standa~ds to maintain acceptabl~'
'. and reliable performance an the roadway system. These standards
.'~~~~ "
(1) ldentifyiitg capacity dejiciencies on the roadway system.
.' (2) Evaluating the impacts on raadways of amendments to. .
transportation plans, acknawledged comprehensive plans and'
land-use regulations, pursuantto.the TPR (OAR 660-012-
. 0060).' . .
.(3) Evaluatingdevelapmer;t applicatio,,;'jar consistency witli the
'land-use regulations: of the applicable local government
jurisdiction..' ' .
,b. Acceptable a'nd reliable perforniance is dejined by the follawing
levels of service lindeI' peak hour traffic c'onditians: LOS E .within
'Eug~ne 's Cetltral Area Transportatio~! Study (CATS) area, and
LOS D elsewhere. ' . -
c. Performance standards from the OHP sillill be applied on state
j~cilities in the Eugene-Springjield m.e~ropalitan area., '
In some cases, the l~vel af service may be sl!bst~ndart( The local
gowirnmentjurisdictian may find that transpartatian system
improvements to bring perfarmance up to 'standard within the planning
horizan may.not be feasible, and safety will not be compromised, and
broader community gaals would be better served by alia wing a
substandard level of service. The limitation ontlzefeasibility afa
tra'nsport,ition system impravement may arise from severe constraints, .
including but not limited to enviranmental canditions, lack afpublic
agency jimUlcial resources, or land use constraint fa ctars. It is nat the
intent afTSI Raadway Policy #2: lvIotar Vehicle Level of Service to
require deferral of development in such cases. The intent is to defer'
motor vehicle capacity increasing transportation impravements until
existing constraints can be overcome ar develop 'an alternative mix of,
'strategies (such as: larlll use measures, TDL'vI, short-term safety
impravements) to. address the problem.
, .
Subsection a.(2) in the above policy requires an.evaluation of the proposal pursuant to the
state Transportation Planning Rule (TPR) The accompanying Trafflc Impact Analysis
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provides the factual basis to. determine that th~ propose,d redesignation would not result in
a "significant effect" as defined under the TPR (OAR 660~012-0060(1)). '
. '
Specificall y, the proposal does not 'changethe fi.lrlctional 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 th~ T1A, the proposal also does not:
. Result in types or'\evels of trafflc or access' that are inconsistent with thefunc'tional ,
. classification of Main Street or any other nearby roadway; . , ,
. Reduce performance oftrafflc on Main'Street or other affected intersections to a level
that is below acs;eptable established performance standards; or"."
. ,Make performance of existing facilities worse (i.e., below acceptable mobility'
standards) than would. be the case other u~es permitted under'.existing designations or
,zonmg. '
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 requi~ed. The request is therefore consistent \Yith the above policy.
8. Public Facilities and Service Element
G.1 Extend the minimum level andfllll range of key llrbanfucilities and
services in an .orderly and ejjicient miinner cOllsiste.llt with the growth
management policies in ChapterlI-B, relevant poliCies in this chapter alld other
l'vl etro Plan policies.
. The subject property is located in Springfield's city'limits VGB. 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 pol\cy. . .
, .'
9. Parks and Recreation Facilities Element policies
Policies in this element of the Metro Plan are not relevant to the requested diagram'
, amendment. .
10. Historic Preser;ation Element Policies'
Policies'in this element of the Metro Plan are not relevant to the requested diagram
amendment.
. 5-61
Metro P\aniEMR? Diagram Amendment ' '
PeaceHealth Oregon Region
March 15 2007
Page 17
11. Energy-Element policies,
. Policies in this element of the ivIetr~ Plan are not relevant to the requested diagr'am
, amendment. ' '
,',
. 8.0 East Main Refinement Plan Consistency , . , '
'The follo\Ying' demonstrates how the proposal is consistent with applicable policies in the
. East Main Refinement Plan (EMRP), ~ '
. 1. Mixed-Use Element
. Policy 2) Area #2
",
A) TheJollowingland uses are allowed under Community Commercial
zoning:
. All Communitv Commercial uses subject to Article) 8.oJ 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 allo,v long-standing
existing commercial uses on Tax Lot 402 to continue as permitted under Article 18, and
consis\ent with neighboring uses to the west and south, which are also zoned and
designated for commercial uses.
"
2. Commercial Element
Criteria (or, CommerCial Refinement Plan Desi!!nation.
1., Generally, 'the Com'nitlility Commerda{refinement plan designation
shall be applied tinder the following circtllllsttlnces:
(
AJ. 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.
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. B) }~h~re itdoes not increa~.e conflictbetweeii Low Density
,,,.'. . Residential and COl/lmercial;
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 subjectsites would actually result ina decrease of c~nfEi;ts' '.
" 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 'thisresidential area' '
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r'. '
,C) wltere ~riteriafo"designating ly'!edilll/l..Density Residential
land does no't apply;': ' .
Criteria for designatingMDR lan~ does n6t apply to'th~'subject ~ite.
.' D) whe~e legally created commercial llse!upcist;
T;x Lot 402 has existing, long-standing commercial ~ses that were legahy created
prior to development of the Metro Plan or EMRP. . "
E)
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where adequate cllsto;ner and ser~ice access to an arterial'
.. . .
street can be provided; .,. and '. .
,0',
The subject site has adequate legal access onto Main Street, which is classifi'edas
an arterial str'eet. . '
F) where des~gnated Commercial on the..Metro Plan Diagram:
Approval of this application would result in a Commercial designation on the.
. Metro Plan diagram, which \Yould also automatica.lly modify the designation on
the EMRP diagra.m. ' .
.
Policy 2) Appljsite-specijic Commerci{lh'ejin~ment plan designations:
to clearly dejine the limits of new commercial uses where there is not an
existing, legally established, and benejiciai mixing of uses. ,
Approval of the requested redesignation \Yould apply Commercial plan designations. to'
the subject properties, allo\Ying the existing, legally established coinmercial uses on Tax
Lot 402 to continue. It would also enable commercial uses to be established on Tax Lot
, 400, thereb y 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
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, Metro PlaniEMRP DiagramArnendment
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Page \9. '
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'. . the proposal w~uldd~fine the limits of new commercialus'es 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.
, Policy3) Reduce the number of vehicular access points and require the
rebuilding 'oj wrbs and installation oj sidewalks and street trees along
Main Street, through the Site Plan Review process and in public.
improvement projects.
.,f'.
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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 asingle driveway access onto Main Street, eli;-ninating one 'of the two existing curb
cuts on this site. Side\Yalksand street trees are already located along its Main Street
. frontage, consistent with the above policy. .'
Policy 4) provide bufJering between coi/lmercial and r~sidimtialuses.
throughArticle 31 oJthe Springfield Developme/lt Code, Site Plan
Review pr!:icess.
Exi~tingresidential uses along the east side of441h 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 \Yould provide (through the
SPR process) improved landscaped buffers between the future use and existing
" residential are,\ to thewest - as required by Code, and consistent withtheabove policy.
3. Industrial Element
PolicY 1) The City shall encourage effo rts oJ various age/lcies to attract
,'/lewa/ld retaih existing jobs and bu~ine~s:s.: '
,lmolementation '
The City shall maintllinll current inventory iJJvaca/lt commercial a;rd
indusiriullllnd aizd structures withi/l the Eastlvlain 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 us'es, and allo\Y future development ofnew employment on Tax Lot 400
with higher than average wages and employment densities than the current designation
and zoning allo\Ys,' .
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Metro Plan I Refinement Plan
Amendment Application'
#LRP2007-00013,
Rezone Application
,#ZON2007 -00012
~..
Metro Plan Amendment fromLMI to
Commercial and concurrent Zoning
.Map Amendment from LMI \0 CC
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P:rope. ?laniling &. Development
m f>eaceHe'alth
....
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March 28, 2007
. ~r; ..
David Reesor, Planner II ' .
City of Springfield
, DeveloprnentServices Department'
225 Fifth Street _
Springfield, OR 97477 .
.'
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Re: Pla~ ,Amendment (LRP2007 -000 13), Zone Change (ZON2007 -00012).
',-
Mr. Reesor,
. . - ,.- . ..
,The following and attached is supplemental information for the above-referenced:
applications for proposed Metro Plan diagram arnend~ent:and z~ne change in east
Springfield." .' .
The proposal seeks to redesignate and rezone approximately ~.24 acres ontwo'parcels
'.from Light-Medium Industrial (LMI) to Commercial. As noted in the application
findings submitted last week, the Springfield Commercial,LandsStudy demonstrates that'
the City has a deficiency in needed commercially designated and zoned land, so '
'approving the proposal would help reduce the identified defi~it in t~at,land use category.'
'/
The Metropolitan Industrial Lands Study (July 1993)was,adopted by the local
jurisdictions and acknowledged by LCDC as being consistent with statewide planllirig
goals and the Metro Plan, specifically fulfilling the Eugene-Springfield area's obligations
under Goal 9 (Economic Development). The Metropolit~n Industrial Lands Inventory, .
Report associated \Yith the MILS identified "about 1,688 constraint-free industriai
acres....Thissupply 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 perforrhed subsequent analysis of industrial land supply as part of periodic
review requirements to dem'onstrate compliance with statewide planning' Goal 5 (Natural
. Resources), As shown in Attachment A, that analysis indicated that even removing the
, possible industrial acreage affected by Goal 5 protection measures (about 100 acres
debited from the Eugene and Springfield inventories) would leave a surplus of.industriil
'lands of between 1,600 and 2,122 acres metro-w,ide.
Staff s GoalS work also calculated the changes in lndustnalland supplies since 1991 as a
consequence of Metro Plan diagram changes (see Attaclirnent B). This analysis'
derponstrated a 'reduction in less than 90 acres of industrial land over the past IS years,
Phont::
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.(541) 3:}5~2593 .
(541) 335-2595 , ~
Ri'ler8end Annex; 123 lntern;alional Way Springfield,.OP;.97477
. \AI'"";^' rlC><:lrphp.::Illh' nro/ore,Qon . 5.....;,71
f?edicore,.f to Er('cprioi7.ul A/edicine
O!/(! Compos,~'i()i.W[e Core
:,.
, . suggesting that there is still an ample supply of available industrial lands to meet existin17
I.. ... ,. . 0::1
, and future developmentneeds.'. . " ' ' . ' . '
This a~alysis may also not reflect other changes within industrially designated land
cate'gories that would further off-set the proposed change to the site's LMI Plan.
designation and zoning. -For example, 11.5 acres was added totheinv.entory'ofLMI .
. zoned and designated land due to City Council approval in April 1997. for land east of the
. 28th/31Sl Street connector and north of Marc 01 a 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 LMldesignated and zoned land to
off-setthe 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 Industrial land and will not.,
'alter the City's continued compliance with Goal 9. .. . ' .
,With acceptance of the above findings and earlier findings and nau'ative 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 notice to DLCD formy files. _..'
,Thanks for your consideration ofthe above: If you need additional infottnation, please
contact me at your coiwenience.
,
:&~l!Ep., !~..
Director, Land Use Planning' & Development
PeaceHealth Oregon Region
Attachments
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5-72
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A TT ACHMENT A'
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- .- ..
. . . ... l' .".. .
,11.0 Impact ofthe Proposed Protections on Buildable Umd '
'lnventories " ," ,.' .' '. . .
.' ,.
This section estirnates the impact of the reco'mmended program for protecting
.Springfield's resource areas on the inventory of buildable residential, commercial and, '
indllstrialland. 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 surnlus of buildable larid that was determined at the adoption of
the inventory.' Case law supports subtracting the protected acreage from the surplus of'
buildaple land. . . .:
Tables 11-1,11-2, and 11--3 below sumlTlanze'the amount ofland that would be.
subtracted from the Eugene-Springfield inventories''Of surplus of buildable residential,
commercial and industrial lands that were iclentified when each inventory was adopted:
. .: '. '" ' .
. ._ J . . . .
Table 11-1. Analysis of Maximum Possible Impact on Supply of Residential
. Lands within the Eugene-Springfield Metropolitan Area' . . r., '
l'.
'Residential Land Supply'
Eugene-Sprinafield Metropolitan Area Residential Lands
o "
and Housing Study S~rplus Acres
Low Demand Assumption
or
High Demand Assumption
Acres Removed from Residential Designation by Previous
Plan Amendments'
Eugene
Springfield
" ,
Acres
Maximum Possible Residential Acres Impacted by .
Eugene Goal 5 Protection Measures . ,
, .
