HomeMy WebLinkAboutNotice PLANNER 7/18/2007 (2)
AFFIDAVIT OF SERVICE
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STATE OF OREGON
County of Lane
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I, Brenda Jones, being first duly sworn, do hereby depose and say as follows:
1. I state that I am a Secretary for the Planning Division of the Development
Services Department, City of Springfield, Oregon.
2. I state that in my capacity as Secretary, I prepared and caused to be
mailed copies of Notice of Adoption for ZON2007-DOO12to DLCD
(See attachment "A") on July 18, 2007 addressed to (see Attachment
"B"), by causing said letters to be placed in a U.S. mail box with postage
fully prepaid thereon.
l. .'
HA/
Brenda Jones
Planning Secretary
. Date Receiv~d: '7'/8 I 01
Planner: DR ~
STATE OF OREGON" County of Lane
q[L~~ /'6 ,2907 Personally appeared the above named Brenda Jones, '
~~~('ta(), who acknowledged the foregoing instrument to be the,ir voluntary act. Before
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r. ,SANDRAMARX J
. i NOTARY PUBLIC. OREGON
i \,., ,/ COMMISSION NO, 385725
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My Commission Expires: II//L/Z 003
52
Notice of Adoption
TillS FORM MUST BE MAILED TO DLCD
WITHIN 5 WORKING DAYS AFTER THE FINAL DECISION
PER ORS 197.610, OAR CHAPTER 660 - DIVISION t8
For DLeD Use Only
Jurisdiction: City of Springfielrl Local file number: ZON2007-00012
Date of Adoption: 7/16/2007 Date Mailed: 7/18/2007
Date original Notice of Proposed Amendment was mailed to DLCD: 4/16/2007
o Comprehensive Plari Text Amendment
o Land Use Regulation Amendment
o New Land Use Regulation
o Comprehensive Plan Map Amendment
1:2:1' Zorring Map Amendment
o Other:
Summarize the adopted amendment. Do not use technical terms. Do not write "See Attached".
The applicant applied for a.Zonin~ Map Amendment concurrently with a Metro
'Ian 1 Refinement Plan map Amendment (lRP2007-00013). The applicant
proposed to rezone the subiect riroperties from Li~ht Medium Industrial (lMIl to
Community Commercial (CC). The City Council voted unanimously to approve
the proposal on July 16'", 2007. The adpoted Ordinance has an effective date 30
days after the Council voted for approval.
Describe how the adopted amendment differs from the proposed amendJ;I1ent. Ifit is the same, write "SAME".
If you did not give Notice for the Proposed Amendment, write "N/ A".
A condition of approval was reauired to limit the trip aeneration from the
, development to the "reasonable worse case development scenario" in. the lM!
zone.
~ MHn C:(1Hnp'erl from'
to:
Z'Lru...lhup CLuuo....c: ;lvu.lo :_1~1
~v~ SS
Location: 17-02-32-00 Tl 400 & 402
SpecifY Density: Previous: N/A
\pplicable Statewide Planning Goals: 9 & 12
Was and Exception Adopted? 0 YES 1:2:1 NO
Acres Involved: 5.24
New: N/A
ATTACHMENT A
I _
. '1 \ 1'0 101
Date Reeeived:~
Planner: DR
DLCD File No.:
Did the Department of Land Conservation and Development receive a Notice of Proposed Amendment......
,Forty-five (45) days prior to first evidentiary hearing? [2J Yes
If no, do the statewide planning goals apply? DYes
If no, did Emergency Cjrcumstances require immediate adoption? DYes
D No
D No
D No
Affected,State or Federal Agencies, Local Governments or Special Districts:
Citv of Sorinafield & ODOT
Local Contact: David Ree~nr
Address: 225 Fifth Street
Zip Code + 4: 97477-
Phone: (541) 726-3783 Extension'
City: Springfielcl
Email Address: dreesor@cLsorinafiel(:l.or
ADOPTION SUBMITTAL REQUIREMENTS
This form must be mailed to DLCD witbin 5workinl! davs after tbe final decision
per ORS 197.610, OAR Chapter 660 - Division 18.
I. Send this Form and TWO (2) Conies of the Adonted Amendment to:
ATTENTION: PLAN AMENDMENT SPECIALIST
DEPARTMENT OF LAND CONSERVATION AND DEVELOPMENT
635 CAPITOL STREET NE, SUITE 150 .
SALEM, OREGON 97301-2540
2. Submit TWO (2) copies the adopted material, if copies are bounded please submit TWO (2)
complete copies of documents and maps.
3. Please Note: Adopted materials must be sent to DLCD not later than FIVE (5) working days
following the date of the final decision on the amendment.
4. Submittal of this Notice of Adoption must include the text of the amendment plus adopted fmdings
and supplementary information.
5. The deadline to appeal will. not be extended if you submit this notice of adoption within five working
days of the final decision. Appeals to LUBA may be filed within TWENTY-ONE (21) days of the
date, the Notice of Adoption is sent to DLCD. '
6. In addition to sending the Notice of Adoption to DLCD, you must notify persons who.
participated iIi the local hearing and requested notice of the final decision.
,
7. Need More Copies? You can copy this form on to 8-l/2xlll!Teen naner onlv: or call the DLCD
Office at (503) 373-0050; or Fax your request to:(503) 378-5518; or Email your request to '
mara.ulloa@state.or.us - ATTENTION: PLAN AMENDMENT SPECIALIST.
bate Received: I -,;7 -tJ7
J:\pa\paa\fomis\form2word.doc Planner: DR reVIst:U; III/LOOS
I CITY OF SPRINGFIELD DEVELOPMENT SERVICES DEPARTMENT,I
, NOTICE OF DECISION
SPRINGFIELD CITY COUNCIL
METRO PLAN I RE:FINEMENT PLAN MAP AMENDMENT &
ZONING MAP AMENDMENT
DATE OF NOTICE:
July 18th, 2007
July 16th, 2007
DATE OF DECISION:
JOURNAL NUMBER:
ZON2007-00012 & LRP2007-00013
APPLICANT:
peaceHealth
I NATURE OF REQUEST
The applicant requested approval of a Metro Plan I Refinement Plan iyIap Amendment to
the Eao;t Main Refinement ~Ian and a concurrent' Zoning Map Amendment. Specifically,
the applicant' proposed to change the Metro Plan designation from Light Medium Industrial
(LMI) to Commercial and a concurrent Refinement Plan Amendment .md Zoning Map
Amendment from LMl.lo CC. The applicant sought approval of these 'amendments in order
to facilitate development of a future medical office building on the site.
I LOCATION OF PROPERTY
The request involved two contiguous properties 'near 44th and Main Street. The subject,
properties are specifically identified as Lane County Assessor's Map No. 17-02-32-00 Tax
Lots 400 and 402.
I DECISION
The Planning Commi,ssion held' a public hearing and work session to consider the
applications on June 5th, 2007 and deliberated on the applications on June 19th, 2007. The
Planning Commission voted unanimously (5-0) to recommend City Cpuncil approval. On
July 2nd, 2007, the City Council held a work session and public hearing on the subject
applications. The City Council. voted unanimously (6-0) to approve the'subject
applications. .
,
IAPPEAL
Pursuant to ORS 197.830(2)(b), a notice of intentto appeal may be filed with the Land Use
Board of Appeals (LUBA) by those who appeared before the local government, special
district or state agency orally or in writing. If you wish to appeal, you must file a notice of
intent to appeal with the LUBA no later than 21 days from the date the decision was mailed
to you by, the local government. Copies of the notice of intent to appeal must be served
upon the local government and others who received written notice of the final decision
from the local government. The notice of intent to appeal must be served and filed in the
form and manner prescribed by LUBA, (OAR Chapter 66a, Division 100. Please call LUBA
at 503-373-1265, if you have questions about appeal procedures.
