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HomeMy WebLinkAboutComments Miscellaneous 6/12/2007 , ,. ) i ;,.... t,. GOAL ONE COALITION em ,~ , ,) " '. , rl., " ",'.. . 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" j ,.." " 0 In """-) '~ - ". . 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: ' "," , '.'. " ' ~ f.' . ' , " , .'1"" ')1.... ':.1 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, l-I": '. ' I. Introduction ,:, ..::: ' '. . , " . .,. , :;. .': ....- .:'" '. I 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, ' ' ' " '.... ..' 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..' ' ,.,' ~"', ~ r .... " \;t \ ~ ., :. .., . i- r ,:. ,t', .. ' ;. n. Criteria applicable totherllquest'" . ' :" ,I: ';:~ J' ,.r' r ' .:.' r '. , .' ' , " ~ 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 . . -;-.' . - .. .' ,-, ~ . . - ,." ' report. .. ,:'-~!T;{t~ '-l~"; "1 ~f\d'..'- ,",: '. ^'> ~-~, . . .>':I'I--.-;fttT;'J'~'t";-'~";~"". \ . " 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 " 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 aJ1 " ~ ' www,go ,org , ..,'., ..' ') G9AL O,>!E COALITION ) - j', especially,land designated and zoned light medium industrial inside ,the Metro UGB, ,even '. ~ ' .! . 'I' .~ . " . .., -.... .-' ." - 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 ", . r' . ". .. -, r.,'" , findings do not address ho\y the, loss ofthes~5.~~'acres impacts the short-term' supply 'ofLMI designated land. ,'" '.., ',' " ,', . '. '". ' _~ .. !;. t ~ . .: ,...... '1 ,- . -. , . ~". ~ . . 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 I " . . ,'f " _ 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., . ..~.(..:~ ,} . , ':..', .:,. . \' . Metro Plan/East Main Refinement Plan, ZO!ll2007.o0012,- LRP 2007-00013 . ' 4 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, 5 GOAL ONE COALITION Policy II is to encourage economic activities which strengthen the metropolitan area's position as a regional distribution, trade, health, and service center. The applicant asserts that the amendment (sic) will 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 6 , .' ... 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 7 ~ . , . 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, ~ Lauri Segel Community Planner Metro Plan/East Main Refinement Plan, ZON 2007-00012 - LRP 2007-00013 8