1862.00
or.
790.00
-84.90
-52,03
- 1:36.93
-445.77
.. .
".
-14.18 I
1265.12
or
193.12 J
Total
Maximum Possible Residential Acres Impacted by"
Springfield Goal5 Protection Measures
- Remaining Surplus
"
"
I
5-73
" .
.' ':
Table 11-2 . Analysis .of M.aximum Possible Impact on:Supply of'
Commercial lands within the Springfield Urban Growth Boundary ,.'
Acresl
-158 acres 1
I Commercial Land Supply
_J
.. Springfield Commercial Lands Study (2000) projects a deficit of
commercial land: ' .
\ Acres Removed from Commercial Designationby Previous plan
Amendments" ',',.; , ' ' '
\ Max, imum possible Commercial Acres Impacted by Springfield's
Goal 5 Protectlon Measures .,'. . ,
I Remainjno Sur Ius (Deficit)
-2.8 acres
-11.56 acr.es
(-I72.36acres) I
Table 11-3. Analysis of Maximum Possible Im'pact on Supply of Industrial
Lands within the 'Eugene-Sprillgfield Metropolitan Area .
I Industrial L';nd Supply
Metropolitan-'Industrial Lands Inventory, Report Surplus Acres
, , .Low Demand Assumption,
,or
"Hi~h Demand Assumption
. .
Acres Removed from Industrial Designation by Previous Plan
Amendments" ..
Eugene
Springfield "
Acres
_ J
2954.28
or
_ 1432.28'
,
-642.30
-90.80
-732.80
Total
Maximum p~ssible Industrial Acres Impacted by Eugene Goal 5 .
Protection Measures .
-44.73
. MaximumPossible1ndustrial Acres Impacted by Springfield
Goal 5 Protecti0n Measures . ~l
Remaining Surplus
-54.43
. , 2122.01
. or
_, ,_'" .." ., . 1.600.011
"Does not consider actions taken by Eugene to add additional lands to the surplus.
'11,.1 Impact on the Reside~tial lands IriYE::ntory :
In 1999, the Eugene-Springfield Metropolitan M~a Residential Land and Housing Study
(Residential Lands Study) estimated the amount of vacant b).lildable residential land in
the area. In Springfield, a total of3,087 acres of buildable lands were identified, The
Study classified wetlands listed on the Springfie1dLoc8:J Wetland Inventory as
unbllildable and \Yere not included. in the estimated supply of buildable residential lands.
Other types of constraints \Yere also considered and classified as unbuildable and were
not counted in the buildable residential land inventory. The list of constraints included:
.
Floodways;
'!
5-.14
,',
1
-,
"
WetlUndslisted on the Springfi'eld LocalWetlands Invep.torylarger than .25
acres; . ; '" , .,' 1.-,.
Land within the 'easement of 230 KV power lines; .
, Land within 75 feet ofa.Class A stream or pond;
Land within SO feet 'of a Class B stream or pond; and
, Small irregularlY,shaped lots.,
'. ,Since the Residential Lands Study d.id not inclllde 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 redllce that inventory. The
development setbacks recommended for significant wetland sites in this study will
. , slightiy reduce the inventoried acreage of vacant buildable land adjacent to wetland
features. ,. .
c,
,
. .:-.
.
.
.
.
t",
.
Wetland Setbacks
As noted in Table 1 1-4 below', about 9:95 acre~' oflow-densitj:residential (LDR) and .59 "
. acres of medium densityresidential (NlDR) land \vill.be removed from the residential
lands in~entory by the 25~foot setback recommended for those wetlands IJot already
protected by the 50 and 75 foot setbacks required by Springfield's storm\Yater quality , .
protection policies., Keep in mind t~at this is a worst case scenario and assumes that the
developer is uu'able to locate required stonTIwater facilities within the 'recommended" "
setbacks and that sllbdivision design cannot arrange for the yard areas of affecied
dwelling units to be placed adjacent to the wetland, thllS reducing or eliminating lost
development area.
Riparian ,S etbacks'
In addition to wetland setbacks, recommended riparian setbacks will also result in the
, . removal of vacant acreage from the inventory ofbuildabk residential lands. As noted'in,
Table'IIA, about 3.42 acres oflo\Y-density residential (LDR) and .22 acres of medium
density residential (MDR) land \Yill be removed from the residential lands inventory by
the 25-foot setback recommended for those wetlands not alread~ protected by the so arid'
75 foot setbacks required by Springfield's stormwater quality protection policies.."
The combined impact of the proposed 25-foot setbacks 'for \Yetlands 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 \Yas published, updating the
residential lands inventory to reflect development through 2003. The report estimated .
that at the end of2003 there was 1,361 acres of remaining buildable residential land in
. Springfield, ,The amount of land removed from the buildable inventory by the 25-foot
wetland and riparian setbaCKS proposed by this report represents about 1 % of remaining
1,361 acres,
5-75
. .
Table,11-4. Vacant Residential "Land witnin Proposed Protection Setbacks
. . . - .. . '
. . . .
. .
Setback Distance ' Vacant . Vacant. ' Total Acres. .
LDR lVID R
Acres Acres
I'Wetland Setbacks' I
I 25 foot 9.95 .59 10.54 I...
I 50 foot. 9.4 2.73 12.131
\ 75 foot . 4.97 4.15 9.12 I
I 'Total 24.32 7.47 31.791
'1 Riparian Setbacks I ,
t 25 foot 3.42 .22 3.64 I .
50 foot 6.06 2.73 8.79 I
1 75 foot 4.97 4.15 9.i2 1
\ Total 14.45 7.1 21.55 I
I Grand Total' 38.77 14.57 53.34 I
11.2 Impact on the Commercial Lands Inventory '/
The SpIjngfield Commercial Lands Study (2000) listed several types of development.,'
constraints that ~ffected 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;
. .
Floodway and floodway fringe;
Wellhead zone of influence;
Wetlands listed on the Springfield Local Wetland Inventory;'
Other potentially regulatednatural resource sites [Natural Resources Study
Inventory];' ','
Sites with Plan/Zone conflicts.
The Commercial Lands Study classified sites on theon the Springfield Local Wetland
Inv~ntory as constrained. The presence of these wetlands was noted and the inventory of
vacant commercial lands was rioted to reflect the constraint. The riparian sites which are'
part oOhis study were also includ'ed 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 the SpringfieldCo~ercial Lands St~dydid not remove wetland; and riparian
sites, protection measures proposed by this study will have an impact!Oll the inventoried
acreage of vacant commercial lands. The development setba~ks recommended for
significant wetland and riparian sites will further reduce the inventoried acreage of v.acant
. buildable commercial land adjacent to these resource sites. The extent of this impact is'
o ' . .
discussed below. .
The Commercial"LandsStudy concluded that the.re was abo,~t 85 acres of vaca~t
buildable commercial land in Springfield. An additional 12, acres was projected for
redevelopment by the Study bringing the total to 97 buildable acres. Demandfor vacant
comme.rcialland for the planning horizon 2015 was 255 acres. The 2000 Commercial. .
. .
Lands Study concluded that there was a 158 acre deficit of buildable commercial land. .
Wetland Impacts. .
Table 11','5 shows that .07 acres of vacant commercial land would be removed~om 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 i.47 acres of vacant commercial land from development. This figure - ..
assumes that the developer is unable to locate required stormwatei facilities or requir"ed
landscaping 'yithin the recommended setbacks, thus reducing or eliminating lost
. development area. .
.f.,"
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 Impacts
Table 11-5 shows that about"acres 2.78 of vacant commercial'land lie~ withininventori~d
. 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 vacantcommerciallarid will be removed from the inventory by the
proposed 25-foot setbacks.
The total imp~ct on the Commercial Lands Inve~tory wOllld be a reduction of 1.54 acres
if wetland and riparian sites and their setbacks were fully protec'ted. This'represents 1.8%
of the 85 acres of buildable commercial land described i~ the Springfield Commercial.
Lands Study.'. .,' ., .
Table'11-5. Vacant Commer.cial Land within Proposed Protection Setbacks
I Zoning Distril:t-
I Wetlands -:-
I Communitv- -. -
Site
Acreage
\25 ft.
Setback
1
,07 I 1.47
50 ft.
Setback
75 ft..
Setback
Total'
Acres
I
I
1.65 I
o
,11.
5-77 .
, '1 Zoning District . 25 ft. - - -. .- --
Site 50 ft. 75ft. Total 1
Acreage Setback Setback Setback Acres I
I Commercial --.- n_
. \ Neighborhood .0 0 0 0 0
. CommercIal ,
I
I General Office 0 0 0 0 " ~i
Major Retail 0 0 0 .0
Commercial .. I
Wetland Total 0.07 1.47 0.11 .0 J',65 \
\ Riparian Areas
'\ Commuruty 2.78 0 0 2.6 5.38
Commercial
\ Neighborhood 0 0 0 0 0
Commercial ..
General Office 0 0 0 0 0
Major Retail 0 0 .24 0 .241
Commerc"iai . ' ,
"
I Riparian Total 2.78 0 0.24 2.6 5.62
1 Grand Total I 2.85 1.47 .35 2.6 7.27
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 ofbllildable 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.
F or that reason, protection of 'v.etland and riparian lands under the policies proposed by
thi~ study will reduce the inventory ofbllildable industrial lands. The extent'ofthis
'. . impact is discussed below. '
. Wetland Impacts'
. GIS analysis shows that about 30.64 acres of vacant industrial land are affected by .
\vetlandsthat 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 Lapd 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 wOllld 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. .
Riparian Irripacts
.'
.,
5-7~
, "
.-,.
. GIS analysis shows that 13:70 acres of vacant industriallandare.affe~ted 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 tinder the Springfield Nafural Resources Study.':rhese setbacksadd '
another 3.27 acres to the amount of industrial zoned land'thai would be removed from the
Industrial Land Inventory if wetland sites and the setbacks were fully protected under the'
. po licies recomIDendedby this study. The total impact to the inventory of industrial lands . .
would be 16.97 acres. Table 11-6 shows the total acreage for 19-nd affected by riparian
corridors and the acreage 'protected by setbacks from both this program and the existing
SQMprogram.
, '
Totallmpact .
TIle to'ta'\ impaCt ~ri the Industrial Lands Inventory W01.J!d be a redliction of 54.43 acres if'
all wetland arid riparian sites protected by this program and their 25-ft setbacks were fully',
"protected. This represents l~ssthanl % ofthe709 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 not Setback Setback Setback Acres' ,
Site Protected
Acreage bySQ!'il
Wetlands
Light- 28.20 (21:76) ,4.81 ' .82 0 33.83 \
Medium '.'
Industrial 34.32 \
I Heavy . . 13.16 (1.88) 2.01 ,,19.15 0
Industrial' 1.631
I Campus .35 0 0 1.28 0
Industrial
Special 0 0 '0 0 0 0 ,
Heavy
Industrial ,.
\ Quarry 0 0 0 0 0 01
Mining 0.601.
I Booth KelTy- .13 0 0 .47 0
MU
I Wetland 41. 84 (30.64) 6.82 21.72 0 70.38
Total
-- - -- -
Riparian Total Site 25 ft. 50 ft. 75 ft. Total
Areas Riparian Acres not Setback Setback Setback Acres
Site Protected
Acreage by SQM
---- - --
5-79
'.
~. . .
5-80
Metro Plan Diagram ~hanges Affecting the Supply of Residential, Commercial and Industrial Land
. _ ~ Changes in Metro Plan Designations
MOR . CC NC CI LMI HI PQs' G&E. NR
-0.1 01 Q\"li,,",'i~
. j ?~Jmrc~
35.0 5.0 W5fJ!O --
5.3, -5.3 0.0
0.5 0.0 0.0
--
3.7 0.0 0.0
-3.0 3.0
-0.9 0.9
';',i,,'%!~iii .1''';38)7
c.n
I
co
~
I
I
ILocal File Number
.190-04-058
90-12-201
92-04-77
'93-01-33
93-01-12
93-06-087
94-10.0H14
95-02-036_
95-02-036
95-02-036
95-02-1i:Jb
195-02-036
195-08-0157
197-05-101
199-02-038
199-02-041
199-09-230
102-03-0062
\02-03-0063
02_07 -200
\02-08-243
LRP-2002-12431
. 'ILRP-2004-00031
I LRP-2005-00015'
Re'side nti,,1 Jotal",isiriGil(~ 995fJ,(i~?,
6.5
LOR
n.!;~){:'i;4,~';t~i', :::_';:\~l~'~'O m
'~':~:;,~~9 ,:_~ U1J\Aj~\,':t(~~\
';?8~~~;;2n'5
',";'.1'5':3'
;i:t.fJ::;~~~ 8': 0
;:.~'!,:i-i.;;}; ,,,,,,jj(':Ind US tria 1 'total515 fnc'orM arcliC.19 911:5
AG
MU'
-3.7
I
I
\
1
1
\
1
I
72.0
18.0.. .