[ QUESTIONS
If you have any questions concerning this matter, please contact David Reesor, Planner III
at 541.726.3783.
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David Reesor, Planner III
'7 -{?I-o....."
Date Received: /
Planner: DR
, "
ORDINANCE NO.
6200
Date 'ReceiVed: 7/, ~I 07
Planner: DR ~ ( ..
(General), ' z.
/'/1Ze))
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 INDUSTRIAL (LMl), TO COM-
MERCIAL WITH AN AUTOMATIC REDESIGNA TION TO THE EAST MAIN REFINE-
MENT PLAN FROM LMI TO COMMUNITY COMMERCIAL (CC).
THE COMMON COUNCIL OF THE CITY OF SPRINGFIELD FINDS THAT:
1. 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 Melro Plan amendment is enacted that requires an amendment to a refinement
plan or functional plan diagram or map for consistency, the Metro Plan diagram
a;'endment 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 Development Code sets forth procedures for Refinement Plan
diagram amendments; and
4. On March 16'h, io07 the applicant/owner 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 Commercial with 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 4'h, 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'h, 2007 after the written record was left open for seven additional days 'and after
reviewing additional written testimony. The Planning Commission deliberated and voted unani-
mously (5-0) to forward a recommendation of approval to the City C,:)Uncil;, and
6. On July 20', 2007 the Springfield City Council held a work session and a public hearing
to co'nsider and to receive testimony and hear comments on this proposal. The City Council is
now ready to take action on this proposal based upon the above recommendation and the evi-
dence and testimony already in the record as well as the evidence and testimony presented at this
public hearing held in the matter of adopting this Ordinance amending the 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 incorporated herein by reference, is hereby
amended from Light Medium Industrial to Commercial.
ORDINANCE NO. A?OO
PAGE IOF2
Section 2. The East Main Refinement Plan designation of the subject property is hereby
amended from Light Medium Industrial 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 affect the validity of the remaining portion 6fthis 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-
formance of this amendment to the Metro Plan, applicable State statutes and applicable State-
wide Planning Goals and Administrative Rules, and is attached as Exhibit A.
ADOPTED by the Common Council of the City of Springfield this 16th day of
,Tulv ,2007by a vote of ~ for and ~ against.
APPROVED by the Mayor of the City of Springfield this 16t~ay of
July
.2007.
~(f
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ATTEST:
~~
City Recorder 0
REVIEWED & APPROVED
AS TO FORM .
;',..,.,.,.,.....3 \...0;0,\"'"'1
DATE:J..",,-2M-nf
OFFICE of CITY ATTORNEY
,
ORDINANCE NO, Ii/nn
PAGE 2 OF 2
ORDINANCE NO. 6201
Date Received:!/.l1k..7
Planner: DR. ~
(General) ( 2 p.-ro<:)..)
AN ORDINANCE AMENDING THE SPRINGFIELD ZONING MAP BY REZONING
APPROXlMATEL Y 5.24 ACRES OF LAND IDENTIFIED AS LANE COUNTY ASSESSOR'S
MAP 17-02-32-00, TAX LOTS 400 & 402, FROM LIGHT MEDIUM INDUSTRIAL (LMI) TO
COMMUNlTY COMMERCIAL (CC).
THE COMMON COUNCIL OF THE CITY OF SPRINGFIELD FINDS THAT:
1. Article] 2 of the Springfield Development Code sets forth procedures for Springfield
Zoning Map amendments; and
2. On March 16th, 2007 the applicant/owner of the subject property initiated the followirig
Springfield Zoning amendment
Rezone approximately 5.24 acres of land from Light Medium Industrial to Community
Commercial, Case Number ZON2007-000 12, for property identified as Lane County As-
sessor's Map 17-02-32-00, Tax lots 400 and 402; and
3. On June 4'h, 2007, the Springfield Planning Coml11ission held a work session and public
hearing to receive testimony' and hear comments on this proposal. A second public hearing was
held on June IS"', 2007 after the written record was left open for seven additional days and after
reviewing additional written testimony, The Planning Commission deliberated and voted unani~
mously (5-0) to forward a recommendation of approval to the City Council; and
4. On July 2"d, 2007 the Springfield City Council held a work session and a public hearing
to consider and to receive testim.ony and hear comments on this proposal. The City Council is
now ready to take action on this proposal based upon the above recommendation and the evi-
dence and testimony already in the record as well as the evidence and testimony presented at this
public hearing held in the matter of adopting this Ordinance amending the Springfield Zoning
Map.
NOW THEREFORE, based upon the foregoing findings the City of Springfield ordains
as follows: '
Section 1. The Springfield Zoning Map, more particularly described in Exhibit A at~
tached hereto and incorporated herein by reference, is hereby amended from Light Me-
dium Industrial to Community Commercial.
Section 2. 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 affect the validity ofthe remaining portion of this Ordinance.
FURTHER, although not part of this Ordinance, the Springfield City Council adopts
findings 1-4 herein above, and the findings set forth in the Staff RepOli which demonstrate con-
formance of this amendment to Section 12.030 of the Springfield Development Code and to ap-
plicable Statewide Planning Goals, and is attached as Exhibit A.
ORDINANCE NO. 6201
PAGE I OF2
ADOPTED by the Common Council of the City of Springfield this 16 t:h day of
July, 2007 by a vgte of L for and ......2- against.
AP.PROVED by the Mayor of the City of Springfield this16thday of
-~~
July
Mayor I
ATTEST:
~. .ktrvJt-
City Recorded
REVIEWED 8. APPROVED
~ TO FORM \
~.....~..)......~
DATE: 1,..,-7~~n,
OFFICE OF GIn' ATTORNEY
ORDINANCE NO, fi201
'PAGE 2 OF 2,
,2007.
,
EXHIBIT A
SP.RINq~11!1..D
Type II Metro Plan Map Amendment
&. Zoning Map Amendment.
Staff Report and Findings
Hearina Date:
June 4"', 2007 - Planning
Commission
June 18"', 2007 -
Planning Commission
July 2od, 2007 - City
Council
Acolicant
Case Number:
ZON 2007-00012
LRP 2007-00013
Date Received: '71 i g 07 -
Planner: DR ~, '
(' I zo eA-6<:~5)
Andrew Head (TL 402)
1616 Ardendale Ln.
Eugene, OR 97405
t,oolicant's
Representative
Philip Farrington. Alep
Director, Land use
Planning & Development
PeaceHealth 0regon .
Region
123 International Way
Springfield, OR 97477
Owner
PeaceHealth Oregon Region
123 International Way
Springfield, OR 97477
Hyland Business Park, LLC (TL 400)
Attn: Shaun Hyland
, 1941 - A Laura Street
Springfield, OR 97477
'......" .
Date Submitted: March 16"', 2007
EXECUTIVE SUMMARY:
The applicant is seeking approval of a Metro Plan Amendmeni I Refinement Plan
Amendment and a concurrent Zoning Map Amendment from Light Medium Industrial
(LMI) to Community 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 ~r 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 44th and Main Street (Highway 126). The site'consists of
two parcels, and is located on approximately S,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 designaledCommunity CommerciaL
As mentioned in findings in this report, Staff supports the proposed Metro Plan I
Refinement Plan and Zoning Map Amenpment. As noted in the City of Springfield's 2000
LRP2007.000 I J 8< ZON2007-000/1
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 Goal 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 P'lan
Amendment is a Type II Amendment, meaning it is site specific and is located within the
city limits.
