HomeMy WebLinkAboutOrdinance CMO 7/16/2007 (2)
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.' ORDINANCE NO.
6200
(General)
.il
AN ORDINANCE AMENDING THE METRO PLAN DESIGNATION OF APPROXI-
MA 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 INDUSTRlAL (LMI), TO COM-
MERCIAL WITH AN AUTOMATIC REDESIGNA TION TO THE EAST MAfN REFfNE-
MENT PLAN FROM LMI TO COMMUNITY COMMERCIAL (CC).
, THE COMMON COUNCILOFTHE CITY OF SPRINGFIELD FINDS THAT:
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I. Article 7 of the Springfield Development Code sets forth procedures for Metro Plan dia-
gram amendments; and '
2. Springfield Development Code Section 7 .110(4) 'states:
"When a Metro Plan amendment is enacted that requires an amendment to a refinement
plan or functional 'plan diagram or map for consistency, the Metro Plan diagram
amendment automatically amends. the refinement plan or functional plan diagram or map
if no amendment to the refinement plan or functional plan text is involved... " ; and
3, Article 8 of the Springfield Deyelopment Code sets forth proc'edures for Refinement Plan
diagram. amendments; and
4. On March 16",2007 the applicantiowner of the subject property initiated the following
Metro Plan Diagram amendment with automatic amendment to the East Main Refinement Plan:
Redesignate approximately 5.24 acres of land on the Metro Plan Diagram from Light
. Medium Industrial to Commerciahvith automatic redesignation of said property on the
: East Main Refinement Plan diagram from LMI to Community Commercial (CC), Case
Number LRP2007-000 13, for property identified as Lane County Assessor's Map 17-02-
32-00, Tax lots 400 & 402; and
5. On June 4th, 2007, the Springfield Planning Commission held a work session and public
hearing to receive testimony and hear comments on this proposal. A second public hearing was
held on June 18'", 2007 after the written record was left open for seven additional days and after
reviewing additional written testimon~. The Planning Commission deliberated and voted unani-
mously (5-0) to forward a recommendation of approval to the City Council; and
.. ..
6. On July 2"d, 2007 the Springfi~ld City Council held a work session and a public hearing
to consider and to receive testimony alld 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 rec~rd as well as the evidence and testimony presented at this
public hearing held in tlie matter of adopting this Ordinance amending the Metro Plan Diagram
and East Main Refinement Plan Map. ;,
NOW THEREFORE, based upon the foregoing findings 1-6 the City of Springfield or-
dains as follows:
Section I. The Metro Plan designation of the subject property, more particularly de-
scribed in Exhibit A attached hereto and ilicorporated herein by reference, is hereby
O aml'lrd from Light Medium Industrial to Commercial.
ate Received:fo tn. . ., .
Planner: DR (, 7. . "'\ OlilllNANCE NO, 10700
\1..1. 1d1#1/ PAGE 1 OF 2
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.Section 2, The East Maiil Refinement Plan designation of the subject property is hereby,
amended from Light Medium }ndustrial to Community Commercial.
Section 3. If any section, subsection, sentence, Clause, phrase, or portion of 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, and independent provision and.
that holding shall not affectthk validity of the remaining portion of this Ordinance: .
"
,
FURTHER, although not part of this Ordinance, the Springfield City Council adopts
findings 1-6 herein above, and the findings set forth in the Staff Report which demonstrate con-
. fon~ance of this amendment to the M~tro Plan; applicable State statutes and applicable State-
wide Planning Goals and Administrative Rules, and is attached as Exhibit A,
ADOPTED by t;,e Co';'mon Council Jfthe City of Springfield this 16th day of
.Tul v . 2007 by a vote of ~ for and -.L against.
APPROVED by the Mayor ofthe.Ci~ ofSpdngfield this I6tl1layof
July
,2007,
"iMv>(}
Mayor I cr
~~ ATTEST:
~~
City Recorder a
il
REVIEWED & APPROVED
AS TO FORM
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DATE: k7f";.[)(
OFFICE of CiTY ATTORNEY
OIillINANCE NO. . 10700
PAGE 2 OF 2
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EXHIBIT A
SPRINQP11!l..D
Type II Metro Plan 'Map Amendment
. & Zoning Map Amendment
Staff Report and Findings
Hearing Date:
June 4'", 2007 - Planning
Commission
June 18111, 2007-
Planning Commission
July 2nd, 2007 - City
Council
Aoolicant
PeaceHealth Oregon Region
1~3 International Way
Springfield, OR 97477
Case Number:.
ZON 2007-00012
LRP 2007-00013
Owner
. Aoolicant's
Rel;lresentative
Philip Farrington, AICP
Director, Land use
Planning & Development
PeaceHealth Oregon
Region
123 International Way
Springfield, OR 97477
Hyland Business Par'", LLC (TL 400)
Attn: Shaun Hyland.
1941 - A Laura Street
Springfield, OR 97477
Andrew Head (TL 402)
1616 Ardendale Ln.
Eugene, OR 97405
Date Submitted: March 16th, 2007
EXECUTIVE SUMMARY:
The applicant is seeking approval of a Metro Plan Amendment I Refinement Plan ·
Amendment and a concurrent Zoning Map Amendment from LightMedium Industrial
(LMI)tOCommunity Commercial (CC) As described in the Springfield Development'
Code, a Refinement Plan Amendment automatically occurs on a site concurrently with a
Metro Plan Amendment if no new Refinement Plan text is needed or proposed. The
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 Main Street (Highway 126), The site consists of
two parcels, and is located on approximately 5.24 acres identified as Tax Lots 400 and
402 on Assessor's Map No. 17-02-32-00. The majority 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
LQ,oZOO 7.000 I ] & ZON2001-000/2
ATTACHMENT
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Commercial Lands Study, there is a shortfall of commercial lands within city limits, The
1992 Industrial Land Inventory and the City's adopted c;oal 5.analysis support the fact
that there is a surplus 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 demand 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 demonstrate compliance with
the Statewide Planning Goals, Metro Plan, Oregon Administrative Rules, State Statutes,
and demonstrate the ability to service the site with adequate public facilities and
services.
This Staff Report provides findings of fact relevant to'each of the applicable criteria of
approval and recommendations to the Planning Cornh,ission, Upon review of the
evidence provided by the applica'nt, site visits, existing structuresluses and review of the
applicable criteria of approval, staff finds that the applicant's req\Jest for a Metro Plan I
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 propodl to the City Council with a
recommendation for adoption.
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 10catedne'ar'Main Street and 44111 Street. A
Metro Plan Amendment at this time (not during peri6dic Review) is known as a Post
'Acknowledgement Plan Amendments (PAPA), This ~ame 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. .' '. I . .'
Pursuant to SDC 7.110'(4), approval olthe requested Metro Plan diagram amendment
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:
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The subject site is located on approximately 5.24 acres identified as Tax Lots 400 and
402 on Assessor's Map No. 17-02-32-00. I
The subject properties include a vacant, flat parcel (Tax Lot 400) and existing
commercial development (Tax Lot 402) ea$t of 44111:Street along Main Street in east
Springfield. The site is bordered on the south by M'ain Street, on the east by the Hyland
Business p'ark on the north by an open area south: of the Weyerhaeuser mill site (Tax
Lot 400) or an 'existing commercially zoned parcel (Tax Lot 402), and on the west by
other small-scale commercial enterprises (e.g., a cabinet shop and karate school)
fronting Main Street and residential homes along 44111 Street west of Tax Lot 400.
lRP2007.000'J & ZON2007,OOOl2
5-2
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Commercial enterprises are located immediately south of the site across Main Street
(~.g., Gray's Garden Center).
While historically involved in agricultural uses, since around 1990 Tax Lot 400 was used
as a storage and sales yard for land$cape organics and forest by-products. The current
property owners also used the site to store modular construction offices, tool trailers,
construction equipment and concrete form plywood. Tax Lot 402 has had various
commercial services on site since til'e 1950s. .
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);'currentiy designates the subjjct property for
industrial uses.
The abutting property to the east is 'designated Light/Medium 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 Community Commercial. Property to the west of Tax Lot 400 alorig 44111
Street is zoned and designated Medium Density Residential.
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lRP200 7,000 I J "ZON2007.00012
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Existing & 'Proposed Metr? Plan Designation:
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Metro Plan Designation
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D Low Den. Res.
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Refinement Plan
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Low Density Residential
Mediu'm DenSIty Residential
Light-Medium Imuslrial
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~.''21 Mixed Use 2 & 3
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Existing 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'
EXistinJ business park on property located east of TL'
400 I
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lRP2007-000 13 & ZON2007-000/2
~-8 -
REVIEW PROCESS:
The propased Metra Plan Amendment is a Type II Amendment because it is located
inside the city limits and is site specific, The applicant has requested that applicatian
ZON2007-00012 (Zaning Map Amendment) be raised to a Type IV review procedure
and be reviewed concurrently with the Type II Metro Plan" Refinement Plan Amendment
Application LRP2007-00013, Thesetwo applications use similar criteria af appraval and
have been combined into. one staff ~eport for ease of review. Bath applications have
criteria req'uiring cansistency with the Metro Plan and ather similar criteria, Rather than
repeat these criteria far each application, they will be addressed a'nly once and then
referenced where appropriate. Crit~ria that are different will be addressed separately;
the end result will be that all applicable criteria will have been addressed,
This application was submitted to the Development;Services Department on March 16'",
2007, and deemed as complete an April 11lh, 2007. Notice far both applicatians was
mailed to. Department of Land Conservation and Development (DLCD) an April 16111,
2007. Notice of the public hearing date was mailed out on Tnursaay, April 19, 2007 to
property owners within 300 feet af the proposed zone change per Sectian 14,030 (1) (a)-
(n) of the SOC. Public natice of the'hearing was published in the local newspaper
(Register Guard) on May 17l11, 20m', as required in Sectian 14,030 (2) of the SDC, No
written comments were submitted at the time of issuing this report.
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METRO PLAN DESIGNATION:
The subject property is designated LMI as shown in the Metra Plan diagram, The
subject property is part of the Ea~t Main Refinement Plan (EMRP), which provides a
more localized scope related to. F;'lan Designation, The subject property is designated
LMI an the Refinement Plan Diagram. Specific Findings related to the Metro Plan and
EMRP Street Refinement Plan Designation are written in this report,
METRO PLAN DIAGRAM AMENDMENT
CRITERIA OF APPROVA~ - SDC 7.070(3)(a)-(b)
"The fallawing criteria shall be'app/ied by the City Cauncil in approving or denying a
Metro Plan amendment applicatiah:. ' , "
(a) The amendment must be consistent with the relevant Statewide
planning gaals adapted by the Land Canservatian and Development
Cammissian; and
, (b) Adaption of the :,amendment must nat make the Metro Plan internally
inconsistent." ': .' ' "
CRITERIA OF APPROVAL - SDC .7.070 (3)(a),
APPLICANT'S NARRATIVE:
Consistency with Statewide Planning Goals:
lRP2007.0001] & ZON2007,OOOl2,
8
.5-1) ,
The following findings address compliance with Metro Plan criteria in SDC 7.070 (3)(a),
Approval of a Metro Plan diagram. amendment also correspondingly changes the ,
applicable refinement plan diagram, as established in SDC 7.110 (4). '
APPLlC!,>NT'S NARRATIVE RELATED TO GOAL 1:
Goal1 _ Citizen Involvement: To develop a citizen involvement program that insures
the opportunity for citizens to be involved in a/l phases of the planning process,
Goal1 addresses the need to develop a citizen involvement program to ensure citizen
involvement in all phases of the land use planning process. The Planning Commission
and the City Council will hold public hearings and accept testimony on the proposal.
Through the prOcedures established by the city, citizens will receive notice of hearings in
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 near15y property owners, 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.
STAFF'S FINDINGS RELATED to COMPLIANCE WITH GOAL 1:
Finding 1: These applications comply with Goal 1 because they are being reviewed
under an acknowledged citizen involvement program,
As previously mentioned in this report, notice for both applications was mailed to
Department of Land Conservation and Development (DLCD) on April 16111, 2007.
Notice of the public hearing date was mailed out on Friday, May 11111, 2007 to
property owners within 300 feet of the proposed ~one change per Section 14,030 (1)
(a)-(n) of the SDC, Public, notice of the hearing w'as published in the local newspaper
, (Register Guard) on May 17111, 2007, as required jn Section ,14.030 (2) of the SOC.
,
Staff concurs with the applicant's written statement related to Goal 1.
I .
APPLICANT'S NARRATIVE RELATED TO GOAL 2:
Goal 2: Land Use Planning: To establish a land use planning process and policy
framework as a basis for all decision and actions 'related to use of land and to assure
an adequate factual base for such decisions and ~ctions, '
I
Goal 2 requires that local comprehensive plans bi consistent with the Goals, that local
comprehensive plans be internally 'consistent, ana that implementing ordinances be
consistent with acknowledged comprehensive plans, Goal 2 also requires that land
use decisions be coordinated with affected jurisdictions and that they be supported by
an adequate factual base, As required in SDC 7,050, the City is required to give
referral notice of the proposed Type II Metro Planjdiagram 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 st~tutorily required notice of the initial
public hearing 45 days in advance to the state Department of Land Conservation and
Development, ensuring that they are given opportunity for comment and review
conformity to applicable statewide planning goals,
,
lRP2007.0001 J & ZON2007.00012
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'The Metro Plan and the SOC, as well as the Statewide Planning 'Goals and applicable
statutes, provide policies and,:criteria for the evaluation of comprehensive plan
amendments, Compliance with these measures assures an adequate factual base for
approval of the proposed Metro Plan diagram amendment. As discussed elsewhere in
this document, the amendments are consistent with the Metro Plan and'the Goals,
Consequently, by delT10nstrating such compliance, the amendments satisfy the
consistency element of Goal 2. '
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 2:
Finding 2: l:hese applications comply with Goal 2 because the SOC requires
consistency between the State0ide Planning Goals, the acknowledged Metro Plan,
adopted refinement plans and special area plans and the zoning.
. . ~ . . .
Staff concurs with the applicant's written statement related to Goal 2. ,
APPl:ICANT'S NARRATIVE RELATED TO GOAL 3:
Goal 3 _ AgriculturalLand: To preserve and maintain agricultural lands,
11. '
This goal is inapplicable because a~ provided in OAR 660-15-000(3}, Goal 3 applies only to
rural agricultural lands, The subject properties are located within an acknowledged urban
growth boundary, are inside Springfield's corporate limits, and have nQt been in
agricultural use for decades,
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 thes9 applications because the subject property
is within Springfield's city limits'
APPLICANT'S NARRATIVE RELATED TO GOAL 4:
Goal4 _ Forest Land: To conserve forest lands by maintaining the forest land base
and to protect the state's forest economy by making possible economically efficient
forest practices that assure the, continuous growing and harvesting of forest tree
species as the leading ~se'onforest land consistent with sound management of soil,
air, water, and fish and wildlife resources and to provide for recreational opportunities
and agriculture. "
Goal 4 does not apply within urban growth boundaries, per OAR 660-06-0020, and the
areas affected by the Plan ame~dments are inside Springfield's acknowledged UGB,
, '
STAFF'S FINDINGS RELATED li.O COMPLIANCE WITH GOAL 4:
'.
Finding 5: The subject proper;ty is loc'!ted within an acknowlei:lged urban growth
boundary, Goal 4 does not apply within urban growth boundaries, Staff concur with
the applicant's written statement related to Goal 4,
lRP2007,OOO/3 & ZONZ007:000/2
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APPLICANT'S NARRATIYE RELATED TO GOAL 5:
Goal 5 _ Open Spaces, Scenic and Historic Area, and Natural Resources: To conserve
open space and protect natural and scenic resources,
, '
Goal 5 requires local governments to protect a variety of open space, scenic, historic, and
natural resource values, Goal 5 and its implementing rule, OAR Ch, 660, Division 16,
require planning jurisdictions, at acknowledgment and as a part of periodic review, to
(1) identify such resources;
(2), determine their quality, quantity, and location; ,
(3) identify conflicting uses;
(4), examine the economic, social, environmental, and energy (ESEE)
consequences that could result from allowing, limiting, or prohibiting
the conflicting uses; and
(5) develop programs to resolve th,e.conflicts, ,
, The subject properties are not on Spririgfield's acknowledged Metro Plan Goal 5 inventory,
No threatened or endangered species have been,inventoried on the site, and no
, archeological or significant historical inventoried resources are located on'the site. The
National Wetland Inventory and Springfield Local Wetland Inventory maps have been
consulted and there are no jurisdictional wetlands located on the site, Therefore, the
proposed amllndment does not alter the City's compliance with Goal 5,
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 5:
Finding 6: Goal 5 does not apply to these applidations because there are no
inventoried resources on the subject property. Oregon Administrative Rule 660-023-
0250 establishes the applicability of Goal 5 rulesl to, Post Acknowledgement Plan '
Amendments (PAPA), the requested Refinement Plan Amendment and Zoning Map
Amendment do not affect the Metro Plan's ado pied Goal 5 inventory, Staff concurs
with the applicant's narrative related to Goal 5 compliance.
I
APPLICANT'S NARRATIVE RELATED TO GOAL 6:
Goal6 _ Air, Water and Land Resources Quality: To, maintain and improve the quality
of the air, water and land resources of the state,
The purpose of Goal 6 is to maintain and improve the quality of the air, water and land
resources of the state, Generally, Goal 6 requires that development comply with
applicable state and federal air and water quality standards, In the context of the
proposed Metro Plan diagram amendment, Goal 6 requires that the applicant demonstrate,
that it is reasonable to expect that applicable state and federal environmental 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 tlean-up list. A Phase 1
environmental assessment on the subject property ..las conducted and recommended
additional analysis, Upon recommendations throug~ the Phase 2 environmental
assessment a nominal quantity of soil (less than 10 cy) impacted by earlierlhistoric use
was removed from the site and properly disposed, Given the nominal impact generated by
historic uses on the site, it is reasonable to conclude that future development on the site
will be able to demonstrate compliance with City standards for water quality protection
II
LRP2007.000 IJ & ZON2007,OOOl2
<;-12
through the site plan review process,thereby complying with applicable state and federal
environmental quality standards,: '
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 6:
, I
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Finding 7: The proposed Metro Plan I Refinement Plan Amendment or Zoning Map
Amendment does not modify any of the Goal 6 related policies of the Metro Plan nor
do they amend the Regional Trahsportation Plan, the Springfield Development Code,
other applicable ,Goal 6 policies, or any regulations implementing those policies.
The subject property is located in the Zone of Contribution and outside any of the
Time of Travel Zones, which is r,egulated by the Drinking Water Protection Overlay
District _ Article 17, Any new development on the subject property is subject to
compliance with Article 17 and other applicable regulations related to Goal 6, Staff
concurs with the applicant's narrativ~ related to Goal 6 compliance,
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APPLICANT'S NARRATIVE RELATED TO GOAL 7:
Goal 7 _ Areas S~bject to Natural Disasters and Hazards: To protect life and-property
from natural disasters and hazards,
Goal 7 requires that development subject to damage from natural hazards and
disasters be planned anellor. constructed with appropriate safeguards and m'itigation,
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,
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STAFF'S FINDINGS RELATED TO C'OMPLlANCE WITH GOAL 7:
Finding 8: Staff 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 applicant's narrative related to Goal 7, compliance,
The site is flat and not subjecttb iandslide hazards, and is located well outside of any
established FEMA flood hazard area,' Therefore, approval of the proposed Plan
,
amendment and Zoning Map Amendment will not alter the City's acknowledged
compliance with Goal 7 through its adopted plans, codes and procedures,
APPLICANT'S NARRATIVE RELATED TO GOAL 8:
I:
Goal 8 _ Recreation Needs: To"satisfy the recreational needs of the citizens of the state
and visitors and, where appropriate, to provide for the siting of necessary recreational
facilities including destination;iresorts.
Goal8 requires local governments to plan and provide for the siting of necessary
, recreational facilities to "satisfy the recreational needs of the citizens of the state and
visitors," and where appropriate, provide for the siting of recreational facilities including
destination resorts, The subject S,ite is not included in an inventory of recreational sites',
and the 'proposed amendments wi,li not have an impact on the community's recreational
facilities or needs; therefore, the proposal does not implicate Goal 8,
.LRP200 7.000 /3 & ZON2007.00012
12
,5-13
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 8:
Finding 9: Staff has consulte'd the Wi/lamalane 20-year Parks and Recreation
Comprehensive Plan in relation to Goal 8 compliance, The Wi//amalane 2G-year
Parks and Recreation Comprehensive Plan was adopted by the City of Springfield as
part of the Metro Plan's compliance with Goal 8, None of the various studies ' '
inventories, and facilities plans regarding recreational facilities in the adopted
Wi//amalane 20-year Parks and Recreation Comprehensive Plan have designated
the subject site for parks and open space in an adopted inventory, declared it a
significant resource, or slated it for acquisition. Staff concurs with the applicant's
narrative related to Goal 8 compliance,
APPLICANT'S NARRATIVE RELATED TO GOAL 9:
Goal 9 _ Economic Development: To provide adeq.uate opportunities throughout the
state10r a variety of economic activities vital to the health, welfare, and prosperity of
Oregon's citizens,
\
Goal 9 requires the city to provide adequate opportunities for a variety of economic
activities vital to the health, welfare, and prosperity of the citizens, The proposed
amendment to the Metro Plan diagram will increase the city's capacity for economic
development by adding 5 acres of CC in place of the existing industrial designation,
Permitting the construction ,of future clinic facilities and allowing long-standing
commercial uses on Tax Lot 402 to become conforming uses consistent with commercial
zoning is consistent with numerous policies in the City's adopted plan for compliance with
Goal 9, the Springfield Commercial Lands Study (SCLS).
Specifically, the following SCLS policies are applicable to the proposal:
Policy 1-A: "Maintain a mixed supply of large and small com";'ercial sites through '
strategies such as rezoning or annexation to serve Springfield's future population,"
I ' '
i
The proposal fulfills this policy objective by redesignating and - through accompanying
zone change _ rezoning land hom industrial to comm~rcial, for two tax lots of varying,
sizes and commercial uses; thereby maintaining,exisling employment and commercial use
in Tax Lot 402 and providing the ability for growth in medical sector employment by
allowing future clinic uses on Tax Lot 400.
Policy 1-C: "Maintain at least a five-year supply 01 commercial land within the Urban
Growth Boundary (UGB) that is currently servedor readily serviceable with a full range of
urban public facilities and services," t
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 publib facilities and services available to
s'upport existing commercial development on Tax Lot 402, and future developmeni on Tax
Lot 400, ,The SCLS identifies (pg, 33) a need to suppbrt "employment in population-
dependent sectors such as retail sales and health se;rvices" to meetSpringfi~ld'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 sector!;, Approving the proposed .
redesignation and zone change would help meet Springfield's demonstrated need for
employment and commercial services,
I
/J
LRP2007.0001J & ZON200 7-000 I 2
S-1t. !
Finding 3 in the SCLS (pg,.36) cited the acknowledged 1992 Industrial Land Study as
demonstrating that "a surplus of industrial sites exists in the Metro Area," Therefore, the
proposedredesignation (and corresponping rezoning) would not result in a deficit of
needed industrially designated and zoned land, but it would help reduce the commercial
lands deficit identified in the SCLS, Therefore, approving the proposal would be
consistent with SLCS Implementation Strategy 3-A (1): "Evaluate inventories based'on
demonstrated need for the plannin'g period, Initiate rezo~ing or redesignation of s'urplus
land uses where more appropriate for commercial, consistent with the Metro Plan,"
The proposal in fact consistent with inventories for commercial and industrial lands
adopted by the City Council and acknowledged by DLCO as being consistent with Goal 9,
Oregon Administrative Rules concerning Goal 9 implementation (OAR 660-009-0010(4))
call for amendmentsto land use designations "in excess of two acres within an existing
urban growth boundary from an industrial land use designation to a non-industrial use
designation" to have to address applicable planning requirements - such as consistency
with the Metro Plan and other local plan policies (Le,..,SCLS) or be,co'nsistent 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-tJuildable lands for either category of
uses, The proposal enables continued use of the existing and long-standing commercial
center to continue to operate and provide employment opportunities, while also allowing
higher-value employment associated with future development on Tax Lot 400, These
types of employment-generating uses are arQPng those identified in OAR 660-009-0005(6)
as eligible non-industrial employment activities'that can justify approval of the proposed
Plan diagram amendment without the need for an economic opportunities analysis apart
from the SCLS, which OLCO acknowledged as fulfilling the City's obligations under Goal 9,
Because the requested redesignation and concurrent zone change implements SCLS
policies and does not result in a deficiency of needed industrial lands, and is otherwise
demonstrated to be consistent with relevant Metro Plan policies, approval of the requestis
consistent with the City's compliance with Goal 9 and applicable administrative rules
regarding Goal 9 implementation.
Additional Goal 9 information submitted by applicant on March 28'", 2007:
The Metropolitan Industrial Lands Study (July 1993) was adopted by the local jurisdictions
and acknowledged by LCOC 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 1,1.72
acres." (pg, 73) The Inventory Report also stated: "The 1,688 constraint-free acres may be
the best suited to meet short-term industrial demand, This portion of the supply also
exceeds the twenty year demand projection,"
The City performed subsequent analysis of industrial land supply as part of periodic
review requirements to demonstrate compliance with statewide planning 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 industrial
lands of between 1,600 and 2,122 acres metro-wide,
Staff's GoalS work also calculated the changes in industrial land supplies since 1991 as a
consequence of Metro Plan diagram changes (see Attachment B), This analysis
demonstrated a reduction in less than 90 acres of industrial land over the past 15 years,
/
lRP2007,QOO/ J~, ZON2007,OOOl2
/4
5'-lS
syggesting that there is still. an ample supply of available industrial lands tDmeet existing
and future development needs, . '" " ' , ' ,',
This analysis may also nDt reflect Dther changes within industriall.y designated land,
categDries that would further Dff-set the propDsed change to the site's LMI Plan ,
designatiDn and zDning, For example, 11,5 acres was' added ,to the inventory Df LMI zDned
and designated land due to City Council approval in April 1997 for land east Df the 28'"/31"
Street cDnnector and north Df Marcola Road (Ordinance No, 5851), Insofar as the City and
metropolitan area cDntinue 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 inventDry Df LMI desig'nated and zoned land to off-set the
prDposal to remove Dnly about 5 acres from the LMI inv~ntDry,
We therefore respectfully submit that the prDposed Metro Plan diagram amendment and'
zone change will not materially affect the inventory Df needed Industrial land and will not
alter the City's CDntinued CDmpliance with Goal 9,
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL'g:
Finding 10: The City of Springfield has two adopted inventories which support the
proposed Metro Plan Amendment I Refinement Plan Amendment and concurrent zone
change request _ the 1992 Industrial Land Study and the 2000 Commercial Land Study,
The applicant references both of these adopted inventories and sites specific polices
which support the proposal. As noted by the applicant, Finding 3 in the Springfield ' '
Commercial Land Study (SCLS) 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) of the S[CS which's,tates: "Evaluated inventories based
on demonstrated needfor the planning period. Initiate rezoning or redesignation of .
surplus land uses where more appropriate for comm'ercial, consistent with the Metro
, Plan." Staff finds that these referenced policies and adopted strategies support the
applicant's proposal. , ]"
,
In addition to referencing the SCLS and the 1992 Industrial Land Study, the applicant
also references the adopted Goal 5 inventory work, which provides a more up-to-date
analysis of industrial lands in the Metro area. As noted in the City of Springfield Goal 5
analysis, even with a reduction of inventoried 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 Goal 9 '
implementation (OAR 660-009-0010) call ior amendments to land use designations "in
excess of two acres within an existing urban growth/boundary from an industriaIland use
designation to a non-industrial use designation" to have to address applicable planning
requirements _ such as consistency with the Metro Plan and other local plan policies
(i.e, SCLS) or new consistent with an economic opportunities analysis (EOA), OAR 660-
009-0010 states that a reviewing authority can find that the proposal complies with '
relevant local plan policies by converting one form qr employment-generating land use to
another, withoLit negatively impacting the supply of buildable lands for either category of
uses, As npted by the applicant, there are existing tommercial uses located on TL 400
which are part of the subject'property, Additionally, 'the applicant is seeking to develop
future commercial uses on the property which will maintain the property for employment-
generating activity,
/5
lRP2007.000 I J & ZON2007,OOOl2
S-1R
.
Given the information provided in th~ .adopted commercial and industrial lands
inventories (a shortfall of commercial 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 '(lith G,oal 9:requirements, Staff finds that the proposal
does not represent a "significant change" to the adopted EOA.
APPLICANT' S NARRATIVE RELATED TO GOAL 10:
Goal 1 0 ~ Housing: To provide for the housing needs of cjti~ens of the state,
LCDC's Housing goal requires cities to maintain adequate supplies of buildable lands for
needed housing, based on an acknowledged inventory of buifdable lands, The proposal
does not affect the City's inventory 9f residential lands, .