16.5
-34.5
-22.0
6,0
I
041
. I
~3,01
,,',
. .,..----.
~ptaI1B'~~Ti~~fq~_ff~$f~Jt{tTii~Ui1t~;~
LOR Low Density Resid'ential
MDR Medium Density Resi~enIJa'
CC Commerc:lal Center
NC Neig~borh,ood Com~ercial
CI Campus Indu'slrial
LMI Ught ~edium Industrial"
HI Heavy Industrial
POS Public Open Space.
G&E Government and Education
. NR Natural Resource
AG Agriculture
~u Mixed Use
o'
..'--.-
- ....~
,~ .- -, -
.' .
'''.
- ~ .:
'.."."'....._'
...1
.: .
., " ~
.' '.
"<'-'. ,..
v
.' -I.
-I.
)>
(')
..:1:
:5::.
'. m
z
-I
'(0
", ..:,~ . ':
.,C -,
... ~'Pea~~Health'
".'. .
March 15, 2007 ,
'Zone'ChangeAppllcation'
- , . " - ~
'-
, . Written Explanation of the Proposal
. .'
.' Applicant:
PeaceHealth Oregon Region' .
770 E. 11 tn Avenue
P.O. Box 147'9 '
Eugene, Oregon 97440 . :
.'i'
,
':
.' Hyland B~~iness Park, UC (Tax Lot 400);
1941-A Laura Str.eel .
Springfield, OR 97477 :
Attn: Shaun Hyland .
,(541) 726-8081, "
_ Property Owners: .
Andrew'Head (Tax Lot 402) ,
1616 Ardendale Ln. '
Eugene, OR 97405
.(541) 521-3403
Applicant's
.Rep~esentative: .
Philip Farrington, AlCP ,
. Director, Land Use Planning & Deyelopment
Pe'!-ceHealth Oregon.Region . '
123 International Way
, Springfield, Oregon 97477
(541) 686-3828 *. Fa:,- ~541) 335.2595..
P farringto n@p eaceheal ~~; org
1.0 Land Use Request' . .
PeaceHealth Or.egon Region (the" Applicant") requests approval to change the zoning .'
classification on the Clty'S zoning map from Light Medium Industrial CLMl") to.' .
. Community Commercial ("CC") for approximately 5.24 acres identified as Ta:<: Lots ~OO . .
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 LMI to CC, as allowed in .
Springfield Development Code ("SDC") 12.020 (1)(0.)1, .
5-82
,.
'.
. Page 2 .
,.... 'Zone Change" Ap'pt!catio~
'P7ace~ealth :Oregon Region-.
. March 15.2007
.'"
"f
. . . . .
The area subject tothe propased r~zoningis ~apped .on Attac,hmerit A, and is referred to.
. .' collectively in this appiicationas.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 commercial uses (i.e., Tax Lot
400), including a'possible future medical clinic which could serve residents in the.
growing east Springfield area, and to be allowed to continue long-standing commer~ial
operation's (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 an Tax Lot 400 - a vacant and underused
industrial site. The proposal would also help beautiI'; this portion of Main Street from its'
. traditional industrial yard uses, arid future development would provide a superior buffer
for residential uses to the west than currently exists.
(.
"
As described in later sections of this narrative the prap.osal is cansistent 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 autamatic.EMRP diagram amendment) - complies
with EMRl' 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 benefi~iai mixing of uses." (pg. 12) The proposal to allow far a broader,
more beneficial range of commercial and emplayment-generating us'es 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 Contexf
The subj~ct propel1i~s include a currently vacant, flat parcel (Tax Lot 400) and existing
cammercial development (Tax Lat 402) east of 44th Street along Main Street in east .
Springfield. The site is bordered on the south by Main Street, on 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 caoinetshop and karate school) franting Main
Street and residential homes along 44th Street west of Tax Lot 40,0. Coinmercial .
enterprises are located immediately south of the site acrosS Main Street (e.g., Gray's
.Garden Center). ;
, .
. "'{nile historically involved in agricultural. uses, since araund .1990 Tax'Lot400 was used
asa storage and sales yard for landscape organics and forest by-produfts. The current
property owners also used the site to store modular construction offices, tool trailers;
. construction equipment and concrete fOml plywood. Tax Lot 402 has had various
commercial' services on site since the 1950s.
'.
. 5-83
,
. Page 3
. Zone Change'0Pp\ication
PeaceHealth o"reoon Region
. Q
March 15 2007
j . ' . .
. The properties have no jurisdictional wetlands ,or inventoried Goal 5 natural or historic
resources. 'The site is within the Springfleld 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 abutting property to the east is desigilat~d LightlNlediuin Industrial in the EMRP . .
'. diagram and zoned LMl. The areas immediately to the west and south,of the site fronting.
Main Street are identified as being within Mixed,Use Area #2 in theEMRP, and are all
zoned Community Commercial. Prop~rty to the west of Tax Lot 400 along 44th Street is .
. . zoned and designated Medium Density Residential. .
. ..~ .
,.
,.'
4.0.. Applicable Approval c:riteria" .'
Zone 'change proposals are evaluated according to the criteria of approval contained
withiriSDC 12:030 (3), which requires:. ' .., .
I. ..Consistency with. applicable Metro Plan poiicies 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, services"
and transportation networks to support the use, or will be provided
concurrent with pro'pel-ty developmenL .
Legisl~tivezone map amendments are also required to show thatthey meet the.
criteriafor,Plan amendments outlined in SDC.ArtiCle 7-; and that it complies with
the state Transportation Planning Rule (OAR 660-012-0060); where applicable. .
Findings demonstrating consistency with the approval criteria are. outlined below.
.
4.1. Consistency with Metro Plan Text and Diagram . "
Consistent with SDC 12.030 (3)(a), this narrative only addresses those policies that apply,
to the proposal, and does nordiscuss those portions 'ofthe 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 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 speciflc development
proposals that will be addressed thr'ough compliance with applicable City regulations
. during site plan review of a given future.development proposal.
Except for the Growth Management Goals, which are .addressed below; each of the Metro
Plan policies are addressed in the order in which they appear in the Plan Element section
of the Metro Plan.
...:;
5-84
..'
Zone Cha~~e Application
PeaceHealth Bregan Region
March 1 S. 2007
" fage 4
.. :'
,". -
4.1.1 lYle'tto Plan Elements, '.'
. 1. GrowthIVlanagement
. policies. .
, .
. 1. The wban growth boundary and sequential developmentshall
. continue to be implemented as an essential means to achieve
" compact urban growth. Provision of all urban services shall be
, concwtrated ills ide the urball growth boundary.
..l ~ .
The proposal satisfies this policybecause the subject property is inside the UGB and city'
limits and as such; encourages compact urban growth. Also, urbaI"\.services are available'
at sufficient levels to accommodate the existing a,nd'futureinfill development resulting
'. approval of from this application. The City's 'site plill1'review processes e.nsure that the'
appropriate level of services is available to serve future development. .
2. Residenti,il Land Useand Housing Elein~nt . ..'.
Policies
. '.
A.ll. Generally locate higher density resid,erztiai development near
employment or comn;ercial services, in proximity to major :. .
transportati~n systems or ,within transportation~efficient nodes.
The proposed redesignation does not affect the i~ventory or availability of residentially
designated or zoned land, including the single-family resid~ntial area abutting Tax Lot
400 that is zoned and des;gnated for Medium Density Residential, or higher density
residential developments located east of the site along Main Street. '
,
However, approval ofth'e'requested redesignation to Community Commercial would
allow for residential areas proximate to the slMect area to have close and efficient access
to existing commerclal serviceson Tax Lot 402 and to future medical facilities propos~d .
for Tax Lot 400, consistent with the above policy. The areas proposeil forredesignation
otTer existing and future employment opportunities and provide commercial services
along a major trwsportation system that c.an support the needs of nearby residential .:
development. .'
A.22 Expand opportunitiesfor d mix of uses in newly developing 'areas
and existing neighborhoods through local coning and development
regulations. . ,:
The proposed' map amendment and 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 request would expand commercial
opportunities to serve these neighborhoods consistent with.the above policy,
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3. Economic Element"
Policies
" .B.l' D'emonstrate Ii positive interest in existing and new industries, .
especialiy those providing above-above wage and salarylevels, and'
. increased 'variety of jOb opportunities; a rise in the standard oj living,
and utilization of our existing comparati~e advantage in the level oJ.
education and skill oj 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 zon~ change will enable . .
increased job opportunities.withhigher than average wages thereby raising the standard.
of living and meeting the needs of Springfield citizens, wnsistent wjth the"above policy.
B.2 Encourage economic development which utilizes local and imported
capital, entrepreneurial skills, and the 'resident labor force. . '. "'
. The construCtion of and the use of commercial and medical us~s will utilize both local'
and importeQ 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 undeveloped land zoned Jor light industry.
. and commercial uses correlating tire eJJective supply in terms oj
. sllit(;bility ([ltd availability with tire projections oJdemand., .
The proposal will add approximately 5.24 acres of Community ,Commercial land, . .
consiste'nt with recommendations to increase the commercial lands inventory made in the
. Springfield Commercial Lands Study. The SCLS and acknowledged metropolitan
Industrial'LandsStudy 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 copsistent \vith the above policy The proposal .
correlates the need, suitability, and availabillty 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 distriblltion, '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. .
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6, Envirorim~nblDesign 'Element
'. Policies
E.iln orde( to promote the gniatest possible degr~e of diversity, a br;ad
variety of commercial, residential, and recreational lill;d uses shall be'
eIIcollraged when consistent with other planning policies. . '
Approval of the proposed map amendments will add just oved acres into the City's
inventory of commercIally designated and zoned land, thereby allowing fora variety of
needed commercial uses to occur on the subject property. Long-standing exi'sting .
.' 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 'services that will serve th'e needs of the growing residential areas east and south
of the subject site, consistentwiththe above policy: ' ',,, . . "
7. Transportation Element
. La'nd Use policies '" .
. I"
F.3 Provide for transit-sllpportive land llse patte~ns and development,
inclllding higher intensity, transit-oriented development along major
transit corridors and near transit stations; medillm-and high-density
residential development within one-qllarter mile of transit stations,
major tra/lsit corridors, employment centers, and downtown areas; and,
developmimt and redevelopmellt in designated,areas that are or collld be
, well served by e,~isting or planned transit
, .1'\
The proposal will.enabte lahduse patterns and development consistent with the above
policy. Approval of the r,equested zone change (and concurrent redesignation) vi ill allow
. for higher intensity development along Main Street, a majot ttansit corridor. An existing
L TO stop is located on the frontage ofTax Lot 400 (see photo, pg. 2, Appendix A of the
TlA), and will providecoi1Yenient access to existing and projected employment on the
subject site, as well as access for patients to future o~t-patient medical facilities projected
on Tax"L6t 400. .
Transportation System Improvements: Roadways policies
, F.iS iYJotor vehicle level of service policy:.
a. Use motor vehicle level of servic~ stczndards to maintain acceptable
and reliable performance on the roadway"systerri. These standards
. shall be llsedjor:
(1) identifying capacity dejicienci;son the roadway system. .
(2) Evalllating the impacts on roadways of amendments to .
transporrarion plam, acknowledged.comprehensive plans and.
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land-use regulatiens, jJLIrstian't to the TPR (OAR 660-012-
0060). .
(3) Evaluatingdevelopmen't applica'tionsfor consistency with.the'
. land-use regulations oj the applicable local governlitent
. . jurisdiction.
. b. ' Acceptable and reliable perJormance is defined by theJ~llowing
. levels of service under peak hour traJfic conditions: LOS E withi~
. Eugene's Celltral Area Transportation Study (eA TS) area, and
. LOS D elsewhere. .
c. Peljormance standards from the OHP s-hall'be applied Oil state'
facilities in the Eugene-SpringfieLd metropolitan area. .