In order to approve these'applicatioris, the applicant ~ust 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 Commission. Upon review of the
evidence provided by the applicant, site visits, existi'ng structures/uses and review of the
applicable' criteria of approval, staff finds that the applicant's reg<Jest for a Metro Plan /
Refinement Plan Amendment and concurrent Zoning Map Amendment from LMI to CC
is appropriate for the subject property andrecommends the Planning Commission'
approve the attached Order and forward the proposal 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 located near Main Street and 44th Street. A
Metro Plan Amendment at this time (not during Periodic Review) is known as a Post
Acknowledgement Plan Amendments (PAPA). This same acreage on the site is being
proposed for a concurrent amendment to the Springfield zoning map from LMI to
Community Commercial (CC), as allowed in Springfield Development Code (SDC) .
12.020 (1)(a)1. .
,I
Pursuant to SDC 7.110(4), approval of the requested MetrbPlan diagram amendment
automatically amends the refinemel1t plan diagram and is processed concurrently. ' '
Findings of fact addressing the criteria of approval inSDC 7.070(3) are included in the
applicant's narrative statement and in this report..
SITE DESCRIPTION:
The 'subject site is located on approximately 5.24 acres identified as Tax Lots 400 and
402 on Assessor's Map No. 17-02-32~00.
The subject properties include a vacant, flat parcel (Tax Lot 4(0) 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, on the east by the Hyland
Business Park, on the north by an open area south of the Weyerhaeuser mill site (Tax
Lot 400) or an existing commercially zoned parcel (Tax Lot 402), and on the west by
other small-scale commercial enterprises (e.g., a cabinet shop and karate school)
fronting Main Street and residential homes along 44th Street west of Tax Lot 400,
2
LRP2007.000 13 & ZON2007-000/2
5-2
Commercial enterprises are located immediately south of the site across Main Street
(e.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 landscape 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 the 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) currently designates the subject 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 along 44'h.
Street is zoned and designated Medium Density Residential.
lRP1007-000/3 & ZON1007-00011
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Existing & Proposed Metro Plan Designation:
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?/ffi Change from Light Medium Industrial to Commercial
Metro Plan Designation
III Commercial MU
D Light Med. Indust.
D Low Den. Res,
D Med. Den Res.
.. Heavy Industrial
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June, 2007
LRP2007-000/3 &'ZoN2001-000/2
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Existing & Proposed R~finement Plan Designation:
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~ Change from Light Medium Industrial (LMI) to Community Commercial (CC). '
Refinement Plan
_ Community Commercial
low DenSITY Residential
Medium Density Residential
Ught-Medium Industrial
_ Heavy Industrial
>,;;;Xl Mlxed Use 2 & 3
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June, 2007
LRP2007-000/3 & lON2007.000 /2
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Existing & Proposed Zoning:
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Zonirg _
Medium Density Residential
low Density Resj~ential
... Community Canmercial
Ught Medium Industrial
_ I-eavy Irdustrial
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June, ZJ07
lRP2 00 7-000 /3 & ZON2007-000J 2
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Existing Site Conditions:
Existing commercial uses on TL 402
Existing modular units located on TL 400
LRP2007-000J3 & ZON2007-00012
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Existing empty structures on TL 400
Existing business park on properry located east of TL
400
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REVIEW PROCESS: ,
The proposed Metro Plan Amendment is a Type II Amendment because it is located
inside the city limits and is site specific. The applicant has requested that application
ZON2007-0001:? (Zoning Map Amendment) be raised to a Type IV review procedure
and be reviewed concurrentlY with the Type II Metro Plan I Refinement Plan Amendment
ApplicationLRP2007-00013. These two applications use similar criteria of approval and
have been combined into one staff report for ease of review, Both applications have
criteria requiring consistency with the Metro Plan and other similar criteria. Rather than
, repeat these criteria for each application, they will be addressed only once and then
referenced where appropriate. Criteria that are different will be addressed separately;
the end result will be that all applicable criteria will have been addressed.
'This application was submitted to the DevelopmentServices Department on March 16"',
2007, and deemed'as complete.on April 11lh, 2007. Notice for both applications was
mailed to Departmentot'i_and Conservation and Development ,(DLGD) on April 16"',
2007, Notice of the public hearing date was mailed Qut on Thursday"ApriI19, 2007 to ,
property owners within 300 feet of the proposed zone change per Section, 14.030 (1) (a)-
(n) of the SOC. Public notice of the hearing was pUblished in the local newspaper
(Register Guard) on May 171h, 2007, as required in Section 14.030 (2) of the SOC. No
written comments were submitted at the time of issuing this report.'
. .' .
METRO PLAN DESIGNATION:
The subject property is designated LMI as shown' in the Metro Plan diagram. The
subject property is part of the East Main Refinement Plan' (EMRP), which provides a
more localized scope related to Plan Designation. The subject property is designated
LMl on the Refinement Plan Diagram. Specific Findings related to the Metro Plan and
EM8P Street Refinement Plan Designation are written in this report.
METRO PLAN DIAGRAM AMENDMENT
CRITERIA OF APPROVAL -SDC 7.070(3)(a)-(b)
"The following criteria shall be applied by the City Council in approving or denying a
Metro Plan amendment application:
(a) The amendment must be consistent with therelevant Statewide
planning goals adopted by the Land Conservation and Development
Commission; and , '
(b) Adoption of the amendment must not make the Metro Plan internally
inconsistent. " '
CRITEORIA OF APPROVAL" SDC 7.070 (3)(a)
APPLICANT'S NARRA TJVE:
Consistency with Statewide Planning Goals:
LRP2007-000/3 &.zON2007-000/2
5,...B -
",
8
The following findings address compliance with Metro Plan criteria in SDC 7.070 (3)(a).
Approval of a Metro Plan diagrani"amendment also correspondingly changes the
applicable refinement plan diagram, as established in SDC 7.110 (4). '
APPLICANT'S NARRATIVE RELATED TO GOAL 1:
'Goal1- Citizen Involvement:"To develop a citizen involvement program ihat ins~res
the opportunity for citizens to be involved in all phases of the planning process.
Goal1 addresses the need to develop a citizen involvement program to ensu.re 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 nearey p'roperty 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 inthe procedure, the proposed amendments are consistent
with Goal 1. .
STAFF'S FINDINGS RELATED to.COMPLlANCE; WITH GOAL 1:
Finding 1: These applications comply with Goal 1 because they are being reviewed
under an acknowledged citizen involvement program.
As preyiously mentioned in this "report, notice for both applications was maiiedto ,
Department of Land Conservation and Development (DLCD) on April 16th, 2007.
Notice of the public hearing date was mailed out on Friday, May 11th, 2007 to
property owners within 300 feet of the proposed zone change per Section 14.030 (1)
(a)-(n) of the SOC. Public notice of the hearing was published in the local newspaper
, (Register Guard) on May 17th, 2007, as required in Section 14.030 (2) of the SOC.
Staff concurs with the applicant's written statement related to Goal 1.
!....
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 actions.
Goa1'z 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 Z 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 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. '
LRP2007-000 J 3 & lON2007-00012
9
~-1n,
The Metro Plan and the SDC, as well as the Statewide Planning Goals and applicable
statutes, provide policies and criteria for the evaluation of comprehensive plan
a'mendments. Compliance with these measures assures an adequate factual base for
approval of the proposed Metro Plan diagramaniendment. As discussed elsewhere in
this document, the amendments are consistent with the Metro Plan and the Goals.
