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HomeMy WebLinkAboutOrdinance CMO 7/16/2007 (2) ., .' 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: ,ii 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 " .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 ~""'.....} \."""'\"""1 DATE: k7f";.[)( OFFICE of CiTY ATTORNEY OIillINANCE NO. . 10700 PAGE 2 OF 2 ii' ., iI 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 <;-1 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: , I 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$t of 44111:Street along Main Street in east Springfield. The site is bordered on the south by M'ain Street, on the east by the Hyland Business p'ark on the north by an open area south: of the Weyerhaeuser mill site (Tax Lot 400) or an 'existing commercially zoned parcel (Tax Lot 402), and on the west by other small-scale commercial enterprises (e.g., a cabinet shop and karate school) fronting Main Street and residential homes along 44111 Street west of Tax Lot 400. lRP2007.000'J & ZON2007,OOOl2 5-2 ," 2 Commercial enterprises are located immediately south of the site across Main Street (~.g., Gray's Garden Center). While historically involved in agricultural uses, since around 1990 Tax Lot 400 was used as a storage and sales yard for land$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. .. lRP200 7,000 I J "ZON2007.00012 J ')-3- Existing & 'Proposed Metr? Plan Designation: , , ~'~'u~ i i e I' . : --~ I : . 1 I I ~ I t ;-:--_...-~~-.. , '----. j- --'I ': i. , !. i ----;-'--..-Li-T-~~C! I I , . . .' '--.J ' ,/ ,.__=.=_1 ~/~" -;~~- I /- /, ;\( I jr-- .// <, 1'1 .:_- :1 ~ 1-- ~ ./ ') '--:-I~r--~ ,~/ j L-J .' I I I ". I I I ; , !-----) . . '. . ...'.__.~._-._-,--- I: -- ,_'L_ I I .I I , I--~ Ii .! ;1 I "'. ; I I 'I! I_I' ! , ! ~ 1;1 . ~_.lJ.____.____-' ----T-LI.' /..., i \ "> r '.~ '"--1-"-- . I .-.'.--"!. r-- o i,! .. , ~ Change from Light Medium Industrial, to Commercial Metro Plan Designation _ Commercial MU o Light Med. Indus\. D Low Den. Res. o Med. Den. Res. _ Heavy Industrial ~~~ 1~.", 1m,,,,, ..~rr",,'"'' '''''/<1U"'''''''''''.v ,,,up,ud.,,'1 II (J,,'.,.. "'","'ollll '~~pu,,,.r1lr~rYfo""',, '''''1 or a.,""'!>",,'u'''g f"''''''''_v .""'. ,,,,,,,;11""''' ftJ" ilUnal"'"'''''''''"Y''f lilt< P"";''''l , I "" :00 Feel June, 2007 LRP2007-0001J & ZON2007.00012 4 <;-<; Existing & Proposed Refinement Plan Designation: .\,1 ,,/:\ .1' ',..)..- '-," ,-".:-', ? . ""'NST I,.. '1 .../. '1" 1 ". " . .. '." . . -'"...,,~.,. '.- .. ',": ....c.-" :.' -,..-- .,. ,------'" . , ., 1__..j_.LJ '.! ''!.'''~. C2'.J'.;.:.,',\,:1 /r......I.JI. '1 ...,1.. 'I'~I'I..:......I ~ ! I. . ",. . ,.1 I ., II . . I "---._..__~J.l_._.._~~_~ " o z * o ii;%~i;C;~;~';;i,~\:.'~nkt:r' ':'<o''';(:-:~~~''r7~'~';.:~:)J}~'~:;:'-r:..:~.<~;~: C k,'., /.... [r'~:"" '~'.>~j~ .' .. .' .'. : ".\,,:_.:( '~}2t+ ., I , . ! W Change from Light Medium Industrial (LMI) to Community Commercial (CG) Refinement Plan _ Community Commercial Low Density Residential Mediu'm DenSIty Residential Light-Medium Imuslrial !!!!Ii Heavy Imustrial ~.''21 Mixed Use 2 & 3 , <I i I I ~~ "/I,.~ art~" ",""'t/"no:!" ihat ,,~a"f'<"'_v IIrU proc1w;r. Lhn <l.In<me <lll rnporudJ,IJI,vjOn.J/l.> Ion fJ' Jam"!:" Ul'll'~.( fiv"'<Jn.~""""', "'"""'Oll" fU'lalJftlJl"'Q,'<Urt";.