. In some cases, the level oj service may be substandard. The local
govemmentjurisdiction 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 oj service. The limitation on the Jeasibility of a
transportation system improvement may arise Jrom severe constraints, .-
ineluding but not limited to environmental conditions, lack oj public
agency financial resources, or land use COllstraintJactors. It is -not the
intent ofTS] RaodlVay Policy #2: NIotor Vehicle Level 4 Service to .
require deferral of development in such cases.. Tlie intent is to defer
motor vehicle capacity increasing transportationimprovements until
existing cOllstraints can be overcome or deyelop'all allerllalive mLc of
strlltegies (such llS: Illlld use measures, ,TDiYJ, short-term safety' .
improvemellls) 10 address the problem,
.,
Subsection a,(2) in the above policy requires an evalll:!tion of the propos:!! pursuant to the
state Transportation Planning Rule (TPR) The accompanyingTraffic Impact Analysis
provides the factual b'~s\s to determine that the proposed iedesignation would.not result in ' .
a "signific:!nt effect" as defmed under the TPR (OAR 660-012-0060(1)).
. .
\
Specific:!lly, 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 TlA, the proposal also does not:
. Result in types or levels of traffic or access that are inconsistent'with the functional
classificatioil of Main Street or any other ilearby roadway;
. Reduce perfonnance of traffic on Main Street or other affected intersectioils to a level
that is below acceptable established performance standards; or
"
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,. Make performance of eXIsting facilities w,orse (i.e., below acceptable mobilIty
s!andards) than would bethe case other uses permitted under existirigdesignationsor
. zomng. ~ .
,
AdditionalTPR findings are further located in the TlA, see pp. 31-32. Because the
proposal does not result in a "significant effect" as established by applic~bli: OARs, no
further TPR analysis is required. The request is therefore consistent with the above
~~. .
8. Public Facilities and Service Element
Policies
"
G.1 Extendthe minimum level and full r!Znge of key urban
facilities and services.iri an orderly andeffii:ient manner consistent
with the growth management policies in Chapter II-B, relevant.. .
policies in this chapter a~d other Metro Plan policies.
"
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The subject property is located in Springfield's city limits UGB, All necessary, .-
infrastructure and key urban facilities/services are present to serve exi~ting development
(Tax Lot 402) or ate available to serve future in fill development on'Tax'Lot 400.
Therefore, the proposal is consistent with the above policy. ,
9. . Pa;k's ~nd Recreation Facilities Element policies
Policies in this element of the Metro Plan are not'relevant to the requested zone change.
10, HistoricPreservation Element policies
Policies in this element oftheI'vletro Plan are notrelevant to the' requested ione change.
. . Ii. Energy Element policies' . . . "
Policies in this element'of the Metro Plan are not relevant to the requested'zone change.
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. ' 4.2 . Consistency with East Main Refinement Plan " ..,'
.': The following demonstrates how the proposal is consistent with applicable policies in the
East Main RefinementPlan (EMRP).
1.. '. MLxed-Use'Element
. Policy 2) Area #2.
A). The follo}ving land uses are allowed iwder Community Commercial
zoning:
, All {:ommunitv Com,iwrcia( ;,ses'subject to ArtiCle 18'ofthe
Springfield Development (ode... '
. .
. The proposal reque~ts rezo~ing'the subject properties from LMI to c~mmunity'
Commercial (and ~oncurrently redesignating the properties to c,C),'as the above policy
and other EMRP policies allow. Approval of the request would allowlong,standing
existingcornmercial 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:
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2.
Commercial Element
Criteria for Com/nereial Refinement Plan Desif!nation
. 1. Generally, the Community Commercial refinement plan designation:
, shall be applied under the following ,ircumstan'ees:" .
. . .
A) where it is not all ilItrusion iniolvell-I~aintaihed residential
neighborhoods;
The area proposed for rezoning does not intrude ihto 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 benveen 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 r'ezoning of
the subject sites would actually result in a decrease of conflicts between abutting
residential and non,residentialland 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.
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C) where criteriaJor designating i\IedillinDensity Residential
.. 'land doeslio( apply,' .' ,.'
Criteria for designating MDR land does not apply to the subject site,
'D) where legally created commerciahlses exist;.
Tax Lot 402 has ex.isting, long-standing commercial uses that were legally-created
prior to development of the Metro Plan or EMRP. Tax Lot 400 has had avariety
. of commercial services located on-site over the years. .
E) where adequate customer and'sen'ice access to an' ~rterial
street can beJirovided; .., and; ,
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The subject site has adequate legal access onto MaIn Street, \vhich is classified as
an arterial street. .
F) wher~ designated Commercial on' the lYletro Plan Diagram.
Approyal 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 site-specific Commercial refinementplan designations
to clearly defin~ the lirriits of new commercial uses where there is Ilot an
existing, legally established, and beneficial mL--cingoJ uses.
Approval of the concurrently requested redesignation would apply Commercial plan
designations to the subject properties, allowing the existing, legally established
commercial uses on Ta.x Lot 402 to continue. It would also enable ~ommercial uses to .be
established on Tax Lot 400, thereby defining the limits of new commercial uses b~tween
the pre-existing commercial uses on Tax Lot 402 andothers: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 for in the above policy, and also provide the ability to make superior buffering and
other improvements associated with future development on Ta., Lot 400 through the site
plan review process, . "
Policy 3) Reduce the number of vehicular access'points dlld require the
rebuilding of curbs and installatioll of sidewalks alld street trees along
il'iain Street, through the She Plall Review process and ill public
improvemellt projects.
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: The proposal. would result in reducing the number o[existing access points as required
aboye, Through the Site Plan Review process, future development on Tax Lot 400 v,:il1
. . have a single driveway access onto Main Street, eliminating one of the two ex.isting curb
. cuts on this site. Sidewalks and streeUrees are already located along its Main Street
frontage, consistent with the above policy, .
Policy 4),Provide brlffering between cGn,m'ercial an'd residential uses
through A rticld 1 of the Springfield Development Code, Site Plan
Review process.
Existing residentiai uses ~longthe ~ast side of 44th Street have hadno re'al buffer from
pre-existing industrial uses on Tax Lot 400. Approval of the proposal would allow for
attractive in fill development of future medical facilities that would provide (through the'
. SPR process) improved landscaped buffers bet\~een the future use 'and existing
residential are~ to the west _ as required by Code, and co Clsistent whh the above policy. .
"
3. . Industrial Element
Policy 1) The City shall encourage efforts of various agencies to attract,
new and retaill e.."'Cisting jobs and businesses. .
Jmolementatio'!
. The City shall maintailt a current inventory'ofvacant com'mercial and
industrial land and structures within the East lyJain area.
.'
. .'
"consistent with the above policy, approval of the requ~s'ted~onechange and
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 LotAOO with higher th~\fi average wages and employment densities than the
current designation and zoning allows. . '
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'. '4.3.'. ProviSion 'of Adequate Publiciacilities, .'.
'The subject properties were'annexed into the Springfield corporate limits ill i960, and
. therefore are provided with City police, fire, and other government,services.. Other basic.
infrast\'licture is in place to serve existing development on Tax Lot 402 and ~ny 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 e~isting and/or future development on the subject site. Transportation
. . ,.
services are also readily available to serv~ existing and. future development, as Main
Street is fully improved with curb, gutter, etc. .
" As indi~ated in the Traffic lmpact Malysis accoriJpanyingtheconcurrentlysubmitted
zone change and Metro Plan diagram amendment, approval of the proposal would not
. ~ ,--
. result in a "significant effect" to the transportationsy~tem, apdtherefore'is'consistent '.
with the state Transportation Planning Rule. The TlAfurther demonstrates that existing'.
.and future development under the proposed zone change has safe and efficient access and,
circulation for vehicles,."and also will benefit from the sidewalks, bike lanes, and.transit
. . service existing on Main Street.
"
. Therefore, th~ 'proposed zone change complies with the requirement for having ~dequate
public facilities and service,s to serve development, as established.in SDC 12.030 (3),'
." , " " ...... . ' - .."
. .
4.4 C~nsistency with Approva.1 Criteria inSbC 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 apphcation, and al:JIJ demonstrate that tIllS proposal complies with Metro
Plan policies as requu'ed In SDC 7,070 (3) and WIth zone change approval' criteria in SDC
12.030. Both the findings below relative to Goal 12 and those above pursuant to Metro
Plan Transportation.Elementpolicies address consistency with the state TPR, as called
fur~SDCj2.mO .
It should also'b~ noted that approval of a t:'letro Plan"diagram amendment' also
correspondingly changes the applicable refinement plan (East Main RefiriementPlan)
diagram, as established in SDC 7.\10 (4). '. . '.
Goa:ll.- Citizen Involvement ,'" , .:.
Goal I addresses the need to develop a citizen in~oivement program to ensure titizen
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 ofhe;rings 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 notice, and any established neighborhood organization, Since the.
pr~cess compiles with the City's citizen involvement program and citizens have
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.. opportunities. to be involved in the procedure, the proposed plan arid zonernap.
"amendmentsare consistent with Goal!. - .' .
..',
Goal 2 -Land Use Planning , . . .
Goal 2 requires thatlocalcomprehensive, plims be'consistent with the Goals; that local ."
. comprehensive plans be internally consistent, and that implementing ordinances be' ,
. consistent with acknowledged corpprehensive 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 referr~l
. notice of the proposed TypeJI Metro Plan diagram amendment to the City of Eugene and'
. Lane County so they may determine if there are grounds to participate as parties tei-the"'
he~ring,' The Cityalso sends the statutorily required notice of the initial public hearing
45 days in advance to the state Department of LandC6nservation and Development,
eI}suring that they ar~ given opportunity for comment and review conformity to
. : applicable statewide planning goals. .
'. The Metro.Plan and the SDt, as well as the Statewide planning G~als and applic~ble'
..' 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 compliance, the proposal
satisfies 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 properti~s'are located within an acknowledged. .
urban growth boundary. are insideSpringfteld's corporate limits, and have not b~en in
agricultural use for decades.
, Go~14 - 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 Springfleld'sacknowledged UGB. .
'. GoalS - Natural Resources .
Goal 5 requires local governments to protect a variety of open space, scenic, historic, and
natural resource-values.' Goa! 5 and its implementing rule, OAR Ch, 660, Division 16,
require pbnningjurisd;ctions, at acknowledgment and as a part ofperioClic review, \0
(1) identify such resources;
(2) determine their quality;' quantity, and location;
. (3) identify conflicting uses;
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(4). ,examine the economic, social; environmental, and energy
.' . (ESEE) consequences thatcould result from allowing,- .
limiting, or prohibitlllg the conflicting uses; and .,..; . .' ,
(5) develop programs' to resolve the conflicts. '. .
The subjec't properties are not on Springfield:'s acknowledgedMetroPl~' Goal.5
inventory. No threatened or endangered species have been inventoried on the site, and n~
archeological or significant historical inventoried resources are located on the site, The'
National Wetland Inventory and Springfield Local Wetlandfuventory maps have been
. consulted and there are no jurisdictional wetlands located on the site. Therefore, the
proposal does not alter the City' s compliance with Go~l 5.
.' ".' -
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Goal 6 -Air, \Yater, and Land Resources Quality' .
'The purpose of Goal 6'is to maintain and improve t)1e quality ofth~ air, water and land .
. reso\lrces of the stat~, Generally, Goal .6 requires that development comply with.
. applicable state and federal air and water quality standards. In the context of the
. proposed Metro Pl~n diagram amendment and zone change, Qoal 6 requires that the
applicant demonstrate that it is reasonable to expect that applicable state and federal. ' .
erivironmental quality,standards canbe met. .
. .
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Though Tax Lot 400 has been used for low-vahle storage and quasi-industrial uses, the ..
site is not listed qn any state 'orlocal environmental clean-up list. A Phase 1 ,
environmental assessmellton the subject property was conducted and recommended
additional analysis. Upon recommendations through the Phase2 environmental .
assessment a nom;nal quantity of soil (less than 1.0 cy) impacted by earlierlhistOlic use
was removed from the site' and properly,disposed. Given the nominal impact generated
by historic uses on the site, it is reasonabie to conclude that futljre development on the.
site will be able to demonstrate compliance w.ith City standards for water quality
protection through the site plan reYiew process, thereby complying with applicable. state
and federal environmental quality standards~ . .
Goal7 _ Areas.Subjectto Natural Hazards
Goal 7 requires that deveIiJpment subject to damage ii-om natural hazards and disasters be
plal1l1ed and/or constructedwitb appropriate safeguar.c)s and mitigation., The goal also .
requires that plans be based on an inventory of kno;vn areas of natural disaster and
hazards, such as areas prolle to landslides, flooding, etc. .