Consequently, by demonstrating such compliance, the amendments satisfy the
consistency el~ment of Goal 2.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 2:
Finding 2: These applications comply with Goal 2 because the SDC requires,
consistency between the Statewide Planning Goals, the acknowledged Metro Plan,
adopted refinement plans and special area plans and the zoning.
,
Staff,concurs with the applicant's written statem.entrelated to Goal 2.
APPLICANT'S NARRATIVE RELATED TO GOAL 3:
Goal3 -Agricultural Land: To presefYe and-maintain agricultural1ands..
This goal is inapplicable because as provided iniOAR 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 not been in
ag'riculturaJ 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 or within the urban growth boundary.
Finding 4: Goal3 does not apply to these applications because the subject property
is within Springfield's city limits.
APPLICANT'S NARRATIVE RELATED TO GOAL 4:
Goal 4 _ Fore;'t Land: To conserve forest lands by maintaining the forest land base
and to protect the state's forest economy by making possible ecpnomicaJ/y efficient
forest practices that assure the continuous growing and harvesting of forest tree
species as the leading use on forest land consistent with sound'management of soil,
air, water, and fish and wildlife resources and to provide for redeational opportunities
and agriculture. '
Goal 4 does not apply within urban growth boundaries, per, OAR, 660-06-0020, and the
areas affected by the Plan amendments are'inside Springfield's ,acknowledged UGB.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL ~t
. ,. ~
Finding 5: The subject property is lo~ated within an acknowle6ged urban growth
boundary Goal 4 does not apply within urban growth boundaries, Staff concur with
the applicant's written statement related to Goal 4.
lRP2007-0001 J & ZONlo07-000/l
10
"_11
APPLICANT'S NARRATIVE 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.
Goal5 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 Springfield'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 amendment 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 applications because there are no
inventoried resources on the subject property. Oregon Administrative Rule 660"023"
0250 establishes the applicabi,lity of Goal 5 rules toPost Acknowledgement Plan
Amendments (PAPA), the requested Refinement Plan Amendment and Zoning Map
Amendment do not affect the Metro Plan's adopted Goal 5 inventory. Staff concurs
with the applicant's narrative related to Goal 5 compliance.'
APPLICANT'S NARRATIVE RELATED TO GOAL 6:
Goal 6 _ Air, Water and Land Resources Quality: To maintain and improve the quality
of. the air, water and la'nd resources of the state.
The purpose of Goal 6 is to maintain and improve the quality of the air, v.niter 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 ihat the applicant demonstrate,
that it is reasonable 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 envir~nmental clean-up list. A Phase 1
environmentai assessment on the subject property was conducted and .recommended
additional analysis. Upon recommendations through the Phase 2 environmental
assessment a nominal quantity of soil ,(Iess than 10 cy) impacted by earlier/historic use
was removed from the site and properly disposed. Given the nominal impact generated by
, historic uses on the site, it is reasonable to conclude that future development on the site
will be able to demonstrate compliance with City standards for water quality protection
LRP2007.0001] & ZON2007.000J 2
II
5-12
,through the ~ite plan r,eview process, thereby cOmplying with applicaple state and federal
environmental quality s.tandards.'
'ST AFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 6:
, '
Finding ~: 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 Transportation: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 a'ny of the.
Time of Travel Zones, which is regulated by, the Drinking Wate'r'Protection Overlay
District _ Article 17, Any new development onthe subject property is subject to
compliance with Article 17 and other applicable regulations related to Goal 6. Staff
;concurs with the applicant's narrative related toGoal 6 compliarce,
.1
APPLICANT'S NARRATIVE RELATED TO GOAL 7:
Goal 7~, Areas Subject to Natural Disasters and- Hazards: To pro,tect life andproperty
from natural disa,sters and hazards. . ,
Goal 7'requires that development subject to, damage from natural hazards and
disasters be planned and/orconstructed with appropriate safeguards and mitigation:
The goal also requires that plans be based on an inventory of known areas of.natural
disaster and hazards, such as areas prone to landslides, flooding, etc. '
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 7:
'. -,
Finding 8: Staff has reviewed the natural constraints map and the FEMA Floodplain
Map in relation to'the subject property, A~ noted by the applicant,the subject si~e is
not included in the City's inventory of known areas of natural hazards. Staff concurs
,with the applicant's narrative,related to GO,aI7 compliance.
The site is flat and not subject fa landslide 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 notalter'the City's acknowledged'
'.c;ompliance with Goal 7 through'its adopted 'plans, codes and procedures. .
..
APPLlC~NT'S NARRATIVE RELATED TO GOAL 8:'
Goal 8- Recreation Needs: To satisfy the recreational, needs ofthe citizens of the state
and visitors and, where appropriate, to provide for the siting of:~ecessary recreational
facilities including destinatio'n resorts. '. ' "
Goal a requires local governments to plan 'and providefor the siting of n.ecessary ,
recreatioriaffacilities to "satisfy the recreational needs of the citizens of the state and
visitors," and where appropriate, provide for the siting of recreational facilities including
destination resortS. The subject site is, riot included in an inventory of recreational sites,
and the proposed amendments will not have an impact on the community's recreational
facilities or needs; therefore, the proposal does not implicate Goal 8.
Il
LRP2007.000U & ZON2007.00012
,S~13
STAFF'S FINDINGS RELATED TO, CQMPLlANCE WITH GQAL 8:.
Finding 9: Staff has consulted the Willama/ane 20-year Parks and Recreation
Comprehensive Plan in relation to Goal 8compliance. The Willamalane 20-year
Parks and Recreation Comprehensive Plan'wasadopted by the City of Springfield as
p~lft ofthe Metro Plan's compliance with Goal 8. None of the various studies,
inventories, and facilities plans'regarding recreationaUacilities in the adopted
Willamalane 20-yeai 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, GQAL: 9:
Gaal 9 _ Ecenamic Develapment: To. pre vide adequate eppertunities thraughout the
state for a variety of economic activities vital.to the health, welfare, and prosperity of
Oregon's citizens. ' '
Gaal 9 requires the city to provide adequate oppertunities for a variety of ecenemic'
activities vital to. the health, welfare, and prosperity of the citizens. The propased
amendment to. the Metra Plan diagram w,i11 increase the city's capacity far ecanomic
development by adding 5 acres af CC in place af the 'existing industrial designation.
p'ermitting the constructian af future clinic facilities and allowing long-standing
cammercial uses'an Tax lat 402 to became canfarming uses consistent with commercial
zaning is cansistent with numerous paliCies in'the City's adapted plan far campliance with
Goal 9, the Springfield Cammercial lands Study (SClS).
Specifically, the follawing SClS palicies are applicable to the praposal:
Palicy 1-A: "Maintain'a mixed supply af large and smal'l cammercial sites through
strategies such as rezening or annexation to serve Springfield's future papulatian;"
The proposalJulfills this palicy objective by redesignating and - thraugh acco'mpanying
zane change _ rezaning land from industrial to. cammercial, fa'r two. taxlats af varying
sizes and 'commercial uses, thereby maintaining existing employment and cammercial use
in Tax lot 402 and praviding the ability for grewth in medical sectar emplayment by ,
allawing futu're clinic uses an Tax ,Lat 400. '
Palicy 1-C: "Maintain at least a five-year supply of cammercialland within the Urban
Growth Boundary (UGS) that is currently served ar readily serviceable with a full range af
urban public facilities and services." .