In Iact, approval of the requested redesign"ation for T.ax Lot 400 would enable,
redevelopm'ent of an industrial site abutting existing residential development. Through,
the site plan review process, future development on that property will provide a superior
buffer and a higher use that will benefit'the adjoining residential properties, Because the,
proposal involves redesignation from industrial to commercial land uses, it does not affect
Springfield's continued compliance with Goal1Q, ' '
STAFF'S'FINDINGS RELATED TO 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 buildablr;lands
"inventory be'cause 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,
APPLICANT'S NARRATIVE RELATED TO GOAL 11:
Goa111- Public F.acilities and Services: To plan and develop a timely, orderly and efficient
arrangement of public facilities and services as a framework for urban and rural
development. '
OAR 660-011-0005(7)(a)-(d) Definition of ~ublic 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 Springfield UGB and city
limits, and Is already designated for urban levels of use, The proposed amendment to the
. Plan map' designations from LMI to CC will not affect the ability to pr,ovide needed services
since all the required urban services are available to support existing or future commercial
uses on the subject site, '
16
LRP2007.000 I J & ZON2007.000 12
5-17
,->
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL11: '
, Finding 12: As noted by the applicant, the Metro'Plan and associated facility pl~ns
have been acknowledged to conform to Goal 11 ensuring that public facilities and
sef'lices are currently available to the subject site. The proposed Metro Plan I
Refinement Plan Amendment and Zoning Map amendment is on "infill" property,
which currently has city sef'lices 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 sef'l.ices to sef'le the site, These applications
comply with Goal 11 because there are urDan level public sef'lices available to'the '
subject property , .)
APPLICANT'S NARRATIVE RELATED TO GOAL"f2:
Goa/12 _ Transportation: To provide and encouraJe a safe, convenient,and economic
, trans'portation system, " I" -,
Goal 12 requires local governments to provide and en~ourag'e a safe', convenient and
economical transportation system, The proposed map amendments involve
approximately 5.24 acres of property, though existing land 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 irlcrease the trip generation for that
parcel. As the attached Traffic impact Analysis (TIA) demonstrates, future development of
medical office facilities on TL 400 will not degrade m~bility standards below acceptable
levels and allow for adequate queuing lengths at applicable' intersections, Therefore, the
proposal will not have a "significant effect" on transpbrtation facilities as defined in the
Transportation Planning Rule (OAR 660-012-060), '
Existing development at Tax Lot 402 is, not affected by the proposal, and is assumed to'
'retain its current access points off Main Street. It is further assumed that future
development on Tax Lot 400 will result in some acce~s changes as will be reviewed
through the site plan' review process, thereby consoli'dating two existing curb cuts located
on Tax Lot400 into a single access point located app'roximately in the center of the parcel.
The TIA demonstrates that these access points will not result in any degradation of
mobility standards below'acceptable levels, and that safe and efficient circulation can be
realized through approval of the requested land use redesignaticin (and companion zone
change).
Furthermore, reducing the number of access points for future development on Tax Lot 400
is consistent with policy objectives found in East Main Refinement Plan (EMRP) Access,
Circulation & Parking Element policy 1 B (pg, 17) and Commercial Element policy 3 (pg.
12). ",
Because the proposal, as demonstrated in the TIA, is consistent with the requirements of
the TPR and with applicable policies in the EMRP, it is consistent with Goal12 and
applicable ,local implementing policies,
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 12:
Finding 14: The proposed Metro Plan Amendmen\ is from LMI to Commercial, and
Refinement Plan Amendment / Zoning Map Amendment is from Uvll to CC, The
applicant indicates in the submitted narrative that a'pproval of the proposal will not result
, '
17
lRP2007-0001] & ZON1007,OOOl1
5-18
in any changes to the type or intensity of uses on the site, and will not increase the trip
generation for that parcel. Staff does not concur with this statement.in reviewing all of
the potential CC uses on the site, Staff does concur,however, with the applicant's'
statement if the future medical office use is in fact developed on the site, and not other
potential "reasonable worse case" CC uses.
Pages 18~1 9 of the applicant's TIA list Peak Hour Trip Generation for both the existing
zone (LMI) and the proposed zone (CC), The applicant's TIA listed Peak Hour Trip ,
Generation for Medical Office Building, While this is a permitted use in the CC zone and
is the primary ,use that the applicant is seeking to use the property for: it is not the
"reasonable worse case" scenario for traffic generation given other allowable uses in the
CC zone. During Staffs review of the proposal, staff researched potential vehicle trips
pet 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 condition it is
clear, that a 30,000 square foot Medical Office Building is much less intense than other
uses that would be' permitted in the CC zone, On a per-square-foot basis the Medical
Office is estimated to generate 2.47 vehicle tipsl1 ,000 SF and 3,43 vehicle tipsl1,OOO SF
during the AM and PM'peak hours respectively, For comparison the average rates for a
'~Fast-Food Restaurant with Drive-Through Window" are 53,11 vehicle tips/1 ,000 SF and
,34.64 vehicle tips/1,OOO SF, These calculations are taken from the Institute for Traffic
Engineers (ITE) Manual.
As shown on Table 6 of the TIA, a reasonable' worse case traffic generation ,scenario for
the existing zoning (LMI) is 243 trips, The proposed use o.f Medical Office Building is
shown in Table 7 as 177 trips, While the Medical Office use trip generation is less than
the reasonable worse case scenario for the existing zoning, it does not take into account
other more intensive commercial uses (i.e, drive thru restaurants, banks, etcJ 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, City Traffic Engineering
Staff, and ODOT Staff) agreed on a recommended condition of approval (see attached
emails from OOOT 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 (24?
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 dev,elopment scenario" under the existing zoning (LMI) as submitted by the
applicant in the Traffic Impact Analysis for the subject property,
LQP2007.0001 J & ZON2007-00012
18
5-19
APPLICANT'S NARRATIVE RELATED TO GOAL 13:
Goal 13 _ Energy Conservation,: To conserve energy, Land and uses developed on the
land shall be managed and controlled so as to maximize the conservation of all forms
of energy, based upon sound economic principles, '
The Energy goal is a general planning goal and provi'des Iimitedguidance'f~r site-specific
map amendments, The proposed amendment has no direct impact on energy
conservation, though it would in fact will promote greater energy efficiency by enabling
needed clinical services available to growing residential areas in east Springfield.
Therefore, the proposed amendment is consistent with, and does not alter the City's
continued compliance with Goal 13. '
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 pursuant to Goal 13 compliance
of the Metro Plan, ' !
APPLICANT'S NARRATIVE RELATED TOGOAL 14:
, 'I
Goal 14 _ Urbanization: To provide for an orderly and efficient transition from rural to
urban land use,
I .
. Goal 14 requires local jurisdictions to provide for an "orderly and efficient transition from
rural to urban land use," The subject property is within the UGB and the city limits of
Springfield, and within an existing urbanized area of the community, Therefore, Goal 14 is
not applicable to this appli~ation. :
I
I
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 14:
Finding 16: As noted by the applicant, all of the barcels affected by this applic~tion
are currently within the Urban Growth Boundary and were annexed ,into the City of
Springfield. All annexations are reviewed for compliance with the Metro Plan and the
Springfield Development Code, As previously mentioned, urban facilities are
available to the s'ubject site, The proposed Refinement Plan and Zoning Map
Amendment are in compliance with Goal 13.
AP.PLlCANT'S NARRATIVE RELATED TO GOAL 15:
Goal 15 _ Wiflamette River Greenway: To protect, conserve, enhance and maintain the
natural, scenic, historical, agricultural, economic an'd recreational qualities of lands
along the Willamette River as the WiJlamette River Greenway.
This goal is inapplicable because ,the subject property is not within the boundaries of the
Willamette River Greenway. .
I'
STAFF'S FINDiNGS RELATED TO COMPIJANCE!WITH GOAL 15:
Finding 17: As noted by the applicant, the subject property is not located within the
Willamette River Greenway. Goal 15 does not apply to the subject Refinement Plan
and Zoning Map Amendment applications, '
I
lRf2007.0001J &. lQN2007-00012
1
I
19
5-20
APPLICANT'S NARRATIVE RELATED TO GOALS 16-19:
Goal16 through 19: (Estuarine Resources, Coastal Shorelands, Beaches and Dunes,
and Ocean Resources): '
The coastal goals are not applicable to this application,
STAFF'S FINDINGS RELATED TO COMPLIANCE WI;rH GOALS 16"19:
Finding 18: As noted by the applicant, the subject site is not located within any
coastal, ocean, estuarine, or beach and dune resources related area, Goals 16-19 do
not apply to these Refinement Plan and Zoning Map Amendment applications,
CRITERIA OF APPROVAL - SDC 7.070 (3)(b).
APPLICANT'S NARRATIVE RELATED TO SDC7,070(3)(b):
The applic'ation requests amendment of the Metro Plan diagram from LMI to CC for
approximately 5,24 acres, This section of the application narrative addressesthe
consistency of the amendment with the applicable policies of the Metro Plan, 'to
demonstrate that adoption of the amendment will not make -the Metro Plan internally'
inconsiste~t (as required by the approval criteria in SOC 7,070(3)(b)) ,
This narrative only addresses those policies that apply to the proposal, and does not
discuss those portions of the Metro Plan that: (1) apply only to rural or other lands outside
, of the 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 99als, policies and
implementation measures apply to specific development proposals that will be addressed
through compliance with applicable City regulations during site plan review of a given
future development proposal. .
The Metro Plan Introduction, Sectio~ o' provides the following definitions:
A goal as a broad statement of philosophy that describes the h'opes of the
,people of the commun'ily for the future of the community. A goaJ:may never be
completely attainable, but is used as a point to strive for,
An objective is an attainable target that the community attempts to reach in
striving to meet a goal. An objective may also be considered as 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 Growth Management Goals, which are addressed below, each olthe, Metro
Plan policies are addressed in the order in whic'h they appear in the Plan Element section
of the Metro Plan,
Metro Plan Elements
1, Growth Management
lHP2007,OOOIJ & ZON2007-iJ00/2
20
,-21
Policies .
1, The urban growth boundary and sequential development shall con"tinue to be
implemented as an essential means to achieve compact urban growth. Provision of all
urban services shall be concentrated inside the urban growth Qoundary, '
The proposed amendments satisfy this policy because the subject 'property is in~ide the
UGS and city limits and as such, encourages compact urban growth, Also, urban services
are available at sufficient levels to accommodate the existing and future infHl 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 Element
Policies '
A.11 Generally locate higher density residential dev,elopment near employmen't or
commercial services, in proximity to major transportation systems or within
transportation-efficient nodes,
The proposed redesignation does not affect the inventory or availability of resid'lI1tially ,
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 Stre!,t.
, I
However, approval of the requested redesignation to Community Commercial would allow
for residential areas proximate to the subject area to have close and efficient access to
existing commercial services on Tax Lot 402 and to future medical facilities proposed for
Tax Lot'400; consistent with the above policy, The'areas proposed for redesignation offer
existing and future employrnent opportunities and pr6vide,commercial services along a
major transportation system that can support the needs of nearby residential
development.' I ' '
I '
A,22 Expand opportunities for a mix of uses' in neWIY!deve/OPing areas and existing,
neighborhoods through local zoning and deve/opmerit regulations,
I
The map amendment 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 s~rve 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 saiary levels: and ihcreased variety of job opportunities,
a rise in the standard of living, and utilization of our Jxisting 'comparative advantage in the
level of education and skill of the resident labor forcJ, '
, I
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/
LRP2007.000/ ] & ZON1007,OOO/1
, ""':22
opportunities with higher than average wages thereby helping raise the standard' of living
arid meet the needs of Springfield,'citizens, consistent with the above pO,licy,
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 uses will utilize both local and
imported capital and will employ the"locallabor force 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 commercial
, ,
uses correlating the effective supply in terms ofsuitabiJity and availability with the '
projections of demand,
The proposal will add approximately,i5.24 acres of Community Commercial land,
consistent with recommendations to increase the co.mmerciallands inventory made in the
Springfield Commercial Lands Study, The SCLS and acknowledged metropolitan"
Industrial Lands Study concluded that there is a deficit of needed commercial land, and a
. J .
surplus of industrially zoned and designated land, Approval of th~ requested ,
redesignation will not cause the inventory of needed industrial land to go into a deficit, but
in fact would, consistent with the above policy, The proposal correlates the need-and
suitability, and availability of the subject site for commercial uses with the need for such
uses as demonstrated in the adopte~ SCLS, ' .
B,11 Encourage economic activitie;! 'which strengthen the metropolitan area's position as
a regional distribution, trade, health'; and service center,
The amendment will facilitate the development of medical uses that will serve the needs of
,the growing residential areas in east, south and southeast Springfield, and strengthen the
metropolitan area's position as a premier locale for healthcare services, consistent with
this policy objective,
6, Environmental Design Element
'Policies
E.1 In order to promote the greate';t possible degree of diversity, a broad variety of '
commercial, residential, and recreational land uses shall be encouraged when c~nsistent
with other planning policies.. ' '
Approval of the proposed 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 comm,ercial 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 6f the growing residential areas east and south of the
subject site, consistent with the above policy, ' ' .
7, Transportation Element
Land Use Policies
F,3 Provide for transit-supportive land use patterns and development, including higher
intensity, transit-oriented development along major transit corridors and near transit
stations; medium- and high-density residential development within one-quarter mile of
transit stations, major transit corridors, employment,centers, and downtown areas; and
;1
LRP2007,OOO/ J & ZON2007-iJ0012
22
~-n
B,
qeve/opment and redevelopment in designated areas that are or could be well served by
existing or planned transit.' .
The proposed map amendment and concurrent zone change will enable land use patterns
and development consistent with the above policy, Approval of the proposal will allow for
higher intensity development along Main Street, a major transit corridor, An existing L TO
stop is located on the frontage of Tax Lot 400 (see photo, pg, 2, Appendix A of the TIA),
,and will provide convenient access to existing and p~ojected employment on the subject
site, as well as access for patients to future out-patient medical facilities projected on Tax
Lot 400,
Transportation System Improvements: Roadways Policies'
.F.15 Motor vehicle level of service policy:
a, Use motor vehicle level of service standards to maintain acceptable
, and reliable performance on the roadway system, These standards
shall be used for: . . '
(1) Identifying capacity deficiencies on the roadway system,
, (2) Evaluating the imp~cts on roadways of am~ndnients to
transportation plans, acknowledged comprehensive plans and
land-use regulations, pursuant'to the TPR (OAR 660-012-0060),
(3) Evaluating development applic~tions for consistency with the land- '
'use regulations of the applicable local government jurisdiction.
b, Acceptable and reliable perfordJance 'is defined by the following
, levels of service under peak hdur traffic conditions: LOS E within
Eugene's Central Area Transp6rtation Study (CA TS) area, and LOS
o elsewhere, ' , " ',' ,
c. Performance standards from the OHP shall be applied on state
facilities in the Eugene-Springfield ~etropolitan area.
. . I '
In some cases, the level of service may be substandard, The local government ,
jurisdiction may find that transportation systemlimprovements to bring performance
up to standard within the planning horizon may not be feasible, and safety will not be
compromised, and broader community goals would be better served by allowing a
'substandard level of service, The limitation on the feasibility of a transportation
system improvement may arise from severe cohstraints, including but not limited to
environmental conditions, lack of public agency financial resources, or land use
constraint factors,' It is not the intent of TSI Raodway Policy #2: Motor Vehicle Level
of Service to require deferral of development in1such cases, The intent is to defer
motor vehicle capacity increasing transportatio~ 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,
t
,
Subsection a,(2) in the above policy requires an evaluation of the proposal pursuant to the
state Transportation Planning Rule (TPR), The accompanying Traffic ImpaCt Analysis
provides the factual basis to determine that the prop6sed redesignation would not result
in a "significant effect" as defined under the TPR (O~R 660-012-0060(1)). '
Specifically, the proposal does not change the functi~nal classification of Main Street or
any other nearby roadway, and it does not change th'e standards for implementing the
City's functional classification system of roadways, as identified in the Regional
Transportation Plan, As demonstrated in the TIA, th~ proposal also does not:
.
,
Result in types or levels 01 traffic or a1ccess that are inconsistent with the
functional classification of Main Street or any other nearby ro;KIway;
2]
'LRPZO07,OOO I] & ZON1007.00011
'1-;4
L
. Reduce performance of traffic on Main Street or other affected
intersections to a level that is below acceptable established performance
standards; or ' '
. Make performance of rxisting facilities worse (i,e" below acceptable
mobility standards) than would be the case other uses permitted under,
existing designations or zoning.
Specific TPR findings are further loc~ted in the TIA, see pp, 31-32. Because the proposal
does not result in a "significant effect" as established by applicable OARs, no further TPR
analysis is required, The request is therefore consistent with the above policy,
8, Public Facilities and Service Element
G,1 Extend the minim um "level and full range of key urban facilities and services in an
orderly and efficient manner consistent with the growth management policies in
Chapter /I-B, relevant policies in this chapter and other Metro Plan policies,
The subject property is located in 'Springfield's city limits UGB, All necessary
infrastructure and key urban facilities/services are present to serve existing development
(Tax Lot402) or are available to serVe future infill development on Tax Lot 400, Therefore,
the proposal is consistent with the ~bove policy,
9, Parks and Recreation Facilities Element Policies
Policiesin this element of the Metro Plan are not relevant to the requested diagram
amendment. ' ,
,
10. Historic Preservation Elern'ent Policies
, Policies. in this element of the Metro Plan are not relevant to the requested diagram
amendment. ' , '
11, Energy Element policies
Policies in this element of the Metro Plan are not relevant to the requested diagram
amendment.
,',
STAFFS FINDINGS RELATED TO SDC 7,070(3)(b):
Finding 19: The requirement of this criterion that adoption of these proposed
applications not m'ake the Metro Plan internally inconsistent does not mean that every
goal, objective, finding and policYI,of the Metro Plan must support these applications,
Because of recognized conflicts ir 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 nar(ptive discusses' numerous Metro Plan Policies and
Elements related to the proposal. '
Staff has reviewed the applicant's choice of applicable Metro Plan Policies and Elements
and concur that the'noted policie's and Elements are applicable to the proposal. Findings
addressed regarding Goal 9 and ,Goal 12 in this report also support the stated Metro
. I
Plan policies, Specifically, as co~ditioned in this report related to Goal 12 compliance,
the Metro Plan Transportation Element and Transportation Policy F, 15 are satisfied,
Z4
LHPZQQ).QQQ I ] & ZONZO07.()QOI Z
~-25
1;he stated Policies and Elements have been reviewed by staff and are found to be
applicable and consistent with the 'proposal. '
REFINEMENT PLAN MAP AMENDMENT
CRITERIA OF APPROVAL - SDC 8.030 et seq.
In reachirig a decision on these actions, the Planning Commission and the City
Council shall adopt findings which demonstrate conformance to the following:
(1) The Metro Plan;
(2) Applicable State statutes,
(3) Applicable State-wide Planning Goals and Administrative Rules,
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH SDC ,8,030 (1 H3):
, .
Finding 20: SDC 8.030(1)-(3) indicates that a Refinement Plan Amendment must be
consistent with (1) The Metro Plan (2) Applicable State Statues; and (3) Applicable
Statewide Planning Goals and Administrative Rules. 'Each of these' criteria are
addressed in this report as part of the Metro Plan Amendment Criteria and the Zoning
Map Amendment Criteria, Asnoted in the applicanfsinarrative, SDC 7:110(4) states:
"When a Metro Plan amendment is enacted that requires an amendment to a refinement
plan or functional plan diagram or map for consistency, the Metro Plan diagram
amendment automatically amends the refinement plJn or functional plan diagram or map
if no amendment to the refinement plan or functional1plan text is involved, ,,"
There is no refinement plan text amendment proposJd as part of this application,
Therefore, no separate refinement plan application i~ required, As stated in the above
Teferenced section of the SDC, the refinement plan i~ automatically amended upon
approval of the Metro Plan amendment. I
, I '
The applicant's narrative related to co~sistency with ~specific refinem'ent plan policies is
most appropriately addressed as part of the Zoning Map Amendment criteria, later in this
report,
METRO PLAN MAP & REFINEMENT PLAN AMENDMENT (LRP2007-00013)
CONCLUSION AND RECOMMENDATION
Staff finds that the request meets the criteria of SpC 7,030(a) - (b) and SDC 8,030,
Upon review of the evidence provided by the applicant, site visits, existing
structuresluses and review of the applicable crit~ria of approval, staff finds that'the
applicant's request for a Metro Plan & Refinement Plan Map Amendment is appropriate
for the subject property with the following recommerlded condition of approval:
1. Trip generation from development on the subject Iproperty shall be limited to a '
maximum of 243 PM Peak-h'our vehicle trips, which is based on a "reasonable worse
case development scenario" under the existing zoning (LMll as submitted by the
applicant in the Traffic Impact Analysis for the subject property,
25
lRP2007,OOOlJ &. ZONZ007,OOOl2
5-26
ZONING MAP AMENDME~T
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" appr~ve with conditions or deny a quasi-judicial Zoning Map
amendment based upon approval criteria (3)(a)-(c) below. The Planning Commission or Hearings
Official shaff make the flnallocal 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 with applicable Metro Plan policies ,and the Metro Plan diagram
(b) Consistency with applicable Refinement Plans, Plan Djstrict maps, Conceptual
Develop:nent Plans' and functional plans; 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 development of the property.
II ,
NOTE FROM STAFF REGARDING APPLICANT'S ZONING MAP AMENDMENT
, NARRA T1VE: The applicant's narrative for the Zoning Map Amendment is si~i1ar
to the narrative for the Metro Plan & Refinement Plan Amendment, addressing
many of the same criteria, The portion of the Applicant's Narrative related to
Refinement Plan policies is included below, Rather than be duplicative in this
report, and for ease of review, Staff has attached the remaining portions of the
applicant's written narrative in (ts entirety for reference,
STAfF'S FINDINGS RELATED TO COMPLIANCE WITH SDC 12,030(3)(a):
,
Finding 21: This criterion is also found in SDC Section 7,070(b) under the Metro Plan
Amendment criteria. Specific findings related to compliance with Metro Plan policies and
the Metro Plan diagram has beer: 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,
I
Conclusion: The proposed rezone request is consistent with Metro Plan policies and
the Metro Plan Diagram,
APPLICANT'S NARRATIVE RELATED TO COMPLIANCE WITH SDC 12,030(3)(b):
The following demonstrates how the proposal is consistent with applicable policies in
the East Main Refinement Plan (EMRP),
1, Mixed-Use Element
lRP2007.000 I] & ZON2007-000/2
16
F-:2L.
, ',Policy 2) Area #2
A) The following land uses' are allowed under Community Commercial zoning:
All Communitv Commercial uses subject to Article 18 of the Springfield
Development Code, .
The proposal requests redesignating the subject prope'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 e'xisting commercial uses on Tax ,Lot 402 to continue as permitted
under Article 18, and consistentwith neighboring uses to the west and south, which
are also zoned and designated for commercial uses, '
2, Commercial Element
Criieria for Commercia'l Refinement Plan Desic,natio~ '
1, Generally, the Community Commercial refinement plan designation shall_be
applied under the following circumstances:
A) where it is not an intrusion into well-maintained residential
neighborhoods;
The proposed redesignation does not intrude into the existing residential area west of
the subject site along 44"' Street, and is therefore consistent with the above criterion:
B) where. it does ryot increase conflict between Low Density Residential
and Commercial;
Although the abutting residential area is zoned M~dium Dens,ity Residential, it is
developed in low density residential uses, Approval of the proposed redesignation of
the subject sites would actually result in adecrea~e 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. I '
,
C) where criteria for designating Medium Density Residential/and does
not ~pp/y; , j , '
Criteria for designating MDR land does not apply to the subject site,
,D) where lega';y 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 se""1 ice access to an arterial street can
be provided; ... and
,
The subject site has adequate legal access onto ~ain Street, which is classified as an
arterial street.
27
LRP2007-000 13 & ZON2007,OOO 12
:..28
F) where designated Commercial on the Metro Plan Diagram,
Approval of this application wouid result in a Commercial designation on the Metro
Plan diagram, which would also automatically modify the designation on the EMRP
diagram. .
Policy 2) Apply site-specific Commercial refinement plan designations to clearfy define
the limits of new commercial uses where there is not an existing, legally established, and
beneficial mixing of uses, . '
Approval of the requested redesignation would apply Commercial plan designations to
the subject properties, allowing the existing, legally established commercial uses on
Tax Lot 402 to continue, It would also enable commercial uses to be established on
Tax Lot 400,'thereby defining the,IIi'mits 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 e~st. 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 propohl would define. fhe limits of new commercial uses as
called for in the above policy, and also provide the ability to make superior buffering
and otherimprovements associated with future development on Tax Lot 400 through
the site plan review process.
Policy 3) Reduce the numberof vehicular access points and require the rebuilding of
curbs and installation of sidewalks and street trees along Main Street, through the Site
Plan Review process and in public improvem~nt projects,
, :1
The proposal would result in reducing the number of.existing access points as
required above, Through the Site Plan Review process, future development on Tax Lot'
400 will have a single driveway ~ccess onto Main Street, eliminating one of the two
existing curb cuts on this site, Sidewalks and street trees are already located along its
M'ain Street frontage, consistent with the above policy,,' ,
Policy 4) Provide buffering betweery commercial and residential uses through Article 31 of
the Springfield Development Code, Site Plan Review process,
Existing residential uses along the east side of 44'" 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 encourag~ efforts o(various agencies to attract new and retain
existing jobs and businesses,
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 of the requested redesignation will enable
existing, long-standing jobs and businesses on Tax Lot 402 to remain as legal,
conforming land uses, and allow future development of new employment on Tax Lot
28
lRP2007,OOO' ] & ZON2007.000/2
,_')f\
,400 with higher than average wages and employment densities than the current
designation and zoning 'allows"
STAFF'S FINDINGS RELATED TO COMPLlANCE-WITH SDC 12.030(3)(b):
Finding 22: As previously mentioned in this report, the subject property is located within
the East Main Street Refinement Plan area, The applicant's narrative above discusses
refinement plan Elements and Policies,
Finding 23: The applicant references policies in the Mixed Use Element, Area 2, This
area (Area 2) is located south of the subject property (across Main,Street), and is not
part of the subject property, Reference to this policyis not applicable to this applicatio~.
Finding 24: The applicant discusses specific criteria'listed in the refinement plan for
commercial and industrial uses. Staff concurs with the applicant's narrative related to the
commercial criteria.
Finding 25: Criteria of approval for consistency with all applicable City of Springfield
functional plans have been previously,addressed in this report, As noted in the findings,
in this report, the proposal is in compliance with all applicable functional plans, '
, Conclusion: BGJsed on the above findings, the propJsed zone change is in compliance
with SDC 12,030 (2). " I,
, I
I
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH SDC 12,030(3)(c):
Finding 26: As previously noted in this report and J stated by the applicant, the subject
properties are currently served by sanitary sewer sy~tems and storm drain systems
Springfield Utility Board (SUB) has sufficient capacity to provide electrical and water
service to the site, ,
Finding 27: The property is served by Springfield Fire and Life Safety,
,
Finding 28: The site is within Springfield,School District 19.
Finding 29: The site is within the Willamalane Parks and Recreation District.
Finding 30: Transportation systems currently provibe access to the property The
subject site takes access from 44'" Street which is uhder City of Spnngfield jurisdiction
and Main Street, which is under ODOT jurisdiction.
Finding 31: The'proposed zone change is from Uyll to CC, The subject lot has existing
develooment on all sides, and is located on 18111 and Main Street. As previously
discus~ed in findings in this report, and as conditi6ned, the proposed zone change will
not significantly affect the existing transportation network, The proposed zone change
will not negatively affect existing public transit service, '
LRP2007-000/J & ZON2007.000/2
'.=Jil._
"
t
29
. I
F.inding 32: Solid waste management service is available at the subject property. The
City and Sanipac have an exclu$ive franchise arrangement for garbage service inside
the city limits,
Finding 33: The site receives police protection from the City of Springfield, consistent
with service provision throughout the city and with service that is now provided to
adjacent properties,
Finding 34: The City of Springfield Development Services Department provides land ,.
, use control for property within the City's jurisdiction, .
Finding 35: Qwest and Comcast currently provide telephone and cable communication.
service in this area for and an array of wireless companies provide a number of different
communication services, The City has no exclusive franchise arrangements with
telecommunication or wireless companies, The field, is competitive and therefore
guarantees a wide selection currently,'
'Conclusion: All key urban facilities and serVices required for the proposed rezone are
available to the site. Any specific public and private improvement requirements and
utility connection points will be determined when the property is developed. The proposal
meets 12,030(3)(c),
, ZONING MAP AMENDMENT CONDTIONS OF APPROVAL:
SDC12.040
SDC Article 12 allows for the Approval Authority to attach conditions of.approval to a
, Zone Change request to ensure that the application fully meets the criteria of approval.
