HomeMy WebLinkAboutComments Miscellaneous 6/12/2007
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GOAL ONE COALITION
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Goal One;s Citizenlnvoivement
City ofSpringfieid Planilittg ComiDission ,t;}]i:', ,
David Reesor ' " ( I, /If '
City ofSpringfitild ,',' Date' ReceiVed:~ 0 1
225 FifthStreet . .' Planner: DR ' ',_
Springfield,OR97444",.,,' , " (<v v;':/,:'V"
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June 12,2007
F.,.ECErV~D
JUN 1 2 2007
BY:'):/' i::
'RE: ZON 2007 -o00121LRP 2007-00013, Plan Amendment & Zone Change
Dear.Members of the Commission: ' "," , '.'. " '
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The Goal One Coalition (Goal' One) 'is a nonprofit organization whose mission is to provide
assistance and support to Oregonians in ,matters affectil}g, their, communities. Goal One is
participating in theSe proceedings at the request of and, on behalf of its membership residipgin
Lane County. This testimony is presented on behalf of Goal One and its -membership"
including NancYfalk, 2567 Marcola Road, Springfield Oregon 97477, as an individual,
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I. Introduction ,:, ..::: ' '.
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This proposal is for a site-specific Metro Plan Am~d!nentl Refjr!effient Plan-Arri'endment and
a concuirent Zoning Map Amendment from Light Meditim Industrial (~MI) ~o,Community
Commercial (CC) within the Springfield city limits, ' ' ' "
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The subject site isJoC{l.t851'near44t,h and Main,Street (Highway 1,26)_ The~iie consists, of~o
p,arcels underst;parate,ownership~, and is located on approxinlately. ~,?1 acresi~entified,aS
Tax Lots 400 and 402:on Asse~sor's Map,N\>_ 17"02-32-00, TL.100 (5,01 acres) has several,
vacant buildings on site, including portable trailer type structures, 'Thesinallerof the' two
subject lots, TL 402 (,24 acres), has an existing commercial development on-site, although the
plan designation and zone are LMl. Properties located to the north (Weyerhauser) are zoned
and designated heavy industrial. Parcels located west of the subject site are designated mixed-
use on the East Maili. Refinerrient:Plim, Property located east and adjacent to TL #402 is built
out ,as a busiriess park, ~ddesignated LMl, Properties Idcated south.ofthe subject site, across
Main Stre!lt, are zonecl:anaoesigriatedCommunity Conimercial..' ' ,.,' ~"',
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n. Criteria applicable totherllquest'" . ' :" ,I:
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Local approval criteria, are{ound)n,!Qc;Jo!lowigg d,C)cum~nts:' Sprin~fie!~ DeY!llopment
Code, Metro General, Plan;' and East,MainRefinement. Plan,. as indicated in the staff
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report. .. ,:'-~!T;{t~ '-l~"; "1 ~f\d'..'- ,",: '. ^'> ~-~, .
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The proposed plan amendrllent'must also'be fOlmd tbCbe consistent with, applicable statewide
planning goals. ORS I 97.1 75(2)(a). Applicable,goals include Goal I, Citizen Involvement,
Goal 2, Land Use Planning; Goal 9, Economy of the State; and Goall2; Transportation, The
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Eugene office: 642 Chamelton 5uite 100, Eugene OR 97401 . 541-431-7059' Fax 541-431-7078
Lebanon office: 39,~25 A1men Drive' Lebanon OR 973,55 . 541-2?8-6074 ' Fax 541-258-681 0
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G9AL O,>!E COALITION
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especially,land designated and zoned light medium industrial inside ,the Metro UGB, ,even
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though Metro Plan (comprehenSive plan) Economic Element policy # 12 establishes that the
cities are to "discourage future Metropolitan Area General Plan am'eridments' trult would
change development ready ind~iriallands (sites defined as short - tern;' hi'ilie inetropolitan
Industrial Lands Special Study, 1991)tonon-in4~strial designations." The applicant and staff
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findings do not address ho\y the, loss ofthes~5.~~'acres impacts the short-term' supply 'ofLMI
designated land. ,'" '.., ',' " ,',
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The applicant makes the.argurrieritthat the propOsed plan amendment and zone charige would
have the effect of , correcting 'existillg non-conforming uses on TL #402, (map 17-02"32);
however,the 2000 'SCLC, at Appendix C, "Sites, with Plan/Zone Coh~icts" does not include ·
the subjec.t property, It appears that, the existing noncon,forrnipg ,uses ~ereactually establisjIed
AFTER adoption of the 2000 SCLS, indicating.1hatthe existing Uses' were actually permitted
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by the'City with the knowledge'that these'uses would create plail/wI,le conflicts, '
In addressing applicability of the Springfield Commercial'Lands Study (2000 SCLS), the
applicant appears to,try to separate the Metro Area by jUrisdictional boundary, However,
Eugene and Springfield have a shared and adopted UGB, Comprehensive Plan, and Industrial
Lands study. The jurisdictionally focused SCLS does not analyz'e supply and demand for the
entire Metro UGB area and cannot be relied upon on it's own to establishconsistency With the
requirements of'OAR 660~009-00ro (4), which establishes'that the proposed PAPA be
consistent with both (emphasis added) the most recent econo.micYPIM~unities analysis (i,e.