~oJj-tJw proc1~<" lOa ;ooFeeI. = June, 2007 , I LRP2007.000 13 & ZON2007.00011 5 ~-~ Existing & Proposed Zoning: I- I I 1---, L._.J ! ! ...-j : I ;! ~_..~"j I .-T---' ; , ;. 1;-.1 i-'I 1,--1, " : ~ I : /,,1 lj , L. \ i:. , ~.: ~ Olange from Lght Medium Industrial (LMI) t? Community Commercial (Ge) Zonirg Medium Density Residential LDw Density Residential _ Community Canmercial Ugh! Medium Industrial _ i-'eavy Imustrial ~:-~ n,~rr""'f!U."""'''''''':r UtUlu<.';<J"poJ"y iJtupm.J\,.'I Gion I1Uume all '<:sp<>>t.llhrlll."/ur ~".' lu~ a"lamm;_ ,'~"'''g fNJ"'<l1I.v..mr.".......'u"lIr.."""""''''''<:,,<n1Cy~flh''l'r'',},'':1 , t, '" 3l0F.el June, 2007 , . LRP2007.0001J & lON2007-000/2 ",-7 I " 6 ! " Existing Site Conditions: Existing commercial uses on TL 402 Existing empty structures on TL 400, .. Existing modular units located on TL 400' EXistinJ business park on property located east of TL' 400 I i " 7 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. -I 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 . ~-1('u " 9 '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 10 S-11 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 , , 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, . ~ . i 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, , , . , 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 ~ , I I EXHIBIT A..t. . 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 ~ ~ gl' r l ~ ~~ ;.~ :~ ~3 ,J ~,1 11 . ";;. " 1~ ~1 . ''8 I.~ ili ,l~ 1}l .~ ., c., _~l ~ ~J ~ ~ :~ ~,:ll ~ ~:; ..{I ,j t~ ~ (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 -' , ., ' 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 -' . i 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 -------~---_............ ------..---- ---.--.--.---.---- 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 , ' " " , ',I ,'I' I~ .. 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 ~ ' 5-50 - Metro PlanlEMRP Diagram Amendment , PeaceHealth Oregon Region ~{.~~~~ ~~ ?nn7 _ ___ Page 6 .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 5-51 Metro PlanlEMRP Diagram Amendment PeaceHeulth Oregon Region 'March 15, 2007 . :Page 7 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 " 5-52 P~ge 8 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, 5-53 - Metro Plan/EMRP Diagram Amendment PeaceHealth Oregon Region March 15 70n7 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 5"':54' 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 5-55 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. 5-56 " " , ' Melro PlaniEMRP Diagram Amendmenl PeaceHeallh Oregon Region 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 I' 5-57 Metro PlaniEMRP Diagram Amendment PeaceHealth Oregon Region March 15 2007' Page 13 The proposed amendment is consistent with this policy because it will allow medical clinic uses to be developed to serve growing areas in east and south Springfield, As is observed in the 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. 5-58 Metro Plan/EMRP Diagram Amendment PeaceHealth Oregon Region March 15, 200i Page 14 '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 " ". .' 