The specific language from the code section is listed below:
12.040 Conditions of Approval
The Approval Authority may attach conditions as may be reasonable necessary in order
to allow the Zoning Map amendment 10 be granted '
Staff ha~e reviewed the Zone Change request and supporting information provided by
the applicant and do not recommend any conditions of approval other than the condition
already stated for the Metro Plan 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
lHP2007.QOO/ ] & ZON2007,OOO/2
30
I
t;_~1
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 structuresluses and review of the
. applicable criteria of approval, staff finds that the applicant's request fora zone change
from LMI to CC is appropriate for the subject property and recommends the Planning
Commission approve the attached Order and forward the proposed Zoning Map
Amendment Application ZON2007-0001~ to the City Council with a recommendation for
adoption,
LQP2007.000/] & lON2007-000/2
3/ ,.
'::-'1"
J ..,...
I
:1
I
.
EXHIBIT A-1
.
, '
5,0 TR.IP GENERATION AND DISTRIBUTION
5.0 TRlr GENEf\ATION
To determine the traffic impacts of a developme[lt on a roadway system, the number of
vehicle movements resulting from the developmerrt must be estimated, These
movements are referred to as "trips". Trip generation is the estimated volume of trips
resulting from the development.
The amount of trips expected to be generated by thepropgsed development was
determined using the information contained in the lTE Trio Generation Manual 7'h
Edition, The eq~lations in the manual predict the number of trips generated bas~d on ,the
gross square feet of J100r area, Separate trip generation analyses were perFormed for th'e '
. . ..
AM and PM peak hours for the development. .
Under the current Light:Medium Industrial zoning the development site can be built out
...... .. n
to include a variety of land uses specilied in Springlield Development Code Article 20,
The maximum trip generation of the development was det~rmined for the allo,xed land
uses under the current zO[ling. Tables 5 and 6 illu~trate the maximum development
potential and subsequently the maximum, trips generated by.the development site using
the following lTE Land Use Codes:
j'
.: i
. Land Use Code 760 . Research and Development
. Land Use Code 714 - Corporate Headqual1ers .'
. LandUse Code 492 - Health/Fitness Club
. Land Use Code .565 - Daycare Center
Research and,
, Development'
760
80
114',.. 0,~3 ' :'0,17 . :95. '; 19
. . .....'
~~~~~~~~~Rl0J,~~~it~}J:,,~~<~1[~;~: j~1~~:j~J~~~~11~~1~~t~~~l~i~~~Il[;~~~t1i.~~11i~l~i
Health Fitness Club 492 4 . T=121'x ' 5 0,42 0.58 .2 3 .
i"j;f:::0;_~1t~~:!:.t;tehJl~,:t't;~;~~)j:~IJ.~~i~.:%ff~tJ~t~;~ft.~i~1~,~~;i~'r,~ j'\;i~~J] ~~~I':'litN~~~~~ "
Total Trips
229
163
61
I~H TIV,NSPO~TATION ENG1NEE~ING I E"'S:':j:J'"cld ~,e:cne. 9prlngoeld, Ocegon I March 6, 2007116
I
EXHIl:l11 A-'L
"
.
Table 6:'
Research and
Development '"
760
80, Ln(T)=O,83'ln(x)+1.06
, 16:: .,'" 93:'"
',;.-;-
f~GoTp' o'rafeHe'adqua7ters~i r?:-70li~~ t~~)07~~ ~7EO(':n';o:8i~f::'''~J'tl1llW,::'3r,:::1 ~15~'1::~ i~a:g~ '::.fJ~~1 ~33;W,'
1""'~' ~. '.'H'U. _, ~'. '...~ ,.....-.,....,' "'~A::ll1i!t' '!<J",.. .". .\: ," ';<;''(1.,- :;0 ~j,'-~t"~~'lm ".
"YfJ' <~;k"? rc.aO:{ t, 't,;::-~;"*~~,:y)';,:;,:'j 'ii1\;~1}1/.:;~,~:1 ~!;.1-~ '.~. i~l;fj '1:~:it:~ft':~~1~&'1 0-1;ii,f" ~'~r4'jJi -;:i~;;:~1~ :.f.~~~~ p,"t\~ ~~t~~
tli~ ~lt~..,'. ~::.2:~~t.l~~)2~'~t<:~J~;~l ~~~.,~l',tf~~ltj it:'~~b~{;;~';"?~ r~,uJ)"::~~~.~J.::rJ.l,]l ~"'~lt.)Nl'i!,;~~ ~?~~~~ l1\:~u~ ~~~
',:" Health Fitness Club 4924 . T=4.0S'x.' ,.",." '16J.. 0,S1'0.49 ..','~'8':.",y:,' 8 i."
. . . . j - . \.]~~~~~ ~Fvr~~~~,i~:r'j~8;:;:D~~: )\F;;,.' ,~.,.';,o".';r..~~. ':'-"!"':"~I~~O-~,:,;",5-:{",~,;,',,?;~J.'i if)!?;,;;;
{hi'!:;,. :;"-~;;'IP":s<~h'fo~?';;;,;~;_ r,~:i.2 d: m If ' ;.)
,. ~.t:",'.'lt{"~,3'J' ',1'"1",..," ;'~"""'~';'l"t.':~.~" :k "I'tf~;),. ;>i'.l,q-~(fr.(':f
,~~1&~~ &'{~~~~~~JZg~1~4~ ,f'1~~~~1 ~~I~ l?\i&
-., " 'TotaITfjps:OO:2~/'~'!~';j,..'.:,;~ih~6.~i"j!?,S
I
-\
,
I
\Vith the zone change the development site will be built to include an approximately
30,000 square foot medical office building. The land use code for a fully developed
, medical ol1ice building was no - Medical-Dental Oflice Building, This was used in
place of Land Use Code 630 - Medical Clinic because, after close inspection of the Trip
Generation Manual. itwas detemlined that the sample size for this category of land use'
'\vas too small,to create a reliable estimate of trips generated: Table 7 illustrates the tmffic,
generated by the proposed 30,000 square foot medical oftite bLlilding. Tax Lot 402 is
currently occupied by a commercial/specialty retail center., With the proposed zone
change, the building will remain on the property and will c'ontinue to operate as a ' '
specialty retail center. Vehicle trips using this site have alr~adybeen accounted for on the
roadway in the background tranic volumes: therefore, no Jew development trips were
assigned to this Tax Lot, '
'f
i
l'
s!~\~~;,~~~l~~~~;:~J~,~t~~fot~ t:i~~fl~f~
AM
I
,
;f&~'t~P ;0~~~m;:%1 ~&li~~ ;,\f~~:~J~g -
[.\;;" ~~.,~ ,i'::;":,,'~;;i,;!.: "J';;,Yu'(;.;!;1"~" :".}~t.~~
;~:~~lg :~~;j~~l@ -If!.;~~T$1 '1,j~~~t; '.
T=2.4S"x
74
79% 21%
S8
16
;01~=~~:~iln(:()+!~~i~~~~iil if~i~;f~~~~~~;~l ~~]c~ '
There are 155 fewer AM and [40 fewer P~,[ vehicle trips Jenerated by the medical oflice
building when compmed to the maximum potential of the site under the current zoning,
JR.H H_;J..NsrOR.TATlON ENGINEER.II'IG I East Springfield P,e:Ohe. Springfield, Or;gon 1,'v\ard~'6, 2~~7119
5-34
.
5.1 TR.lr DISTR.IBUTION AND ASSIGNMENT
, ,
After determining the trip generation, the next step in the analysis requires distributing
and assigning the trips to the existing trafticnetwork. Trip distribution allocates'the'trips
genemted 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 roadway
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 BUILD TRAFFIC VOlUMES
To determine the Build trat1ic volumes the development trips assigned throughout the
study area were added to the background trat1ic data, The year 2008 'AM and PM Build
year traffic volumes are illustrated in Figures 11 and \2, respectively"The year 2023 AM
and PM Blrildyear traffic volumes are illLrstmted il) Figures 13 and 14, respectively
JR.H TF....ii,NSrOR.T~,TlOt'l ENGII'IEERJNG I East Sprin"gfield Re:one. - Springfield, Oregon I, iv.larch 6,2007120
5~35
CAnlOll I-\~.j
.
~
1
,
~,
I
I
I.
1
,
1
~,;
;
~
i
i
.:
i
i
I
i
I
~
,
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I
EXHIBIT A..t.
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7.0 TPR FIND1NGS
,'The follo\ving discusses the Oregon Administrative Ruling 660-012-0000, the
Transportation Planning Rule, and the effect 6fthe proposed development on the
transportation facilities as it applies to the ruling,
660-012-0060
Plan and Land Use Regulation Amendments
I
,
(1) Where an wnendmenl to ajimUlonal plan, an ackn~wledged comprehensive plan, or
'a land use regulutlon wouldslgnificantly ajfect an exl.sling or planned transporlallOn
',frieilily. {h'e local gOl'ernmenl shall pul in place meastt;es as provided In seclion (2) of
this rule 10 ClSsure thai allowed land uses are consiSlent wilh Ihe Idenlifiedfunction,
capaclly and performance Slandards (e,g. level of service, volwne'/o capacil)' reilio, elc.)
oflhefacllity. A plan or land use regulation amendmenf slgnificcmtly affecls a
, transportalion fucllil)' if it would:
!
(ci)Ch~'inge the jzmctlonol classification of WI existingqr planned transporlationjilcilily
(exclusive o/correctlo'n ofrrlClp errors in an adopted pl~II1): , .'
'The addition of development trafflc on the adja~ent roadways does n'ot cause the
, change in functional classitication of any of theltransportation facilities,' '
(b) Chunge standards implemenling ajzmctlonulclCiSs&icution.sYSlem: or
I
The standards implementing a functional classiFcation system within the project
study area are not changed by the proposed development:
, ' , 'I ' .
(c) As measured at the end of the planning period identified in the adopted trcmsportatiun
, syslem pion:
,
I
I
I
I
(A) Allow lond L1ses or levels o/development Ihot wOLlld result il1types or levels oftrav,el
or occess Ihat are ,ini:ol1si"tenl wilh the fLlnctionol clasj'ijication of an existing or plonned
transporiC/llonjilCllity; i
I
The proposed development does not result in types or levels of travel or access
that are lnconsiltent with the functIOnal classltlcatlon of the studled transportation
facilitles.
r ;
(B) Reduce the perjiJrmancf of an existing or plaflned'lrCLllSportallonjilcility below the
minimum aL:ceplable peljomlClnCe stan'dard idenlijied!in the TSP or comprehensive plan:
or ' I
I
The addition of development trat1ic does not reduce the performance ot' an
existlng or planned transportation facility belo\v the minimum acceptable
performance standard
, I
II'.H TI'.ANlrOI'.TATlO,1 ENGINEE~I~IG I East Springf,eld Rezone. Springfield. Oregon I March 6,2007 I 31
5.:.36- ' ,
.,
EXHIB,.IT A-sli
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(C) Worsen the performance of an e,~isting or planned Iransporlalioii/ClCili; thCit.'is
otherwise projected (0 perform belol\' the minimum acceptable pe'fo~m:mce standard
idel1tiJied in the TSP or comprehensive plan. . '
The addition of development traffic does not further degrade the perfomlance of
intersections projected to perform below the minimum acceptable performance
standard, "
As shown, the proposed redesignation of Tax Lot 400 and 402 does not result in a
"signiticant effect" on the transportation facilities as defined in the TPR. , '
8,0 SUMMARY AND RECOMMiNDATIONS
This report provides an analysis of potential traffic impacts resuliing'from the proposed'
redesignation/zone change and future development of the subject site in Springfield,
Oregon. This development will include approxiI11ately 30,000 squardeet of medical
oftice space. The parcel proposed for development is located east of 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 Lot 402 is assumed, :
Completion 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 amlysis was performed for the year 2023.
F:
A performance analysis was completed for the intersections of Main Street and 42nd
Street, Main Stre~t and 48th Street, Main Street at 44'h Street, and Main Street at 46th
Street. The operatiorial a~aly~is of allintersectioris within the study area shows' that
under the Build condition no degradation in volume-to-capacity ratio in comparison to ,
the No-Build condition occurs due to the' additional trips produced by this development.
All study areas meet'the mobility standard for the Build condition.
Aqlteuing analysis w~s performed for the intersection within the study area. The quelling
analysis, which assumes the current lane contiguration throughout the planning horizon,
was perfom1ed to determine the amount of required storage length due to the construction
of the project. The results ot' the queuing analysis indicate that all existing storage lengths
will bcilitate the qlleuing anticipated for the tmfflcdemand. including the proposed
development.
According to the tinding under Oregon Administrati ve Ruling 660-012-0000, the
Transportation Plarwing Rllie, the proposed redeslgnation onax Lot 400 and 402 does
not result in a "signiticlnt effect" on the transportation bcilities as defined in the TPR,
- '
JP..H TP_',NSrOI'.T.'ITlmJ EtJGINEEiUNG I East Springfield R,oon,' Springl,eld, Oregon t March 5, 20071"2
5-37
EXHIBIT A-6
Memorandum
City of Springfield
Date: ' April 4, 2007 .
To: David Reesor, Planner HI
From: Gary McKenney, P,E., Transportation Planning Engineer
Subject: LRP2007 -00012 PeaceHealth PAPA
The following comments and recommendations are based 9n my preliminary review of the
assumptions used in the traffic analysis report (TIA) and other materials'provided with the
subject application, Pertinent pages of the TlA are attached for reference,
, Traffic Impacts Analysis
In estimating the trip-making potential of site development under existing LMI
designation/zoning the TIA assumethe land uses. as depicted in Table 5 ,(Page 18),
Recommendatiof!: Confirm that the uses assumed, in the "existing-designation"
development scenario are permitted, and thit they ,represent a "reasonable worst case."
In estimating the trip-making potential of site developme~t under proposed CC ,
designation/zoning the TIA assumed a single land use (Medical Office Building) as depicted in
Table 7 (Page 19), '
Recommendatiof!: Confirm that the use assumed 'in the "proposed-designation':
development scenario represents a "reasonable w6rst case," If not, we need to decide
whether limiting allowed development to the level assumed in the TIA would be an
acceptable means of ensuring that future developrbent would not generate traffic in
excess of what is estimated in the TIA, lfwe find that the assumed Medical Office use
would under-utilize the land, then we will want theTlA revised to reflect the impact of a
true "reasonable worst case," .
Goal 12 TPR Analysis/Findings
The PAP A application refers to the Goal 12 findings contained in the TV\. These are presented
on pages 31 and 32. The validity of these finds will dep~nd on the details of the technical
analysis and supporting assumptions"
5-38
EXHIBIT A-7 '
REESOR David
From: MCKENNEY Gary
Sent: Thursday, April 05, 2007 9:23 AM
, To: REESOR David
Subject: PeaceHealth PAPA Traffic Analysis
Follow Up Flag: Follow up
Flag Status: Red
David,
.
In considering what a "reasonable worst case" development scenario might be for the re-zoned condition
it IS clear that a 30 KSF Medical Office Building is'much les,s illtense than other uses that would be
permitted in the CC zone. On a per-square-foot basis the MO is estimated to generate 2,47 vehicle'
tips!l,OOO SF and 3.43 vehicle tipsll ,000 SF during the AM and PM peak hours respectively. For
, comparison the average rates for a "Fast-Food Restaurant with Drive-Tht:ough Window". are 53,\\
vehicle tipsll,OOO SF and 34.64 vehicle tips!I,OOO SF,
In considerilfg the Goal 12 "insurance policy" issue some more I thought of anot)1er possible way,to deal
with it, which we did not discuss yesterday, We might choose to limit the trip generation for the
rezoned [and to be no greater than what would be expected from development under a reasonable worst
case with existing zoning. '
I'd like to discuss these Ideas further in our meeting with .Ed Moore.
Gary
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5-39
DATE:
TO:
FROM:
C^nIDI f J-\~d
,I
-Oregon
Theodore R, Kulongoski, Governor
Department of Transportation
'Region 2 Tech Center
f\55 Airport, Road SEBuilding A
, Salem, Oregon 97101-5397
Telephone (503) 986-2990
, Fax (503) 986-2839
\
May 10,2007
I
"
I
File: Ti5-2
Ed Moore
Area 5 - Senior Planner
Stephen B. Wilson~ PE'
Region 2 Senior Traffic Analys
.
SUBJECT: East Springfield Rezone
Traffic ImpaetAnalysis Review '
Highland Business Park - Peaeehealth Medical Office Building
McKenzie Highway - OR 126 Bus. (Highwa} #15) ,. '
Milepost 4.61- 5.00
. City of Springfield
Lane County
I
, "I '
,These are review corruTIents for the EaslSpringfidd Re,one Traffic Impacf Analysis (TIA) , prepared by
JRH Transportalion Engineers, The focus of this review is the analysis methodologies and assumptions,
The results and conclusions cif this study arc in question, due tb noted inconsistencies, [tis recoinmendcd
this study be revised, taking into account these comments, 'IRegion 2 TmIfic will need to review any
revised traffic study, to ensure it complies with ODOT requirernents, before ,is,Gan be deemed acceptable,
",..,. "'."c:ominent' ".'.':' 1
The classification of MamSt~eet (OR 126) must also be I,isted by the \'
ODOT highway classlficatlOIT. ',--' ,
This study needs to demonstrate how the Seasonal Adjustment factors '
were applied to the raw traffic data'. A graphic showing ,the raw
traffic volumes should also be included. '
The peak hours assumed for this study seem reasonable; assuming the
Peak Hour Factors were calculated off data from these asswned hours
and were the same for all inldrsections, ,',.' :
The 2006 Existing PM Peakitraffic volumes do not seem correct. As
part of this review, calculations were made using the rdW trafEc data
and the assumed Seasonal A~ju.etment factors, presented in this study,
The review calculations wele unable to confirm the traffic volumes
~resented in Figure 4. See r~lated corruTIent for Page 8,
ODOT does not have a standard from which you can compare an
Intersection Crash ROle. This study cites a crash rate threshold of J.D.
This is not an ODOT standhrd, and it is unclear where this standard
may have originated. The ~nlY ODOT standard for comparison is a
Segment Crash Role, which~ should becalcuJated for the crashes in at
least a mile of thi: study area roadway,
--,.:
I P,lge 'p ara gra ph
I 7 Table 1
8 Seasonal
Adjustment
------
8 Peak Hours
II
Figure 4
12
Section 3.1
5-40
..Pa~e
'EXHIBIT A-9, \
Comment I
This study must demonstrate how the Historical Gi'OWlh Rates were
applied to the 2006 30'h Highest Hour traffic vol~mes, Calculations to
confitm,the 2008 and 2023 data were unable to duplicate the future
volumes~i~edintb.is rel'o.rt,_ _ _ -....-..- - .
This report states the maximum development potentwl was
determined for the property, given its current zoning of Light-Medium
Industrial. ,For this scenario, how was the maximum allowable
develo?ment determined?
The trip generation assumptions and output in this table are accurate,
This study's trip generatiorr arralysis for the proposcd zoning, assumed
a 30,000 sf Medical qffice Building would be the only developrnent
on this site. To satisfy the requirements for a TPR.level analysis, the
trip generation study for the proposed zoning must be for the
max.imum atrow-able d~veloomenl on that site, given ,the Citis
development codes and reguhitto.ns.
The trafflc volumes for all Future Build-Out data sets, will need to be
revised to account for corrections made 'to address the previous
comments.
Paragraph'
13 . Growth Factors
~Existing
18 Zoning Trip
, Generatlon
18, Table 5
Proposed
19 Zoning Trip
. Generation
nla
nla
Future
Build-Out
'Trafflc
Volumes
Section 6.0
rJa
'Manual Count
Data
rJa
S ynchro
Analysis'
"I
j,
Sectton 7,0
-_.- - ------.--
The traffic data for this study is in question, Any analysls made from
these <;tata sets ls also questionable and must be revised; taking into
account the previous comments, This comment can also be applied to
tile queuing analysis developed for this study,
The scope of work for this TlA required 3-hotll' Mamra! C1as'iflcation
COLlI1I.1" for all study-area intersections. However, a review ,of the
manual count data was .unable to determine Cl./).Y tlUck volumes ~r
perGentages- The uuck traffic in tl~is study area is signi~ficant, and
must be taken into account.
A review of the Synchro output has noted sevet'al inconsistencies
throughout. the' analysis:
. An [deal'Saturation Flow'rate of 1900 pcphpl was assumed
for both signalized intersections '(42'" & 48'10), whiIe 1800
pcphpl was assumed for the two unsignalized intersections.
The ODOT ,>\nalysis Procedures Manua! requires a saturation
, flow cate of 1800 pcphpl for all intersection analysis.
. The ~ruc~ percentages must be based art [-eal.world data. '"The
Synchro'defaull of2% lS not acceptable. '
Unless the Yellow Time (s) entered into Synchro for the
. signalized intersections is bElsed on either an ODOT or City
timing sheets, thls analysls should assume 4,5 seconds of
yellow fot' the OR 126 approaches, and 4,0 seconds of yellow
for the City-street approaches, The 5,0 seconds of yellow ls'
generaity reserved for higlnvays with an 85lh Percenhle Speed
, e~ual 10. or greater than 45 mph,
The TPR findlngs from this study are ,In question, due to the
lnconsistencles noted In this review, 11 is very likelY, they will need to j
be revtsed, based on the recommendations in this J~\I'i~w - -
. ..-_..-,-,..-
5~41
C^nl::J11 H~I\..; "
32 Section 8,0
-- '" -.. ..
. ":/~~'ft;~~~;:~~::/fg~~;~~~~~:~~_~~~~,:;_:~t:~~:~;:::LJ:'0 nim'~'rit.~~ti:~~7jfllr*:~;G+;Y'9~~:-, ~:',.: ." .':- ~'O':' '.... ~
Based on"the previous comments in this review,the conclusions
drawn and recomniendations, proposed are in question, It is very
likely they will need to be revised, based on therecommendations in
this review, ' ' .' ,
I
r ;Page\' ''':A:Pa'ragraph
If you have any questions regarding my comm'ents. please contact'me by phone at (503)986-2857 orby
. e.m~i~.at stenhert. n. wilson.(@odot.stute.or.u.\'.
Cc: Jim Hanks - JRH
David Warren
Jane Lee
Mike Spaeth
, .Dennis Santos
File
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5-42 '
FW:,Springfield - East Springtio'1 Kezone ll'KNldlj>" "-~Y1~~
.. "0'
EXHIBIT A-11
REESOR David
-.-.-..-
From: MCKENNEY Gary'
Sent: ' Tuesday, May 15, 20074:28 PM
To: REESOR David
Subject:. RE: Springfield - East Springfield Rezone TPR Analysis Review
Attachments: LRP2007-00012 Trans mem01.DOC
David n_
I believe Steve Wilson is thinking in the context of an unconditioned approval of theP AP NZC"
Given the approach we planned to take in conditioning this approval; I think only Item #18 ofhis noted
issues is relevant to ensuring Goal 12 compliance," .
This issue was discussed in my April 4,. 2007 memo to you (copy attached), I assume you can respond
to Steve's question on how we conclude that theassurned existing-zoning development scenario isno
more intense than "worst case,"
If we condition the PAPA to limit trips to less than or equal to Wl1at would be generated by the "worst
case," all the other issues appear moot.
Gary
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---.--.--.---.----
From: REESOR David
Sent: Monday, May 14, 2007 10:34 AM
To: MCKENNEY Gary
Subject: PN: Springfield - East Springfield Rezone TPR Analysis Review
Gary-
What are your thoughts on the attached memo?
-DR
-...--.-~-----.._-~'---_.-,.~-......,'-
----_._---_._--,---,._-_....-------......--~.-.-..,-_..~-
From: ,~100RE Ed W [mailto:Ed,W,MOORE@odot.state,or:us] ,
Sent: ~londey, May 14,20078:06 AM
To: REESOR David; MCKENNEY Gary
Subject: FW: Springfield - East Springfield Rezone TPR Ana,lysis Review
FYI
5-43
.. -:;:,:- . ....,... ..
EXHIBIT A-1 i
REESOR David
From: MOORE'Ed W [Ed,W.MOORE@6dot.state.or.us]
Sent: . Monday, May 21,20073:14 PM
To: REESOR David
Subject: RE: PeaceHealth Plan and Zoning Map Amendment
Dave, that is what we agreed to at our meeting and it still hold for us, Ed
,
-----Original Message----- ,I
From: REESOR David [mailto:dreesor@cLspringfield,or,us]\
Sent: Monday, May 21, 2007 11:49 AM '
To: MOORE Ed W (OR)
Cc: MCKENNEY Gary .
Subject: PeaceHealth Plan and Zoning Map Amendment.' -
Hi Ed-
, I just wanted to clarify with you ODOT's position on the PeaceHealth proposal (LRP2007 -D0013 & "
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 under existihg zoning (LMI). Does this sound correct to
you? ' '
Thanks, '
David Reesor
Planner \II
City of Springfield
541.726.3783
.
.
, 5-44
FW: Springfield - East SpringF-1<j KezoneU'K iillaly:m .t<..CVICW
... .....~......... "'.. '-
EXHIBIT A-12
---Original Message_un
From: WU-?ON Stephen B
,Sent: Friday, May 11, 2007 10:03 AM
To: MOORE Ed W '
Cc: jimhanks@jrhweb.com; WARREN David; LEE Jane ?; SPAETH Michael. A; SANTOS Dennis N
Subject: Springfield, East Springfield Rezone TPR AnalYSj~ Review
,
,
,
Ed .i'
_, I
This is my technical review of this TI~ submitted by JRH, I apologize for the delay in
getting this review out, ,I
, 1
<<East Springfield Rezone TPR Analysis Review,pdf>>
. ~I
Stepfien$. WiLoM, PE
Senior Transportation Analyst
ODOT - Region 2 Tech Center
455 Airport Road SE - Building 'A'
Salem, OR 97301-5397
(503)986-2857
, '
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5-45
"
j
~ PeaceHealth
March 15,20.0.7
Type II Metro PlanlEast Main Refinement Plan
Diagram Amendments
Written Explanation of the Proposal'
Applicant:
peaceHealth Oregon Region
'770 E, 11th Avenue , "
P,O. Box 1479 I
, Eugene, Oregon 9744o.i
, I
, p'roperty Owners:
Hyland Business Park, ,LLC (Tax Lot 40.0)
1941-A Laura Street I
Springfield, OR 97477
Attn: Shaun Hyland
(541) 726-808 I
Andrew Head (Tax Lot 402)
16 I 6 Ardendale Ln,
Eugene, OR 9740.5
(541) 521-3403
. Applicant's
Representative:
Philip Farrington, Alep
Director, Land Use Planning & Development
PeaceHealth .oregon Region
123 International Way
Springfield, Oregon 97477
(54l) 686-3828 · Fax (541) 335-2595
P farringto n@peacehealth.org
1.0 Land Use Request
PeaceHealth Oregon Region (the "Applicant") requests approval to change the map
. '
designation on the Metropolitan Area General Plan'("Metro Plan") diagram from Light
Medium Industrial CLM]") to Community Comm~rcial ("CC")for approximately 5.24
acres identified as Tax Lots 400. and 40.2 'on Assessor's Map No, 17-0.2-32-0.0., This same
acreage on the site is being proposed for a concurrent amendment to the Springfield
zoning map from LM! to CC, as allowed in Springfield Development Code CSDC':)
120.20. (I)(a) 1.
5-46
Metro P lanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15, 2007
Page 2
The area,subject to the proposed lan~ use designation changes ismapped on Attachment,
A, and is referred to collectively in this application as the "subject properties",or "site."
I
. " II
Pursuant to',SDC 7, II 0 (4), approval of the requested Metro Plan diagram amendment '
automatically amends the refinement plan diagram and is proc'essed concurrently. .
findings offa~t addressing the critepa of~pprovalin SDC 7.070(3) are included in this
narrative statement (see Section 5 belo\v).
. . ':
2.0 Project PurpoSe, Relationship ,to East Main Refinement Plan ' " ,
,
The Applicant seeks to redesignate :~nd rezone the subject properties to CC so they may
be developed for commercial uses q,e.,Tax Lot 400), including a possible future medical
clinic which could serve residentsi~ the !5To;ving e.ist Springfield area, and to be allowed
to continue long-standing commercial operations (i,e" Tax Lot 4(2). Approval of this
,\: ,.,'
land use request would preserve employment and existing viable commercial operations
ori Tax Lot 402, and create stable family-wage employment opportunities on Tax Lot 400
_ a vacant and underused industriall'site, The proposal would also help beautify this'" '
portion of Main Str~et f~om its traditional industrial yard uses, and future development
would provide a superior buffer fOil residential uses to the west than currently exi,sts.
, I, .' , '
The proposal is also consistent with the East Main Refinement Plan (EMRP) 'criteria for
designating property as Commerci~l within the refineme";t plan (EMRP, pg..12) since: ' '
a) The proposal would not be:,hn intrusion into a well-maintained residential
neighborhood The propos:al would allow for higher quality development than has
historically existed on the yacant industrial site (Tax Lot 400), therefore providing
opportunity for improved buffering between abutting residential and non-
residential uses, Tax Lot 4,02 borders only Tax Lot 400 and two corhrnercially
zoned parcels, so legitimizing the pre-existing commercial uses oil that property
,would not affect the existing residential area nearby,
.,. '." 'r
b) 'It does not inc~ease confliS,t between Low Density Residential and Commercial
uses, but In fact can proVid,e for uses and development farsuperior to those that
have tniditionally been lochted adjacent to the abutting residential areD..