The SelS (see Table'3-8, pg. 32) faund thereto be a deficit 01158 acres in the supply af
commercial land aver demand projected through the year 2015. The propasalwauld allow
far redesig[lation, and rezening, af five acres thereby reducing t.he.deficit af cammercial
land. The subject site has a full range of urban public facilities and services available to
suppart existing commercial development on Tax lot 402, and future development on Tax
lot 40'0. The SClS identifies (pg. 33) a need to. suppart "emplayn:ent in population-
dependent sectars such as retail sales and healttiservices" to meet Springfield's growing
community. The SClS also noted (pp. 27~29) state and lacal trends in greater emplayment
in retail tr<ideand well-paying health~ervices sectors. Approving the propased
redesignation and zone change wauld help meet springfield's demonstrated need for
emplayment and cammercial services.
13
LRP2007,OOOI] & ZON2007-0001 2
S-1d!
o ~
Finding 3. in the SCLS(p9. 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
corisistentw\th SLCS Implementation Strategy 3,A (1): "Evaluate inv,entories basedon
d~monstrated need for the planning period. Initiate rezoning or rede~ignation 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 OLGO as being consistent with Goal 9.
Oregon Administrative Ruies concerning Goal 9 implementatiory (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 ha've to address applicable planning requirements - 'such as consistency
with the Metro Plan and other local plan poliCies (i.e., SCLS) or be consistent with an
economic opportunities analysis. The City can find that the proposal complies with
relevant local plan policies by converting one form or employment-generating land use to
another,without negatively impacting the supply of buildable lands for either category of
uses. Jhe proposal enables continued use of the eXisting and long-standing commercial
center to continue to operate,and provide employment opportunities, while also allowing
higher-valu"e employment associated with future deyelopment on Tax Lot 400, These
types of employment-generating uses are among those identified in OAR 660-009-0005(6)
as eligitile 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 an'd 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 iequest is
consistent with the Giiy'S compliance with, Goal9 and applicable ad~inistrative rules '
regarding Goal 9 implementation.
Additional Goal, 9 information submitted by applicant on March 28th, 2007:
The Metropolitan Industrial Lands Study (July 1993) was adopted by the local jurisdictions
and acknowledged by LCOC a~ being consistent with statewide pianning goals and the
Metro Plan, specifically fulfilling the Eugene-Springfield area's obligations ''-nder Goal 9
(Economic Development). The Metropolitan Industrial Lands"lnventory 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,f,ee 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 S (Natural
Resources). As shown in' Attachment A, that anaiysis indicated that even removing the
'possible industrial acreage affected by GoalS protection measures,,(about 100 acres
debited from the Eugene and Springfield inveniories) would leave a:surplus' of industrial
lands of between 1,600 and 2,122 acres metro,wide. . .
Staff's Goal 5 work also calculated the changes in industrial land supplies since 1991 as a
consequence of Metro Plan diagram changes (see Attachment B). This analysis
demonstrated a reduction in less than 90 acres of industrial land over the past1S years,
LRP2007-000J J & ZON2007-000 /2
/4
. 5':"15,
"t, ";:,,,
sl1ggesting that there is still an ample supply of available industrial lands to meet existing
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 inve'ntory of LMI zoned
and designated land due to' City Council approval in April 1997 for land east of the 28'"/31"
Street connector and north of Marcola Road (Ordinance No. 5851). Insofar as the City and
metropolit~n area continue to enjoy a surplus of needed Industrial land, and specifically
Heavy Industrial zoned and designated land, the ,above-referenced change added more
than enough acreage to the inventory of LMI designated and zoned land to off-set the
proposal to remove only about 5 acres from the LMI inventory.
We therefore respectfully submit that the proposed Metro Plan diagram amendment and'
zone change will not materially affect the inventory of needed Industrial land and will ':'ot
alter the City's continued'compliance with Goal 9.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 9:
Finding 10: The City o(Springfield has two adopted inventories which support the
proposed Metro Plan Amendment ( Refif1ement' Plaf1 Amef1dmellt alld cOllcurrent zolle
challge request -the 1992 Illdustrial Lalld Study af1d the 2000 Commercial Laf1d Study.
. The applicant references both of these adopted inventories and sites specific polices
which support the proposal. As noted by the applicaf1t, Finding 3 in the Springfield "
Commercial Land Study (SCLS) cited the ackf10wledged 1992 lf1dustrial Land Study.as
demof1strating that "a surplus of if1dustrial sites exists in the, Metro Area." The applicaf1t
also r~feref1ces Strategy 3-A(1) of the SLCS which states:."Evaluated'inventories based
Of1 demonstrated f1eedlorthe plaf1nif1g period. Initiate rezoning or redesigf1ation of .
surplus land uses where more appropriate for commercial, consistef1t with the Metro
Plan." Staff fif1ds 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 proviaes a more up-to-date
analysis of industrial lands in the Metro area. As noted inthe 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 for amendments to land use de1ignations "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 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 or employment-generating land use to
another, without negatively impacting the supply of buildable, lands for either category of
uses. As noted.by the applicant. there are existing commercial uses located on TL 400
which are part of the subiect property Additionally, the applicant is seeking to develop
future commercial uses on the property which will maintain the property foremployment-
generating activity.
lRP2007-000 13 & ZON2007-00012
15
~~1fi
,
. Given the information provided in the adopted commercial and industrial lands
inventories (a shortfall of commercial and an inve.ntoried excess of llldustrialland)
compared with the size of the proposed. Plan Amendment and Zone',:Change, staff,find
that the proposal is consistent with Goal g requirements, Staff finds that the proposal
does not represent a ."significant change' to the adopted EOA.,
T . ..'
APPLICANT'S NARRATIVE RELATED TO GOAL 10:
Goal 1 0 _ Housing: To provide for the housing needs of Citizens of the state.
LCDC's Housing goal requires cities to maintain adequate supplies of buildable lands for
needed housing, based on an acknowledged inventory of build_able lands. The proposal
does not aff~ct the City's inventory of residential lands.
In fact, approval of the requested redesignation for Tax Lot 400would 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 benefit the adjoining residential properties. Because the'
proposal involves redesignation from industrial to commercial land 'uses, it does not affect
Springfield's continued qompliance with Goal 10. .
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 10:
,.
Finding 11: The proposed Metro Plan I Refinement Plan Amendment and Zoning
Map Arilendment does not affect the Metro Plan's residential buildable lands
inventory because no residentially designaied 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 1 0 compliance. .
"
'.
APPLICANT'S NARRATIVE RELATE!;) TO GOAL 11:
Goal 11 _ Public Facilities and Services: To plan and develop a timely, orderly and efffi:ient
. arrangement of public facilities and services as a framework for urban and rural
development.
, .'
OAR 660-011-0005(7)(a)-(d) Definition of Public. Facilities':
(a) Water
(b) Sanitary Sewer
(c) Storm sewer
(d) Transportation
Thi,s 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 a/use. The propqsed 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. '
/6
lRP2007-0001J & ZON200 7-000 I 2
5-17
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 11:
Fin-ding 12: As noted by the applicant, the Metro Plan and associated facility plans
have been acknowledged to conform to Goal 11 ensuring that public facilities and
services are currently available to the subject site. The proposed Metro Plan I
Refinement Plan Amendment and Zoning Map amendment is on"infill" property.
which currently has city services available to the site. The proposal does not affect
the Metro Plan's compliance with Goal ,11.
Finding 13: The subject Metro Plan I Refinement Plan Amendment and Zoning Map
Amendment applications have been reviewed by Public Works and Planning Staff to
assure that there are adequate public services to serve the ,site. These applications
comply with Goal11 because there are urban level public services available to the'
subject property.