'I ',I 5-43-%8 Metro PlarJEMRP Diagram Amendment PeaceHealth Oregon Region March 1,5 2007 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 PeaceHealth Oregon Region 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 5-64 . .... /S6-/. Dc' , ,..f49,8.2' I I I I I I '~I . "i ~ If f\ OJ " \ '+/35/.2S0'~~-~I~ ~--- 77...9C",". .J/..-sz./-4' SOO, <?' 401 I I I I , 'I I 501,'- . . . . 2 32 2 4 , '0 OJ 2 MITH ~ , \ / =~~. ~-~' r::;, '.--- - ~~ I , en Ul I I.j . t-.. ~, \ll " .. ,g ~ ~~ ~ t: .- II! _~_ --~~ -'~-::T-'5.+~._~~ _.~ - -- -';.i-'-~~~-- , .r J- J- ;i;Zir;P~.Ft:-.r - . r' ' ",., r', , ~'400 , ,",-~ :t " ".",'. ,.',i;:;f,H~~~ ,', 402),.r'.'~ ;,bV:>', t-.. ~ , Ir) iI1' I.. ~, l , , , -1'\ " . ~ ~ \1' t)'" ~ EXISTI!' ~ ' (C,( , --:!'if' , .9.'ff/ciJl L sol' /tj-L283 ./_ "'" NE COR./' NW COR. -:: TD EDWARDS AWl-\AMMI1 ~ D.L.C. 55 D.Le. 36, 100 . ~ , ~ ~~ ~ -. ~ '- 0') t<) N C> 2. a ~, <t- .0 n:: -;;~q.44~l'e 'Q' l\ " " n ,. =;;:. ". _ ' " _ >- }- 2: :J o o II Community Commercial Light Medium Industrial Medium Density Residential - ,. -- /-35"/,02 77..9C~;.:J-/-")l./4~ 5"00,<;' . ,7-4 9.8-'" . I 401 501 I I 32 I() I / 2 2 4 OJ I 2 I I, , I I ,r>) I 'Il .,' I. I , % l\. ~ J t-. I '- '~I ~ . I ' ,- '" ~ ;8 ~ '-. '~ 'il '<i ~ ~ ~ \l' ~ \f ~ '1<>' 01 ,~ ,~ ' ~ "\ lJl ::>'-'5. + . --- /.35/. 3'0' I " -500- . PROP_?SE~.__... "! 6'0/' /'0' (2~_l_ NE COR./ NW COR ::. TD EDWARDS AW HAMMIT ~ D.L.C. 55 D.L.C. 36 100 . ~ , ~ ~~ '<) ... ~ '- <;~""44'e 'lJ ~ "- " -,. " en to N L, Z Cl ..:r o cr >- I- Z --- -- - ::> ,0 (.) m Community Commercial Light Medium Industrial , Medium Density , Residential , ,'-700- " -'1&2',"', ' 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 ~'~'r:.!~~:V!91~t~0~~~~lI _Q .'._ _'~",____ .~1;(1I . _..; Of' ..~~,.J..: "~ ,~<.:.":~__""..'_" -:_.;:- '~>lY~~ -...._ '!,.'-::""_"J': 'Co" '" -,",,-e';.,.p:"~. ~ ' ~\/.:~_.~'v<&-" t""r...J,~"~ .-.---- " ~1,!~~~;~$;~:~~lu.,~;t~~~".' """,."",._.LV e ro, ~':\t~_~~:;;~<~'~~':~f~ ->?:~..; i ....".";::";,:.';.,,-" .", .,./,.:.~ ,,_-:o,;~:.:~~:'+~;: '~::~~i~.:~~~cc~0:.~:~.L~; : :,~'!:~,~: ;~~,( , _~ ~_:,~~-::.r p ~ :.=-.. l1li ' .,_~h~:_~- ~... ~ - ~: JD~.iIII 1lII' :~ c :" ~ -.:.-:~~;:-~,::ii:,,:~~,- -~,_..-"'_.,_....,-_. - III 'lI ~I.. _.......__ ~ 'I ~ ~r:.=:~:.::::: ~- ';g- ", L- ~:::'~:';'. . - ;4 ,~.- '-.-,' ' . . 1 5-67 .-- -;_. - -,- --'- - - - - -- --- 'Ir^~ ~'\,~ u'l~,,~Ni' '~,"" ~i1n (\t,!I,f, "<;-+~i;%' :tf ,}:;~ \t..-I ~r,: ~, If ~ l' ---... - ---- co <0 I LD ,.,,~,;~:~tj;~-~tW~~~}: ~,f!i"H"}"_"!_'i"'" ~lI(' '-'"~'-""",l".:' ~~:Zi;~~~'~i, \,:"""";:";:~'''"'':''I',, ~/:)~~~r'~Jl~ ;ft,~\ ';J};':~~i,}!;:J'~!:l;'.: '1';t.'.;,\!'~(~~:i~~1 CJ1 I 0'> <0 w \" . ~ Ouestions? I' 5-70 I I I I I j l , I L 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 . ."" ," y, , '.d'~j:,4}l;?:i:<5~\1Ji~~~~1i~f, ""ld us hia l'.totaHi/s hie'arM a'rcll!i1 <n I = LDR MOR -0,1 35.0 -5.3 -' 0,0 0,0 -3,0 -D,9 .\i~:;;~flH~_ ;~Jt38~7 ~.\\:~::;:~i{.i~L ,.:::Iff.~ om . ~!:_~,);i~,9 -'"2 ,:!;tV:::~i,:;:!~I~/ :'!-)~li;L7(5 ,,;',~~;:~~~7:,~ :i-~-~,t~: 5;:3~~~F~~~~? ~jf"r.8-:0~~1~~~,~ !~~~:.\t+72, 0 ~\>>-fl~:~;~,~J;Yi ~t;:;,i;;;-~N~i '~~~~~;f6 Iq ;~;~;g#~ ~:~:= ' 5,3, '0.5, 3,7 :~~~~.M:l~ ;m1~m'4 ' ~~f~~iMl~ ~Vit~1i~] '{I;~i~~-:n2' - AG MU CC D.l 5.0 D.D O,D 0.0 3,D 0.9 1 1 j ,~~~fi( ~Jj~pi5 ~.\I4'rW~ ~f:.~~~m; 'i~t~'*'~f\f~~1ti.t'm'." i:&~fJ~\~f~, ~N~~~!~;i. ;?if&?tc~~ ~-.],~.~1_W!.i\il1" 'N't~t,!:ro~Yai" ~i'i6.*IW&J .~,~,.