The site is flat and not subject to landslide,hazards,and is l:pcated well'o~tside of ~ny
established FE/vIA flood hazard area. Therefore, approval of the proposal will not alter
the City's acknowledged compliance with Goal 7 through its adopted plans, codes and,
. procedures.' ,." '.
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Goal8 - Recreatlo~ill Needs
. Goal 8 requires local governments to plan arid 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 inducted 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 Goal 8., .' . . .
Goal 9 - Econoinic 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 Sacres ofCC designated/zoneCl land in place of the existing ".
. industriaI'designation and zoning. permitting the construction of future clinic.facilities,' .
. on Tax Lot 400 and allowing long-standing commercial uses on Tax Lot 402 to continue
and become conforming uses consistent with commercial zoning through approval of the'
proposed Plan diagram amendment find zone'change is consistent with numerous policies
in the City's adopted plan for compliance with Goal 9, the Springfield COrrlmercial Lands'
Study (SCLS). ' . ..' " ;' .' .
Specifically, the t"ollowiflg SCLS policies are applicable to the proposal:
.'
. .
P~licy I-A: "Maintain a mixed supply of large and small comm.ercial sites
through strategies such as rezoning or 'anriexation to serve Springfield"s .
future population."
The proposal fulfIlls this policy objective by rezorling'(and redesignating)larid from'.
industrial to commercial use, for two tax lots of varying sizes and commercial uses;
thereby maintaining existing employment and commercial use in Tax. Lot 402 and' .'
providing the ability for'growth in medical sector employment.byallo-'ving future clini~.
uses on Tax Lot 400. .
Policy.l-C: "Maintairl at least a five-year supply of cormnercialland
within 'the Urbarl Grow.th Boundary (UGB) that is currently served or
readily serviceable with a full range of urban public facilities and
. services,ll,
The SCLS (see Table 3,8, pg. 32) found there to bea deficit of 158 acres in the supply of
commercial land over demand projected through the year 20i5. The proposal would'
allow for redesignation ~nd 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 development on Tax Lot 402, and future
development. on Tax Lot 400. The SCLS identifies (pg 33) a need to support
"employment in population-dependerlt sectors such as retail sales and health services" to
meet Springfield's growing community, The SCLS also noted (pp, 27-29) state and local
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. trends il) iJeater employment in retail trade .andwell-paying health services sectors.
. Approving the proposed redesignation and zone change would help meet Springfield;s'
. ~ demonstrated nee4 for employment and commercial services; , .
Finding3 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) wouldnol 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 ]-,A (1): "Evalu~te inventories based on
demonstrated need for the planning period, .Initiate rezoning or redesignation ofsurplu;
land uses where more appropriate for commercial, consistent with the Metro Plan."
! ' . .
The proposal in fact consistent with inyentories for commer~ial ~nd 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 of two acres within an.
existing urban growth boundary from an industrial land use designation to 'a nori" .
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 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, The proposal enables continued use of the existing and long-standing
comlllercial center to continue to operate and provide employment opportunities, while"
also allowing higher-value employment associated with future development on Tax Lot.
400. These types of employment-generating uses. are among those identified in OAR
. .
660-009-0005(6) as eligible non-industria! employment 'activities that can justify
approval of the proposed Plan diagram amendment without the need for an economic
. opportunities analysis apart from the SCLS, wliich OLCO acknowledged as fulElli~g the
City's obligatIons under Goal 9. .
, .
Because the requested redesignation and '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 proposal is consistent' .
with the City's compliance with Goal9'and applicableadministrative rules regarding
Goal 9 implementation.
GoaL 10 - Housing
LCOC's Housing goal requires cities to maintain adequate supplies of buildable lands for
needed housing, based on an ackno\vledged inventory of buildable lands. The proposal
does not affect the CitY's inventory of residential lilllds.
In fact; approval of the requested redesignation for Tax Lot 400 would enable
c redevelopment of an1l1dustri~1 site abutting existing residential development. Through
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. Zone Chang~..Applicati~n, .
Peac~Health Oregon Region
March 15 2QQ7 '
Page 17
the site plan review pro~ess, futurtdevelopment on that property can piov~de a superior'
'buffer and a higher use that will benefit the adjoining residential properties, Because the' .
proposal does not inyolve directly any change in the amount of residentially designated
. or zoned land, it does not affect Springfield's continued compliance with Goal 10.
. -, . ' .
Goall1- Public Facilities and Services .
This goal requires the provision of a timely, orderly and effi~ient arrangement of public'
facilities and s,rvices. The subject property is located within the Springfield UGBand .
city limits, and is already designated for urban levels of use, 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 cOmrllercial uses on the subject site.
Goal 12 _Transportation .'
Goal] 2 requires local governments to provide and encourage a safe, co'nvenient and
economical transportation system, The proposed map amendments and zone change
involve approximately 5.24 acres of property, though existing and long-standing.
commercial uses occur on Tax Lot 402 such that approvaLof 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 acceptabl'e levels and allow for adequate queuing lengths at
applicable intersections. Therefore, the proposal will not have a "sigriificant effect" on
transportation facilities as defll1ed in the Transportation Planning Rule (OAR 660-012-
060). '
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Existing de~elopmentatTax 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 ,VilI' be revie~ved . .
. 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 resuit in 'any degradation.
of inobility standards below acceptaole levels, and that safe and efficient circulation can
be realized through approval of the requested land use redesignation and zone change.
. .. . . .
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Furthermor~, reducing the number of access points for future development on Tax Lot.
400 is consistent wlthpolicy objectives found in East Main Refll1ement Plan (EMRP)
Access, Circulation & Parking Element policy I B (pg. (7) and Commercial Element
policy 3 (pg. 12).
Because the proposal, as demonstrated in the TIA, is consistent with the requirements of
theTPR and with applicable policies in the'EMRP,it is consistent with Goal 12 and
applicable local implementing policies, .
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. . Zo~~ Chan~e'App'Ecdtio~
.' PeaceHealth Oregon Rt::gian
March \5.7007
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,'. . Goall3 - Energy Conse[yation '
The Energy goal is a general planning goal and provides limited guidahce for,
site-specific map amendments. The proposal 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 area~ in east Springfield,
Therefore, the proposal is consistent with, and does not alter the City's continued.'
'.' compliance with Goal 13, "'..
Goall4 ~ Urbaniz~tion'. '
. Goal 14 requires local jurisdictions to prQvide 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
lA is not 'applicable to this application. . '.,' "
Goal 15 _ WiIlamette River Greenway ,
This goal is inapplic'able becau~e the subject property is not within the boundaries of the'
Willamette River Greenway, .' .
Goals 16-19 - Coastal Goals
The coastal goals are riot applicable to this application.
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Staff Respo~se to writtelrcomme~ts.to Applications
ZON 2007-00012 / LRP2007-00013 .
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~XECUTIVE SUMMARY:
Staff receiyed one written testimony from Lauri Segel, Goal One Coalition Planner, on
June12th,-2007, A written rebuttal to Nls. Segel's letter was then submitted by the .
, th' ..' "
,applicant the following day, June \3 ,2007. Both letters were received within the.
specified deadlines as noted in the Plannihg 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
rev.iew by the Planning Commission, Copies of the *,,0 letters in their entirety are
. attached for reference and review in addition to the excerpts and Staff responses in this
report. .
Ms. Se!'el's Submittal' Issue #1.: "Applicant Relies heavily on the,acknowiedged
2000 Springfield Commercial Lands Study (SCLS), which does not address the
entire Metro UGB area, and is not a refinement plan of the Metro Plan.., The
, pr'oposed findings rely on reports and other docllments containing inventories, .
assllmptions, and data that have not been establishedfor the entire Metro UGB
area, bllt rather only for the Springfield portion of the UGB area .... ..
Aoolicant's Rebuttal:. "The cities of ElIgene and Springfield have separately
. adopted and acknowledged commercia!-lands studies fidfilling the reqllirements
of Goal 9. .As such, the SCLS serves as the City of Springfield's "most recent
. eco~omic opportllnities analysis," as lvls..Segal notes above by her own
admission... There is no reqllirement that the Applicant or the City perform iz'
metro-wide anal,vsis of commercial lands in order to adopt findings satisfying
. compliance with lYletro Plan policies and Goal 9... .. .
STAFF RX}SPONSE: TheSCLS wasa Period Review Task required by OLCO and was
. approved by said agency as part of Springfield's compliance with Goal 9 during the
PeriodicReview process: As such, it is a valid document to reference related to this Post'
Acknowledgement Plan Amendment (PAPA) proposal. TheSCLS 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 OLCO 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 dernand 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 OLCD concluded
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It was not necessary to adopt the SCLS as ail amendment to,the tyletro Plan because all
. recommendations regarding inventory adjustments contained in the Study could be ' '.
implemented throug~ the PAPA process as increases in the brnm'erci al larids inveiltory;
theSCLS would ~e used. at that time as part of the findings, reasons and conclusions for
thosePAPAactions,-, . . .
"
Best available data ';as used in the analysis of these applications, which included the '
SCLS. There are no comprehensive studies (i.e..commerciallands'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.' . .
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Ms: Se?el's Submittal-Issue #2:.' "The adepted SpringfieidNatural Resource
Study (adoptf'd.by Ordinance #6150) shows little, of: no impact on the commercial
lands inventory from 'Goal protection measures, andproviddittle if any analyses
. of land avajlability within the entire Metro UGB area. ratherthanJust the
Springfield UGS area. The analysis shows an imp'act of 11.56 acres on
Sprinifield's (not the urban growth boundary area in its entirety)... The
referenced studies / analyses referenced by" the applicant do not take into account
. the 100 acres of ne-'v commercialla,:,d designated / rezoned to commercial. in the
Gateway iJrea. ., , . ' ','
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Aoolicant's Rebuttal: "Considering that the SCLS identified a deficit of 158
acres in the supply of commerciai'1and over demand, accountingfor this .
additional redesignated/rezoned land, this would still result in a deficit of more
. . than 61 acres of needed commercial land. Approving the requested Plan
amendment/zone change would still leave a defi.citof approximately 55 acres of
needed commercial land:.. Therefore. 'even considf'ring impacts to commercial.
lands inventories from other adopted and acknowledged plans (i.e. the City's plan
for Goal 5 compliance)' and aclolOwledged Plan amendments / zone changes,
approval of the proposal will not result ill -there being an excess' 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 RESPONSE~ The Sp'ringfield 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 ltself. Reference to the SNRS in conjunction wi'th,other referenced documents(i.e,
the SCLS & 1992 Industrial Lands Srudy) lS provided to give the most accurate
information possible given all the available data at this'time. ,
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Again, the applicant's report and staffs analysis reference the most recently adopted,
documents / inventories available. The City currently ,does not have al1ongoing database
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that keeps. track of inventories based upon Plan Ainendments and/or Zoning Map
" Amendments on an ongoing basis'. . .' '.' . ,:. . .' . .' .
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!\'Is, Se~~l'ssubmittril- Issue #3:. "The applicani hasnot)ustified the . . '..
conversion of scarce, shovel ready industriallan.d,. especially land designated and
. zoned light medium industrial inside the Metl'o UGB, :iven thotighthe Metro Plan
(comprehensive plan) Economic Element policy #1'1 establishes that the cities are
to 'discourage jiilw:e Metropolitan Area (Jefzeral Plan amendments that would
. change development ready industrial lands (sites dejinedas'short-term in 'the
metropolitan Industrial Lands Special Stildy, 1991) to nOh-industrial
designations, 'The applicant a';d stafffindings do notaddress how thii loss oj
these 5.24 acres impads the short~term supply oj LM] designated land... "..'
;..
Aoolicant'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 Indllstrial Lands Special Study. 1991). '.'...casting
doubt on the applicability of Metro Plan Economic Element Policy 12..,' Even if.
Policy 12 were relevant, it's language is clearly not prohibitive 10 approval oj an
applidllionJor redesignation/rezoning of ai1.industrial site, particularly when
considering it in the context oJilldllstrial commercial land illvento~ies. ....even if
al/ of the acreage redesignated in Springfield werejrom the LMldesignation-
which is no. doubt not the case - there would stil/be asurp'fL,s oj nearly 50 acres
oj Udl designated land even aJterapproval of the r!'quested Plan amendment.