Moreover, the areD. ~buttiri'g Tax Lot 400 to the west is zoned Medium Density
Residential, though in prirTJarily 10Wedensity residential use,
J ,.,
c) The criteria for designating Medium'Density Residential land does not apply
because the subject prope~ties are not currently developed, nor have they ever
been designated; for MDR uses, .'
d) Legally c;eated commercihl uses,have existed on the properties, and the proposal
would facilltate higher quhlilY commercial uses (such as medical offices) than
have existed before on T~k Lot 400, and allow for Plan designat,ions and,zoning
to correspond with long-sfar,ding legally established commercial uses on Tax. Lot
402,
e) AdequClte access exists to'lan arterial street, with existing curb cuts directly onto
Main Street, I
;
5-47
Metro Plan/EMRP Diagram Amendment
PeaceHealth Oregon Region
, March 15, 200' ,
Page 3
f) Upon approval of this request, the site wouldhavea Commercial designation on
the Metro'Plan diagram,
The proposal is also consistent with EMRP Policy 2: l"Apply site-specifIc Commercial
, retinemeI)t plan designations to clearly define the limits of new commer'cial uses wher~
there is not 1m existing, legally established, and beneficial mixing of uses," (pg. 12) The
proposal to allow for a broader, more beneficial rang~ of commercial and employment-
, generating uses on the subject properties, It would alko improve the area and better
distinguish and buffer adjacent residential and industhal business park uses.
3.0 Site Context "
, The subject properties include a vacant, flat parcel ('1Jax Lot 400) and existing' ,
, , commercial development (Tax Lot 402) east of 44th Street along- Main Street in east
Springfield, The site is bordered on the south by Main Street, o~ the east by the Hyland
Business Park, on the north by an open area south of/the Weyerhaeuser mill site (Tax Lot
400) or an existing commercially zoned parcel (Tax Lot 402), and on the west by other
small-scale commercial enterprises (e,g., a cabinet shop and karate school) fronting Main
Street and residential homes along 44th Street west ot-Tax Lot 400, Commerciai
enterprises are located immediately south of the site lacross Main Street (e.g" Gray's
, Garden Center), .
, While historically involved in agricultural use~, sinc,e around 1990 Tax Lot 400 was used
as a storage and sales yard for landscape organics and forest by-products. The,current
property owners also used'the site to store modular ~onstructioh offices, tool trailers,
construction equipment and concrete form plywood,' Tax Lot 402 has had various
commercial services 011 site since the 1950s,
The properties have no jurisdictional wetlands or inventoried Goal 5 natural or historic
.' . I
resources, The site is within the Springfield Urban Growth Boundary, and both parcels.
. . - (
were annexed into the City of Springfield in 1960.jfh~ EMRP diagram (adopted in
1988) currently designates the subject property for industrial uses,
The abutting property to the east is designated LightMedi~~ industrial in theEMRP
diagram and zoned LM!. The areas immediately tol the west, and south of the site fronting
'Mam Street are Identified as bemg wlthll1 Mixed-Use Area #2 1I1 the EMRP, and are all
zoned Community Commercial. Property to the w~st of Tax Lot 400 along 44th Street is
zoned and designated Medium Density Residential! ,.'
i
5-48
, Metro PlanlEMRP Diagram Amendment
PeaceHeahh Oregon Region
March 15, 2rm
Page 4
4.0 Ty.pe II Metro planD;agbm Amendment
Amendments to the MetroP.lan are slassified as Type I or TyPe II amendments,
,
depending upon the specific changeS sought. The proposed Metro Plan ~nd EMRP
amendments are "site specific" and relate to property solely within the corporate limits of
the City of Springfield, The Metro flan defines Type II amendments as:
, '
, . i,I' .'
"[A]ny change to the..Pian diagram or Pian text that is site specific
and not otherwise a Type I category amendment," '
,
The proposed amendment is a Type' II site"speciflc ~mendment because it:
.1'
. Involves a specific geographically identifiable property;
Ii ~ .
. Does not change the'metropolitan Urban Gro\':,th Boundary;
,
. Does not change the Metro Plan jurisdictional boundary;
..' II ."
. Does not require a goadexception;
, ~
I,
. ~
. Does not include a nonjsite-speciflc amendment of the Metro Plan text; and
'I
. Applies only to property located within the Springfield City limits,
. , . ~ - '. .
Accordingly, the current proposal 'is properly characterized as a Type II amendment (as
def,ned in SDC 7,030) that must be reviewed arid approved by the City of Springfield
consistent with SDC 7070 (2)(a))i Per SDC 7,040 (2)(b), this citizen-initiated Type ll'
Metro ~lan amendment can be ini~iated at any time. "
5.0 Applicable Approval G~iteria '
Type II Metro Plan amendments are evaluated according to the criteria of approval
c~ntained within SDC7.070 (J), ~vhich provides
II,
"The follow,ing criteria shall be applied by the City Council in
, '
approving or denying a Metro Plan amendment application:
. . . .
. . 1 '
(a) The amendment must be consistent with the relevant
State\vldeplanning goals adopted by the Land
Conservation and Development Commission; and
(b) Adoption of the amendment must not make the 'Metro
Plan internally inconsistent."
il .
I
Findings'demonstrating consistenCY with the approval criteria are oLitlined below,
I,
5-A9 .
Metro PlanJEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15 7007
Page 5 .
5.1 Consistency With Statewide Planning Goals
The following findings address compliance withMetro Plan criteria in SDC 7,070 (3)(a),
Approval of a Metro Plan diagram amendment also correspo)1dingly changes the
appllcable refinement plan diagram, as established inSDC 7,110 (4),
Goal 1 - Citizen Involvement
Goal 1 addresses the need to develop a citizen involvement program to ensure citizen
involvement in all phases of the land use plaMingprbcess" The PlaMing Commission
and the City Council will hold public hearings and accept testimony on the proposal. .
Through the procedures established by the city, citiz~ns will receive notice of hearings in
generally published local papers and have theoPPol~nity 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 n<!arby property owners, interested
parties requesting notice, and any established neighbhrhood organization, Since the
amendments comply with the City's citizen invblverhent program and citizens have
opportunities to be involved in the procedure, the pr6posed amendments are consistent
with Goall.
Goa12 - Land Use Planning
Goal 2 requires that local comprehensive plans be consistent with the Goals, thatlocal
compreh~nsive plansbei"temally consistent, and that implementing ordinances be
consistent with acknowledged comprehensive plans! Goai 2 also requires \hat land use
decisions be coordinated with affected jurisdictions land that they be supported by an
adequate factual base, As required in SDC 7.050, the City is required to give referral
notice ofthe proposed Type 1\ Metro Plan diagram hmendment to the City'ofEugene and
Lane County so they may determine if there are gro~nds to participate as parties to the
hearing. The City alsosends the statutorily required notice ofthe initial public hearing
45 days in advance to the state Department of Landiconservation and Development, '
ensuring that they are given opportunity for comment and revie~v conformity to '
applicable statewide plaMing goals, :
The Metro Plan and the SDC, as well as the Statewide PlaMing Goals and applicable
statutes, provide poticies and criteria for the evaluation of comprehensive plan
amendments, ' Compliance with these measures asshres an adequate factual base for
approval of the proposed Metro Plandlagram ameddment. As discussed elsewhere in
this document the amendments are consistent with' the Metro Plan and the Goals.
, Consequently: by demonstrating such compliallce, :t,he amendments satisfy the
consistency element of Goal2,
G03! 3 - Agricultural Lands
This goalls lnappllcab\e because as provided in O;'\R 660- \ 5-000(3), Goal 3 applies only
to rural agricultural lands The subject properties are located within an acknowledged
urbGn growth bound[lry, [Ire inside Springfield's c9rponite limits, and have not been in
agncullural use for decades, I
~ '
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Metro PlanlEMRP Diagram Amendment
, PeaceHealth Oregon Region
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.1
Goa14 - Forest Lands , .
Goal 4 does not apply within urban growth boundaries, per OAR 660-06-0020, and the
areas affected by the Plan amendmerts are inside Springfield's acknowledged UGB,
GoalS - Natural Resource~
GoalS requires local goyemments tf. protect a varietY of open space, scenic, historic, and
natural resource values, GoalS and.itts lmplementtl1grule, OAR Ch, 660, Division 16,
reqUlre planntl1g Junsdlctlons, at acknowledgment and as a part of penodic review to
jl . .'
(1) identify such r~sources; ,
(2) determine thei~ quality, quantity, and location;
(3) identify conflicting uses;
(4) examine the e~onomic, social, environmental, and energy
(ESEE) consequences that could result from allowing,'
'limiting; or pr?hibitihg the conflicting uses; and ..
"
(S) develop programs to resolve the conflicts, '
'l ' .
'.1 '
The subject properties are not on Springfield's acknowledged Metro'Plan Goal S
inventory, No threatened orendadgeredspecies have been inventoried on the site, and no
archeological or significant histori'blinventoried resources are located on the site. The
National Wetland Inventory and Springfield Local Wetland Inventory maps have been
consulted and there are no jurisdittionalwetlanct. located on the.site. Therefore, the
proposed amendment does not alth the City's compliance with Goal S, '
1 . ."
'I
, Goa16 _ Air, Water, andjLand Resources Quality
The purpose of Goal 6 is,to mainJain 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 quahty standards, In the context of the
proposed Metro Plan diagram arr\~ndment, Go~l 6 requires that the applicant demonstrate
that it is reasonable to expect that applicable state and federal environmental quality ,
.1 '
standards can be met..: '
:;
Though Tax Lot 400 has been us.~d for low-value storage and quasi-industrial uses, the
site is not listed on any state or Ideal environmental clean-up list. A Phase 1
environmental assessment on thdl subject property was conducted and recommended ..
additional analysis, Upon reco~mendations through the Phase 2 envirOnmental
, assessment a nominal quantity of soil (less than \0 cy) impacted bv earlier/historic use
,. .~....
was removed from the site and p,roperly disposed Given the nominal impact generated
by historic uses on the site, it is reasonable to conclude that future development on the
site will be able to demonstrate 20mplwnce 'with City standards for \vater quality
p'rotection through the site plan ieview process, thereby complying with applicable state
and federal envirorunental quality standards,
r
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Metro PlanlEMRP Diagram Amendment
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Goal 7 - Areas Subject to Natural Hazards'
Goal 7 requires that development subject to damage from natural hazards and disasters be
planned and/or constructed with appropriate safeguards and mitigation, The goal als~'
'requires that plans be based on an inventory of kno\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 anv
established FEMA flood hazard area, Then;fore, appfoval of the proposed Plan -
,amendments will not alter the City's acknowledged compliance with Goal 7 through its
adopted plans, codes ,and procedures,
,
,
,
GoalS - Recreational Needs -I
,Goal S ,requires local governments to plan and provid,e for the siting of necessary
recreational facilities to "satisfy the recreational needs of the citizens of the s'tate 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 impa~t on the community's'recreational
facilities or, needs; therefore, the proposal does not implicate Goal S. ,
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 cir the'citizens. The proposed
, I
amendment to the Metro Plan diagram will inCretlSe the city's capacity for economic
development by adding 5 acres of CCiri place of thlexisting industrial designation,
Permitting the, construction of future clinic facilities land allowing long-standing ,
commercial uses onTax Lot 402 to beco'me conforrrling uses consistent with commercial
zoning is consistent with num'erous policies in the city's adopted plan for compliance
. "
with Goal 9, the Springfield Commercial Lands Study (SCLS)"
Specifically, the followingSCLS policies are applicable,to the proposal:
I
Policy I-A: "Maintain a mixed supply ofla~ge and small commercial sites
through strategies such as rezoning or annexation to serve Springfield's
, future population," I
The proposd fulfills this policy objective by redesikating and - through accompanying
zone change _ rezoning land from industrial to commercial, for two tax lots of varying
sizes and commercial uses, thereby maintaining exi'sting employment and commerci:.rl
use in Tax Lot 402 and providing the ability for gro'wth in medical sector employme~t by
allowlllo future clinic uses Oft Tax Lot 400,
00
Policy \,C: "Maintain at least a five-year supply of commercial land '
within the Urban Growth Boundary (UGB) ,that is cunently served or
readily serviceable with a full range of urbdn public facilities and
serv\.ces
"
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Metro PlaniEMRP Diagram Amendment
. PeaceHealth Oregon Region
M~.rc:h 1. ~ ?.O~~
The SCLS (see Table 3-8, pg, 32) fotmd there to be adeficit of 158 acres in the supply of
commercial land over demand projected through the year 2015, The proposal would
allow for redesignation, andrezoning, 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 $CLS identifies (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 ret~il trade and well-paying health services sectors.
Approving the proposed redesignation and zone change would help meet'Springfleld's
demonstrated need for employment and commercial services.
Finding 3 in the S.CLS, (pg. 36) cited the acknowledged 1992 Iridustrial Land Study as
demonstrating that "a surplus of industrial sites exists in the,Metro Area." Therefore, the
proposed redesignation (and corresponding rezoning) would not result in a deficit of
needed industrially designated and!,zoned'land, but it would help reduce the commercial
lands deficit identified in the SCLS, Therefore, approving the proposal would be
consistent with SLCS Implementation'Strategy 3-A (1): "Evaluate inventories based on
demonstrated need for the plaMing period. Initiate rezoning or redesignation of surplus
land uses where more appropriate 'for commercial, consistent with the lvletro Plan."
The proposal in fact consistent with inventories for cornni.ercial and industrial lands
adopted by the City Council and icknowledgedby DLCD as being consistent with Goal
9. Oregon Administrative Rules concerning Goal 9 implementation (OAR 660-009-
00 I O( 4)) call for amendments to land use designations "in 'excess of twO acres within .an
existing urban growth boundary from an industrial land use designation to a non- ,
industrial use designation" to have to address applicable plaMing requirements - such as
consistencywiththe Metro Plan and other local plan policies (i,e" SCLS) or be consistent
, with an economic opportunities ~nalysis, 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 epables continued use of the existing and long-standing
commercial center to continue to operate and provide employment opportunities, while
, also allowing higher-value employment associated with future development on Tax Lot
400 These types of employment-generating uses are among those identified' in OAR
660-009-0005(6) as eligible nonl:indl1str1al employment activities that can jl1stify .
approval of the proposed Plan diagram'amendment without the need for an economic
opportunities analysis apart from the SCLS, whicb DLCD acknowledged as fulfilling the
" -
City's obligations under Goal 9", '
Beco.use the reql1ested redesigmltion and concurrent zone change implements SCLS
policies and does not resl1lt in a'ldeflciency of needed industrial lands, and is otherwise
demonstrated to be consistent ,""itb 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 implementl1ti?n,
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Metro Plan/EMRP Diagram Amendment
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Page 9
GonlIO - Housing , '
LCDC's Housing goal requires cities to maintain adequat~ supplies of buildable lands for
needed housing, based on an acknowledged inventory of buildable lands, The proposal
does not affect the City's inventory ofresidential lands,
In fact, approval of the 'requested redesignation for Tax Lot 400 would enable
redevelopment of an industrial site abutting existing residential development. Through
the site plan review process, future development on that property will provide a superior
buffer and a higher use that will beneEt the adjoining residential properties, Because the
proposal involves redesignatio~ from industrial to commercial land uses, it does not
.affect SpringEeld's continued compliance with Goal 10.,
Goal 11- Public Facilities and Services
This goal requires the provision of a timely, orderly and efficient.arrangement of public
, facilities and services, The subject property is located within the SpringfleldUGB and
city limits, and is already designated for urban levels of use. The proposed amendment to
the Plan map designations from LMI to CC will not affect the ability to provide needed
services, since all the required urban services are available to support existing or future'
commercial uses on the subject site,
Goall2 _Transportation
Goal 12 requires local governments to provide and e~courage a safe, convenient and
economical transportation system. The proposed map amendments involve
approximately 5.24 acres of property; though existing and long-standing commercial uses
occur on Tax LotA02 such that approval ofthe proposal ,-iil! 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 TrafEc Impact Analysis (TiA) demonstrates, future development
of medical oftice facilities on TL 400 will not degrade mobility standards below
acceptable levels and allow for adequate queuing le~gths at applicable intersections,
Therefore, the proposal will not have a "signiEcant effect" on transportation facilities as '
defll1ed in the Transportation Plar,ning Rule (OAR 660-012-060).
Existing development at Tax Lot 402 is not affected by the proposal, and is assumed to
retain its current access points off Main Street. It is further assumed that future
development on Tax Lot 400 will result in some access changes as will be reviewed
through the site plan review piocess,thereby consolidating two existing curb cuts located
on Tax Lot 400 into a single access point located a~proximately in the center of the
parceL The TIA demonstrates that these access poihts will not result in any degradation
of mobilitv standa;ds bet'ow acceptable levels, and that safe and efficient circulation can
be realized through approval of the requested land ~se redesignation (and companion
zone change), I.'
. '
Furthermore, reducing the number of access points for future development on Tax Lot
400 is consistent with policy objectives found in E~st Main Retinement Plan (EMRP)
I
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Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15,2007 '
Page 10
Access, Circulation & Parking Elerrient'policy IB (pg., 17) and Commercial Element
, I
policy 3 (pg. 12). '
, Because the proposal, as demonstratld in the TIA,is consistent, with the reqUIrements of
the TPR and with applicable policie~ in the EMRP, it is consistent with Goal 12 and,
applicable \ocal implementing pOlicies. "
Ii
Goall3 - Energy Co'nserv~tion
The Energy goal is a general plannihg goal and provides limited guidance'for
site-specific map amendments. Th~ proposed amendment has no direct impact on' energy
conservation, though it would in fa~t will promote greater energy efficiency by enabling
needed clinical services available tq growing reside,f1tial areas in east Springfield. '
Therefor" the proposed amendment is, cQnsistentwith, and does notalter the City's
continued compliance with Goal 13,. , , '" ':' "
Goal 14 - U rbanizatioh "
Goal 14 requires local jurisdictions' to provide for an "~rderly and efficient transition
from rural to urban land use." The:~su1:iject property is within the UGB and the city limits
cif Springfield, and within an existipg urbanized area of the community., Therefore, Goal
14 is not applicable to this application,
;!
GoallS - WiIlamette Riv,er,Greenway ,
This goal is inapplicab1ebecause tre subject property is not within the boundaries of the'
Willamette River Greenway, "
'I
"
Goals 16-19 - Coastal Goals
The coastal goals are not applicab}e to this application,
"i
5,2 Metro Pla~ Con'sis~ency
The application requests amendment of the Metro'Plan diagram from LMI to CC for
approximately 5,24 acres, This s~ction of the application narrative addresses the
. consistency of the amendment with the applicable policies of the Metro Plan, to
demonstrate that adoption of the 'amendment will not make the Metro Plan internally
inconsistel1l'(as required by the approval ,criteria in SDC 7,070(3)(b))
, .
, . I
This narrative only addresses tho:se policies that apply to the proposal, and does not
discuss those portions of the Me\ro Plan that: (1') apply only to rural or other lands
outside of the urban growth bou~dary, (2) apply to land uses other than the current or
,proposed deSignations for the sit~ and will not be affected by th'e proposed Plan diagram
and te,\t amendments, or (3) cleqrlY apply only to specifiC development applications (eg"
site plan ,review submittals,or subdivisions), In many instances the goals, policies and
implementation measures apply)o specific development proposals that will be addressed
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Metro PlanlEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15, 2001
. Page 11
through compliance with applicable City regulations during site plan review of a, given
future development proposal. "
. The Metro Plan 1nlrotltlction, Section D provides the following definition.s:
A goal as a broaCl statement of philosophy that describes the
hopes of the people of the community for the future of the
commlmity., A goal may never be completely attainable, but
is used as a point to striVe for.
An objective is an attainable target,that the community
attempts to reach in striving to meet a goal. An objective may
. . . ,I .
also be considered as an intennediate point that will help
J ' ' ' '
fulfill the overall goal. I' . "
A policy is a statement adopted as ~art ~f the Plan to provide
a consistent course of a~tion moving the community towards
attainment of its goals,
Except for the Growth Man.agement Goals, which are addressed below, each of the Metro
Plan policies are aMressed in the order in which they appear in the Plan Element section
of the Metro Plan,
S.l.A.
Metro Plan Elements
1. Growth Management
po,licies
1, The urbiln growth boundary and seq,uential develop,!,ent shall
c'onlinue to be implemented as an essen:tial means to achieve
compact urban growth, PrOVision of all urban services shall be
concentrated'inside the urban growth b'oundary, . , ,
The proposed amendments satisfy this p~licy becaLe the subject property is lnside the
UGB and city limits and as such, encourages comp'act urban growtl-t. Also, urban.
serfices are available at sufficient levels to accomrhodate the existing and future infill
development resulting approval of from this applic'ation, The City's site plan revtew'
processes ensure that the appropnate level of servihes is available to serve future
development.
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Melro PlaniEMRP Diagram Amendmenl
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March 1 \ 2001
Page 12:,
;1 .
2, Residential Land Use an:d Housing Element
!
PoliCies "
j
II.
- ~
A.ll Generally locate high}r den~ity residential development near
employment or commercial;lservices, in proximity to major
transportation systems or within transportation-efficient nodes.
, .. .
The proposed redesignation does nst affet't the inventory or availability of residentially
designated or zoned land, including the sin'gle-family residential area abutting Tax Lot
400 that is zoned and designated fo'[ Medium Density Residential, or higher density
residential developments located e~st of the site along Main Street, '
"
'"
However, approval of the requesteg redes,ignation to Community' Commercial would
allow for residential areas proximafe to the subject area to have close and efficient access
to existing commercial services oni,Tax Lot 402 and to 'future medical facilities p~oposed
for Tax Lot 400, consistent with th,b above policy, The areas proposed for redesignation
offer existing and future emploYTIl~nt opportunities and provide commercial services
along a major tr'unsportation system that can support the needs of nearby residential
development' , II: . ,
I,
I
J',I
II .. .
A,22 Expand opportunitirs Jor ~ mix oj uses.in newly developing areas
and existing neighborhoo'ds through local zoning and development
I, " ' '
regulations, ' '
The map amendment and concurr,~nt]y proposed zone change will allow for existing
commercial uses on Tax Lot 402[0 continue to serve existing neighborhoods in the mid-
and east,Springtield area, and for:ifutureclinical facilities to be developed to serve this
rapidly growing area of the community,' Approving the requested redesignation and zone
change would expand cbmmerci~l opportunities to serve these neighborhoods consistent
. ~.' If"
WIth the above polICY,
3, Economic Element
policies
B,] Demonstrate II positive, interest in existing and new indilStries,
especially those providili~ above-above wage and salary levels, and
'inG'reased var(ety of job opportunities, a rise in the standatd of living,
alld lltili"lltion oj Ollr e"C:isrillg comparative advantage in the level oj
edtlcationllnd skill oftli'e resident laborfo/'ce,
, I ' '
I
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Metro PlaniEMRP Diagram Amendment
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Page 13
The proposed amendment is consistent with this policy because it will allow medical
clinic uses to be developed to serve growing areas in east and south Springfield, As is
observed in the Springfield Commercial Lands Study (pp,'27, 29), employment in health
services is growing and approving the requested redesignation will enable increased job
opportunities with higher than average wages thereby helping raise the standard oflivina
" 0
and meet the needs of Springfield citizens, consistent jwith the above policy, ,
B.2 Encourage econolllic developmen't which utilizes local and imported
capital, entrepreneurial skills, and the reside/It labor force.
,
The The construction 'of and the use of corrun~rcial aAd medical uses will utilize both'
, ,
local and Impo'rted capital and will employ the locc,llabor force in a variety of skilled,
semi-skilled, and unskilled positIOns, consistent V,iith!this POliCY:.
B.6 Increase the alllount of undeveloped land z'oned for lightindustry
and commercial uses correlating the effectiJe supply in terms of
sdtability and availability with the projectio~,S of demand. ' .
. ~
The proposal will add approximately 5,24 acres .of C'ommunityCommercialland;
consistent with recorrunendations to increase the codunerciallands inventory made in the
Springfield Commercial Lands Study, The ~CLS add acknowledged'metropolitan
Industrial Lands Study concluded that there is a defibt of-needed commercial land, and a
surplus of industrially zoned and designated land. Plppfoval of the requested
redesigrmtion will not cause the inventory of.neededl industrial land to go into a deficit, ,
, I
but in fact would, conslsterit with the .above policy, jThe proposal cOlT elates the need and
, SUItability, and avatlabllity of the subject site for commercwl uses With the need for such
uses as demonstrated in the adopted SCLS. I "
i
B,]] Encourage economic activities whicH strengthen the metropolitan
. area is posiiiOIl as a regiOllal distribution, trade, health, and service
center, I
,
,
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 metropolitin area's position as a premier lcicale.for healthcare services, consistent
with this policy objective. ' '
6, Environmental Design Element
policies,
E.l In order to promote the greatestpossible degree of diversity, a broad
, variety of commercial, residellti~l, alld re~reatiOllallalld lIses shall be
encouraged fvilen cOllsistent wirh other pl,anllillg policies.
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Metro Plan/EMRP Diagram Amendment
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'I '
Approval of the proposed map amenC\ments will add just over 5 acres into' the, City' s
inventory of commercially designat~~ and zoned land, thereby allowing for Ii variety of
needed commercial uses to occur on.,lthe subject property. Long-standing ex.isting ,
, .1 .
commercial services on Tax Lot 402 would be allowed to continue without the specter of
. I .
being considered non-conforming u~es, ang Tax Lot 400 could be developed with
'medical services that will serve the needs of the growing residential areas east and south
of the subject site, consistent with tlie above'policy, '
7, Transportation Elemen't
, ,
I'
,i
Land Use policies
F.3 Provide for transit-~!lpportive land !lse p'atterns and developmwt,
including (,ig}ler intensity, '.transit-oriented developmen(along major
transit corridors and near (ransit'stations; medium- and high-density
. 0 ..r ,"
residential development wiihin one-q!larter mile of transit stations,'
major transit corridors, employment centers, and downtown areas;'alld
, development and redevelop,ment in desigllated areas that are or cOllld be
well served by existing or Alanned transit. ' " '
. .il' . .
.:1
'I
The proposed map amendment and concurrent zone change will enable land use patterns
and development consistent with the above policy, Approval6f the proposal will allow
for higher intensity development a'long Main Street, a major transit corridor An existing
L TO stop is located on thefroniage ofT~x [;ot 400 (see photo, pg, 2, Appendix A of the
TIA), and will provide convenien(; access to ex.isting and projected employment on the
subject site, as well as ac~ess for patief)ts to future out-patient medical facilities projected
on Tax Lot 400,' '
II
:1
"
".
.'
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Metro PlarJEMRP Diagram Amendment
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Page 15
Transportation,System Improvements: Roadways policies
F.15 lYIotor vehicle level of service policy:
a. Use motor vehicle level of service standards to maintain acceptable
and reliable performance on the roadfvay,system. These stlmdards
shall be used for: .
(1) Identifying capacity dejiciencies on the roadway system.
(2) Evaluating the impacts on roadways of amendments to
transportation plans, acknowledged comprehensive plans and,
land-use regulations, pursuant to 'the TPR (OAR 660-012-
, ' ,
0060).
(3) Evaluating development applicationsfor consistency with the
land-use regulations of the applical;le'lpcal go~e'mment
" jurisdiction. I
. ' , ' I ' ' . '
b, Acceptable and reliable perfomiance if iefllled by the following
levels of service llnder peak hOllr traffic conditions: LOS E within
Ellgene's Central Area Tmnsportatiot! Swdy (CA TS) area, and
LOS D elsewhere, "
c, Performance standarifsfi'om the OHlj shall be applied 0'1 state
,facilities in the Eugene-SpringJield metropolitan area.
, '1,'
In some cases, the level of service may be sllbstundard; The local'
government jurisdiction may find that tran}portation system '
improvements to bring performance up to srandard within the planning
horizon may not be feasible, and safety will not be compromised, allfl
broader community goals wOllld be better served by allowing a
substandard level of service, The limitation on the feasibility of a
transportation system improvement may arise from severe constmints,
incllllling but not limited to ellvirollmetlta{'conditions, lack ofpllblic
agency jinllltcial resources, or land llse coristraint factors, It is not the
intent of TS! Raodway Policy #2: lyIotor Vehicle Level of Service to
regtlire deferral of development in such cales, The intellt is to defer
motor vehicle capacity iltcreasing transpor1tationimprovements 'Ulti/.
existillg constraillts can be overco,me or de'velop alt alternative mix of
, ,
strategies (stich as: land llse measures, TDiY!, short-term safety
improvementS) to address tlte problem, I '
, .
Subsection a,(2) in the above policy requires an evaluation of the proposal pursuant to the
state Transportation Platlning Rule (TPR), The accompanying Traffic Impact Analysis
5-60
Metro PlanlEMRP Diagram Amendment
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March \5, 2007,
Page \6
provides the factual'basis to determine that the proposed redesignation would not result in
a "signiftcant effect" as deftn~d undkr the TPR (OAR 660-0 12-0060( 1)), , '
Speciftcally, the proposal does not 'change Jhe functional classiftcation of Main Street or
any other nearby roadway, and it do'b not change the standards for implementing the
City's functional classiftcation system of roadways, as identifted in the Regional
Transportation Plan, As demonstrated in the TIA, \,he proposal also does not:
, .