~...Jj,.j'~';-' _ ?;~3aw~ ~\~~, W~il.ft1f: -~(~~t;,m5 ~~~fI~~:1 ~~1ij..~ - -' - {~f:';~~l;11z~~~~i; ~::~ 9.2 ~ (i!W~5'3 1!,",,,""O',:fj '<o,...-K", - :-....-:.... __ 0~J&~~L, ~:'::~~ ~~~~ ~,mo ~{~,$~';; ----~- 'ft:'~~'t t?fl:iJf~~~~ ~1Wj~, ,!"~"*~t\iW6!6 f!iQ!Kl;~ - - ":1',\lw-,,,,,,:,, ,,"~".'_: ' . ....c__,_,"'.'" Th,1il~i;i\~i~ \1.1i'!A'i:iW;\~O:'l. ~~i<El ;~r~'22t;O, i~~m.\'~~~Elr- -22.0 it:{~tt"t;;r~:~~i'] 1)>'3'5'0 . 6.0 .'>I'tfj.":"~1~"!~ ,"';::" ,,'., rt(~~ ~~~ r~~ 1}:~""'C';'M~ "\n>-'-lm'.l1ii.i.' -'-~~ ~~~~ "~~,,.:f~ ~~: f4:?~~ ~~~$~lt-~'Jt~~1 V~;~*'t1~Gi I ~~S~W:e&J.Zi~( ffi31li'{4W-i "j"(<!';r&g,'t,.Sfl~;-:~,2't,"'rr6 },1.:,.!t~~:1;l ",~~",'I,. ::~:~;~~~ ~~~~~';)?~!~~~ ;(otaj!d.bi~(ic;i!f,,~f<!.\tTaj~lliM '1t-i,'1i'it<:?;!!1l 'l"\i.J,;"!~\1;;~-;i;\::J::"i1'6V;\;\~P;';~"~;i'J'~I).trti:IS~ .J; 'jj:~2 B;~5, ~~~~;~'3.~3 iL;,5 9W_ :rOtairci~tlffi~18~'i"ndllsWlaiWjnl~irn,~i l&ik~:iWg~_O~B .v --l --l )::> () I :5:: m Z, --l [IJ -3,7 6.5 \ j \ 72,0 18.0 16,~ -34,5 0.01 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 . 5-88 , Page 8 Zone Chinge:Application 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 5-89 . Page 9 Zone Change f.pplicatlon PeaceHealth Oregon Region March \ \, 2007 , 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, 5-90 Page 10' Zone Change Application PeaceHealth Oregon Region 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 " , , ! ! 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, 5-91 Page 1 t Zone Change.ApplicatLon PeuceHeuithOregon Reg;on ~[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 5-92 Page 12 Zone Change.Apptlciltian PeaceHealth Oregon Region March I ~ 7007 -- - - -_.- -." 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 . ' . 5-93 Zone Change....Application PeaceHealth Oregon Reglon March 15 20r7 '" 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, I I , , 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; I ;, I i I I I ! i ,I (1) ldentify such resources; (2) determine their quality, qmntity, and location; I 5-94 Page 14 :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, 5-95 .Zone Change.~pplication PeaceHealth Oregon Region 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' 5-97 Page 17 lane Change,Applicatlon ." 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" I I '. " 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, 5-98 / f Zone Change Applicalion PeaceHealth Oregon R~gion March 15 2007 Page 18 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 5-100 I I , I I 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 . . 'I' '.' I ! I I 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 l~~l!.: (':?:::.~.... .)Il/:; . ~' ":.'/''i>-,,;. . . I ,) ::.:....i.:":.:,>., j":;,~ ,j ,)/)/7 .~--)/ '~':' . I I '_"'- . " I ..........~ I ....-..~ ! , - - I -...:-......... ~::::J I 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 I , ' , I 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. ' I I , , 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., , I . 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 '- . 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 \. -~~ , . P 1ilip Farringt n, ,\ICP Director, Land Use Planning & Devdopment PeaceHealth Oregon Region cc: Jim Werfelmann ?Jldrew' H-::ad Shaun Hyland I I 5-120