APPLICANT'S NARRATIVE RELATED TO GOAL-12:
'Goa'/12 _ Transportation: To provide and encourage a safe, co,nvenient and economic
transportation system.
Goal12 requires local governments to provide and encourage a safe, convenient and
economical transportation system. The proposed map amendments involve
approximately 5.24 acres of property, though existing a'nd long-standing commercial uses
occur on Tax Lot 402 such that approval of the proposal will not result in any changes to
the type or intensity' of uses on the site, and'will not increase the trip generation for that
parcel. As the attached Trafficlmpact Analysis (TIA) demonstrates, future development of
medical office facilities on TL 400 will not degrade mobility standards below_acceptable
levels and allow for adequate queuing lengths at applicable intersections. Therefore, the
proposal will not have a "significant effect" on transportation facilities as defined in the
Transpcrtatich,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 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 approximately in the center of the parcel.
The TIA demonstrates that these access points will not result in any degradation of
, mobility standards below acceptable lev'el~, and that safe and efficient circulation can be
realized through approval of the r~quested land use:redesignation (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 Goal 12 and
applicable local implementing policies.
STAFF'S fiNDINGS RELATED TO COMPLIANCE WITH GOAL 12:
Fincling:1"4: The proposed Metro Plan Amendment is from LMI to Commercial, and
Refinement Plan Amendment I Zoning Map Amendment is from LMl to ee. Tne
applicant indicates in the submitted narrative that approval of the proposal will not result
/7
lRP1007-000 13 &,ZON1007.00011
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 cbncur,however, with the applicant's
statement if the future medical office use ,is in fact developed on the site, and not other
potential "reasonable worse case" CC uses, . '
Pages 18"19 of the applicant's riA list Peak Hour Trip Generation for both the existing
zone (LMl) 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 app,licant 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 researc;hed potential vehicle trips
per day for potential uses in the CC zone. There are some other potential uses in the CC
zone which are much more intensive uses th,m Medical Office. In considering what a
"reasonable worst case" development scenario migl1t be for the re-zoned condition it is
clear that a 30,000 square foot Medical Office Building is much less)ntense than other
uses that would be permitted in the CC zone. On a per-square-lootbasis the Medical
. .. '. ..
Office is estimated to generate 2047 vehicle tips/1.,OOO.SF'and 3,43 vehicle tips/1 ,000 SF
during the AM and PM peak hours respectively, For comparison the average rates for a
"Fast-Food Restaurant with Drive-Through Window" are 53.11 vehicle tips/1 ,000 SF and
34.64 vehicle tips/1.000 SF. These calculations are taken from the Institute ior Traffic
Engineers (ITE) Manual: '.
"
As shown on Table'S of the TIA, a reasonable worse case traffic generation scenario for
the existing zoning (LMI) is 243 trips. The proposed use of 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, etc). Planning
Staff met multiple times with City Traffic Engineering Staff and ODOTStaff to review the
'submitted TIA. ODOTs review of the submitted TIA indicated that there were multiple
issues that were not adequately addressed in the submittedTIA 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
emalls from ODOT and City Traffic Engineering Staff). In order to preserve the existing
and future road system, staff recommends that a trip cap be required as a condition of
approval not to exceed tJ're reasonable worse case scenario for the existing zoning (243
trips) Because these' numbers of trips are already allowed with the existing zoning, the
application complies with Goal 12. ' .
RecommendedCondition of Approval: '
1, Trip generation from development on the subject property shall be limited to a
maximum of 243 PM Peak-hour vehicle trips, which is based on a "reasonable worse
,case development scenario" under the existing zoning (LMI) as submitted by the
applicant in the Traffic Impact Analysis for the subject property.
18
lRP200/-000 I J & ZON200/-00012
5-19
APPLICANT'S NARRATlVE RELATED TO GOAL 13:
Goal 13.- Energy' ConselYation: To conselYe 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 provides limited guidance for site-specific
map amendments. Tne 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 notalter 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 PJan.
APPLICANT'S NARRATIVE RELATED TO GOAL 14:
Goal t4 _ Urbanization: To provide for an orderly and efficient transition from rural to
urban land use. .
Goal 14 requires local jurisdictions to provide for an "orderly and efficient transition from
rural to urban land use." The subject property is within the UGB and the city limits of
Springfieid, and within an existing urbanized area of the community. Therefore, Goal 14 is
not applicable to this application.
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 14:
Finding 16: As noted by the applicant, all of the parcels affected by this application
, are currently within the Urban Growth Boundary and 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 subject site. The proposed Refinement Plan and Zoning Map
Amendment are'in compliance with Goal,13. .
APPLICANT'S NARRATIVE RELATED TO GOAL 15:
Goal 15 _ Willamette River Greenway: To protect, conselYe, enhance and maintain the
natural, scenic, historical, agricultural, economic and recreational qualities of lands
along the Willamette River as the Willamette River Greenway.
This goal is inapplicable because the subjeft property is not within the boundaries of the
Willamette River Greenway. "
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 15:
Finding 1i 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.
LRP2007.000 /3 & ZON2007.DDO 12
/9
,,5-20 .
APPLICANT'S NARRATIVE RELATED TO GOALS 16-19:
Goal 16 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 WITH GOALS 16"19:
Finding 1 S: As noted by the applicant, the subject site is not located within any
coastal, o~ean, estuari~e; or beach and dune resources related area. Goals 16-19 do
not apply to these Refinement Plan and Zon,ing Map Amendment applications. .
CRITERIA OF APPROVAL - SDC 7.070 (3)(b)
APPLICANT'S NARRATIVE RELATED TO SDC 7.070(3)(b):
The application requests amendment of the Metro Plan diagram from LMI to CC for
approximately 5.24 acres. This" section of the ap.plication narrative addresses the
consistency of the amendment with the applicable policies of the Metro Plan, to. .
demonstrate that adoption of the amendment will riot make the Metro Plan internally,
inconsistent (as required by the approval criteria in SDC 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 goals, 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, Section 0 provides' the following definitions:
A goal as a broad statement of philosophy that describes the hopes of the
people of the commun'ity for the future of the community. A goal. may never be
completely attainable, but is used as a point to strive for.
..'
o.
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
interm~diate 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 comm~nity towards attainment of its goals.
. "
Except for the Growth Management Goals, which are addressed below, each of the Metro
Plan policies are addressed in the order in which they appear in the Plan Element section
of the Metro Plan. " " " .
,..
Metro Plan Elements
1. Growth Management
lRP2007.000/3 & ZON2007.iJ0012
20
.~-21
Policies
1. 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 inside, the urban growth Qoundary.
The proposed amendments satisfy this policy because the subject 'property is inside the
UGB and ,city limits and as such, encourages compact urban growth., Also, urban services
are available at sufficient levels to accommodate the existing and future infill development
resultin-g 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",lopment near employment 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 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
developments located east of the site along Main Street. -
However, approval ofthe 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 Lot400, consistent with the above policy. 'The areas' proposed for redesignation offer
'existing and future employment opportunities and provide commercial services along a
major transportation system that can support the needs of nearby residential '
development.
A.22 Expand opportunities for a mix of uses in newly developing areas and existing
neighborhoods through local zoning and development regulations. '
The map amendment and concurrently proposed zone change will allow for existing,
commercial uses on Tax Lot 402 to continue to 'serVe existing neighborhoo~s in the mid-
and east-Springfield area, and for future clinical facilities to be developed to serve this
rapidly growing area of the community. Approving the requested redesignation and zone
change would expand commercial opportunities to serve these neighborhoods consistent
with the above policy. .