.
Result in types or levels of traffic or access that are inconsistent with the fi.mctional
. ~
classiftcation of Main Street or any other nearby roadway;, "
Reduce performance of trafftc bn Main Street or other affected intersections to a level
,[,' '
that is below acceptable establi~hed performance standards; or
. ,Make performance of e:<isting facilities worse (i.e., below acceptable mobility
standards) than would be the c~se other uses 'permitted unde{existing,designations or
zomng,
r
.
Speciftc TPR ftndings are further located in the TIA, see pp, 31-32. Because the proposal
does not result in a "significant efffct" as established by applicable 'OARs, no further
TPR analysis is required. The reqLlest is therefore consistent with the above policy,
. -. j .
Ii'
8, Public Facilities and S':ervice,:Elem~nt
"
G,l Extend the minimwn level fwd full range oj key urban facilities and,
services in an orderly ami ejjicient manner consistent with the growth
management policies in Chapi~rll-B, relevant policies in this chapter and opzer
jyletro Plan policies,
The subject property is located in;ISpringfteld's city limits UGB All necessary
infrastructure and key urban facil,ities/services are present to serve e:<isting developmerit
(Tax Lot 402) Dr are available tokerve future infill development on Ta:<Lo,t400,
Therefore, the proposal is consistent with the abovepolicy,
. 'Ii "
9, Parks and Recreation Facilities Element policies
pollcies in this element of the M~tro Plan are not relevant to the requested diagram
amendment. ' '
,
J!
10, Histo~ic P'reservati,on,Element policies
pollcles in this element 'of the 1v(etro Plan are not relevant to the,requested diagram
amendment. ' 'I,
5-61
Metro PianlEMRP Diagram'Amendment
PeaceHealth'Oregon Region
March i 5, 200"
Page 17
11. , Energy Element policies
Policies in this element of the Metro Plan are not relevant to the requested diagram
amendment.
, 8.0 East Main Refinement Plan Consistency
The following 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) Thefollowing land uses are allowed und,er Community COlnmercial ,
zonillg:
All Commullitv Commercial uses. subject to Article 18 of the
Sprillgfield Development Code. ,
I
i
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. Approva\ of t~e 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 soJtli, which are also zoned and ,
designated for commercial uses, I '
\
2, Commercial Element
, I
Criteria (or Commercial RefinemelltPla/l Desi!!rwtion
,
i
1, Generally, the COllllllu;,ity Commercialrefinement plall designation
shall be applied under the following ci~cumstances: ' ,
,
A) where it is Ilot un illtrusion illtoi well-maintailled residelltial
neighborhoods; I
I
I
The proposed redesignation does not intrude into tqe e:<isting residential area west'
of the subject site along 44'h Street, and is therefor~ consistent with the above'
criterion. "\
5-62
Metro PlanlEMRP Diagram Amendmenl
PeaceHealth Oregon Region
March 15.2007
, Page 13
,
Although the_abutting.residential area is zoned Medium Density Residential, it is
developed in low deflsity residential i~ses. Approval of the proposed
redesignation of the subject sites woltld actually result in a decrease of confEcts
between abutting residential and nod-residential [and uses by allowing future infill
development on Tax Lot 400, afld through the site plan review proces's
establishing improved landscaped b\lffers and a use more compatible thanthe
. industrial uses that historically abutting this residential area, '
;1
B) where it does not increase conflict' betJVeen Low Density
Residential and Commercial;
. I ' '
',C) where criteria for designating Medium Density Residential
land does not apply;
Criteria for designating MDR land does not apply to the 'subject ~ite.
, I ",
,
D) where legally cr~ated commercial uses exist;
,
Tax Lot 402 has existing, 10ng-staI)ding commercial uses that were legally created
prior to developmeflt of the Metro flan or EMRP, '
The subject site has adequate legal access onto Main Street, which,is classified as
an 'arterial street '
E) where adeqllate clIstomer and service access to an arterial'
street can be p~pviiled; ", and '.
"
, 'I '
F) ,where designated Commercial on the j'detro Plan Diagram,
Approval,of this appllcation woul~ result in a Commercial designation Ofl the
Metro Plan diagram, which would also automatically modify'the designation on
the EMRP diagrom,
.
Policy 2), Apply'site-spesUic Commercial rejinement plan desig/lations
to clearly deji/le the limiis ofnhv commercial mes wher~ there is /lot an
existing; legally establisHed" a/ld beneficial mb:ing of lISeS,
,
Approval of the requested redesl~ation \~ould apply Commercial plan designations to
the subject properties, allowing the existing, legally established c9mmercial uses on Tax
Lot 402 to cOfltlnue, It would afso enable commercial uses to be establishedofl Tax Lot
400, thereby defining the limits bf flew 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 flot have afl existing or benefiCial mix of
llses, but has historically housed, industrial'yard-type operatiofls, Therefore, approval of
" 5-63
.. '
Metro PlaniEMRP'Diagram Ameadment
PeaceHealth Oregon Region '
1vlarch I j 2007
Page 19 '
"
the proposal would define the limits of new ,commercial uses as called for in the above
policy, and also provide the ability to make superior buffering and other improvements
associated with future development on Tax Lot 400 through the site plan review process,
Policy 3) Reducethe nt/mber of vehicular accesS points Cl!Idrequire the
rebLlilding of curbs and installation of sidewLllks and street trees along
ll1ain Street, through the Site Plan Review proceSS and in public
improvement projects,
The proposal w'ould result in reducing the number of ~'xisting access points as required
above, Through the Site Plan Review process, futureidevelopment on Tax Lot 400 will
have a single driveway access,onto Main Street, eli;ninating one of the two existing curb
. . I .
cuts on this site, Side\valks and street trees are already located along its Main Street
fr011tage, consistent with the above policy, 'I,':" ,
, , ,
Policy 4) Provide bLlJTering between comme'rcial and residential L1ses
throLlgh Article 31 of the Springfield Development Code, Site Plan
Review proceSs.
Existing residential uses along the east side of 44th Street have had no real buffer from
pre-existing industrial uses on Tax Lot 400, Approv~l of the proposal would allow for
attracti \fe' infill development of future medical bcidies that would provide (through the
SPR process) improved landscaped buffers betweenlthe 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 shull encourage efforts ofvarioLls agencies to attract
new and retain existing jobs and bLlsinesse},
lmolementation
The City shall maintain a CIIrrent inventory of vacant commercial and
industrial land and structures lVithi/! the E'ast idai/! area,
,
Consistent with the above policy, approval of the r~quested redesignation will enable
existing, long-standing Jobs and businesses on TaxlLot 402 to remain as, legal, ,
conforming land uses, and allow future deyelopme(lt of new employment on Tax Lot 400
with higher than average wages and employment densities than the current designation
and zo~ing allows,' . j' '
i
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MetroPlar1/ Refir1emer1t Plar1
Amer1dmer1t Application
#LRP2007 -00013
Rez.one Applicatior1
#ZON2007 -00012
Metra Plan Amendment"fiOm LMI to
Commercial and concurrent Zoning
Map Amendment from LMI to CC
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5-70
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Propel -'tanning & Development
March 28,2007'
.i
~ PeaceHealth
David Reesor, Planner II
City of Springfield
Development Services Department:: ,
225 Fifth Street
Springfield, OR 97477
Re: ' Plan Amendment (LRP2007-00013), Zone Change (ZON2007-00012)
'I
Mr. Reesor,
The following and attached is supplemental information for the above-referenced
applications for proposed Metro Pian diagram amendment and zone change in east
Springfield, '
The proposal seeks to redesignateand rezone approximately 5.24 acres on two parcels
from Light-Medium Industrial (L~lI) to Commercial. As noted in the application '
findings submitted last week, the Springfield Commercial Lands Study demonstrates that'
the City has a deficiency in needed corrimercially designated and zoned land, so
approving the proposal would help reduce the identified deficit in that land use category,
The Metropolitan Industrial Lands Study (July 1993) was adopted by the local
jurisdictions and ackii.owledged by LCDC as being consistent with statewide planning
goals and the Metro Plan, specificLally fulfilling the Eugene-Springfield area's obligations
under Goal 9 (Economic Development). The Metropolitan Industrial Lands Inventory
Report associated with the MILS 'identified "about 1,688 constraint-free industrial
acres...,This supply exceeds the projected demand over the next twenty years, which is
between 650 to 1,172 acres," (pg" 73) The Inventory Report also stated: "The 1,688,
constraint-free acres may, be the best suited to meet short-term industrial demand, This
portion of the supply also exceeds the twenty year demand projection,"
The City performed subsequent analysis of industrial land supply as part of periodic
review requirements to demonstr~te 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 GoalS protection measures (about 100 ac'res
debited from the Eugene and Springfield inventories) would leave a surplus of industrial
lands ofbecween 1,600 and 2,122 acres metro-wide,
Staff s Goal S work also calculated the changes in industria! land supplies since 1991 as a
consequence of Metro Plan diagram changes (see AttacrJIlent B). This analysis
demonstrated a reduction in less than 90 acres of indusrrialland over the past 15 years,
Phon!.::
F:l.'i.:
(54l) 3:~5-2593.
(5d.1) 335.2595
Ri'/er8end Annex, 123 International Way
pedicured to Exc:cpriol7r.tI kk:dicil1l!
ond Compossiul1i.1le Core
Springr:<?\c O? 97J.77
5':'71'
I
suggesting that there is still anample supply of available industrial lands to,meet existino
'.' I' ;;,
and future development needs. ' . ,\ ' . ,
, '
This analysis may also not reflect other changes within industrially designated land
categories that would further off-set the proposed change to the site's LMI Plan '
designation and zoning, For example, 11.5 acres was added to the invent,ory ofLMI
zoned and designated land due to City Council approval in April 1997 for land east of the
23th/31 st Street connector and north of Marc ala Road (Ordinance No, 5351), 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 enoLlgh acreage to the inventory of LMIdesignated and zoned land to
off-set the proposal to remove only about 5 acres from the LMI inventory,
We therefore resp~ctfully submit that the proposed Metro Plan diagram amendment and
zone change will nO,t materially affect the inventory of needed Industriallarid and will not,
alter the City' s continued compliance with Goal 9, .
With acceptance of the above findings and earlier findings and narrative in the prior
submitted applications, we believe the' applications aie complete and ready to be set for
Planning Commission hearing,. Please notify me whe,n the hearing is set, and send me a
copy of the required hearing notice to DLCD for my files, ,
, Thanks for your consideration of the above, If.You n~ed additi~nal inf~rmation, please
contact me at your convenience;
.
:&~5cp F
Director, Land Use Planning & Development
PeaceHealth Oregon Region
Attachments
I
i
5-72
ATT ACHMENT A
1.1,0 Impact of the Proposed Protections on Buildable Land
Inventories ' '
This section estimates the impact of the recommended program for protecting
Springfield's resource areas on the inventory,ofbuildable residential, commercial and
industrial land. The administrativ~,";';le quoted above is somewhat vague about how to
compute.the impact. Some contend ~hat the protected acreage should be subtracted from
the current inventory of buildable land. Others contend that the protected acreage should
be subtracted from the sumlus of buildable land that was detennined at the adoption of
the inventory, Case law supports subtracting the protected acreage from the surplus of'
buildable land.
Tables II-I, 11-2, and 11-3 below summarize the amortnt of land that would be
subtracted from the Eugene~Springfield inventories of surplus of buildable residential,
commercial and indust~allands tha~ were identified when each inventory was adopted,
Table 11-1, Analysis of MaxiflJum Possible Impact on Supply of Residential
,Lands within the Eugene-Springfield Metropolitan Area
Residential Land Supply
Eugene-Sp-nn;:'field Metropolitan l\rea Residential Lands
o ' .
and Housing Study Surplus Acres "
Low Demand Assumption 'I
or
High Demand Assumption" ,
Acres Remo~d from Residential Designation by Previous
Plan Amendments'
Eugene
Springfield
Acres
-- .- - .'-- .- .--- --
1862,00
or
790.00
Total
-84.90
-52,03
-136.93
!
-445.77
Maximum Possible Residential Acres Impacted by
Eugene GoalS Protection Measures
Maximum Possible Residential Acres Impacted by
Springfield Goal5 Protection i'/Ieasures
Remaining Surplus
-14.18
1265,12
or
193.12 i
5-73
Table 11.2. Analysis of Maximum Possible Impact on Supply of
Commercial Lands within the Springfield Urban Growth Boundary
I Commercial Land Sup'lly
Springfield C<JInmercial Lands Study (2000) projects a deficit of
commercial land.
\ Acres Removed from Commercial Designation by Previous Plan
Amendments. .
\ Maximum Possible Corn.rnercial Acres Impacted by Springfield's
Goal 5 Protection Measures
I Remaining Surplus (Deficit2... -..J:172.36 acres) I
I
Acres \
-153 acres
-2.8 acres 1
-11.56 acres
Table 11-3, Analysis of Maximum Possible Impact on Supply of Industrial
Lands within the Eugene-Springfield Metropolitan Area
I Industrial L aod Supoly
Metropolitan Industrial Lands Inventory. Report Surplus Acres
Low Demand Assumption
or
High Demand Assumption
Acres Removed from Industrial Designation by Previ,ous Plan
Amendments'" '
Eugene
Springfield
Acres
2954,28
or
2432.28
.642.30
-90.80
-732.30
Total
- - -- -- - -- -
Maximum Possible Industrial Acres Impacted by Eugene Goal 5
Protection Measures I
. Maximum Possible Industrial Acres Impacted by!Springfield
Goal 5 Protection Measures I -54.43
Remaining Surplus' I 2122,01
or
I _ u_ _ _ 1600.01 I
* Does-not-~onsic:ler actlons taken by Eugene to add 'additional lands to the surplus. '
11,1 Impact on the Residential Lands In)entory , ,
-44,73
In 1999, the Eugene.Springfield Metropolitan Ar,ea Residential Land and Housing Study
(Residential Lands Study) estimated the amount of ~acant bllildabie residential land in
the area, In Springfield, a total of 3,087 acres of buildable lands were identified, The
Study classified wetlands listed on the Springfield !.local Wetla!1d LrlVentory as
unbllildable and were not lnclllded in the estimated kupply of buildable residential lands,
Other types of constraints were also considered and~classified as unbllildable and were
not counted in the blliidable resldentialland inventory. The list of constraints included:
. Floodways;
5-74
.
Wetlands listed on the Sp.ringlield.Local Wetlands Inventory larger than .25
, '
acres;
Land within the easement of 230 KV power lines;
Land within 75 feet ofaClass A stream or pond;
Land within 50 feet of a Class B stfeam or pond; and
Small irregularly shaped lots,
"
.
.
.
Since the Residential Lands Study did not include wetlands listed on the Local Wetlands
Inventory in the buildable lands inventory, it is assumed that protecting these wetland
sites from conflicting residential development will not reduce' that inventory. The
development setbacks recommended for significant wetland sites in this study will
slightly reduce the inventoi-ied acreage of vacant buildable land adjacent to wetland,
features.
Wetland Setbacks
As noted in Table 11-4 below, about 9,95 acres of low-density residential (LDR) and ,59 . '
acres of medium density residential ,(MDR) land will be removed from the residential
. . i
lands inventory by the 25-foot setback recommended for those wetlands not already
protected by the 50 and 75 foot setbacks required by Springfield's stormwater quality
protection policies. Keep in mind that this 'is a worst case scenario and assumes that the
developer is unable to locate required stormwater facilities within the recommended
setbacks and that subdivision design cannot arrange for the yard areas of affected
dwelling units to be placed adjacent to the wetland, thus reducing or eliminating lost
development area. ' "
Riparian,Setbacks
In addition to wetland setbacks, recommended riparian setbacks will also result in the
removal of vacant acreage from ttie inventory of buildable residential lands, As noted in
Table 11-4, about 3.42 acres of low-density residential (LDR) and .22 acres of medium
density residential (MDR) land will be removed from the residential lands inventory by
the 25-foot setback recommended for those wetlands not already protected by the 50 and
75 foot setbacks required by Springfield's stormwater quality protection policies.
The combined impact of the'proposed 25-foot setbacks for wetlands and riparian areas is
14,18 acres, This represents .45% of the 3,087 acres of buildable residential land '
described in the 1999 Residential Lands Study,
ill May 2004, a Residential Lands Study Monitoring Report was published, updating the
residential lands inventory to ref]~ct development through 2003, The report estimated
that at the end of2003 there was l,361 acres of remaining buildable residentiallund in
Springfield. The amount of land removed from the buildable inventory by the 25-foot
wetland and r.parian setbacks proposed by this report represents about 1 % of remaining
,. '
1,36l acres.
5-75
'Table 11-4. Vacant Residential Land within Proposed Protection Setbacks
I Wetland
I 25 foot
\ SO foot
I 75 foot
I
'I Riearian
I 25 foot
I SO foot
I 75 foot
I
I
V acan t
LDR
, Acres
I
, Vacant
lVIDR
Acres
Total Acres
Setback Distance
Setbacks
10.54
12.131
9.12 I '
31.79 I
I
3.64 I
8.79 I
9,12 I
21.55 I
53.341
Total
9,95
9.4
4,97
24,32
Setbacks
3.42; .22
6,06 'i 2.73
4,97, 4.15
Total 14.45 7.1
Grand Total 38.77 , 14.57
. ,I
11.2 Impact on the Commercial Lands Inventory
, I
,
The Springfield Commercial Lands Study (2000) list~d several types of development
constraints that affected cOnuTIercial properties, TheJe 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 regulated natural resource sites [Natural Resources Study
Inventory];
Sites with Plan/Zone conflicts,
The Commercial Lands Study ciassilied sites on the on the Springlleld Local Wetland
lnvemoryas constrained, The presence of these wetlands was noted and the inventory of
vacant comrnerciall;mds was noted to reflect the cohstraint, The ripari,<ln sites which are
part of this study were also included as constrained,: since they were part of the draft
Springfield lnventory of Natural Resource Sites at the time Commercial Lands Study 'was
conducted,
5-76 -
Since the SpringfieldCominercialLa~ds Study did not remove wetlands and rip'arian .
sites, protection measures proposed by this study willhave an impacton the inventoried
acreage of vacant commercial lands, The development setbacks recommended for
significant wetland and riparian sites will further reduce the inv~ntoried acreage of vacant
, buildable commercial land adjacent to these resource sites,' The ,extent of this impact is ,
discussed below, "
The Commercial Lands Study concluded that there was about 85 acres of vacant
buildable commercial land in Springfield. An additional 12 ~cres was projected for
redevelopment by the Study bringing the total to 97 buildable acres, Demand for vacant
commercial land for the planning.horizon 2015 was 255 acres, The 2000 Commercial '
Lands Study concluded that there was a 158 acre deficit of buildable commercial land.
Wetland Impacts
Table 11-5 shows that ,07 acres of vacant commercial land wO\lld'be removed from the
Commercial Lands Inventory if wetland sites zoned for commercial development were
fully protected, The 25-foot wetland setback recommended by this study would remove
an additional 1.47' acres of vacant commercial land from development. This figure
assumes that the developer' is unable to locate required storrllwater facilities or required
landscaping within the recommend~d setbacks, thus reducing or eliminating lost
development area..
The total impact on the Commercial Lands Inventory would be a reduction of 1.54 acres
if wetland sites and their setbacks were fully protected,
, '
Riparian Site Impacts
Table 11-5 shows that about acres },78 of vacant commercial land lies within inventoried
riparian sites that are protected by'the Springfield's Stcirmwater Quality Management
program, Therefore, no commercial acreage is removed from the Commercial Lands
Inventory by the implementation of proposed protections in this study, As noted in
Table 11-5, no vacant commercial land will be removed from the inventory by the
proposed 25-foot setbacks.
The total impact on the Commercial Lands Inventory would be a reduction of 1.54 acres
if wetland and ripman'sites and their setbacks were fcllly protected. This represents 1.8%
of the 85 acres of buildable commercial land described in the Springfield Commercial
Lands Study,
Table 11-5, Vacant Commer.cial Land within Proposed Protection Setbacks
\ ZouingDis';;:;ct 'I' Site \ 25 It. .
Acreage, Setback
I W etla~ds- - I I
I Communitv --- I ,07 I
\ 50 ft.
Setback
i
1.4 7 I
--. - .-- - .- ._- -
I 75 ft, \ Total
_ __~~tbac~.__ ~(;res
I
, ill
I
01
----
I
I
i
1.65 I
5-77 '
I Zoning District Site 25 ft. 50 ft. 75 ft. Total 1
Acreage Setback Setback Setback Acres \
I Commercial
\ Neighborhood 0 0\ 0 01 0\
, Commercia:! o 1
I General Office 0 0 0.1 01
Major Retail, \ 0 0 0 0\ OJ
Commercial I
I Wetland Total 0,07 1.47 0.11 01 1.65
\ Riparian Areas \
\ Community 2,78 O. \ 01 2,6 5,38
Commercial I
Neighborhood 0 0 01 0 0
Commercial
I General Office 0 0 0\ o 1'--- 01
\ Major Retail 0 0 .24 \ 0 ,24 \
Commercial
I Riparian Total \ 2.78 0 0.241 2.6 5.62 I
I Grand Intal 2,85 1.47 .351- 2,6 7.27 I
,
11.3 Impact on the Industrial Lands, Inve~tory
, . '. ' ' ' I " , ' '
The 1992 Metro Area Industrial Lands Study assessed the supply and demand for '
industrial land in the greater Eugene-Springfield areal The study concluded that there
,
was'about 709 acres of buildable industrial land within Springfield's UGB. Like the
,
Springfield Commercial Lands Study, the Industrial I<.,ands Study noted those industrial
, 1
sites with wetland and riparian constraints but did not exclude them from the inventory.
For that reason, protection of wetland and riparian lands under the policies proposed by
this study will reduce the inventory ofbuilda'ble indu'striallands. The extent of this
, '
impact is discussed below. '
Wetland Impacts
GIS analvsis shows that about 30,64 acres of vacant industrial land are affected bv
4 . j 4
wetlands that are not already protected by, the Springfleld Stormwater Quality
Management (SQM) program. These wetlands are recommended for protection by a 25. ,
foot development setback under the Springfield natutal Resources Study. These setbacks
add another 6,82 acres to the amount of industrial zdned land that would be removed'
from the lndustrial Land lnventory if wetland sites apd the setbacks were fully protected
under the policies recommended by this study, The total,impact to the inventory of
industrial lands would be 37.46 acres, Table 11-6 s~ows the lotal acreage for la.'ld
affected,by wetlands and the acreage protected by sJtbacks from both,this program and
the existing SQM program.
Riparian Iinpacts
5-78
GIS analysis shows that 13,70 acres of vacant industriillland areaffe~ted by riparian
areas are that not already protected by: the Springfield Stonnwater Quality Management
(SQM)program. These riparian areas are recorrunended for protection by a 25-f;ot
'development.setback under the Springfield Natural Resources Study. 'These setbacks add
another 3,27 awis to the amount of iridustrial zoned land that would be removed from the
Industrial Land Inventory if wetland sites and the setbacks were fully protected under the
policies recorrunended by this study, The total impact to the inventory of industrial lands
would be 16.97 acres, Table 11-6 sh?wS the total acreage for land affected by riparian
corridors and the acreage protected by setbacks from both this program and the existing
SQM program. '
, Total Impact
Tlg:total impact on the Industrial La'nds Inventory would be a reduction of 54.43 acres if
all wetland and riparian sites protected by this program and their 25-ft setbacks were fully'
. protected, This represents less than 1 % of the 709 acres of buildable industrial land for
Springfield in the Industrial Lands Study,
Table 11-6, Vacant Industrial Land within Proposed Protection Setbacks
__ ,II " . .
Zoning
District
Site
Acres not
Prote'cted
Acreage by SQiVl
I
28,20
25 ft.
Setback
Total
Wetland
Site
[,
4,8 I
(2776)
13.16
(2.88)
2.0\
.35
o
o
o
0\
13 \
o
o
(30,64)
6.82
Acreage
Site
Acres not
Protected
bY SQM
25 ft.
Setback
5-79
_ -,,-- ..-. u ___ --
50 ft.
Setback
, 75 ft.
Setback
Wetlands
Light-
Medium
Industrial
Heavy
lndustrial
I Campus
Industrial
Special
Heavy
lndustrial
I Quarry l
Minin~
I Booth Kelly -~I- -
MU
\ \.Yetla~d-\ - - - 41.34\
Total
Riparian Total
Areas Riparian
Site
,82
o
I
19.151
1_
},28 (
o
o
o
I
01
:47\
o
21.72
50 n.
Setback
o
o
_01
, 0
0\
o
~. ~_~ I
75 ft.
Setback
. Total
Acres
33.83
34.32
1,63 I
o
01
I
0.60 i
I
70,381
, I
Total
Acres
.,
Zoning Total ' Site 25 ft. ' 50 ft, 75 ft. Total
District Wetland Acres !!Q! Setback Setback Setback Acres
Site Protected
Acreage by SQM
Light. 16.48 (10,89) 2,05 4,72 ,1,26 24.51
Medium
Industrial
\ Heavy 68.31 ' (2,81) ,1,22 ' 8,93 \ 0 78.46
Industrial
, \ Campus' , 3,22 0 0 2.83 \ .03 6,081
, ' Industrial ' !
" 'Special 0 0 0 0 0 0
Heavy .
,
Industrial I 0\
\ Quarry , 0 0 0 Ol 0
Mining
\ BoothKelly , ,21 0 0 . ,82 0 1.03
tvru " ' :1 I
" Riparian 88.22 (13.70) 3,27\\ 17.3 \ 1.29 \ 110.08
, Total
Grand Total 1 130,06 (44,34) 10.0911' 39.021 1.29\ 180.46
I
.
,
,
i
,.
5-80
Metro Plan Diawam Changes Affecting the Supply of Residential, Commercial and Industrial Land
Changes in Metro Plan Designations
tiC CI LMI III pas G&E tlR
I WfttitiJJE\' ~~~ ~1i~
J'f!~"i"1;! r"1:9'0 ':0"9'0 -
\"","",/Ar...,I."f\';\, "'- ~_-
~Hi;~tili1
I Local File Number
90-04-058
00-12-201
, ~2-04-77
,93-01-33
193-01-12
193-06-087
94-10-0194
95,02-036
95-02-03fi
95-02-036
95-02-036
95.02-036
,95-08-0157
97-05-101
90-02-038
199-02-041
199-09-230
102-03-0062
102-03-0063
\02-07-200
D2-08-243
U<P-2DD2-12431
LHP-2004-D0031
LHP-2005-00D15
Resictenliall()taI5:siii~e',199~iit(i4'~ ~i(i;~15;Q ',!,!;l;!~\6
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33.C
LOR Low Density ResIdential
MOR Medium .Density Residential
ce' Com~-nerc1al Center
Ne' NeIghborhood Commercial
CI Camplis Industrial
LMI Ught Medium Industrial
HI Heavy Industrial
pas Public Open "Space
G&E Government and Education
NR Natural Resource
AG Agriculture
MU. Mixed Use
~' peaceHealth
March 15,2007
Zone Change Application
Written Explanation of the Proposal
Property Owners:
, PeaceHealth Oregon Region
,770 E, 1'1 th Avenue .
P.O, Box 1479
Eugene, Oregon 97440 1
, I,
Hyland Business Park, LLC (Tax Lot 400)
,
1941-A Laura Street ' .
Springfield, OR 97477 I
, Attn: Shaun Hyland
(541) 726-8081
i'
,
Applicant:
I
Andrew Head (Tax Lot 402)
1616 Ardendale Ln,
Eugene, OR 97405,.
(541) 521-3403
Applicant's
, Representative:
Philip Farrington, i\ICP
Director, Land Use PlaMing &. Development
peaceHealth Oregon Re~ion
123 International Way
, Springfield, Oregon 97477
(541) 686-3828' Fax (Ml) 335-2595
pfarrington@peacehealth,org ,
1.0 'Land Use Request
PeaceHealth Oregon Region (the "Applicant") requests approval to change the zoning
classification on the City's zoning map from Lig.l-Jt Medium Industrial ("LMI") to
Corru-r\unity Comnlercial ("CC") for approximately 5'.24 acres identified as Tax Lots 400
and 402 on Assessor's Map No, 17-02-32-00, This s~me 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)(a)I,
5-82
Zone Change:.Application
PeaceHealth :Oregon Region
,March 15, 2007
Page 2
The area subject to the proposed rezoning:is mapped on Attachment A, and is referred to
collectively in this application as the "s~bjectproperties" or "site,"
, 2,0 Pr"oject Purpose
The Applicant seeks to rezone (and tlu:,ough concurrent application, redesignate) the
subject properties to CC so they may ~,e 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 ~e allowed to continue long-standing commercial
operations (i,e" Tax Lot 402), Approval of this land use request would preserve
employment and existing viable commercial operations on Tax Lot 402, and create stable
family-wage employment'opportunities on Tax Lot 400 - a vacant and underused
industrial site, The proposal would also help beautif,;,this portion of Main Street from its
. ~ .