the 2000 SCLS) and the comprehensive plan,
A related problem. with placing such heaVy reliance oft the 2000 SCLSto establish Goal 9
compliance is that in'analyziiig 'supply and demand, the study'fails to consider or.o'thelWise,
account for lands 'added to the~.:';;.ercial inventory via applicant initiated and city approved
zone changes and plan amendments. One very obvious example of an addition to the
Springfield commercial lands inventory was the 2003 plan amendment and zone change (LRP
2003-0013 and ZON 2003-0019) at the roO-acre Gateway Medium Density Residential site
that had the effect of rezoning and redesignating 100 acres of residential land to,coInmercial,
The appliCant pro~!ies a spreadsheet (their,Attachment B) that supposedly accounts for all
Metro Plan diagraffi changes" affecting' the supply of residential, commercial and industrial
Lands in the city of Springfield betWeen'1991 and the present, buthas failed to account for or
otherwise address the addition of commercial land to 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,
This ofuission'raises doubt as to the accuracy of applicant's Attachment B in supposedly
accounting for additions to and subtractions from the.various land inventories,
The applicant also relies in part on inventories established in conjunction with adoption of
Springfield's Natural Resource (NR) Study, by Ordinance #6150 on November 28, 2005.
While those inventories may be relevant to 'this proposal in that possible 'impacts' resulting
from Goal 5 protection measures were considered for all zoning classifications, the analysis of
maximurri possible impact onsilpply of cOmmercial 'lands pursuant to the study is limited to
the area within the Springfield portion of the Metro UGS (table 11-2). 'Again, because
Eugene and Springfield share a UGB and a comprehensive plan, an analysis of the entire
lJGB'm:ea is necessary to establish an accurate picture of the supply of commercia! lands., .
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Metro Plan/East Main Refinement Plan, ZO!ll2007.o0012,- LRP 2007-00013
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GOAL ONE COAUTION
In any case, the NR Study found that the maximum possible impact of GoalS protection
measures on the Springfield Commercial' Lands Inventory would be the loss of 11,56
"commercial acres."
LOSS OF INDUSTRIAL LAND
The proposed plan amendments and zone changes would remove 5'.24 acres of shovel ready
light medium industrial land from the Metro UGB area industrial lands inventory, This is in
addition to an additional 56 acre conversion of CamPUS industrial to community commercial
land less than 2 miles away which is currently pending approval by the Springfield city
counciL The applicant is vague about the purpose of the proposed plan amendment and zone
change, noting that, with approval of the plan amendment and zone change, the uses could
include a possible future medical clinic, and the provision of family wage jobs. The applicant
has said nothing about the existence of their other 100 acre medical campus located within
about 5 miles of the subject properties proposed for plan and zone changes. Given this fact,
the applicant has not justified the removal of shovel ready light medium industrial land for
commercial uses. This area within the Springfield city limits is already inundated with
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 III, Section B) of the Plan as relevant to the proposed PAPA.
The four Plan policies considered by the applicant as relevant to the supply of industrial land
are policies I, 2, 6, and II
Policy I is to Demonstrate a positive interest in existing and new industries, especially those
providing above wage job and salary levels, and increased variety of job opportunities, a rise
, in the st;jndard of living, and utilization of our existing comparative advantage in the level of
. education and skill of the resident labor force, However, the applicant is not specific abo.ut
what uses will be cited should the proposal be approved, and there is no way to knowif in fact
above wage jobs and salaries.
Policy 2 is to encourage economic development which utilizes local and imported
capital, en;"~p,,:.ueurial skills, and the resident labor force. Again, there is no way to
establish if the applicant will in fact utilize local and imported capital, skills etc, as no
commitment to a use has been established,
Policy 6 merely states: "Increase the amount of undeveloped land zoned (emphasis added) for
light industrial and commercial uses correlating the effective supply in terms of suitability and
availability with the projections of demand."