3. Economic Element
Policies
B.1 Demonstrate a positive interest in existing and new industries, especially those
providing above-above wage and salary levels, and increased variety of job opportunities,
a rise in the standard of living, and utilization of our existing comparative advantage in the
level of education and skill of the resident labor force.
The proposed amendment is consistent with this policy because it will allow medical clinic
uses to be developed to serve growing areas in east and south Springfield. As is
observed in the Springfield Commercial Lands Study (pp. 27, 29), employment in health
services is growing and approving the requested redesignation will enable increased job
LRP2007.000 13& lON2007-000/2
2/
~:"22
,.
opportunities with higher than average wages th~reby helping raise the standard of living
and meet the needs of Springfield citizens, consistent with the above policy. .
8.2 Encourage'economic development which utilizes local and imported capital,
entreprenewial skills, and the resident labor lorce,
The construction of and the use of commercial and medical uses will utilize both iocal and
imported capital and will employ the local labor fprce in a variety of skilled, semi-skilled,
and unskilled positions, consistent with this policy. .
8.6 Increase the amount of undeveloped land zoned for light industry and commercial
uses correlating the effective supply in terms of suitability and availability with the
projections of demand.
The proposal will add approximately 5.24 acres of Community Commercial land,
consistent with recommendations to increase the co.mmerciallands inventory made in the
Springfield Commercial lands Study. The SClS a'nd acknowledged metropolitan
Industrial linds 'Study concluded that there is a'deficit of needed commercial land, and a
surplus of ihdustrially zoned and designated land. Approval of thi; requested
redesignation will not cause the inventory of ne~ded industriai 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 forcommercial uses with the need for such
uses as demonstrated in the adopted SClS.
8.11 Encourage 'economic activities which streQgthen the metropolitan area's position as
a regional distribution, trade, health, and service ce'!t~r. '
The amendment wilrfacilitate 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 greatest possible,degree of diversity, a broad variety of
commercial, residential, and recreational land u,ses shall be encouraged when consistent '.
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 commercial uses to occur on the subject property. long-standing existing
commercial services on Tax lot 402 would be allowed to continue without the specter of
being considered non-conforming uses, and Tax lot 400 could be developed with medical
services that will serve the needs of the growing' residential areas east and south of the
,subject site, consistent with the above policy." '
7. Transportation Element
land Use policies
F.3 Provide for transit-suppo'rtive 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
lRP2007-0001] 8: ZON2 00 7-000 I 2
21
~-?1
develapment and redevelapment in designated areas that are ar cauld be well served by
existing ar planned transit." " '
The proposed map amendment and concurrent zane change will enable land use patterns
and development consistent with the abave, palicy. Appraval of the proposal will allow far
higher intensity development along Main Street, a major transit corridor. An existing L TO
stop is located an the frontage of Tax Lat 400 (see photo, pg. 2, Appendix A of the TIA),
and will pravide convenient access to existing and projected employment on the subject
site, as well as access for patients to future out-patient medical facilities projected on Tax
Lot 400.
Transportation System Improvements: Roadways Policies
F.15 Motor vehicle level af service policy:
a. Use motor vehicle level of service standards to. maintain"acceptable
and reliable performance an the roadway system. These standards
shall be used for: --.
(1) Identifying capacity deficiencies an. the roadway syste[11.
(2)Evaluating the impacts on roadways Of am~ndments,to'
transportation plans, acknawledged camprehensive plans and
land-use regulations, pursuant,ta the TPR (OAR 660-012-0060).
(3) Evaluating development applications far consistency with the land-
use regulations of the applicable lacal gavernment jurisdictian.
b. Acceptable and reliable perfarmance is defined by the follawing
levels af service under peak haur traffic conditions: LOS E within
Eugene's Central Area Transpartatian Study (CAT~) area, and LOS
D elsewhere. '
c.. Perfarmance standards fram the OHP shall be applied an state
faciii\ies in the Eugene-Springfield metropolitan. area.
In same cases, the level of service may be substandard. The lacal government
jurisdiction may find that transportation system improvements to. bring performance
up to. standard within the planning harizon may nat be feasible, and safety will not be
compromised, and broader community gaals would be better served by alia wing a
substandard level of service. The limitatian on the feasibility af a transportatian
system improvement may arise from severe constraints, including but not limited to.
. enVironmental conditions, lack af public agency financial resources, or land use
constraint factors. It is not the intent of TSI Raadway Policy #2: Motar Vehicle Level
of Service to require deferral of development in such cases. The intent is'to defer'
motor vehicle capacity increasing transpartation improvements until existing,
, canstraints can be avercome ar develap an alternative mix of strategies (such as:
. land use measures, TOM, short-term safety improvements) to. address the problem.
Subsection a.(2) in the above policy r~quires an evaluation af the,proposal pursuant to the
state Transportation Planning R.uhi (TPR). The accompanying Traffic Impact Analysis
provides the factual basis to determine that the proposed redesignation would not result
in a "significant effect" as defined under the TPR (OAR 660-012-0060(1)).
Specifically, the proposal does not change the functional classification of Main Street 'or
any other nearby roadway, and it does not change the standards for implementing the
City's functional classification system of roadways, as identified in the Regional
Transportation Plan. As demonstrated in the TIA, the proposal aiso does not:
. Result in types or levels of traffic or access that are inconsistent with the
functional classification of Main Street or any other nearby roadway;
23
LRP2007-000 13 & lON2007-00012
Fi-?4
.
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 existing facilities worse (i.e., below acceptable
mobility standards) than wauld be:the case other uses permitted under
existing d,esignations or zoning. '
.,
Specific TPR findings are further located in the TIA, see pp. 31-32. Because the proposal
does not result in a "significant effect" as established by applicable OARs, no further TPR
analysis is required. The, request is th~refore consistent with;the above policy.
8. Public Facilities and Service Element
,
\
G.1 Extend the minimum level and fu/l range af key urban facilities and services in an
arderly 'and efficient manner consistent with the grawth management'palicies in
Chapter /I-B, relevant policies in this chapter an? other Metra Plan palicies.
The subject property is located in Springfield's city'limits UGB. .AII necessary
infrastructure and key urban facilities/services are present to. serve existing develapmerll
(Tax Lot 402) or are available to serve future infill develapment on Tax Lot 400. Therefore,
the proposal is consistent with the above jl.Olicy;
9. Parks and Recreation Facilities Eiem;~t Palicies
Policies in this element of the Metro Plan are riot relevant to the iequested diagram
amendment. '
10. Historic Preservation Eiement Policies'
, Palicies in this element cif 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 TOSDC 7.070(3)(b):
Finding 19: The requirement of this criterion that adoption of these proposed
applicatio~s not make the Metro Plan internally inconsistent does not mean that every'
goal, objective, finding and policy of the Metro Plan must support these applications,
Because of recognized conflicts in the Metro Plan, the proper inquiry is whether on'
balance the most relevant of the Plan polices.support the Metro Plan Diagram
Amendment. The applicant's narrative di,scus~es numerous Metro Plan Policies and
Elements related to the proposal. '
Staff has reviewed the applicant's choice of a'pplicable Metro Plan Policies and Elements
and concur that the noted Policies and Elements are applicable to the proposal. Findings
addressed regarding Goal 9 and Goal 12 in this report, also support the stated Metro
Plan policies. Specifically, as conditioned in th.is report' r.elated to Goal 12 compliance,
the Metro Plan Transportation Element and Transportation Policy F.15 are satisfied.