, traditional industrial yard uses, and future development would provide a superior buffer
for residential uses to the west than currently exists,
.
As described in later sections of this narrative the proposal is consistent with East Main
Refiriement 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 amendme.nt (an4 automatic EMRP diagram amendment) - complies
with EMRP Policy 2: "Apply site-specific Commercial refmement plan designations to
clearly define the limits of new commercial uses where there i"s not an existing, legally
~. .
established, and beneficial mixing of uses." (pg, 12) The proposal to allow for a broader, ,
more beneficial range of commercial and employment-generating uses on the subject
properties. It ,vould also improve the area and better distinguish and buffer adjacent
residential and industrial business p,)rk uses.' '
3,0 Site Context
The subject prope'ties include a currently vacant, fiat parcel (Tax Lot 400) and existing
commercial development (Tax Lot 402) east of 44'h Street along Main Street in east ,
,Springfield, The site is bordered on the south by Main Street, on the e:lSt by the Hyland
Business Park, on the north by an open area south'of the Weyerhaeuser mill site (Tax Lot
400) or an existing commercially zoned'parcel (Tax Lot 402), and on the west by other
small-scale commercial enterprises(e,g" a cabinet shop and karate school) fronting Main
Street and residential homes alongf4'h Street west of Tax Lot 400. Commercial
enterprises are located immediately south of the site across Main Street (e.g" Gray's
Garden C,:nter),
While historic~ily invoived in agri~ulturai uses, since around 1990 Tax Lot400 was used
as a storage and sales yard for landscape organics and forest by-products. The current
property owners :!Iso used the site .to store modular construction offices, tool trailers, ,
construction equipment and concr~teform plywood, Tax Lot 402 has had various
commercial services on site since the 1950s.
I
5-83
Page J
Zone Change-t-pplication
Pe,ceHe,lth Oregon Region
March 1\ 3007
The properties have no jurisdictional wetlands or inventoried Goal 5 natural or historic
resources, The site is within the Springfield Urban Gro\vth Boundary, and both parcels
were annexed into the City of Springfiel~ in 1960, 'The EMRP diagram (adopted in
1988) currently designates the subject property for industrial uses, ,
The abutting property to the east is designated LightlMedium Industrial in the EMRP
,diagram and zoned LM!. 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 Community Commercial.Prop~rty to the west of Tax Lot 400 along 44'h Street is
. zoned and designated Medium Density Residential. '
4.0 Applicable Approval Criteria
Zone change proposals are evaluated according to the criteria of approval contained
withinSDC 12,030 (3), which requires: ' '
1, Consistency with applicable Metro Plan policies and the Plan
, Diagram;
2. Consistency with applicable Refinement Plans, Plan District maps,
Conceptual Development Plans and functional plans; and
I
,
3, That the property is p'rovided with adequatelPubliC facilities, services
and transportation networks to support the use, or will be provided
, concurrent with property developmenL i ' "
Legislative zone m2.p amendments are also required to show that they meet the
. .,.1
criteria for Plan amendments outlined in SDC .A.rtic\e 7i; and that it complies with
. ,I .-
the state Transport.ation Planning Rule (OAR 660~012-,o060), where applicable,
Findings demonstrating consistency with the approval crit.eria 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 not discuss those portions 'of the Metro Plan that: (1) apply only
to rural or other lands outside of the urban growth boundary, (2) apply to land uses other
than the current or proposed designations for the'site and willnot be affected by the
proposed Plan diagram and text amendments, or (3) c\~ariy apply only to specific
development applications (e,g" site plan review submittals or subdivisions), In many,. '
instances the goals, policies and implementation meastues apply to specific development
proposals that will be addressed through compliance .j,.ith applicable City regulations
, during site plan review of a given future development./proposaL
Ex.cept for the Growth Man~gement Goals, which are addressed below, each of the Metro
Plan policies are addressed in the order in which they appear in the plan Element section
of the Metro Plan,
5-84
Page 4
Zone Change~Ap.plicatlon
PeaceHealth Bregan Region
Morcn 1\ ?007
4.1.1 Metro Plan Elements
1. Growth Management
Policies
], The urban growth boundary and sequential development shall
, continue to be implemented as an essential means to achieve
compact urban growth. Provision of all urban services shall be
concentrated iilside the w:ban growth boundary,
The proposal satisfies this poli9 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 level of services is available to serve future development.
2, Residential Land .use al\,d Housing Element
Policies
A,Jl Generally locate higher density residential development near
employment or commerciai'services, in proximity to major '
t,'ansportation systems or ,within transportation-eJficient nodes,
The proposed redesig'nation does nO,t affect the inventory or availability of residentially
designated or zoned land, including the single-family residential area abutting Tax Lot
400 that is zoned and designated for Medium Density Residential, or higher density
residential developm::nts located east of the site along.tvlain Street. ' .
However, approval of tli'e requested redesignation to Community Commercial would
allow for residential areas proximate to the subject area to have close and efficient access
to existing commercial services. on}ax Lot 402 and to future medical facilities proposed
for 1ax Lot '400, consistent with the above policy" The areas proposed for redesignation
offer existing and future employm~nt opportunities and provide commercial services
along a major tf:Lnsportation system that can support the needs of nearby residential
development.
A,22 Expand opportuniri~sJor a mix oJ uses in newly developing areas
and existing neighborhoods through local coning and development
regulatio/1s.
The Froposed map amendment a~d zone change will allow for existing commerci~!'uses
on Tax Lot 402 to continue to serve existing neighborhoods in the mid- and east-
Springfield are~, and for fclture ciinical facilities to b"e developed to serve this rapidly
growing area of the community', i Approving the request would expand commercial
opportunities to serle these neighborhoods consistent with the above poticy,
5-85
Page 5
Zone Change ~pplication
PeoceHeolth Oregon'Region
March 15 7001
3. Economic Element
policies
B,l Demonstrate a positive interest in existing and new industries,
especially those providing above-above wage and salary levels, and
increased variety ofjob opportunities, a rise in the standard of living,
and utilization of our existing comparative advantage in the level of
education and skill of the resident labor force.
, The proposal is consistent with this policy because it will allow medical clinic uses to be
develop~d 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 and zone change will enable '
increased job opportunities .with higher than average wages thereby raising the standard
of living and meeting the needs of Springfield citizens, ,consistent with the above policy,
. B.2 Encourage economic development which utilizes local and imported
capital, entrepreneurial skills, and the resident labor force. , '
, ;
,
,The construction of and the use of commercial and medical uses will utilize both local
and imported capital and will employ the local labor fqrce in a variety of skilled,
semi-skilled, and unskilled positions, consistent withtris policy: '
I '
B,6 IlIcrease the amount of undeveloped lanq zoned for ligirt industry
and commerciul /lses correlating the effectivelsupply in terms of
, suitability alld availability with the projections ofde11lalld, '
, 'I' '
, '
. ..'
, '
The proposal will add approximately 5,24 acres ofCommun~ty Commercial land, "
consistent with rec'ommendations to increase the corn.inerciallands'inventory made in th'e
, ' .
Springfield Commercial Lands Study, The SCLS and acknowledged metropolitan
, .'
Industrial LandsSiudy concluded that there is a deficil'of needed commercial land, and a
surplus of industriall v zoned alld 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 consistent with the above policy' The proposal
correlates the need, suitability, and a'lailabillty of the subject site for commercial uses
with the need for such uses as demonstrated in the adopted SCLS,
i
B.II Encourage economic activities which strengthen the metropolitan
area's position as a regional distrib'l1ion, trdde, health, and service
,
cellter.
I
The amendment will facilitate the cieve\opment of medical uses that will serve the need.s
of the growing resiciential 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, t
5-86
Page 6
Zone C'hange Application
PeaceHealth Oregon Region
March 1\ J00'
6, Environmental Design'Elerrient
policies
E,] In order to'promote the gr~atest possible degree of diversity, a broad
variety of commercial, residential, and recreational land uses shall be'
encouraged when consistent with other planning policies.
Approval of the proposed map amendn'ients will add just over 5 acres into the City's
inventory of commercially designated ~nd zoned land, thereby allowing for a variety of'
needed commercial uses to occur on thOe subject property, Long-standing existing
, commercial services on Tax Lot 402 would be allowed to continue' without the. specter of
being considered non"conforrning uses, and Tax Lot 400 could be developed with
medical services that will serve the ne~ds of the growing residential areas east and south
of the subject site, consistent with the above policy, '
7, Transportation Element
,.
'Land Use policies, ' ';
, '
F.3 Provide for transit-sllpportive land use pat/ems and development,
including higher intensity, transit-oriented development along major
transit corridors and near tra'nsit stations; medium- and high-density
residential development within one~quarter mile 'of transit stations,
major (raMit corridors, employment centers, and dowlltown areas; and
development and redevelop"lent in desigllated areas that are or could be
well served by e.~isting or planned transiL
"
The proposal will enable lahduse 'patte~s and development consistent with the above
policy. Approval of the requeste'd zone change (and concurrent redesignation) will allow
for hig.her intensity development along Main Street, a major transit corridor. An existing
L TO stop is located on the frontage 'pfTax Lot 400 (see photo, pg. 2, Appendix A of the
TlA), 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 faciiities projected
on Tax Lot 400," '
Transportation System Improvements:. Roadways policies
F.15 IHotor vehicle level of service policy:
a, Use motor vehicle lev'e! of service standards to maintain acceptable
alld reliable perfonrta/lce on the roadway system. These standards
shall be used for: '
(1) Identifvillg capariey dejiciencies on the roadway system,
(2) Evaluaring rhe impacts Ort roadways of amendmel!ts to
transpvrrarionp(ans, acknowledged comprehensive plalls and
5-87
Zone Change._App'\ic:1tion
PeaceHealth Oregon Region
March '5 ZQQ7
land-use regulations, pursua!'t to the TFR (OAR 660-012-
006~, ",'
(3) Evaliwting development applications for c'onsistency withthe
lane/-use regulations of the applicable local government
jurisdiction.
b. Acceptable and reliable performance is defined by the following
levels of service I/nder peak hour traffic conditions: LOS E within
Eugene's Central Area Transportation St'udy (CA TS) area, alld
LOS D elsewhere, !
,
i
c. Pelforrnallce standardsfrom the OHP ;;}(all be applied on state
facilities in the Eugene-Springfield metropolita!l area. '
,I ' '
In some cases, the level of service may be substandard. The local
govemmentjl/risdiction may fwd that transpo~taiion system '
improvements to bring performance up to stan1dard within the planning
horizon may not be feasible, and safety wiil nol( be compromised, and
- ~ I '
, broader community goals >vol/ld be better servrd by,allowing a, '
substandard level of service. The limitation oil the feasibility of a '
I
transportation system improvement may arise from severe constraints,
incll/ding but not,limited to environmental cohditio;,s, lack of public
agency financial resources, or land use collst;'aimfactors, It is not the
intent ofTS! Raodway Policy #2: i'dotor Vehicle Level of Service co
re'll/ire deferral of development ill such cas~s,1 The intellt is to defer
. I"
motor vehicle capacity increasing t/'allsportiltion' improvements ""til
,existillg collstraints call be overcome or d~'vel~i'tlll alternative mLt of
strategies (sl/ch as: land use meilSl/res, TDi'vJ, short-term safety'
improvemeJltS) /I} address the problem:
page 7
Subsection a,(2) in the above policy requires an evaluJ.tion of the p'roposal pursuant \0 the
state Transportation Planning Rule (TPR), The accompanyingTraffic impact Analysis
provides the factual basis to determine that the proposed redesignation would not result in
a "significJ.nt effect" J.S defll1ed under the TPR (OAR:660-012-0060(1)),
SpecificJ.l\y, 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 classtflcation system of roadways, as identified in the Regional Transportiltion
Plan, As demonstrated in the TIA, ~le proposal also ~oes not: '
,
R I I c c~ I,." h h " ' ,
. ' esu t in types or leve s Oc tracne or access th3.t are inconSistent Wlt. t e runctiona!'
classiftcation of Main Street or any other nearby !oadway;
. Reduce performance of trat'fic on Main Street or other affected intersections to a level
thiltis below acceptable established performance'standards; or .
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PeaceHealth Gregon Region
March 15 2007
. M~ke,performance of existing f~cilities worse (l.e., below ~cceptable mobility
standards) than would be the case other uses permitted under existing designations or
zoning.
, , '
Additional TPR findings are fiJrther located in the TLA.., see pp, 31-32. Because the
proposal does not result in a "significant effect" as established by applicable OARs, no
further TPR analysis is required. The request is therefore consistent with the above
policy.
8, Public Facilities and Service Element
Policies
G.1 Extend the minimum level andfull r~nge of key urban
facilities and services in an,orderly and efficient manner consistent
with the growth management policies in Chapter II-B; relevant
policies in this chapter an~,other j'detro Plan policies. '
"
The subject property is located in Springfield's city limits UGB. All necessary ,
infr~structure and key urban facilitie~/services are present to serve existing development
(Tax Lot 402) or are ~vailable to serve future infill development on Tax Lot 400.
Therefore, the proposal is consistent with the above policy,
, ,. .
9, Parks and Recreation Facilities Element policies
Policies in this element of the Metro'iPlan are not relevant to the requested zone change.
10, Historic Preservation Element policies
Policies in this element ofthelvletrq, Plan are not'relev~nt to the request'ed zone change.
11. 'Ener"y Element policies
" '
Policies in this element of the Metro Plan are not relevant to the requested zone change.
'j I
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,
4,2 Consistency with East Main Refinement Plan
The following demonstrates how the proposal is consis~ent with applicable policies in the
East Main Refinement Plan (EMRP). i
1, Mixed~UseElement
Policy 2) Area #~
I
,4), ,~~~i~~:oWil1g land uses are allowed ttndel Community Commercial
_ All Communitv Commercial uses subject to Article 18 of the
, Springfield Developme/1t Code,,! ' '
.\
The proposal requests rezoning the subject properties from LMI to Community
Commercial (and concurrently redesignating the prope'rties to CC),'as the above'policy
and other EtvlRP policies allow.' Approval of the requbt would allovilong-standing
ex.isting commercial uses on Tax Lot 402 to continue as permitted under Article 18, and
consistent with neighboring uses to the west and soud, which are also zoned and
designated 'for commercial uses, ' . '
2,
Commercial Element
Criteria ror Commercial Refinement Plan De!ii!!l1atio/1.
, I',
1, Ge/1erally, the Community Commer,cial rkfl;,eme/1tpla/1 designation
shall be applied u/1der the jollowingcircl,\nlSla/1Ces: " .. . ,
, . ,,', I'" ' ,"
A) where it is not an intnlsion into' ,~eLl_;naintained residential
neighborhoods; , I
The area proposed for reloning does not intrude iht6the e;<.isting residential area
west of the subject site along 44'" Street, and is therefore' consistent with the
above criterion.
,(.
I
B) where it does 110t increase confliCt bel1Veen Low Dwsity
ResidelHialand Commercial;
":!
AlthouiL1\ the abuttin~ residential area is zoned Medi1um Density Residential, it is
developed in low-de;'sity residential uses. Approval of the proposed rezoning or
the subject sites would actually result in a decreClse 6f conflicts between Clbutting
residentiClI and p,on-residential land uses by allowing future inftll development on
TClx Lot 400, and throlJgh the site plan review process establishing improved
landscClped buffers and a use more compiltible than the industri,al uses tJ1.Clt
historicCllly abutting this residentiClI area,
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Zone Change Application
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March 15,1,007
:
(::) where criteria for drsignating iYIedium Density Residential
land does/lot apply;
Criteria for designating MDR land does notapply to the subject site. ,
, '
,Tax Lot 402 has ex.isting, long-standing c6mniercial uses that were legally created
prior to development of the Metro Plan or EMRP, Tax Lot 400 has had a variety
of commercial services located on-site over the years,
D) where legally created coplmercialuses ~xist;
E)
where adequate CL)stomer and ser;:ice access to an arterial
street can be provided; ", and'
I
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,
,
!
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The subject site has adequate legal ascess onto Main Street, which is classified as
an arterial street,
F) where designated' Commercial on the lvIetro Plan Diagram,
Approval of the concurrently submitted Plan diagram amendment application
would result in a Commercial designation 'on the Metro Plan diagram, which
would also automatically modify the designation on the EMRP diagram.
Po/icy 2) Apply siie-specijic Com,!.erc;al refl/lemwt pill" designations,
to clearly defin~ the limits of new commercial uses where there is not an
existing, legally established; and beneficial mixing of uses,
Approval of the concurrently requested redesignation would, apply Corrunercial plan
designations to the subject properties, allowing the e;,isting, legally established
commercial uses on Tax Lot 402 to"continue, It would also enable commercial \lses to be
established on Tax Lol400, thereby defining the limits of new commercial uses between
the pre-existing commercial uses on Tax Lot 402 and others to the west, and the
developed industrial business p:J.rK to the east. Tax Lot 400 does not have an existing or
beneficial mix of uses, but hClS historically housed industrial yard-type operations,
Therefore, approval of the proposal would define the limits of new commerci:J.1 uses as
called for in the above policy, and 'also provide the ability to make superior buffering and
other improvements associated wiih furure develooment on Tax Lot 400 through the site
I' -
plan review process. ' "
Policy 3) Reduce the IJlIlliber of vehicular acceSS points a/1d, require the
rebuilding of curbs and installation of sidewalks llnd street trees along
fHai" Street, through the Site Plan Review process and ;/1 pl/blie
improvement projects,
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~[urch 15 2007
,
t
, The proposal would result in reducing the number of existing access points as required
above, Through the Site PlanReview process, future development on Tax Lot 400 will
, have a single driveway accesS onto Main Street, eliminating one of the two existing curb
cuts on this site, Sidewalks and street.trees are already located along its Main Street
frontage, consistent with the above policy.
Policy 4) Provide buffering between commercial and residentialllses
through Article 31 of the Springfield Development Code, Sire Plan
Review process,
Existing residential uses al~ng the east side of 44th Street have had no real buffer from'
pre-existing industrial uses on Tax Lot 400. Approval of the proposal would,allow for
attractive in fill 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 whh the above policy.
3. Industrial Element
Policy 1) T/Ie City shall encourage efforts of various agencies to attract
new and retail1 e.-cisting jobs and businesses. I '
'I
The City shall muintail1 a current il1ventoryoJvacal11 co~I'/11ercia[and
indllstrialland and strIlctures within the Ea~:i Mai" area,'
, " ' [ , ',' '" .
Consistent with the above policy, approval of the ~eq,\ested,~one change and
redesignution will enable existing, long-st~ndingjobsland businesses'on Tax Lot 402 to
remain as legal, conforming land uses, and allow fututE: development of new employment
on Tax Lot 400 with higher than average wages and employment densities than the
current designation and zoning allows. "
I/11olementatiol1
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-- - - -_.- -."
4.3 'Provision of Adequate Public Facilities
'The subject properties were annexed into the Springfield corporate limits in 1960, and
'therefore are provided with City police, fire, and other government services, Other basic,
infrastructure is in place to'serve existing development on Tax Lot 402 and any future
development on Tax Lot 400: Specifically, sanitary sewer, storm water, and water lines
are all located along the site's Main Street frontage':' all of which are adequate to serve
the needs of existing andlor future dev'elopment on the subject site, Transportation
servic,es are also readily available to serve existing and future development, cis Main
Street is fully imp~oved with curb, gutter, 'etc~ '
, '
As indicated in the Traffic Impact Analysis accompanying the concurrently submitted
zone change and Metro Plan diagram amendment, approval of the proposal woUld not
result in a "significant effect" to the ttansportation system, and therefore is consistent
with the state Transportation 'P lanning Rule, The TIA further demonstrates that existing
and future development under the proposed zo'ne change has safe and efficient access and
circulation for vehicles, and also wilFbenefit from the sidewalks, bike lanes, and transit
service existing on Main Street.
Therefore, the proposed zone change complies with the requirement for having adequate
public facilities and services to serve: development, as established in SDC 12,030 (3), .
4.4 Consistency with Approval Criteria in'SDC Article 7
The proposed zone change is submitted concurrently with an application to amend the
, Metro Plan diagram. The followin::i findings are contained in the Plan diagram
amendment application, and algi) demonstrate that this proposal complies with Metro
Pion policies as requiredinSDC 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 Melro
Plan Transportation Elementpolicies address consistency with the state TPR, as called
for in SDC 12,030.
It should also be noted that approval ofa Metro Plari diagram amendment also
correspondingly changes the appli~able refmement plan (East Main Refmemenl Plan)
diagram, as established in SDC 7,1,[0 (4).
Goal 1 - Citizen Involvement
Goal! addresses the Deed to develop a citizen involvement program to ensure,citizen,
involvement in all phases of the,lahd use plarU1i..g process, The Planning Commission
arid the City Council will hold public hear\rlgs and accept testimorlY on the proposal.
Through the procedures established by the city, citizens will receive rlotice ofhearirlgs in
generally published local papers ar,d have the opport1.mity to be heard regarding the
proposed dia!rram amendment and zone change, Notice of the publlc hearings will also
_ 1 -
be given in accordance with SDCrequirements to nearby property owners, interested
parties requesling notice, and any established neighborhood organization. Since the
process compiles with the City's citizen involvement program and citizens have
. ' .
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March 15 20r7
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Page 13.
opportunities to be involved in the procedure, the proposed plan and zone map
"
amendments are consistent with Goal 1, ' " , .'
Goal 2 - Land Use Planning
Goal 2 requires that local comprehensive plans be consistent with the Goals, that local
comprehensive plans be internally consistent, and that implementing ordinances be,
consistent with acknowledged comprehensive plans. Goal 2 also requires that land use
decisions be coordinated with affected jurisdictions and that they be supported by an
adequate factual base, As required in SDC 7,050, the City is required to give referral
. notice of the proposed Type II Metro Plan diagram amendment to the City of Eugene and
Lane County so they may determine if there 'are grounds to participate as parties to the
hearing, The City also sends the statutorily required nojice of the initial public hearing
, 45 days iri advance to the state Department of Land, Conservation and Developmen't,
ensuring that they are given opportunity for comment ~d review cot:lfoimity to '
,applicable statewide planning goals, ' "
j
The Metro Plan and the SDC, as well as the Statewide Planning Goals and applicabl~
, statutes, provide policies and criteria for the evaluation!of comprehensive plan
amendment and zone change proposals. Compliance ~ith these measures assures an
adequate factual base for approval of the proposals, A~ discussed elsewhere in this
document, the Plan diagram and zone map amendments are consistent with the Metro
'Plan and the Goals, Consequently" by demonstrating s~ch compliance, the proposal
satisfies the consistency element of Goal 2, ' ' ' ,," '
Goal 3 - Aaricultural Lands
, ~
This goal is inapplicable because as provided in OAR 660-] 5-900(3), Goal 3 applies only
to rural agricultural lands. The subject properties are 16cated withiil an acknowledged ,
urban growth boundary, are inside Springfield's corporate limits, and have riot been in
agricultural use for decades, '
Goal 4 - Forest Lands '
Goal 4 does not apply within urban growth boundaries', per OAR 660-06-0020, and the
areas affecled by the Plan amendments are inside SpringfIeld's acknowledged UGB,
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GoalS -Natural Resources .
Goal 5 requires local govermnenls to protect a variety 'of open space, scenic, historic, and
natural resource values, Goal Sand its implementing rule, OAR Ch, 660, Division 16,
require pLmning jurisdictions, at acknowledgment and as a p~rt of periodic review, to
(3)
identify confEcting uses;
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(1)
ldentify such resources;
(2)
determine their quality, qmntity, and location;
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:zone Change .!-pplication
PeaceHealth Oregon Region
Marcc 1 \ 7007
(4)
examine the economic, social, environmental, and ,energy
(ESEE) consequenceS that ,could result from allowing,
limiting, or prohibiting the conflicting uses; and
(S)
develop pro grains to resolve the conflicts.
The subject properties are not on Springfield:s acknowledged Metro Plan Go~IS
inventory, No threatened or endangered species have been inventoried on the site, and n~
archeological or significant historical !nventoried resources are located on the site, The
National Wetland Inventory and Springfield Local Wetland Inventory maps have been
, consulted and there are no jurisdictional wetlands located on the site, Therefore, the
proposal does not alter the City's compliance with GoalS.
Goal 6, -Ail', Water, and Land Resources Quality
The putp()se of Goal 6 is to m~intain'and improve the quality of th~ air, water and land
resources of the state, Generally, Go~l 6 requires that development comply with
applicable state andfederal air and water quality standards. In the context of the
proposed Metro plan diagram amendment and zone change, Goal 6 requires that the
applicant demonstrate that it is reasopable to expect that applicable state and federal
environmental quality standards can be met.
Though Tax Lot 400 has been used for low-value storage and quasi-industrial uses, the
site is not listed on any state or local.ienvironmental clean-up list. A Phase I
environmental ~ssessment on the subject property was conducted and recommended
additional an~lysis. Upon recommendations through the Phase 2 environmental
assessment a nominal 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 reasonable to conclude that future development on the
site will be able to demonstrate compliance with City standards for water quality
protection through the sitepl~nrevi~w process, thereby complying with applicable state
and federal environmental quality standards.
Goal i-Areas Subj'ect to Natural Hazards
Goa! 7 requires that development subject to damage from natural hazards and disasters be
planned and/or constructed with appropriate safeguards and mitigation. The goal also
requires that plans be based on an inventory of k.P.own areas of natura! disaster and
hazards, such as areas prone to lanqslides, flooding, etc.
The site is flat ~nd not subject to landslide hazards, and is located well outside of any
established FEMA nood h~zard area, Therefore, approval of the propos~l will not alter
the City's :lck,nowledged compliance with Goal i through its adopted plans, codes and
procedures,
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.Zone Change.~pplication
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March J 5,2007
Page 15
Goal8 - Recreational Needs '
Goal 8 requires local governments to plan and provide for the siting of necessary
recreational facilities to "satisfy the recreational needs of the citizens of the state and"
visitors," and where appropriate, provide for the siting of recreational facilities i~cluding
destination resorts, The subject site is not included in an inventory of recreational sites, ,
and the proposal will not have an impact on the community's recreational facilities or
needs; therefore, the proposal does not implicate Goal 8,
Goal 9 - Economic Development
. Goal 9 requires the city to,provide adequate,opportunities for a variety of economic
activities vital to, the health, welfare, and prosperity of the citizens, The proposed'
amendment to the Metro Plan diagram will increase the. city's capacity for economic
development by adding 5 acres ofCC designated/zoned land in place of the existing
industrial designation and zoning, Permitting the constrUction of future clinic facilities
on Ta;\: Lot 400 and allowing long-standing commercial uses on TatLot 402 to contiriue
and become confonning uses consistent with commerci'il zoning through approval of the
proposed Plan diagram amendment and zone change is consistent with numerous policies
in the City's adopted plan for compliance with Goal 9, the Springfield Commercial Lands
Study (SCLS), .. ' I
,
Specifically, the following SCLS policies are applicable to the proposal:
Policy I-A: "Maintain a mixed supply oflarge Ld small commercial sites '
through strategies such as rezoning or annexatio'n to serve Springfield's "
future population," '
The proposal fulfills this policy objective by rezoning (and redesignating) land from'
industri,,1 to commercial use, for two tax lots of varying sizes and commercial uses,
thereby maintaining existing employment and commer~ial use inTaxLot 402 and
providing the ability for grO\vth in medical sector employment by allowing future clinic
uses on Tax Lot 400.