This does not account Jor.the 11.5 acres of land added 10 the inventory oj LMI .
zoned and designated land reJerenced in my March 28,'2007 supplemental
inJormation. ... ThereJore. the removal oJ5.24 acres' oj LM] zoned and designated
land will not result in a deficit oj needed land in thai jndustrial designation.
...Moreover, allhough Economic Element Policy 12".~iscourages" Plan.
amendments Jor cerlain il1dllstriallands, there are ccn,ntervailing policies in 'the
lv[etro Plan (i.e., Economic Element Policy 6)and SeLS (i.e., 'Policiesl-A and I-
e) that are directive 10 providing an adequaze supply of needed commercial
lands... ". .
STAFF RESPONSE:. Staff concurs with the applicant's rebutt~l to the issue raised. The
applicant has cited numerous acreage calculations based offof adop.ted inventories which
support the proposal. As noted by the applicant, the subject site w'as not included among
the.sites defll1ed as short-term in the metropolitan Industrial Lands Special Study, 1991.
As ~oted in,the applicant';, rebuttal a'nd as previously noted in this report and the original
. Staff Report, a deficit of commercial land and surplus of industrial land will still exist
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. even after an'apfJT6val of the proposed'Plan Amendment andconcurrent Zoning Map
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,:. iYIs~ ~e~el's Submittal- Issue #4:. :"The Applicant's analysisoftlie'proposals:
',consistency with comprehensive plan Economic Element policies foun'd in the
lvIetropolitan General Plan, Chapter III. B-1 - B,7 is insufficient imd does not
addl~ess the most significant policies that must be 'considered. '"
,.
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. AooUcant'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) thctt are
. '. directive 10 providing an adequate supply of needed commercial lands. The Metro
Plan recognizes such conflicts: "The-respectivejw'fsdictions recognize that-there
are apparent conflicts and inconsistencies berweenand among some goals,
'objectives, and policies. When mal.:ing decisions ba~ed on-the Plan, not all the .
goals, objectives, and policies can be met to the same degree in evei)' instance,
Use of the Plan requires a 'balancing' of its various corripone~ts on a case-by- .
'. case basis, as well as'a selection of those goals. objectives, and policies mo~t
pertinent 10 the issue at"hand. "lpg. 1-4, Melro Plan) ...The appiicant's original
lvlarch 15: 2007 submittal includedfindings addressing relevant Metro Plan '.'
policies (see pg.') of the submittal, pg. 4-5 oJthe Commission's JuiJe 4,2007
hearing packet). Clearly not all oj the 32 lvietro pir;1I1 Economic Element policies'
a;e relevant to the proposal. Many are aspirationd! ill nature and not directive to
a specific quasi-judicial application...
"1
ST AFF RESPONSE: As noted' in the applicant's rebuttal, policies in the Metro Plan are
sometimes 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 aegree in
every instance. Use of the Plan requires a 'balancing' of its yarious 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 appllcant's narrative related to the referenced Metro Plan policies
which support the proposal, given the relationship of those stated Metro Plan policies as
reviewed concurrentlv with the referenced commercial' arid industrial adopted inventones.
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Ms. Se~eFs Submittal - Issue #5:. "The applican~ is not specific about what uses
will be cited shouldthe proposal be appro~ed: and rhere is no way 10 know if in
facr above wage jobs and salaries... there is no way 10 establish ifrhe applicant
will infa~t utilize local and imporred capital. skiils ere. as no commi!ment ro a use
has been established... "
. ADolicant's Rebuttal:. "...Ms Segel's assertio;1 rhat-the application was
unspecific as to .thefillure uses 011 Tax Lor 400 is .inaccurale, The application
narrative clearly stares {he i,nlended purpose of the redesignation/re:olling is to
'5-103'
allow for a fulllre medical clinic on Tax Lot400 and 10 allow the long-stemdino-
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commercial operations on Tax Lot 402 10 continue (pg."'2. pg. 4-2 in the
Commissio~'s June 4 hearing packet). Such clinical uses are not permitted in' any
indu.strial zoning district, thus promopting the needJo rezone (and Redesignate) ,
Tax/ot 400 to allow a medical clinic. Average wages and benefits for m'edical .
workers tends 10 be hightI' than average local wages, and filrther substantiating' .
data can be entered inlO the record at the City Council level... . .... ,.
ST AFF R.l':SPONSE: The applicant has noted the intent of the Plan Amendment ~d
concurrent zone, change is for the eventual development cif a medical office building. This
is mentioned not only in the applicant's narrative, but also in the applicant's Traffic
Impact Analysis, In fact, the referenced table in the TIA (Table 7, pg..19)specifically'
. . calculates tnp generation for the orooosed medical of-:ice buildin\C, 'However, 'as noted by ,
. . Ms. Segel, there is no~ertainty as to what the salaries -,vill 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 property with the existingzoningand 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 Staff's
opinion) that they will pursl1e 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 rebuttal statement and
affirms the origin~\ Staff Report findings indicating that the)roposal is in compliance
with applicable Metro Plan policies.
. '
Ms. Se~el'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 Appendix C, "Sites with Flan/ZoneConflicts" does not incl;,de the
subject property. It appears that the existing nonconforming uses were actually
. established AFTER adoption of the 2000 5CLS,. indicating that the existing uses
were actually permitted by the City with the knowledge that these uses would
. create plan/zone.conflicts,"
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Aoolicant's Rebuttal:. "The applicant does not allege that there is a Plan/zone
conflict on Tax Lot 402; clearly the e:cisting Plan designations and zoning are
LM!. Rather, the point made in our application narrative is that commercial uses
have existed for decades, pre-existing the establishment of the Metro Plan and the
. application of the U41 designation on the subject properties. Ms. Segel provides
. no evidence 10 back up her accusation that the City wittingly allowed commercial
use~ 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 July 2 which will further demonstrate fa cilia lly that commercial uses
and employment have been in the building on Tax Lot 402 for nearly 50 years... "
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'ST AFt RF.SPONSE:'The existin~ zonin~ for TL#402 is Light Medium Indtistnal ':
, . (LMI) The' existing Plan Desirnation. for TL #402 is i.i~htMedium Industrial (LMI),:
,Therefo;e; there is no Plan/zone conflict as alleged by Ms. 'Segel. A non-conforming ~se'
is not the' saine as'a plan/zone conflict. Ms. Segel alleges that the City permitted the
existing uses onTL #402 "AFTER adoptioI1 of the 2000 SCLS..." and further'states that
the uses were ".. ,permitted by the City with the knowledge that these uses would:create
plan/zone conflicts," This allegation has not merit for m'ultiple reasons, Article 5 of the
Springfield Development Code provides provisions to allo;-v existing non~confo~ing
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 coinmercial.uses on TL #402 are most likely
'considered non-conforming uses (i.e, commercial' uses on industrial zoned property). The
. 2000 SeLS does not list TL #402 as a Plan/Zone conflict because it is not a plan zone
conflict. .,'
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Ms. Se!!e!'s SubmlttaI" - Issue #7:,' "The p~oposedchange is not 'logical and
.harmonious' because it is not consistent with the development pattern envisioned.
in the Metro Plan .:.Compliance with statewide planning goals, including goals
2,6,9,10,12 and 13 has not been established. In pacticular, 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... Staff has failed /0 address the impact t~at this proposal will have 6n
. . the dwindling supply of shovel ready industrial land inside the Springfield city
limits, includingprior actionsapp/'oving land use code amendments 10 the
campus industrial zone that established more 'jIexibiliry'for whatuses are
allowed in the ciry 's campus industrial zones. ,,'
. .
Aoolicant's Rebuttal:. "It shouldfirstbe'noted that the application does not
involve or in any way allectthe 'metro area 's supply of campus industrial land. .
Moreover, the application has no effect upon Goal 1 0 (Housing), and has
elsewhere demonstrdted compliance with Goal J.2 and other applicable statewide'
plan~ing goals. Mv guess is that Ms. Segel and Na[Icy Falk, who appeared at the
June 4 hearing and requested the written record be left open for' a week, both .
vigorously appose the Plan amendment/zone change proposed for the Marcola
Meadows project, and are borrowing arguments 10 also object to this modest
request before the Ciry... The contention that the proposal would not result ina
'logical and harmonious' land use pallern is without substance or basis in fact,
and is not an approval criterion. As noted above and elsewhere in the record, this
proposal is consistent with policies and provisions in the Metro Plan. its
Economic Element, supporting refinement pians (i.e., ihe SCLS andAHLS) to the
},,!etro Plan, and Goal 9 and other applicable stat~wide planning goals... '~
ST AFF R.!<"SPONSE: Ms Segel refers to the existing zoning of the subject site as
. "Campus lndustrial" multiple times in her letter. The subject property is zoned and
designated Light Medium Industrial. not Camous industrial.. As noted in the applicant's
rebuttal~ the statement submitted by Ms. Segel indicating that tlie "" .proposed change is
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not 'logical and ha~onious',.,' is not ~'criterion of appniva~ 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,StaffReport. The inventories.of"
, commercial and industrial land have been eyaluated and balanced with the relevant Metro' .'
. ,Plan policies to formulate the recommendation for approval with conditions, Specific .
. findings related to th7 Statewide Planning Goals have also been included in the original
Staff Report. .
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GOAL ONE COALiTION .'
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Goal One isCitizen Involvement
-.:(-
, , City of Springfield Plarining Commission
. David Reesor
City ofSpringfie1d .
225 Fifth Street.
Springfield, OR 97444 .
June 12,2007 .
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',' lUN 12' 2007
B[:z.~
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RE: ZON 2007 ~00'12/LRP 20.07 -<J0013, Plan Amendment & Zone Change
Dear Members of the commission: ' '., , .
The Goal One Coalition .(Go~IOne) i~'a 'nonprofit or~ani;ation 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 beh~]f 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, ?pringfie1d Oregon 97477, as an individual.
,
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. I.lntroductio~
'This proposal is for a site,specific Metro Plan Amendment I Refinement Plan Amendment and.
a concurrent Zoning Map Amendment .from Light Medi\lm, 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 o.:vnerships, and is locateq on appromnately 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'
yacant buildings on site, including portable trailer type.stiuctures. The smaller of the two'
subject lots, TL 402 (.+4 acres), has an existing commercial development on-site, although the
plan designation and zone are L1y[!. properties located to the north (Weyerhauser) are zoned
and designated heavy industrial. Parcels located west.ofthe subject S\\$ are designated mixed-' .
use on the EaSt Main Refinement Plan.-Propert/,located eaSt and adjacent to TL #402 is built
out as a business park, and designated LMl. Properties 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 d~cuments: 'Springfield Development
. Code, Metro General Plan, and East Main Refinement Plan, as indicated in the staff
report.
The proposed plan amendment must also b~ found to be consistent with applicable statewide
planning goals. ORS 197,175(2)(a). Applicable goals incIude Goall, Citizen Involvement,
Goal 2, LmdUse PlaMing; Goal 9, E~onomy of the State; and Goall2, Transportation. The
,Eugene office: 642 Ch,rneleon Sui,e 100 . Eugene OR 9740 I .. 541A3 1-7059 . F;,x 541A3 1,7078
lebanon office: J9625Almen Oriye' lebanon OR 97355' 541-258-6074' Fax 541-258-6810
WN'N.goaJ1.org
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GOAL ONE COALITION
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proposed plan amendment must' also. comply: with
applicable statewide planning goals.
.: Ill. Analysis
COMPRE4ENSIVE PLAN CONSISTENCY AND COMPLIANCE WITH. .'
STATEW1DE 00AL~ . .
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. administrative rules implementing'.
'. .
All comprehensive plan amendments are reviewable. for compliance with 'the statewide
planning goals. Residents of Rosemont v.Metro..!73 Or App321 (20.01); 1000 Friends of
Oregon v.'Jackson County, 79 Or App 93,97,718 P2d 753 (1986), rr;v den 301 Or 445' .
. (1987); Opus Development Corp. v. City of Eugene. 141 Or App 249, 254,918.P2d '116
(1996).
. .;
'. . , Goal 2 _ Land Use Planning is. ':To establish a land use planning process arid 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'. Furt)ler, the information upon
, which land use decjsions are made "shall be contained' in the plan document or supporting
documents." Goal.!, Part L.' , :.. - . . . .. .
In this case, the applicant relies heavily on the' acknowledged 2000 Springfield Commer~ial
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 Plrm, .. .'
The . proposed findings. rely. on reports and other documents containing ,inventories,
assumptions, and data that have not been established for the entire Me~o 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. Ahy decision relying on such findings would not comply
with Goal 2.' ' . .