This policy addresses zoning only, not plan designation, and concems the necessity of having
adequate supplies of land of both commercial and industrial designations. It says nothing
concerning the applicability of favoring one plan designation over the other,
Metro Plan/East Main Refinement Plan, ZON 2007.{)0012 - LRP 2007.{)0013,
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GOAL ONE COALITION
Policy II is to encourage economic activities which strengthen the metropolitan area's
position as a regional distribution, trade, health, and service center. The applicant
asserts that the amendment (sic) will 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. Considering that their 2003
zone change and plan amendments were based on the assertions,that provision of
, medical care pursuant to campus style medicaHacility 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 somehow strengthen Springfield's position as a premier locale for healthcare
services.
The PAPA proposal must be consistent with the Economic Element of the Comprehensive
plan in it's entirety, A major omission found in the application and staff report is an analysis
of all the Metro Plan Economic Element policies other than the four addressed by the , '
applicant. The remaining 28 policies should be addressed in some manner. More
specifically, the following policies are direetlyrelevant to the inventory of industrial lands
throughout the Eugene-Springfield Metro UGB area,
5 - Provide existing industrial activities sufficifmt adjacent land for future expansion.
This Plan provision is directly applicable because the subject properties are currently ,zoned
and designated to take advantage oflight medium industrial designation and zoning, This
proposal to eliminate more'industrial zoning adjacent to existing and developed industrial
zoning, plan designation, and uses is clearly inconsistent with the Metro Plan Econoinic
element, and if approved would have the effect oflirriiting future growth and expansion of the
existing campus industrial uses,
7 - Encourage industrial park development, including areas for warehousing and distributive
industries and research and development activities.
Economic Element of the Metro Plan, Finding # 17 establishes: "Special light industrial firms"
''have varied site location requirements, prefer alternative sites to choose from, and usually
benefit from location of other special light industrial firms within the community and within
the same industrial development." The subject site is located adjacent to an existing light
medium industrial site. '
9 - Encourage the expansion of existing and the location of new manufacturing activities
which are characterized by low levels of pollution and effi,cient energy use.
Staffhasnot discussed efforts to attract and/or encourage expansion of manufacturing
activities that could be sited on canlpUS industrial zoned and designated lands. The only
reference to this issue from staff is that there hasn't been much interest in the site from the
industrial development sector.
15 - Encourage compatibility between industrially zoned lands and adjacent areas in local
planning program.
Metro Plan/East Main Refinement Plan, ZON 2007 ..()0012 . LRP 2007-00013
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GOAL ONE COALITION
Neighbors have expressed no concem about their quality of life from existing industrial uses,
The applicant has not addressed why or how the existing light medium industrial zoning and
plan designation is incompatible with the adjacent neighborhood zoning and plan designation.
16 - Utilize processes and local controls which encourage retention oflarge parcels or
consolidation of small parcels of industrially or commercially zoned land to facilitate their use
or reuse in a comprehensive rather than piecemeal fashion, '
The subject properties are adjacent to a large parcel which is zoned and designated LMI, Staff
is directed by this policy to encourage retention of this parcel of industrially zoned and
designated land, which is one of the few remaining parcels of LMI land within the Springfield,
city limits.
21 - Reserve several areas within the UGB for large scale, campus type, light manufacturing
uses,.
Staff has failed to address the impact that this proposal will have on the dwindling supply of
shovel ready industrial land inside the Springfield city limits, including prior actions
approving land use cOde amendments to the campus industrial zone that established more
'flexibility' for what uses are allowed in the city's campus industrial zones. ' '
28 - Recognize the vital role of neighborhood commercial facilities in providing services and
goods to a particular neighborhood,
This 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 coIilmunity commercial zoning
within a node, or explained why neighborhood COnllnercial wning 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.
m. Conclusion
The proposed plan amendment is not logical and harmonious with the land use pattern for
the greater area. The proposed change is not "logical and harmonious" because it is not
, consistent with the development pattern envisioned in the Metro Plan.
As explained above, the proposed amendment is inconsistent with the intent of the Economic
Element of the Metro Plan, and does not comply with Metro Plan policies. Therefore it cannot
be found to be compatible with these Plans.
Compliance with statewide planning goals, including goals 2, 6, 9, 10, 12" and 13, has not
been established. In particular, it has not been established that the Eugene-Springfield Metro
UGB area's supply of campus industrial land will be protected pursuant to the PAPA and zone
change proposal, "
Metro Plan/East Main Refinement Plan, ZON 2007.00012 - LRP 2007-00013
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GOAL ONE COAUTION
The requested plan amendment does not comply with policies of the Metro Plan and
Metropolitan Industrial Lands Special Study,
The requested plan amendment and zone change does not benefit the public and are not
appJ.Upl~ate.
Goal One and other parties whose addresses appear in the first paragraph of this letter request
notice and a copy of any decision and findings regarding this matter.
Respectfully submitted,
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Lauri Segel
Community Planner
Metro Plan/East Main Refinement Plan, ZON 2007-00012 - LRP 2007-00013
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