Policy.l-C: "Maintain at least a five-year supply of cornmercialland
within the Urban Growth Boundary (UGB) that is currently served or
readily serviceable with a full range of urban public facilities and
services,"
The SCLS (see Table 3-8, pg. 32) found there to be a deficit of 158 acres in the supply of
commercial land over demand projected through the year 20iS, The proposal would
allow for redesignution and rezoning of five acres therkby reducing the deficit of
cOrrLo'TIercialland. The subject site has a fill! range of ~rban public facilities and seriices ,
available to suppor: existing commercial development on Tax Lot 402, and future
development on Tax Lot 400. The SCLS identifies (pg, 33) a need to suppor:
"emplOyment in popul:ltion-dependent sectors such as retail sales and health ser/ices" to
meet Springfleld's growing community, The SCLS aiso noted (pp, 27-29) stale and local
5-96
Zone 'Change. Appllcation
PeaceHeaith'.Oregon Region
M~rch 1.]" 2007
Page 16
trends in greater employment in retail trade and well-paying health' services sectors,
Approving the proposed redesignation' and zone change would help meet Springfield's
demonstrated need for employment andcommercial services. '
Finding 3 in the SCLS (pg. 36) cited the acknowledged 1992 Industrial Land Study as
demonstrating that "a surplus of industrial sites exists in the Metro Area," Therefore, the
proposed redesignation (and corresponding rezoning) would not result in a deficit of
needed industrially designated and zoned land, but it would help reduce the commercial
lands deficit identified in the SCLS. Therefore, approving the proposal would be
consistent with SLCS Implementation Strategy3-A (1): "Evaluate inventories based on
demonstrated need for the planning p,eriod. Initiate rezoning or redesignation of surplus
land Llses where more appropriate for: commercial, consistent with the Metro Plan." ,
, ' '
~
The proposal in fact consistent with inventories for commercial and industrial lands
adopted by the City Council and ackllowledged by OLCO as being' consistent with Goal
9, Oregon Administrative Rules concerning Goal 9 implementation (OAR 660-009- ,
0010(4)) call for amendments to land use designations "in excess of two acres within an '
existing urban growth boundary from an industrial land use designation to a non,
industrial use designation" to have to address applicable planning requirements - such as
consistency with the Metro Plan and' other local plan policies (i,e., SCLS) or be consistent,
with an economic opportunities analysis. The City can tind that the proposal complies
with relevant local plan policies by converting one form or.employment-generating land
use to another, without negatively iIppacting the supply of buildable lands for either
category of uses, Theproposal enaliles continued use of the existing and long-standing
commercial center to continue to operate and provide employment opportunities, while'
also allowing higher-value employment associated with future development on Tax Lot
400, These types of employment-g'~nerating uses, are among those identified in OAR
660-009-0005(6) as eligible non,industlial employment activities that can justify
approval of the proposed Plan diagram amendment without the need for an economic
opportunities analysis apart from the SCLS, which OLCD acknowledged as fulfilling the'
City's obligations under Goal 9, ' '
, '
Because the requested redesignation and zone change implemepts SeLS policies and
does not result in a deficiency of needed industrial lands, and is 'otherwise demonstrated
to be consistent with relevant Metro Plan policies, approval of the proposal is consistent
with the City's compliance with Goal 9 and applicable administrative rules regarding
, Goal 9 implementation,
Caul 10 - Housing
LCDC's Housing goal requires cities to maintain adequate supplies of buildable lands for
needed housing, based on an ackr10wledged inventory of buildable lands, The proposal
does not affect the City's inventO~y of residential lands,
In fact, approval of the requested redesignation for Tax Lot 400 would enable
redevelopment of an industr.al site abumng exisur..g residential development. Throug.fJ'
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PeaceHt:alth Oregon Region
March 1 i 2007
the site plan review process, future development on that property can provide a superior
buffer and a higher use that will benefit the adjoining residential properties. Because the
proposal does not involve directly any change in the amount of residentially designated
or zoned land, it does not affect Springfield's continued compliance with Goal 10.
Goalll- Public Facilities and Services
This goal requires the provision of a timely, orderly and efficient arrangement of public
facilities and services. The subject property is located within the Springfield UGB and
city llmits, 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 commercial uses on the subJ~ct site,
Goall2 - Transportation ' '
Goall2 requires local governments to provide and encourage a safe; convenient and
economical transportation system, The proposed map amendments and zone change
involve approximately 5,24 acres of property, though hi sting and long-standing ,
commercial uses occur on Ta:~ Lot 402 such that approval of the proposal will not'result
in any changes to the type or intensity of uses on the site, a~d will not increase the trip
generation for that fully developed parcel. As the attached Traffic Impact Analysis (TIA)
demonstrates, future development of medical office f~cilities on TL 400 will not degrade
mobility standards below acceptable levels and allow for adequate queuing lengths at
applicable intersections, Therefore, the proposal will hot have a "sigilificanl effed" on
transportation facilities as defined in the Transportation Planning Rule (0,6$ 660-012-
060). i"
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Existing development at Tax Lot 402 is not affected b1y the proposal, andi~,assumed to
'.. retain its current ~ccess points off Main Street. It is further assumed that fu'ture '
development on Tax Lot 400 will result in some access changes as will be reviewed
" '
through the site plan review process, thereby consolidating twO existing curb cuts located
on Tax Lot 400 into a single access point located ap'proximate\y in the center of the
,parcel. The TIA demonstr;)tes that these access points will not result in any degradation
of mobility standards below acceptable levels, and that safe and effIcient circulation can
be realized throug.h approval 0 f the requested land use redesignation' and zone change,
I ,',
Furthermore, reducing the number of access pOlnts fJr future development on Tax Lot
400 is consistent with policy objectives found in East Main Retlnement Plan (EMRP)
Access, Circulation & Parking Element policy I B (p~, (7) and Commercial Element
policy 3 (pg, 12). I
Be~~!Use the proposal, as demoi\strated in the TiA, is!consistent with the requirements of
the TPR and with applicable policies in the HARP, i~ is consistent with Goal 12 and
applicable local implementing. pohcies,
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Goall3 - Energy ConseF'ation .
The Energy goal is a general planning goal and provides limited guidance for
site-specific map amendments. The proposal has no direct impact on energy
conservation, though it \YouI'd in fact will promote greater energy efficiency by enabling
needed clinical services available to growing residential areas in east Springfield.
Therefore, the proposal is consistent with, and does not alter the City's continued
compliance with Goal 13.
Goal 14 - U rbanaa tion
Goal 14 requires local jurisdictions to .provide for an "orderly and efficient transition
'. from rural to urbanland use." The su~ject property is \Yithin the UGB and the city limits
of Springfield, and within an existing 'urbanized area of the community. Therefore, Goal
14 is not applicable to this application; . ..'
Goal 15 _ Willamette River Greenway
This goal is inapplicable because the subject property is not within the boundaries of the'
Willamette River Greenway.'
Goals 16-19 - Coastal Goals
The coastal goals are not applicable to this application.
5-99
. SPRINOFIE1-.D
Staff Response to written comments to Applications
ZON 2007-00012 / LRP2007-00013
EXECUTIVE SUMMARY:.
Staff received one written testimony from Lauri Segel, Goal One Coalition Planner, on
June 12th, 2007. A \Yritten rebuttal to Ms. Segel's letter was then submitted by the
applicant the following day, June 13th, 2007. Both letters were received within'the
specified deadlines as noted in the Planning Commission public hearing on Ju'ne 5'\
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
revie\Y by the Planning Commission. Copies of the t]Vo letters in their entirety are'
attached for reference and review in addition to the excerpts and Staff responses in this
report.
!y[s. Se~el's Submittal - Issue #1.: "Applic~nt Relies heavily on the acknowledged
20M 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'
proposed findings rely on reports and other documents containing inventories,
assumptions, and data that have not been establishedfor the entire Metro UGB
area, bt,t rather only for the Springfield portion of the UGB area... " .
Aoolicant's Rebutta~ "The cities of Eugene pitd Springfield have separately
adopted and acknowledged commercia[-/andsistudies fidfilling the requiremenis
of Goal 9. As sllch. the SCLS serves as the City o/Springfield's "most recent
. economic opportunities analysis. " as ivls. Segal notes above by her own
admission... There is no requirement that the 'Applicant or the City perform a
metro-wide analysis oj commercial lands in order to adopt findings satisfying
compliance with Metro Plan policies and Goal 9.., "
ST AFF RES PONSE:. TheSCLS was a Period Review Task required by DLCD and was
approved by said agency as part of Springfield's compliance with Goal 9 during the
Periodic Revie\Y process. As such,'it is a valid document to reference related to this Post
Ackno\Yledgement Plan Amendment (P AP A) proposal. The SCLS was adopted by
Resolution No. 00-13 as the "policy document guiding,the provision of cornmerciallands
within the Springfield Urban Gro\Yth Boundary." The SCLS \Yas revie\ved by OLCO/and
found to be consistent with the Periodic Review Order and Statewide Planning Goals.
Tne SCLS \Yas not adopted as a specific amendmenl to the Metro Plan. The Clty
undertook a supply and demand analysis to determide if there \Yas adequate commercial
land in the adopted inventory to accommodate projehed demand and, based on these
conclusions, ldentify \Yhat the Clry could do to address these conclusions. Chapter 4 of
the SCLS, whlch includes policies and implementation strategies, all recommended
actions are alreaciy in the Metro Plan or TwnsPlan; are a recommendation to amend the
Code; or are suggestions to improve business practices. The ~ity and OLCO concluded
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itwas not necessary to adopt the SCL'S as an amendment to the Metro Plan because all
recommendations regarding inventory adjustments contained in the Study could be
implemented through the PAP A process as increases In the commercial lands inventorv'
"
the SCLS would be used at that lime as part of the findings, reasons and conclusions for
those PAPA actions. .
Bes~ available data was used in the analysis of these applications, which included the
SCLS. There are no comprehensive studies (i.e. commercial lands inventory) available
for the entire UGB related to commercial lands' within one specific time period. Rather,
there is a conglomeration of various studies that are revie\Yed. For example, the 1992
Industrial Lands study is UGB-\Yide:' The Residential Lands Inventory which is .used by
the City is not UGB-wide. Like\Yise, the SCLS is not Metro-wide.
Ms. 0e~el's Submittal- 1ssue #2:. "The ad@pted Springfield Natural Resource
Sllldy (adopted by Ordinance #6150) shows little or no impact on the commercial
lands inventolY from Goal protection measures, and provide, little if any analyses
of land availability within the entire Metro UGB area, ratherthanjust the
Springfield UGB area. The analysis shows an impact of 11.56 acres on
Springfield'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 new commercial land designated / rezoned to commercial in the
Gateway area. "
Aoolicant's Rebuttal~ "Cdnsidering that the SCLS identified a deficit of 158
acres in the supply of comm,ercialland over demand. accounting for this
additional redesignated/rezoned land, this would still result in a deficit of more
ihan 61 acres of needed commercial land. Approving the requested Plan
amendment/zone change w6uld still leave a deficit of approximately 55 acres of
needed commercialland...::Therefore, even considering impacts to commercial'
lands inventohes from other adopted and acknowledged plews (i,e. the City's plan
for Goal 5 compliance) and acknowledged Plan amendments / zone changes,
approval of the proposal ;vill no! reslllt in there being an ex'cess 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 reqllested redesignation / re:':oning."
STAFF RESPONSE:. Tne Spnngfield Narural Resource Smdy (SNRS) is referenced by
the applicant and stJff as related to this PAP A because it provides a more updated vie\Y
of the city's commercial & industrial lands inventory It is not meant to be all inclusive in
and of itself. Reference to the SNRS in conjunction \Yith other referwced documents (l.e.
the SCLS & 1992 Industrial Lands Srudy) is provided' to give the most accurate .
information possible given all the available data at this time.
Again, the applicant's repor. and staff s analysis reference the most recent)y adopted
documents I inventories available. The City currently does not have an ongoing database
5-101
that keeps track of inventories based upon Plan Amendments and/or Zoning Map
Amendments on an ongoing basis.
The applicant's rebuttal references numbers of acres related to the City's deficit of
commercial land. Staff concurs with the applicant's rebuttal related to number of acres of
corrunerciallands. The redesignation and rezoning of up to 99 acres of residential land
within the Gateway MDR site (as referenced by Ms. Segel) still does not negate the
deftcit of commercial land \Yithin Springfield's city limits.
Ms. Se2el'sSubmittal-1ssue #3:. "The applicant. has notjL,stified the
conversion of scarce, shovel ready industrial land, especially land designated a~d
zoned light medium indus/rial inside the Metro UGB, even though the Metro Plan
(comprehensive plan) Economic Element poli9Y #12 establishes that the cities are
/0 'discouragefi,wre Metropolitan Area Gd,eral Plan amendments that would
change d.e~elopmeni ready iridustriallands (sites definedas shor/-/erm in the
metropolitan Industrial Lands Special Study, 1991) to noh-'industrial
designations. ' The applicant and staff findings do not address how the loss of
these5.24 acres impacts the short-term sllpply of LMI 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
shorr-term in the metropolitan Industrial Lari1ds Special Study, 1991). "...casting
doubt on the applicability ofL'vIetro Plan Ecohomic Element Policy 12... Even if
Policy 12 were relevant, it's language is cledrly not prohibitive 10 approval of an
application for redesignation/rezoning of anhndustrial site. particularly when
considering it in the context of industrial co~mercialland inventories. ...even if
all of the acreage redesignated in Springfielq werefrom the LMl-designation-
which is no. doubt not the case - there wOllldlstill be a surplus of nearly 50 acres
oj UvfJ designated land even after approval of the requested Plan amendment.
This does not accoun/ for the J 1.5 acres of Iqnd added 10 the inventory of L},11l
zoned and designated land referenced in my March 28, 2007 supplemental
. information. ... Therefore, the removal of 5.24 acres of LM1 zoned and designated
land will not restdt in a deficit of needed land in that industrial designation.
...Moreover, although Economic Element Policy 12 "discourages" Plan
amendments for cerrain industrial lands. there are countervailing policies in the
i'vletl.o Pian (i.e., Economic Element Policy 6) and SCLS (i.e, policies I-A and I-
e) that are directive to providing an adequate supply of needed commercial
lands..." .
ST AFF RES PONSE: Staff concurs with the appliCant's rebutwl to the issue raised. The
applicant has cited numerous acreage calculations ~ased off of adopted inventories which
support the proposal. As noted by the applicant, th~ subject site \Yas not included among
the sites defilled as short-term In the metropolitan Ihdustrial Lands Special Study, 1991.
As noted in the applicant's rebuttal and as previously noted In this report and the original
Staff Report, a deficit of commercial land and surplus of industrial land \Yill still exist
5--:102
e.ven after an approval of the proposed Plan Amendment and concurrent Zoning Map
Amendment.' .'
Ms. Segel's Submittal- Issue #4:. "The Applicant's analysis oftlieproposals'
. consistency with comprehensive plan Economic Element policies found in the
lv1etropolitan General Plan, Chapter ffJ, B-l - B-7 is insufficient and does not
address the most significant policies that must be considered." .
Aoolicant's Rebuttal:. "...th.ere are countervailing policies in the Metro Plan
(i.e., Economic Element Policy 6) and SCLS (i.e., policies I-A and 1:C) that are
directive to providing an adequate supply of needed commercial lands. The Metro
Plan recognizes.such conflicts: "The respective jurisdictions recognize that,there
are apparent conflicts and iri,consistencies between and among some goals,
objectives, and policies. When maldng decisions based on the Plan, not all the
goals, objectives. and policies can be met to the same degree'in every instance.
Use of the Plan requires a 'balancing' of its various components on a case-by-
case basis, as well as a selection of those goals, objectives, and policies most
pertinent to the issue at hand." (pg: 1-4, Metro Plan) ...The applicant's original
IV/arch 15, 2007 submittal iiIch,dedJindings address'ing relevant Metro Plan
policies (see pg, 5 of the submittal, pg. 4-5 of the Commission's June 4. 2007
. hearing packet). Clearly not all of the 32 Metro Plan Economic Element policies
are relevant to the proposal. Many are aspirational in nature and not directive to
a specific quasi-judicial application...
STAFF RESPONSE:, As noted inithe applicant's rebuttal, policies in the Metro Plan are
sometimes conflicting to one another. As stated on page \-4 of the Metro Plan, "The
respective jurisdictions recognize that there are apparent conflicts and inconsistencies
between and among some goals, Olljectives, and policies. When making decisions based
on the Plan not all the goals, objectives, and policies can be met to the same degree in
,. '
every instance. Use of the Plan requires a 'balancing' of its various components on a .
case-by-case basis, as well as a selection of those goals: objectives, and policies most
. pertinent to the issue athand." Th~ applicant submitted \Yritten statements relative to the
policies \Yhich supported the proposal. As noted in the original Staff Report, Staff
concurred \Yith the applicant's rjUrntive related to the referenced Metro Plan policies
\vhich support the proposal, given the relationship of those Slated Metro Plan policies as
reviewed concurientlv with'the referenced commercial and industrial adopted inventories. .
[Vis. Se~e1's Submittal- l'ssue #5:. "The applicant is not specific about what uses
will be cited sho,,[d the P,;'oposal be approved, and there is nO way 10 know if in
fact above wage jobs and salaries... Ihere is no way 10 esrablish if the appiicarIl
will in fact utili:e local and imporled capiral. skills etc. as no commitmenllo a "se
has been escablished... .. .
Aoolicant's Rebuttal:. ":,..Ms. Segel's assertiol1,1hat the application was
ul1specific as 10 Ihe filwre llses all Tax LOI 400 is inaccurate. The application
narrative clearly swtes ih~ intended .ow.pose a/the redesignacion/re:oning is to
5-103,'
'.
I
allow for afuwre medical clinic on Tax Lot 400 and to allowthe 10ng-standinO'
_ 0
commercial operations on Tax Lot 402 to continue (pg. 2, pg.4-2 in the
Commission's June 4 hearing packet). Such clinical uses are not permitted in any
industrial ;oning district, thus promopting the need to rezone (and Redesignate)-
Tax lot 400 to dllow a medical clinic. Average wages and benefits for medical
workers tends to be high.er than average local wages, andfurther substantiating
data can be entered into the record at the Ciry Council level...
~T AFF Rf.SPONSE: The applicant has noted the intent of the.Plan Amendment and
concurrent zone ch8l)ge is for the eventual development of a medical office building. This
is mentioned not only in the applicant's narrative, but also in the applicant's Trafflc
Impact Arialysis. In fact, the referenced table in the TlA (Table 7, pg. 19) specifically
calculates trip generation for the orol)osed medical office buildim;. Hov.:ever, as noted by
Ms. Segel, there is no certainty as to what the salaries will be, if it will utilize local
capital, etc. With that said, there is no such'assuranc~ for any new )1se that might go on
the property with the exist)ng zoning and Plan desi~ation either> Given the fact that the
applicant is ~ medical service provider (i.e. Peace Health); that they are pursuing these
applications; and that they have: indicated on their aplplication that the purpose of these
applications is to develop a future medical offlce clinic, it is highly likely (in Staff's
opinion) that they will pursue the medical offlce use\as they've specified. As noted in the
. applicant's rebuttal, average wages and benefits for l(ledical workers tends to be higher
than average local wages. Staff concurs with the applicant's rebuttal statement and .
affirms the original Staff Report findings indicating that the proposal is in compliance
with applicable Metro Plan policies. I.
Ms. Se~el's Submittal - Issue #6: "The ap~licant makes the ar~ument ihat the
proposed plan amendment and ;one change would have the effect of correcting
existing non-conforming uses on TL #402. dnap 17-02-32); however. the 2000
SeLe. at Appendix e. "Sites with Plan/Zon/Conjlicts" does not include the
subject properly. It appears that the e:cistini nonconforming llses were actually
established.AFTER adoption of the 2000 SCLS, indicating that the existing uses
were actually permitted by the Cily ,vilh the knowledge that these uses would
create plan/zone conjlicls." !
Annlican't's Rebuttal."The applicanl does Inot allege that there i~ a Plan/zone
conjlict on Tax Lot 402; clearly the existing!Plan designations and ;oning are'
LMJ. Rather. the point made in our application narralive is that commercial llses
have existedfor decades, pre-existing the establishment oj the Metro Plan and the
application a/the LM! designation on the sL\bject properties, .Ms. Segel provides
no evidence to back lip her accusation that t~e GC" wittingly allowed commercial
uses on Tax LOl402 after adoption of the SIILS. The applicant and owner of Tax
Lot 402 will orovide additional evidence anH teslimony at the City Council
hearin" on j"lv 2 which wiiljt,rther demon}tratejra~tllallv thai commercial uses
>:J " I'
and employmenl have been in the building on Tax Lot 402 for nearly jO years... "
5-104
STAFF RESPONSE: The existin~ zohin~ for TL #402 is Lieht Medium Industrial
(LMI). The existine Plan Desi~mitior. for TL #402 is .Li~ht Mediumlndustrial. (LMI).
Therefore, there is no Plan/zone conflict as alleged by Ms. Segel. A non-conforming use
is not the same as a plan/zone conflicr. Ms. Segel alleges that the City permitted the
existing uses onTL #402 "AFTER adoption of the 2000 SCLS..." and further states that
the uses were ":..permitted by the City \Yith the knowledge that these uses would create'
plan/zone conflicts." This allegation has not merit for multiple reasons. Article 5 of the
Springfield Development Code provides provisions to allow existing non-conforming
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 allo\Yed as a "new use"
under the existing zoning, The existing commercial uses on TL #402 are most likely
considered non-conforming uses (i.e'. comrrmcial uses on industrial zoned property). The
2000 SCLS does not list TL #402 asa Plan/Zone conflict because it is not a plan zone
~~~ . .
Ms. Se?el's Submittal - Issue #7: "The proposed change is not 'logical and
,harmonious' because it is no.t consistent with the development pattern envisioned
in the Metro Plan ...Complidnce 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 PAPA and zone change
proposal... Staff has failed to address the impact that this proposal will have on
the dwindling supply of shovel ready industrial land inside the Springfield city
limits, inchlding prior actiohs approving land use code amendments to the
campus induSlrial zone thal;established more 'flexibility 'for what uses are
allowed in the city's campuS industrial zones. ,,'
Aoolicant'sRebuttal: "It shouldfirst be noted that the application does not
involve or in ani way affec~ the 'metro area 's supply of campus industrial land. '
.A/oreover. the application has no effect upon Goal 10 (Housing), and has
elsewhere de;'onstrated compliance wilh Goa'l12 and other applicable statewide
planning goals, A~v guess is that Ms. Segel and Nancy Falk. who appeared at the
June 4 hearing and requested the .wrilien record be lefl open for a week, both
vigorously appose the Plan amendment/zone change proposedfor the iv/arcola
ivIeadows projecl. and are borrowing arguments to also object 10 this modesl
reqilest before the City... The contention that the proposal would not result in a
'logical and harmonious' land use paltern is without substance or basis in fact.
and is nol an approval criterion. As noted above and elsewhere in the record, this
proposal is consislenr with-policies and provisions in the Metro Plan, ils
Economic Element, StlppO/;ting refinement plans (i.e., Ihe SCLS and MILS) to the
1\1etro Plan. and Goc.1 9 and other applicable statewide planning goals... "
STAFF R~SPONSE: Ms. Segel refers to the existing zoning of the subject site as
"Campus Industr,al" multipletim~s in he, letter. The subject property is zoned and
. designated !,.i~ht Medium Industrial, not Camous Industrial.. As noted in the applicant's
rebuttal, the statement submitted by Ms. Segel indicating that the ".. :proposed change is
.5-105
not 'logical and harmonious'..' isnot a criterion of approval for these applications. Staff
have reviewed the proposal based upon the applicable ~riteria of approval, and found that
it meets the criteria (with conditions) as written in the Staff Report. The inventories of
commercial and industrial land have been evaluated add balanced with the relevant Metro
Plan policies to formulate the recommendation for apP,foval with conditions. Specific,
findings related to the Statewide Planning Goals have also been included in the original'
Staff Report.
I
I,
':.1
~-H1R
:-.
GOAL ONE COALITION
@
Goal O~e is Citizen Invo.lvemenc
City of Springfield Planning Commission
David Reesor
City of Springfield
225 Fifth Street
Springfield, OR 97444
June \2,2007
1~?3~~~=-:S~~\l.~: [ji
.WN 1 2 2007
m<-j-;:;'
RE: ZON 2007 -O0012fLRP 2007 -O0013,'Plan Amendment &' Zone Change
Dear Members afthe Commissian:
The Goal One Caalitian (GaalOne) is a nonprofit arganization \Yhose missian is to. provide
assistance and suppart to Oregonians' in matters affecting their communities. Goal One is
partici'pating in these praceedings at the request of and on behalf af its membership residing in
Lane County. This testimany is p~esented on behalf of Gaal One and. its membership,
including Nancy Falk, 2567 Marcola Road, Springfield Oregon 97477, 'as an individual.
Llntroduction
'1
,
This praposal is far a site-specific Metro Pliln Amendment I Refinement Plan .Amendmen\ and
a concurrent Zaning Map Amendment from Light Medium Industrial (UvlI) to Community
COmrrlercial (CC) \Yithin the Springf1(~ld city limits.' '
The subject site is located near 44lf-, ~d Main Street (Highw~y 126). The site consists of two
parcels under separate ownerships, and is located on approximately 5.24 acres identified as .
Tax Lots 400 and 402 on Assessor's Map No. 17-02-32-00. TL 400 (5.0 I ~res) has several
vacant buildings an site, including portable trailer type structures. The smaller of the two
subject lots, TL 402 (.24 acres), has an existLllg commercial developmerrt orr-site, although the
plan designatiorr imd zorre are Uvll.. Properties located to the north (Weyerhauser) are zoned
and designated heavy industrial. Parcels located \Yest of the subject site are designated mixed-
'use on the East Main Refinement Plan. Property located eaSt and adjacent to TL #402 is built
out as a business park, and designat~d LMl. Praperties located sauth oft!-je subject site, across
Main Street, are zarred and desigilUt~d Community Commercial..' .
n. Criteria applicable to the request
Lacal approval c'riteria are found ,in the fallowing documents: Spr.ngfield Development
Code, Metra General Plan, and East p,'lain Refinemerrt. Plan, as indicated in the statf
report.
The proposed plan amerrdmerrt must also be found to be cansistent \Yith applic2ble statewide
planning gaals. ORS 197.175(2)(a). Applicable goals include Goal 1, Citizer Involvement,
Goal 2, Lillld Use Planning; Goal 9, Economy of the Slate; and Goal 12, Transport:ltion. Tne
Eugene office: 642 Chameleon Suite 100 . Eugene OR 974D I' 541--431-7059 ' hx 541-431.7072
leb.non office: 39625 Almen Drive' lebancn OR 97355, 541-252-6074' hx 541-253-6810
W'N'N.gOaJ 1.org
5-107
GOAL ONE COAUTION
proposed plan amendment must also
applicable statewide planning goals.
comply with administrative rules implementina
"
Ill. Analysis
COMPR.cHEN~lVE PLAN CONSISTENCY AND COMPLIANCE WlTH.
STATEWIDE GOAL:i
All compreheflSive plan amendments are' reviewable for compliance with the state\Yide
plaiming goals. Residents of Rosemont v. Metro, 173 Or App 321. CW01); 1000 Friends of
Oregon v. Jackson County, 79 Or App 93, 97, 718 P2d 753 (1986), rev den 30\ Or 445
(1987); Opus Development Corp. v. Cicy of Eugene, 141 Or App 249, 254, 9\8 P2d 116
(1996).
Goal 2 _ Land Use Planning is: "To establish a land use plaiming process and policy
frame\York as a basis for all decisions and actions r~lated to use of land and to assure an
adequate facrual base for decisions and actions." Specifically, local land use actions "shall be .
consistent with the c?mprehensive ~,Ians." ,Go~l 2,lpar: L Furt1:er, the information upon
. which land use declSIOflS are made shall be contamed m the plan document. or supporting
documents." Goal 1, Part L .
In this case, the applicant relies heavily on the acknowledged 2000 Springfield Commercial
Lands Study (SCLS), which does not address the lentire 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 U; the
Economic Element of the Plan. . I
,
The proposed findings rely, on' reports and o~er documents contauunginventories,
assumptioflS, and data that have not been established for the entire Metro UGB area, but rather
only for the Springfield portion of the UGB area. T)lis material includes d<lta used to justify
findings of compliance with goal 9. Any decision relying on such findings would not comply
with Goal 2. I
GoalS
!1,
COrlceming' applicability of land inventories pursuant to Ordinance #6150 that
adopted the Springfield Nafural Resource Srudy.'. staffs position is that inventories
established pursuant to Goal 5 are relevant considerations in considering availability
of cornmercial and industrial land. Ho\Yever, that analysis (applicant's Attachment
, "
"A" _ tables '11-\,11-2 and 11-3) acrually show little or no impact on the commercial
lands inventory from Goal 5 protection measures, :and provide little if any analyses of
land availability within the entire Metro UGB area, rather than just the Springfield
UGB area. Table 1\-2, I\nalysis of Maximum possible Impact on Supply of
Commercial Lands \Yithin the Springfield Urban 'Growth Boundar; shows an impact
of 11.56 acres'on Springfield's (not the urban grbwth boundar; area in it's entirety)
commercial land supply. I ' . '
,
Metro Plan/East Ivlain P.eflnement Plan, ZON 2007 -DOO 12 - LRP 2007 -D0013
5-108
.
.'
2
GOAL ONE COALlTlON
Additionally, the analysis pursuant to ordinance #61S0fails to account for lands ADDED TO'
the commercial inventory sirice 2000,-including but not limited to the Gateway ~!DR site's
100 acres, providing a skewed pictljie of.the actual commercialland'inventoiy.
To skew the picture even further, the analysis of ma;<irmim possible impact from Goal 5
protection measures on supply of indUstrial lands (ordinance #6150, table 11-1) considers
ALL industrial lands within the entire Metro UGB area, rather than just the Springfield portion '
of the UGB, and does not provide a preakdo\Yn of number of industrially zoned acres in
. r.
Sprmgfield vs. Eugene. The 2000 SCLS, however (Table 3-2) shows that the number of light
medium industrial (Uvll) acres by plan designation in the Springfield UGB area is 198.77,
\Yhile the number of Uvll acres within the Eugene UGB is shown to be 1230.78. The.
applicant fails to establish the relevancy of these tables to the current PAP A and zone change
proposal, considering that only about '16% of the Metro area ugb industrial land supply is
within the Springfield city limits.
:.:.:~,.::
Goal 9 _ Economic Development is:, "To provide adequate opportunities throughout the
state for a variety of economic activities vital to the health, welfare, and prosperity of Oregon's
citizens."