GoalS
..
Concerning' appllcabilityof land ,inventories pursuant "to Ordinance #6150 that
adopted the Springfield Natural 'Resource Study,. staffs position is that inventori~s
estab I ished pursuant to GoalS are relevant considerations in considering availability
of commercial and industrial land, Howeyer, that analysis (applicant's Attachment
"A" _ tables II-I. 11-2 and 11-3) actually show little or no impact on the commercial
lands inventory from Goal S protection measures, and 'provide litt\eif 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 l'U6 acreson,Springfteld's (not the urban growth boundary area init's entirety)'
commercial land supply.
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Metro Plan/East Main Refinement Plan, ZON 2007 -DOO 12 - LRP 2007.-D0013
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G()ALONE COALITION
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. . Additionally, the.analysi~pursuant to Ordihance #6150f~ils to account fo~ lands ADDED TO .
.. . the, cO.(TIIDercial inventory since 2000, including but not. limited to the Gateway N[])R site's'
:' 10q acres, providing askewed pictl.1re of the actual.com.rriercialland inventory. '.
To ske~ the picture even further, the analxsisof max.imum po;sible impact from GoalS
protection measures on supply of industrial lands (Ordinance #6150, table 11-1) corisiders
ALL industrial lands within .the ~ntire Metro UGB area, rather than just the Springfieldp;rtion'
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 mimberoflight
medium industrial (LMI) acres by plan designation in the Springfield UGB area is 198,77, .,' '
while the number of .LM! acres within the Eugene UGB is shown to be 1230.78. The
.applicant fails to establish the relevancy of thesetables to the current PAP A and zone change
. proposal, considering that only about 16% of the Metro area ugb industrianand supply is , .
within the Springfield city. limits.
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Goal 9 _ Eco~o;roc Development is: "1'0 provide adequ&te opportunities'throughout the' ..
state for a variety of economic activities vital to the health, welfare, and prosperity of Oregon's
citizens.'" . .:. .! '. . ',; . '. ,~. . - . . , .,'
The Staff Report's Gba!:9 findings are based upon:the 1992 Industrial Land Studyandthe.
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 consiste'nt with the
compreherrsive plans of cities and counties and regional plans adopted under ORS Chap'ter
. 268. .
'Goal 9 ~ 660-009-00 I O' (4) establishes that for'a post_acklwwledgement plan amendment
'under OAR chapter 660, division 18, that changes the plan designation ofland in excess
of two acres witnin an existing urban growth boundary from an industrial use designation
to a non-industrial use designation, or arr other employment use designatiorr to any other
use designation, a city or county must address all applicable planning requiremerits, and:
(emphasis added) .
(a) Demonstrate that the proposed amendment is coris~stent with \ts most recent economic
opporturrities analysis and (emphasis added) the paris of its acknowledged
comprehensive plan which address the requirements of this division;
'.
The applicant appears to rely heavily 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 witt; comprehensive plan Economic
Element policies found in the Metropolitan General Pl:1n, Chapter Ill, B-1 - B-7 is msufficient
and does rrot address the most significant policies that must be considered.
."
The proposill would de;ease the City's campus mdustrial'land inventory by yet another 5.24
acres. Trre applicant has not justified the conversion of scarce, shovel ready industrial land,
Metro Plan/East Main Refinement Plan, ZON 2007-D0012: LRP 2007-D0013
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GOAL ONE COALITION
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The applicant mal<esthe argUment that the proposed plan ame~dment an,d 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. It appears that the existing n~nconforming uses were actually established
AFTER adoption of the 2000 ?CLS, indicating that the existing uses were actually permitted
bYthe City with the knowledge that these uses would'create plan/zone' conflicts.
. '
In. addressing applicability of the SpringfieldCOmrhercial Lands Study (2000 S'CLS), the
applicant appears to .try to separat~ the Metro Area by jurisdictional boundary. However,
EugeneMd 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 own to establish consistency with the
requiremel1ts 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 pian.
A related problem with placing such heavy reliance on the 2000 SCLS t~ establish Goal 9
compliance is that in analyzing supply and demand, the srudy fails to cOl1sider or otherwise
account for lands added to the commercial)nyentory via applicant initiated and city approved
zone changes and plan amendments. One very obvious example of an additiol1 to ,the ,,'
Springfield commercial larlds inventorj was the 2003 planamel1dmel1t and ZOrle change (LRP .
2003-0013 and ZON 2003-0019) at the \ OO-acre Gateway Medium Density Residential site.
that had lfJe effect of rezoning and redesignating 100 acres of residential land to co~erciaL
. The appiicant provides a spreadsheet (their: Attachmel1t B) that supposedly accounts for all. .
Metro Plan' diagram changes affecting the supply of residential, commercial and industrial .
Lands in the city of Springfield betweel1 1991 and the present, but has faileq to account for or .
otherwise address the addition of corrunercialland to the SCLS, even though it is clear that
. more than 100 acres of commercial land has been added to the invel1tory since the year 2000,
This omissiol1 raises doubt as to the accuracy of applicant's Attachment B in supposedly'
accountin" for additions to and subtractions from the various land inventories, ' .
. o. ... ' -
. The'applicant also relies in part on invel1tories established incorljunction 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 prolecliol1 measures were cOrlsidered for all zoning classifications, the analysis of .
ma"imum possible impact on supply of commercial lands pursuant to the srudy is limited lei
. the area within the Springfield' portion of the Metro UGB (table 11-2). Again, because
Eugene and Springfield share a UGB and a comprehensive plw, an analysis of the entire
UGB area is necessary to establish an accurate picture of the supply of commercial lands, .
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Metro Plan/East Iv\ain Refinement Plan, ZON 2007 -00012, LRP 2007~0013
5-110 '
4
GOAL ONE COALrrlON
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ill any case, the NR Study found. that the m~irn~m. possible impact of Goal 5 .protection
measures on the Sprin'gfield Commercial Lands 'Inventory, would be the, loss of 11.56,' "
. "commercial acres.'" ~ : : . .
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LOSS OF INDUSTRIAL LAND
The proposed pl~ amend~ents and zone changes would remov~S.24 acres of shoyel ready,
light medium industrial land from the Metro UGB area industrial lands inventory, This is in
addition to an additional 56 acre conversion of campus industrial to COrr1munity commercial
land less than 2 miles' ~way which is currently pending approyal by the Springfield city'
council. The applicant is vague about the purpose of the proposed plan amendment and ione,'
, 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 faIpily wage jobs. The applicant
has said nothing about the. existence of their other'l GO acre ,medical campus located within
about 5 miles of the sugject properties proposed for plan and zone changes. Given this fact;',
the applidnt has not justified the remoy'al of shovel ready light medium industrialland'.for
commercial uses. This mea 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 city of Springfield.. .. '
. . b _ .
The applicant cites 4 of the 32 Economic' Element policies pursuant to the c~mprehensive
plan (Metro Plan) (Chapter lll, 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 1,2, 6, and 11 '1 .' .
Policy 1 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 slllndard 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 utili~es loc'al 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 import~d capital, skills etc'. as no
commitment to a usehasbeen established.
it.
Policy 6 merely states: "Increase the amount of undeveloped land :olled (emphasis added) for
light industrial and cormnercial uses correlating the effective supply in terms of suitability and
, availabiliry with the projections of demand." .
This pollcy addresses zoning only, not plan designation, and concerns the necessirj of having
adequate supplies of land of both cormnercial and. industrial designations. It says nothing
concerning the applicability of favoring one plan designation over the other,
i,letro PlanlEast ~lairi;Reflnemenl Plan, ZON,2007-D0012 - LR, P 2007-D0013
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GOALONE COALITION
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Policy 11 is to encourage economic activities which strengthen th~ metropolitan area's
. position as a regional distribution, trade, health, and service center. The applicant
assert.s that the amendment (sic) ,will facilitate the development ofinedical uses that
will serve the needs of the growir!gresidential ar"eas in east, south and southeast
. Springfield,'and strengthen the metropolitan area's position as a premier localefor
healthcareservices, consistent with this policy objective. Considering that their 2003
zone change and plan amendments were based on ~e assertions that provision of
medical care pursuant to campus style medica] facility development is the wave of the .
future, and that the applicant already has established their dommance in the health care
market within the city limits, it lias hard to' fathom why they think another 5.24 acres:
will someho\~ strengthen Sp'ringfie1d's pOsition as a premier locale for healthcare : .'
..' . ". .
'servlces.
.'. +'.
The PAPA proposal 'must be consistent with the Econ~mic Element of the Comprehensive "
plan in it's entirety, A majoromission found in.the applicati9nand staff report is an analysis
. of all the Metro Plan Economic Element,policies other than the four addressed by the .
applicant. The remaining 28 polici~s should be a~dres?ed in some mariner, 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 Plail provision is directly applicable because the subject properties are currently zoned'
and designated to take advantage of light 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 Econo'mic.
element, and if approved would have the effect oflimiting future growth and expansion of the
existin'g campus industrial uses. .
-7 _ Encourage industrial park development, including areas.for warehousing.and distributive
industries and research and development activities.. .
EcorlOmic Element of the Metro Plan, Finding #17 establishes: '~Speciallight 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'subjectsite is located adjacent to an existing light .
medium industrial site,
9 _ Encourage the expansion of existing and the location of new manufacturin'g activities
which are characterized by. low levels of pollution and efficient energy use.
Staffhas not discussed efforts to attract and/or encourage expansion of manufacturing
activities 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. .
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'Melro Plan/East Main P,eflnement Plan, ZON 2007-D0012 - LRP 2007-000Q
. 5~112-
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Neighbors ha~e expressed no concern abou\ their q~ality6flif;~frorr; existing industrial us~s.
. The applicant has not addressed why or hoW the existing light medium industrial zoning and
plan designatio~ iSllcompatible with the adjacent neighborhpo(l zoning .and plan designation.
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~GO~L ONE COAUTJON
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16 -Utilize pro~esse~ andloca\ controls which enc~~age retention'oflarge parc~ls or' .
consolidationofsma11 parcels of industrially or cominercially zSJl1ed land to facilitate their use
or reuse in a comprehensive rather than piecerheal fashion. . '
. . "
The subject properties are adjacent to a large parcel which is zoned and designated UvU. 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 of LMIland within the Springfield
city limits. .' .'
, 21 _ Reserve several areas within the UGB for large scale, campus type, light manufacturing.
uses.
Staffhas failed to address theimpactthat this proposal will have on the dwindlings~pplyof
. ,shovel ready industrial land inside the Spiingfield citylimits, iI}cluding prior actions .
. 'appro~ing land use code amendments. to the campus indtl?triaLzone that established more'
'flexibility' for what uses are allowed in the city's campus industrial zones. .
28 _ Recognize the vital ,role of neighborhood commercialJacilities in providing servicesand >
goods to a particular neighborhood. .'
"
.,
'r
This PAPA proposal requests community commercial plan designation and zoning yet has not
considered or othe~ise addressed the applicability of neighborhood commercial zoning vs, '
the requested community commercial zoning. .
, Staff and app\ic'1Ilt have not addressed the applicability of corpmunity commercial zoning
within a node, or explained why neighborhood commercial zoning is being ignored for higher .
, intensity uses in this existing neighborhood.' .
All the Metro Plan Economic Element poliqies are applicable to this application, and should'
have been addressed by the applicant.'
111. Conclusion
Theproposed plan amendment is not \\lgical and harmonious with the land use patternJor
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 Pl:rn, and does not comply with Metro PI:rn policies. Tnerefore it cannot
be found to be compatible with these Plans.
. . ,
Compli:llce with statewide 'planning goals, including goals 2, 6,9, 10, 12, and 13, has not
been established. . [n 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 PAP A and zone
change proposaL"
, '
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'.lVletr~PlanJEast Main Refinement PI~n, ZO~i2007'()0012 - LRP2007-00013.
5.c113
GOAL ONE COAUTION
The requested plan amendment does not comply with policies or the ty!etro Plan and
Metropolitan Industrial Lands Special Study. '. ' .:,
".
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The request~d plan amendment and ,zone change does, not benefit the public and are not
appropriate. ' .' .
; d ! '"
Goal One and other parties whose addresses appear in the first paragraph of this letter riquest
notice and a copy of any decision and findings regarding this. matter. . , .
Respectfully.submitted,
;. '
'. Lauri Segel
.' Community Planner
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Metro Plan/East Main Refinement Plan, ZON 2007 -00012 - LRP 2007 -00013
.5-;-114
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~PeaceHea1th
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,
Springfield Planning Commission
Attn: DavidReesor, Planner
. City of Springfield
Developine[]l ServIces Department
225 Fifth Street' . . .
Springfield, OR 97477 .
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Re: ZON 2007-00012, LRP 2007-00013 - Plan Ame~dmentJZone Change
Dear Chaim1~\[]'Cross and:Commissioners,
The Commission considered the above-referenced applications on June 5 at a duly
noticed work session and public hearing.. The follo,wi~g 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
. refll1ement 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
jurisdictio[]ally focused SCLS does not analyze supply and demand for,the
. 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 establishes lhn,t the proposed PAP A [Plan amendment] be ,
consistent with both (emphasis added) the most recent economic
opportunities analysis (i,e" the 2000 SCLS)'ulld the comprehensive plan."
(pg. 4, Segel letter) .
,.
Aoolicant's Resoonse:. The SCLS vias 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' O,6.Rs pursuant to perio,dic review
requir'ements established by the Oregon Land Conservati6n and Development
Commissio[], Prior to the SCLS, the City of Eugene had an acknowledged planJor .
complying with Goal'9, .the 1992 ,Eugene Corrunercial Lands Study (ECLS). The ECLS
. . .
states: "The study includes solely the Eugene portion of the metropolitan urban growth
boundary." (pg. 1-3, ECLS)
"Phone; (541) 686-3660
Fn.~: (54') 686-3699
PO Bo~ 1479 Eugene OR 97440'1479
Dedicated ro Exceprionol AJedicini!
and Cvmpassionutl! Care
"
5-115
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Re: ZON 2Q07-00012, LRP 2001_00013'~'Plari'AmendmeniJZone Change
Applicant's Rebuttal '.', -. . ..: .:...,. .., ,. ....
June 13.2007.. .
Page 2 .
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Although there lS in fact an ackno\vledged study covering both communities' industrial
. lands (the 1993 Metropolitan Industrial Lands Policy Report, and companion Inventory
. Report), the cities of Eugene and Springfield have separately adopted and acknowledged
commercial lands studies fulfilling the requirements of Goal 9. As such, the SCLS serVes. '
as the City ofSpririgfield'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 commerciallanqs in order to adopt findings sati~fying compliance
with Metro Plan policies and Goal 9.
Ms. Segel slates that theahalysis Jlrovided does not account for additions
to the Inventory of commercial lands, notably "the Gatew<!y MDR site's
100 acres." (pg,4, Seg~1\etter) "
Aoolicant's Resoonse: The City previously adopted amendments'to the Gateway'
Refinement Plan (Jo, No. 2002-08-244), including GRP 1n1plementation Action 12.1,
which limited redesignation and rezoning of up to 99 acres of residential land within the
Gateway MDR site. Subsequent Plan diagram amendments and zone changes of 96.2
acres and 35 acres resulted in redesignationlrezoning of 96.2 acres to Mixed Use
Co.mmercial or Medical Services of the possible 99,acres available under the GRP,
Considering illat the SCLS identified a deficit of 158 acres in the supply of commercial
land over demand, accounting for this additional redesignatedJrezoned land, this would.
still result in' a deficit of more than 61 acres of needed commercial land. . Approving the
requested Plan amendment/zone change would still1eave 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 ofimp~cts t~ the commercial lands inventory pursuant to the City's
acknmvledged compliance with Goal S periodic review requirements. Table 11-2 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 GoalS protection measures that approximately 11.5 acres
would be removed from the inventory of needed commerciallarids, thus further adding to
the commercial lands deficit established in the SCLS,
" Therefore, even considering impacts to comrnerciallands inventories from other adopted
. and acknowledged plans (i.e., the City's plan for Goal' 5 compliance) and acknowledged
. Plan amendments/zone changes, approval of the proposal will not result in there being an
excess 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, ' .
5-116
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. .,..Re: ZON 1-007,00012, LRP 2007,00013 "CPI":n Amendment/Zone Ch~n'ge
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Applicant's Rebuttal . ,.'
June 13. 2007' "..
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. Ms. Segel st~tes that tlie appiication'ielies "h~avily on inventory ari'd"
'.. . policy statements established by the 2000 SCLS in establishing that th,e .
proposal is consistent with the Goal 9 rule. However, the applicant's, .
'analysis of the proposals' consistency with compreh~nsive plan.Economic:,
. Element policies found in the Metropolitan General ;Plan, Chapter III, B-1
. _ B-7 is insufficient and does not address the most significarit policies that
, 'must be considered." (pg 3, Segel letter)
. She further'alleges that the application hasn't "justified theconversiSJn of " '
. scarce, shovelready industrial land, especially land designated andzoqed
lightmedium'industrial inside'theMetro UGB, even though the Metro .
. Plan (comprehensive. plan) Economic Element polic'y #12 establishes that.
the cities are to 'discourage future Metropoli'tan Area General Plan.
amendments that would change development readYindustriallands (sites'-'
. defined as short-term in the metropolitan industrial Lands:'SpeciaLStudy,
.1991)to non-industrial designatiorls.' The applicant and staff findings do
not address ho,<<the loss of these'5:24 acres impacts'the short-term supply, .'
of LMI designated land." '..
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Aoolicant's Resoonse: The Applicant's original March IS; 2007 submittal included
findings addressing r,elevant Metro Plan policies (see pg. 5:ofthe submittal, pg. 4~5 of the
Commission's June 4, 2007 hearing packet). Clearly not all of the 32 MetroI;'laI)'
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 serVic'es and
goods to a particular neighborhood." (pg. I1I-B-6, Metro Plan) Others are directed to .
actions that the public sectQr jurisdictions are to undertake, such as Policy 3 I, which
Springfield did in conducting in the SCLS: "Conduct a Commercial Lands Study prior'to'
the next major plan update" (pg. []I-B-7, ibid) Nonetheless, to demonstrate that all
policies were considered irrespective of tneir applicability:the Applicant will provide
supplementaI"tindings and enter them into the record priorto the City Council hearing on
these applications. Howev'er, this does not suggest that the Applicant's.findings are .
presently inadequate or that the Metro Plan policies cited are noton point.
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 Iiidustrial
Lands Special Study, 1991)." The adopted and acknowledged Metr?politan Industrial
.Lands Policy and Inventory Reports identify the Sllbject site as being included in
"Subregion;;3 _ East Springfield." Maps and tabular-information in these reports (jJp,
42-44', tables.pp. 13-26; 1993 MIL Policy Report) do not identify the subject site among
the "short-term sites" in 'the industrial lands study, presumably because both were'
considered developed. The abutting property nowdeveIciped with the Hyland B'usiness
Park was, however, identified in the study as site #7 in this subregion. While the Hyland
. property was included ,in the matrix of "short-term sites," it was also identified as being a
"deyeloped" site The MIL Policy Reppr't states that "site~ developed during the study
5-117
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Re:' rON 2907~OOO \2,.LRP 2eu I-ooon :- Plan Ame~dn,entlZone Change'
Applicant's Rebuttal. ., .
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_ were not included i~the sh'ort,terTnsupply of sites: Staff project~d alive year n~edfor
. industrial sites based on development trends in Eugene-Springfield during the previous
. two year period, a time of'economic 'growth,' This short term demand was compared to .
'the existing'supply of sites, excluding those already developed. [emphasis in original'
report]" (pp. IS, 16) 'Therefore, the.subject site was not included in the inventory of
. 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 clearlynot prohibitive to approval of an
application forredesignationlrezoning of an ind,ustrial site, particularly when considerinc.
., - ..:;;,
it in the context of industrial and commercial land inventories. As stated above and'
established in the record, there is a demonstrated need for additional commercial land
. _ ..', . . I
which the proposal helps address, .
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. The.record also includes evidence demonstrating that there is a sllrplus Of needed
industrial land. _ The acknowledged metro industrial lands 'study identified a surplus of .
. buildable light mediumindustrial acreage, and overall industrial acreage, in Eugbne,
Springfield, and corribined in the metro UGB. Table 5 in the MIL Inventory Report (pg.
47) identifIes supplies of buildable industrial land as follows:
..'
LMI Acres
1,230,78
198,77
. 1,429.55
, "
Totallndustrial Acres.
2,895.49
708.80
3,604,29
. Eugene'
Springfield
Metro UGB'
. 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 n~ted in the City's GoalS analysis entered into the record, the' maximum impact of
industrial acreage from GoalS 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 90.80 acres removed from the industrial designation by prior Plan
amendments in Springfield. Therefore, even if all of the industrial acreage impacted by .
Goal Sand all of the acreage redesignated in SpIjngfield were from the LMI designation
_ which is no doubt not th~ case -there would still be a surplus of nearly 50 acres of LMI .
designated land even afterapprova\ of the requested Plan amendment. This does not
accollllt 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 re~oval of 5.24 acres of U'!!l zoned and d~signated land will not result in
a defic;t of needed land in that industrial designation. .
. ..'
Moreover, although Economic Element Policy 12 "di'scourages" Plan amendments for
certain industrial lands, there are countervailing policies in the Metro Plan (i.e:,
,.
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. 5-118
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Re: ZON ZCIO?-OOOIZ,LRP 2007_000'1l.'Plan'AmendmentlZo'ne Ch;nge .
Applicant's Rebuttal . .
June \3 2007' - " ..-'
P~~e 5
. .
..
....
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'_.":
.Ms: Segel's letter stat~s that "the applicantis nO,t specific.about'what'use~
, _ will be cited sh~uld the proposal be approved,and th~re is no way to know'"
if infact [sic] above i:age jobs and salaries." (pg. 5:; Segel letter) : ....
_ ,. 1 . .1.
.,
. She also ;tates that while "the applicant argues that the prop~sal would
have the effect of correcting existing non-conforming uses on IL #4"02"
. ., thatthe property is not included in the "Sites with Plan/Zone Conflicts" in
the SCLS. She goes on to state that "it appears that the. existing.
nonconfoffi1ing uses were actually' established AFTER adop.tion 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." (pg. 4, Segel letter) .
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Aoolicant's Resoonse: The Applicant does not allege~thatthere is a Plan/zone conflict on..
. Tax Lot 402; clearly the existing Plan designations and zoning are LM!. Rather, the.
point made in our application narrative is that com'mercialuseshave existed for decades,
pre-existing the establishment of the Metro Plan and the application of the LM! -.
designation on the subject' properties. Ms. Segel provides.no evidence to back up her' .'
accusation that the City wittingly allowed conunercial uses on Tax Tot 402 after.adoption
. of the SCLS. The Applicant and owner of Tax Lot 402 will provide additionaLevidence'
and testimony at the City Council hearing on July 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
redeslgnation/rezoning 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's June 4 heanng 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 benefits for medical workers tends to
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'5-119
.. .' '.. . -, .- .
Re: ZON 2007-000l2, LRP 2007-000\3 - Plan AmendmentiZone Chamie
. - ,- " ,-, >,- ....
. Applicant's Rebuttal .' .
June 13. 2007
'Paae 6
.. Q. .
~,
,
l'
. be higher than avera"ge local wages, arid fui1her"substa~tiati~g'data'can be entered into the
record at th-e CitxCouncilleve!.' ,....
. Ms, Segel c~ntends that the proposal is not "logical ind harmonious" with
. land use patterns in the greater area, inconsistent with the intent of the'
E"conomic Element of the Metro Plan, doesn't comply with Metro Plan
policies. and hasn'tdemonstrated compliancewith 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 proposa!." ,
Aoolicant's ResDonse:. It should first be noted that ('he application does not involve or in
any way affect the."metro area's supply of campus industrial land." Moreover, the
" applicati~n has no effect upon Goal 10 (Housing), and ha; 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 hea,nng 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 c'ontention that the' proposal would not result ina "logical and harmonious" land use
pattern is witl{out substance or basis in fact, and is not an approval criterion. As noted
above and elsewhere in the record, this proposal is,consistent with policies and provisions
in the Metro Plan, its Economic Element'- supporting refinement plans (i.e., the SCLS and
MILS) to the Metro Plan, and Goal 9 and other applicable statewideplanning goals.
On the basis of the record and arguments before you, we urge you to support the Staff
recommendation and forward to the City Council your recommendation approving the
pending applications. .
,
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Pnilip Farringt n, ,dCP
Director, Land Use Planning & Development
PeaceHealth Oregon Region
cc:
Jim'Werfelmann
Andrew Head'
Shaun Hyland
5-120