The Staff Report's Goal 9 findings ~e based upon the 1992 industrial Land Study andthe
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(?),Part [ Planrllng establishes that city, county, state and federal aaencv
" .. C1"
and special district plans and actions \elated to land use shall be consistent with the
comprehensive plans of cities and counties and regional plans adopted under ORS Chapter
268.' ,
, Goal 9 _ 660-009-00\0 (4) estabtlshes that for a post_ackno\Yledgement plan amendmerrt
under OAR chapter 660, division 18, that changes the plan designation of land in excess
of two acres \Yithin an existing urohn growth boundary from an industrial use desigmition . .
to a non-industrial use designation" or an other employment use designation to any other
use designation, a city or county must address all applicable planrung requirements, and;
(emphasis added)
(a) Demonstrate that the proposeq: amendment is consistent \Yith its most recent economic
opportunities analysis and (emphasis added) the parts of its ackno\Yledged
comprehensive pliln which ilddress the requirements of thjs division;
Tne applicant appears to rely heavily on inventor; and policy statements established by l'le
2000 SCLS in estilblishing that the proposal is consistent with L'le Goa! 9 rule. Ho\Yever, the
applicant's analysis of the proposals' consistency. with comprehensive plan Economic
E!,:rnent policies tound in the Meciopolltci.n Gener:ll Plan, Chapter III, B:l - B-7 is insufficient
and does not :lddress L'le most sigr'~ticant policies th:lt must be considered.
:i
The propos:ll would decrease theCir(s c3..rnpus industri:llland inventor! by yet anoLl-)er 5.24
:lcres. The applicant has not justified the conversion of scarce, shovel ready industrial land,
tvlelro Plan/East tvlain "eflnement Plan. ZON 2007 -~OO 12 - LRP 2007 .(]0013
'. 5-109'
3 ,
GOAL ONE COAUTION
especially land designated and zoned light medium industrial inside the Metro UGB, even
r.'lough Metro Plan (comprehensive plan) Economic Element policy # 12 establishes that the
cities are. to "discotLrage future Metropolitan '!\rea General Plan amendments that would
change developmellt readyindusti'-ial\ands (sites defined as short - term in the metropolitan
Industrial Lands Special Study, 199\) to non-industrial designations." Tne applicant and staff
fmdings do not address how the loss of these 5.24 acres impacts the short-term supply ofLMr'
designated land. . .
'~.,
The applicant makes the argument that the proposed plan amendment and zone change would
have the effect of correcting existing non-conforming uses on TL #402. (map 17-02-32);
however, the 2000 SCLC, at Appendix C, "Sites with Plan/Zone Conflicts" does not include
the subject property. It appears that the existing nonconforming uses \Yere actually established
AFTER adoption of the 2000 SCLS, indicating that tt:e existing uses were actually permitted
by the City with the kno\Y\edge that these uses would create plan/zone conflicts.
. .
In addressing applicability of the SpnngfieldComrh'ercial Lands Study (2000 SCLS), the
applicant appears to try to separate the Metro !\rea Iby jurisdictional boundary. However,
Eugene and Springfield have a shared and adopted UGB, Comprehe'nsive Plan, and Industrial
Lands srudy. The jurisdictionally focused SCLS doesl not analyze supply and demand for the
entire Metro UGB area and cannot be relied upon on ih o\Yn to establish consistency with the
I
.requirements of OAR 660-009-0010 (4),' which establishes that the proposed PAPA be
consistent with both (emphasis added) the mostn~cert economic opportunities analysis (i.e.
the 2000 SCLS) and the comprehensive plan.
A related problem with placing such heavy reliance on the 2000 SCLS to establish Goal 9
compliance is that in analyzing supply and demand, ,the srudy fails to consider or otherwise
account for lands added to the commercial inventory 0a applicant initiated and city approved
zone changes and plan amendments. One very .obvious example of an addition to the '
Springfield commercial lands inventory \Yas the 2003!planarnendment and ZOr1e change (LRP
2003-0013 and ZON 2003-0019) at the 100-acre Ga1teway Medium Density Residential site
, '
. that had the effect of rezorung and redesignating 100:acres of residentmlland to commercial.
The applicant provides a spreadsheet. (their Attachm,ent B) that supposedly accounts for all
Metro Plan diagram changes affecting the supply of residential, commercial and industrial
Lands in the ciry of Springfield between 1991 and thd present, but has failed to account for or .
otherwise address the addition of commercial land t6 the SCLS, even though it is clear that
more than 100 acres of commercial land has been added to the inventory since the year 2000.
,
Tnis omission raises doubt as to the accuracy of applicant's Attachment B in supposedly
accountina for additions to and subtractions from the Various 1:l>'1d inventories.
~ .
Tne aoplicant also relies in p2.ft on inventories established in conjunction \Yith adoption of
Springfield's Natural Resource (NRJ Srudy, by Orainance #6150 on November 23, 2005.
While those inventories may be relevant to this pro~osal in that possible 'lmpacts' resulting
trom GoalS prolectioll me:lSures were c~nsidered fo1 all zorung classificatiOl:,s' ,the analysis of
ma:urnum possible Uilpact on supply ot cOlmnercwllands pursuant to the's'Lluy IS lUillted to
the are3 within the Springfield portion of r.'le l'iletro UGB (table 11-2). Again, because
Eugene and Springfield share a UGB and a comprehensive plan, an analysis of the entire
UGB area is necessary to est3bllsh an accurate picruri: of the supply of com.IT,efcial lands.
ZO~I 2007 -DOO J - LRP 2007-D00 i 3
5-110 I
,
4
Ivlet,o Plan/Easllvlain Refinement Plan,
GOAL ONE'COAUTION
. .
In any case, the NR Study found ~ that the maximum possible impact of Goal 5 protection
measures on the Springfield Commercial Lands Inventory would be the loss of 11.56
'~co(nmercial acres:"
LOSS OF rNDUSTRlA.L LA.!'\[]) ,
The proposed plan amendments and zone changes would remove 5.24 acres of shovel ready
light medium industrial land from the ,Mecro UGB area industrial lands inventory. This is in
addition to an additional 56 acre conversion of campus industrial to community commercial
land less than 2 miles a\Yay \Yhich is currently pending approval by the Springfield city'
council. Tne applicant is vague about;the purpose of the proposed plan amendment and zone
change, noting that, with approval of the plan amendment and zone change, the uses could
include a possible future medical clinic, and the provision of family wage jobs. The applicant
has said nothing about the existence 'of their other IGO acre medical campus located,within
about 5 miles of the subject properties proposed for plan and zone ~hanges. Given this fact,
the applicant has not justified the removal of shovel ready light medium industrial land for
commercial uses. This area within the Springfield city limits is already inundated with
commercial zoning and commercial uses, and approval of this proposal would contribute even
further to over commercialization within the city of Springfield.
. .. .
The applicant cites 4 of the 32 Economic Element policies pursuant to the comprehensive
plan (Metro Plan) (Chapter lll, Section B) of th,e Plan as relevant to the proposed PAPA.
The four Plm policies considered by. the applicant as relevant to the supply of industrial land
are policies 1,2,6, and II ' .
Policy I is to Demonstrate a positive interest in existing and ne\v industries, especially those
providing above \Yage job and salary levels, and increased variety of job opportunities, a rise
in the standard ot'jiving, and utilization of our existing comparative advantage in the level of
education and skill. of the resident l~bor force. . Ho\Yever, the applicant is not specific about
what uses will be cited should the proposal be apptoved, and there is no way to know if in fact
above wage jobs and salaries.
Policy 2 is to encourage economic development which.utilizes local and imported
capital, entrepreneurial skills, and the resident labor force, Again, there is no \Yay to
establish if the applic:wt \Yill in fact.utilize local and imported capital, skins etc. as no
comrnitmem to a use has been established.
Policy 6 merely states: "L'lcrease the amount of undeveloped land :oned (emphasis added) for
light indusmal and cormnercial uses correlating the effective supply in terms of suilabiiiry and
availabiiiry with the projections of demand."
T'nis policy ilddresses zoning only,.not plGI1 designation, ai1d concerns the necessity of having
adequate supplies of land of borh commercial and indusmal designations, It says not\1ing
concerning lfJe upplic~bijirj of favor~'1g one pi"", designation O'/ef the other.
MelrG PlaniEasl ivlai~'p.2finemeni Pla,n, ZOH,2007-00012 - LRP 2007-00013
, ,,-111
i
GOAL ONE COALITION
'Policy 11 is to encourage economic activities which strengthen the metropolitan area's
position as a regional distribution, trade, health, and service center. The applicant
asserts that the amendment (sic) will facilitate 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, consiste(lt with this policy objective. Cansidering that their 2003
zane change and plan amendments were based on the assertians that provision of .
. medical care pursuant to campuS style medical facility development is the wave of the,
future, and that the applicant already has established their dominance in the health care
market within the city limits, it has hard to fathom why they think another. 5.24 acres '
will someho\Y strengthen Springfield's position as a premier lo'cale for healthcare
servIces.
The PAPA proposal must be consistent with the Econoipic Element of the Comprehensive
plan in it's entirety. A majar amission found in the application and staff report is an analysis
of all the Metrb,Plan Economic Element policies other than the four addressed by the '.
applicant. The remaining 28 policies should be addressed in same manner. More
specifically, the follawing policies are directly relevant'to the inventory of industrial lands
throughout the Eugene-Springfield Metro UGB area.
5 _ provide existing induStrial acti vities sufficient adjacent land far future expansion.
This Plan pravision is directly applicable because the shbject properties are currently zoned
and designated to take advantage of light medium indJstrial designation and zoning. This
proposal to ellminate more indUstrial zoning adjacent tb existmg and developed industrial
zoning, plan designation, and ,uses is clearly inconsiste~t with the Metro Plan Economic
element, and if approved would have the effect oflimiting future growt.fj and expansiafl of the
existllg campus industrial. uses.. . ' '
7 _ Encourage industrial park development, including areas for warehousing and distributive
industries and research and development activities.
EconoIT'ic Element of the Metro Plan, Finding #17 est,ablishes:, ':Speciallight industrial firms" .
"have vc.ried site location requirements, prefer alternative sites to choose from, and usually
benefit from location of other special light industrial fIrms \Yithin the community and \Yithin
the same industrial developmenL" Tne subject site is located adjacent to an existing light
medium industrial site.
9 _ Encourage the expansion of existing and the locat\on of ne\Y manufacturing activities
which are characteri.zed by low levels of pollution and efficient energy use.
Slaffhas not discussed efforts to attract and/or encou~age expansion of manufacturing
activities ulat could be sited on carnpus industrial zaned and designated larlds. The only
reference to. this issue from smff is that there hasn't bJen much interest in the site from.the
industrial development se-~tor. I '
15 _ Encaura2e compatibility ber.,'Ieen ~,dustriallv zoned lands and adjacent areas ~'1local
- . .' .
planning program.
Metro Plan/Eas, Main Refinement Plan. Z:O~I 2007 -D0012 - LRP 2007 -DOOn
5-112
6
GOAL ONE COAUTION
Neighbors have expressed no concern about their quality oflife from existing industrial uses.
The applicant has not addressed \Yhy or how the existing light medium industrial zoning and
plan designation is incompatible \Yith the adjacent neighborhood zoning and plan designation.
16 _ Utilize processes and local controls which encourage retention oflarge parcels or
consolidation of small parcels of industrially or commercially zoned land to facilitate their use
or reuse in a comprehensive rather than;piecerneal fashion.
The subject properties are adjacent to alarge 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 LMlland within the Springfield -
city limits.
21 _ Reserve several areas within the UGB for large scale, campus type, light manufacturing
uses. .
"
Staffhas failed to address the impact that this proposal will have on the dwindling,supply.of
shovel ready industrial land inside the Springfield city limits., including prior actions
approving land use code amendments 'to the campus indu,strial zone that established more
'flexibility' for \Yhat uses are allo\Yed in the city's campus industrial zones.
28 _ Recognize the vital role of neighborhood commercial facilities in providing services and
goods to a particular neighborhood. ,
This PAPA proposal requests community commercial plan designation and zoning yet has not
considered or otherwise addressed the applicability of neighborhood commerCial zoning vs.
the requested community commercial zoning.
Staff and applicant have not addressed the applicability of community commercial zoning
within a node, or explained \Yhy neighborhood commercial zoning is being ignored for higher
intensity uses in this existing neighborhood.
All the Metro Plan Economic Element policies are applicable to this application, and should
have been addressed by the applicant.
,
ll1.Conclusion
The proposed plan amendment is.'not logical and harmonious with the land use pa[tem for
the greater area, The proposed change is not "logical and harmonious" because it is not
cOI)sistent \Yith the development pattern envisioned in [he Metro Plan.
As explained above, ~1e proposedamendmem is inconsistent wit.~ the imen! of the Economic
Element of the Metro Pl:ln, ar,d does not comply \Yith Metro Plan policies, Tnerefore it CQJmot
be found to be compatible \Yith these Plms.
Comptiance \Yith state\Yide pl;J.nrjng goals, including goals 2, 6, 9, 10, 12, and 13, has not
been established. In particular, it,,'has no! been established that the Eugene-Spru1gfield Metro
UGB area's supply of earn pus ~1dustrialland \Yill be protected pursuant to the Pi...PA and zone
change proposal.
'Metro Plan/East Main P.efinemenl PI~n. ZOH 2007 -00012 - LRP 2007-00013
5""113
"
7
GOAL ONE COAUTION
The requested plan amendment does not comply with policies of the Metro Plan and
Metropolitan Lndustrial LandsSpecial Study.
'.
The requested plan amendment and zone change does
appropriate.
not benefit the public and are not
I
Goal One and other pwies whose addresses appear in the first paragrarh of this letter request
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 MainPefinement Plan, .ZON 2007 -00012' - LRP 2007 -00013
5-;114
8
m PeaceHealth
June 13, 2007
Springfield Planning Commission
Attn: .David Reesor, Planner
City of Springfield
Development Services Department
225 Fifth Street
Springfield, OR 97477
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Re: ZON '2007 -00012, LRP 2007-00013 - Plan Amendment/Zone Change
Dear ChaimlanCross arid Commissioners,
The Commission considered the aboye-referencedapplications on-June 5 ata duly,
noticed \York session and publlc hearing. The following rebuts written testimony
submitted by Lauri Segel of the Goal One Coalition at the close of the extended record
yesterda y.
Ms. Segel suggests that the ~pplications do not comply with state\Yide
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
. refmement plan of the Metro Plan." (pg. 2; June 12,2007 Segel letter)
~ .
She further states that "Eug~ne arid Springfield have'a shared and adopted
UGB, Comprehensive Plan, and lndustrial Lands study. The
jurisdictionally focused SCLS does not ahalyze supply and.demand for the
entire Metro UGB area andlcannot b~ relied upon on it's [sic] o\Yn to
establish consistency \Yith the requirements ofO.AR 660-009-0010 (4),
which establishes th<J,t the flroposed P A.P A [Plan amendment] be
. '
consistent \Yith both. (emphasis 'added) the most recent economic
opportunities analysis (i.e., the 2000 SCLS) and the comprehensive plan."
(pg, 4, Segel letter)
"
Aoolicant's Resoonse:, The SCLS \Yas developed by the City and adopted by the
Springfield City Council (Resolution No. 00-13 and included in the end pages 6fthe
SCLS) to comply \Yith Goal 9 and applicable OI\Rs pursuant to periodic review
requirements establlshed by the O'regon Land Conservation and Development
Commission. Prior to the SCLS, the City of Eugene had an ack110wledged plan for
complying \Yith Goal9..the 1992 ,Eugene Cormnercial Lands Study (ECLS). The ECLS
stales: "The study includes solely the Eugene portion of the metropolitan urban gro\Yth
boundary." (pg. [-3, ECLS)
Phone. (5<: 1)686-::'650
F~.c (Sd 1) 5Sc.Jo9,)
PO Box \<.179 Eugene OF '37....Q.;J79
Dedic~H{;'d (0 ExcepriOl1all'v!!!dicinl!
and C0n1P(USiV17U{1! Care
5-115
Re: ZON 2Q.07 -00012, LRP 20lwOOO 13 - Plan Amendment/Zone Change
Appticant's Rebunal ' !
June 13 2007
Page 2
i
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Although there is in fact an ackno\v\edged study covering both communities' industrial
lands (the 1993 Metropolitan Industrial Lands Policy ~eport, and companion InventOiY
Report), the cities of Eugene and Springfield have sep,arately adopted and acknowledged
commercial lands studieSftilftlling the requirements of Goal 9. As such, the SCLS serves
as the City of Springfield's "most recent economic opportunities analysis," as Ms. Seg~l
notes above by her own admission. The SCLS also complies with Metro PlanPollcy 31
which called for the City to conduct a commerciallan~s study, and fulfills the City's'
_ Goal 9 requirements pursuant to the perioQic review \~ork order, now accepted as
. complete by DLCD. There is norequirement that the\Applicant or the City perform a '
metro-\Ylde analySlS of commercial lands In order to adopt findmgs satlsfymg compliance
with Metro Plan policies and Goal 9. 1.,.
Ms. Segel stales thatthe analysis provided cici~s not a~count for additions
to the inventory of commercial lands, notablyj'the Gatew,\y MDR site's
100 acres." (pg. 4, Segel letter) ,I '
Ao~\icant's Resoonse: The City previously adopted ~mendments to the Gateway
Refinement Plan (Jo. No. 2002-08-244), including Go/. Implementation Action 12.1,
which limited redesignation and rezoning of up to 99 'acres of residential land \Yithin the
Gate\Yay MDR site. Subsequent Plan diagram amendments and zone changes of 96.2
acres and 3.5 acres resulted in redesignationJrezoninglof96.2acres to Mixed Use
CommerCial or Medical SefVlces of the pOSSIble 99 acres avatlable under the GRP.
Considering that the SCLS identified a deficit of 158 lacres in the supply of commercial
land over demand, accounting for this additional rede~ignatecl/rezoned land, this .would
,
still result in a deficit of more than 61 acres of needed commercial land. Approving the
requested Plan amendmentlzone change would stilllJave a deficit of approximately 55 '
acres of needed commercial land.
The supplemental information submitted into the record by the Applicant included the
Clty's analysis of impacts to the commercial lands in~entory pursuant to the City's
ackno\Yledged compliance with GoalS periodic revi~w 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 Goal 5 protection measu~es that approximately \1.5 acres
would be removed from the inve[\wry of needed commercial lands, thus further adding to
the commercial lands deficit established in the SCLS1. .
. . j
Therefore even considering impacts to commerciall~nds inventories from other adooted
and ackn;wledged plans(i~., the City's plan for GOtl 5 compliance) and acknowledg~d
Plan amendments/zone changes, approval of the prop'osal \Yill not result in there being an
excess of needed commercially zoned and designated land. To the contrary, this analysis
demonstrates that there \Yill remain a deficit of apprdximately 66 acres after approval of
the reqllested redesigr.atiorJrezoring.
5-116
Re: ZON 2-\)07-00012, LRP 2007.00013 - Plan Amendment/Zane Change
Applicant's Rebuttal
June 1],2007
Page 3
Ms. Segel states that the application relies "heavily on inventory. and
policy statements established by the 2000 SCLS in establishing that the
proposal is consistent \Yith the Goal 9 rule. Ho\Yever, the applicant:s .
analysis of the proposals' consistency with comprehensive plan Economic
Element policies found in the Metropolitan General Plan, Chapter III, B-1
_ B-7 is insufflcient and does not address the most significant policies that
must be considered." (pg. 3, Segel letter)
,
She further alleges that the application hasn't "justified the conversion of
scarce; shovel ready industrial land, especially land designated and zoned
, light medium industrial inside the Metro UGB, even though the Metro
Plan (comprehensive plan) Economic Element policy #12 establishes that
the cities are to 'discourage future ~[etropolitan Area General Plan
amendnients that would change development ready industrial lands (sites
defined as short-term in the ITIetropolitan Industrial Lands"Special Study,
1991) to non-'industrial designations.' The applicanrand staff findings do
not address ho\Y the loss ofthese.S.24 acres impacts the short-term supply
" '
ofLMI designated land." .
Aoolicant's ResDonse: The Applicant's original March 15,2007 submittal'inc1uded
findings addressing relevant Metro Plan policies (see pg. 5 of the submittal, pg. 4-5 of the
Commission's June 4, 2007 hearing packet). Clearly not <ill of the 32 MetroP.lan ,
Economic Element policies are relevant to the proposal. Many are aspirationa! in nature
and not directive to a specific quasi,judicial application, for example Policy 28:, .
"Recognize the vital role of neighborhood commercial facilities in providing services and
goods to a particular neighborhood." (pg. 1Il-B-6, Metro Plan) Others. are directed to
actions that.the public sector jurisdictions are to undertake, such as Policy 31, which
Springfield did in conducting in the SCLS: "Conduct a Corrunercial Lands Study prior to
the next major plan update." (pg. [[l-B-7, ibid) Nonetheless, to demonstrate that all
policies \Yere considered irrespective of-their applicability, the Applicant \Yill provide'
supplemental findings and enter them into the record prior to the City Council hearing on
these applications. Ho\Yever, this does not suggest that the Applicant's fmdings are
presently inadequate or that the Metro Plan policies cited are not on point.
j
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 indt/stria!
Lands Special St"dy, 1991)." The adopted and ack.no\Yledged Metropolitimlndustrial
Lands Poiicy and inventory Reports identify the subject site as being included in
"Subregion #8 _ East Springfield." Maps and tabular information in these reports (op.
42-44, tables pp.18-26; 1993 MIL Policy Report) do not identify the subject site among
the "short-term sites" in the i'ndusiri:!! lands study, presumably because both were
'considered developed. The abuttin~ property no\Y developed \Yith the Hyland Business
Park w:!s, however, identifled in the study as site #7 in this subregion. While the Hyland
properlY \Yas included in the matrix of "shOrl-term sites," it \Y:lS also identified as being a
"developed" site, The MIL Policy Report st:ltes that "sites developed during the study
5-11'7
Re: ZON 2907-00012, LRP 2e_. -00013 - Plan AmendmentlZ~ne Change
ApplIcant's Re~unal '
June I] 20r7
Page 4
were not included in the short-term supply of sites. Staff projected a,five year need for
industrial sites based on development trends in Eugerle-Springfteld during the previous
two year period, a time of economic growth. This short term demand was compared to
the eXlsting supply of sites, excluding those already,developed. [emphasis in original
report]" (pp. 15, 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 applicabllity
of Metro Plan Economic Element Policy 12. i. '
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Even if Policy 12 \Yere relevant, its language is clearly notprohibitive to approval of an
application for redesignation/rezoning of an.industridl site, particularly when considering
it in the context of industrial and commercial land in~entories. As stated above and
established in the record, there is a demonstrated neea for additional commercial iand
:. l
which tl1e proposal helps address.
'The record also includes evidence demonstrating tha\ there is a surplus of needed
industrial land. The acknowledged metro industrial lands study identifted a surplus of
. "
buildable light medium industrial acreage, and overall industrial acreage, in Eugene,
Springfield, and combined in the metro UGB. Tablel.s in the MIL Inventory Report (pg.
47) identifies supplies of buildable industrial land as follows:
;rotal Industrial Acres
2,895.49
il08.80
I
3,604.29
I
The report further states that the study "identifies ab~ut 1,688 constraint-free industrial
acres..., This supply exceeds the projected demand over the next twenty years, which is
between 650 to 1,\12 acres." (pg. 73, M1L 1nventor~ Report)
I '
Eugene'
Springfield
Metro VGB
LMI Acres
1,230.78
198.77
1,429.55
. As noted in the City's Goal 5 analysis entered into tne record, the maximum im'pact of
industrial acreage from Goal 5 protection measures in Springfield is 54.43 acres (Table
11.3, pg. 3-25 of the Commission's June 4 hearing packet). The analysis also found that
there \Yere 90.80 acres removed from the industrial designation by prior Plan
amendments in Springfield. Therefore, even if ill of the industrial acreage impacted by
Goal 5 and all of the acreage redesignated in Springfield were from the LMI designation
_ whlch lS no doubt not the case - there \Yould still be a surplus of nearly 50 acres of LMl
designated land even after approval of the requested Plan amendment. This does not
account for the I 1.5 acres ofland added to the inventory of LMI zoned and designated
land referenced in my March 28,2007 supplemental lnformation.
i
Therefore, the removal of 5.24 acres of LMI zoned hnd designated land \Yill no't result in
. . '
a deficit of needed land in that industrial designatlon.
Moreover, although Economic Element Policy 12 "~iscourages" Plan amendments for
certain industrial lands, there are countervailing policles in the Metro Plan (i.e.,
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5-118
Re: ZON re07-00012, LRP 2007,OOOlJ - Plan AmeridmentlZone Change
Applicant's Rebuttal '1
June \ J 2007
Page 5 .
Economic Element Policy 6) and SCLS (i.e:, Policies I-A and I-C) that are directive to
providing an adequate supply of needed commercial lands. The Metro Plan recognizes
such conflicts: "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,.pot all the goals, objectives, and policies can be met
to the same degree in every instance., Use of the Plan requires a 'balancing' of its various
components on a case-by-case basis, as well as a selection of those goals, objectives, and
policies most pertinent to tile issue at hand." (pg. lA, Metro Plan) The Applicant
contends that findings and evidence in the record from adopted and acknowledged
sources demonstrate that approval of the requested redesignation/rezoning is consistent
with applicable polici~s and fulfills the City's employment-generating objectives and
requirements under Goal 9.'
Ms. Segel's letter states that."the applicant is not specific.about what uses'
will be cited should the proposal be approved, and there is no way to know'
if i~ fact [sic] above \Yage jobs and salaries." (pg.. 5, Segel letter)
, She also states that \Yhile "tile applicant argues that the proposal would
have the effect of correcting:existing non-conforming uses on TL #402" ,
that the 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
nonconfom1ing uses were actually established AFTER adoption of the.
1 . .
2000 SCLS, indicating that ,the existing uses were actually permitted by
the City \Yith'the knowledge that these uses would create plan/zone
conflicts." (pg. 4, Segelletth) .
AnTllicant's Resoonse: The Applicant does not a'llege that there is a Plan/zone conflict on
Tax Lot 402; clearly the existing Plan d~signations and zoning are LMI. 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 LMI
designation on the subject properties. Ms. Segel provides no evidence to back up her
accusation that the City \Yittingly a!lo\Yed conunercial uses on Tax.Lot 402 after adoption
of the SCLS. The Applicant and owner of Tax Lot 402 will provide additional evidence
and testimony at the City Council hearing on July 2 ,,,!iich \Yill further demonstrate'
factually that commercial uses and employment have been in the building on Tax Lot 402
for nearlv SO vears. .
. ,
Ms, Segel's assertion that the application \Yas unspecific as to the future uses on Tax Lot
400 is inaccurate. The application narrative clearly states the intended purpose of the
redeslgnatiorJrezoning is [Q allo'~ for :J future medical clinic on Tax Lot 400 and to allow'
the long-standlllg'commercial operations on Tax Lot 402 to continue (pg. 2, pg. 4-2 in the
Commission's June 4 hearing packet). Such clinical uses are not permitted in any
ind1lstrial zoning district, thus prompting the need to rezone (and redesignate) Tax Lot
400 to allow a medical clinic. A~erage \Yages and benefits for medical workers tends to
5,..119
Re: ZON 2007-00012, LRP 2007-00013 - Plan Amendment/Zone Change
Applicant's Rebunal
June I J, 2007
Page 6
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. be higher than average local \Yages, and further substantiating data can be entered into the
record at the Cit; Council level. " "
Ms. Segel contends that the proposal is not "logical and harmonious" \Yith
, land use pattems in the greater area, inconsistent with the intent of the
Ec~nomic Element of the Metro Plan, doesn'\ comply with Metro Plan
policies, and hasn't demonstrated compliance'with state\Yide 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 industrialland.will
be protected pursuant to the PAPA and zone change proposal."
Aoolicant's Resoonse:, It should first be noted that the application does not involve or in
any way affect the "metro area's supply of campus industrial land.." Moreover, the
application has no effect upon Goal 1 0 (Housing), add has elsewhere demonstrated
compliance with Goal 12 and other applicable state0ide planning goals. My guess is that
Ms. Segel and Nancy Falk, who appeared at the June: 4 hearing and requested the written
record be left open for a week, both vigorous! y oppose the Plan amendment/zone change
proposed for the Marcola Meadows project, and are ~orrowing arguments to also object
. to this modest request before the City. . I', '
The contention that the proposal would not result in a "logical and harmonious" land use
pattern is \Yithout substance or basis in fact, and is n6t an approval criterion. As noted
above and else\Yhere in the record, this proposal is c6nsisten~ with policies and provisions
in the Metro Plan, its Economic Element, supporting! refinement plans (i.e., the SCLS and
M1LS) to the Metro Plan, and Goal 9 and other applibble statewide planning goals.
On the basis of the record and arguments before yo) we urge you to support the Staff'
recommendation and forward to the City Council yo~r rec'ommendation approving the
pending applications.' I
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P 1ilip Farringt n, ,\ICP
Director, Land Use Planning & Devdopment
PeaceHealth Oregon Region
cc: Jim Werfelmann
?Jldrew' H-::ad
Shaun Hyland
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5-120