LRP2007,000I3 & ZON1007-00011
14
~-25
1;he stated P.olicies andElements have been reviewed by staff and are,found to be
applicable and consistent with the proposal. .
, REFINEMENT PLAN MAP AMENDMENT
CRITERIA <?F APPROVAL - SDC8.030 et seq.'
\
In reaching a decision on these actions, the Planning Commission and the City
Council shall adopt findings which demonstrat" 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)-(3):
. . - ". " : . -
.~, ,
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. As noted in the applicanfs narrative, sac 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..: '
There is no refinement plan text amendment' proposed as part of lhis application.
Therefore, no separate refinement plan application is required. As stated in the above
referenced section of the SOC, the refinement plan is automatically amended upon
approval of the Metro Plan amendment.
Theapplicanl's narrative related to consistency with specific refinement 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'SOC 7.030(a) - (b) and SOC 8,030,
Upon review of the evidence' provided by the a.ppl'lcant, site visits, existing
structures/uses and review of the applicable criteria of approval, staff finds that'the
applicant's request for a Metro Plan. & Refinement Plan Map Amendment is appropriate
for the.subje~t property with the following recommended condition of approval:
1. Trip generation from aevelopment on the subject property shall be limited to a
maximum of 243 PM Peak-hour vehiCle trips, which is based on a "reasonable worse
case development scenario" under the existing zoning (LMI) as submitted by the'
applicant in the Traffic Impact Analysis for the subject property.
LRP2007-000 13 & ZON2007-00012
25
5-26
ZONING MAP AMENDMENT
CRITERIA OF APPRbV AL - SDC12.030 et seq.
SDC 12.030' (1) _ Quasi-judicial Zoning Map Amendments - The' Planning Commission or
Hearings Official may approve. approve with conditions or deny. a quasi-judicial Zoning Map
amendment based upon approval cntena (3)(a)-(c) below. The Planning Commission or Hearings
Official shall, make the final local decision on all quasi-judicial Zoning map amendments that do
not include a Metn?Plan iJiagram amendment. '
SDC 12.030(3) Zoning Map amendment criteria of approval:
'(a) Consistency with applicable Metro Plan policies and the Metro Plan diagram
(b) Consislency with applicable Refinement 'Plans, 'Plan District m~ps, Conceptual
Development Plans and functional plans; and ' .'
(c) The property is presently provided Wijll adequate public facilities. services and
transportation networks to support the use, or these facilities, services and transportation
networks, are planned to be provided ~oncurrently with ttie development of the property.
NOTE FROM STAFF REGARDING APPLICANT'S ZONING MAP AMENDMEN7.',
NARRA TIVE: The applicant's narrative for the Zoning Map Amendmentis similar
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
a'ppli~ant's written narrative in its, 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 been addressed in.this report. The applicant is proposing a. ,
Metro Plan Map AmWldment as part of this application from LMI to Commercial. Upon
approval of the Metro Plan Amendment application (LRP2007-00013), the proposed
zone change will be consistent with the Metro Plan diagram.
Conclusion: :rhe proposed rezone request is consistent with Metro Plan policies and
the Metro Plan Diagram,
APPLlCANTS'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 13 & ZON2007-00012
26
.5-2L
Policy 2) Area #2
A) The following land ui;'es .are allowed under Community Commercial zoning:
All Communitv Commercial uses subject to Article 18 of the Sp~ingfield
, Development Code. '
The proposal requests redesignating the subject properties to Community
'Commercial, and concurrently rezoning the pr,operties to CC, as is allowed by the
above policy and consistent with,other EMRP policies. Approval of the request would
allow long-standing existing commercial uses on Tax Lot 402 to continue as permitted
under Article 18, and consistent with neighboring uses to the west and south, which
are also zoned and designated for commercial uses. '
2. Commercial Element
Criteria for CC)mmercial Refinement Plan Desicnation
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 subjectsite along 44th Street, and is therefore consistent with the above criterion.
B) where it does noUncrease conflict between Low Density Residential
and Commercial;
Although the abutting res.idential area is .zoned Medium Density Residential, it is
developed in low density residential uses. Approval of the proposed redesignation of
the subject sites would actually result in a decrease of coriflicts between abutting
residential and non-residential land uses by allowing future infill development on Tax
Lot 400, and through the site plan review process establishing improved landscaped
buffers and a use more compatible than the industrial uses that historically abutting
this residential area.
,C) where criteria for designating Medium Density Residential land does
not apply;
Criteria for des.ignating MDR land does not apply to the subject site.
D) where legally created commercial uses exist;
Tax Lot 402 has existing, long-standing commercial uses that were legally created
prior to development of the Metro Plan or EMRP.
E) where adequate customer and service access to an arterial street can
be provided; ... and -
The subject site has adequate legal access ,onto Main Street, which 'is classified as an
arterial street.
LRP2007-00013 & ZQN2007-00011
8-128
"
.
27
. ,
F) where designated Commercial.on the Metro Plan Diagram.
Approval of this application would result in a Commercial designation:ontheMetro
Plan diagram, which would also automatically, modify the designation o'n theEMRP
diagram.
Policy 2) Apply site-specific Commercial refinement plari designations to clearly define
the limits, of new coml71ercial uses where there is,not an existing, legally established, and
beneficiai'mixing of us'es. ' '
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 limits of new commercial uses between the pre-
existing 'commercial uses on Tax Lot 402 and others .to the west, and the developed
industrial business park to the east. Tax Lot,400 does not have an existing or
beneficial mix of uses, but has historically housed industrial yard-type operations.
Therefore, approval of 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) Reduce the number of ~ehicular access points and require'the r~buildirig of
curbs and installation of sidewalks and street trees a/o'ng Main Street, through the Site
Pllm Review process and in public improvement projects.
The proposal w~uld 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 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 residential uses through Article 31 of
the Springfielq Development Code, SitePlan Review process.
Existing residential uses along the east side'of 44th Street have h'ad no real buffer from
pre-existing industrial uses on Tax Lot 400. Approval of the proposal would allow for
attractive infill developm~nt of future,medic~1facilities that would provide (through the
SPR process) improved limdscaped buffers between the fut!-,re use and existing
residential area to the west - as required by Code, and consistent with the above
policy.
3. Industrial Element
Policy 1) The City shall encourage efforts of va(ious agencies to attract new and retain
existing jobs"and businesses. "
Imoiementation
The City shall maintain a current inventory of vacant commercial andindusirialland and
structures within theEast Main area.
Consistent with the above policy, approval of the requested redesignation will enable
existing, long-standing jobs and businesses on Tax Lot402 to r,emairi as legal,
conforming land uses, and allow future development of new empl?yment on rax Lot
LRP2007-000J J & ZON2007-000/2
28
'_').0_
400 with higher than average wages and employment densities than the current
designation and zoning allows. '
"
STAFF'S FINDINGS RELATED ,TO COMPLIANCE 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), andis not
part ofthe subject property. Reference to this policy is not applicable to this application.
, .
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: Based on the above findings, the proposed zone change is in compliance
with SDC 12.030 (2).
STAFF'S FINDINGS RELATED TO COMPLIANCE WITH SDC 12.030(3Kc):
Finding 26: As previously noted in this report and as stated by the applicant, the s'ubject
,properties are currently served by sanitary sewer systems 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 provide access to the property The
subject site takes access from 44" Street which is under City of Springfield jurisdiCtion
and Main Street, -which is under ODOT jurisdiction.
Find.ing 31: The proposed zone change is from LMI to CC, The subject lot has existing
development on all sides, Glnd is located on 1Sth and Main Street. As previously
discussed in findings in this report. and as conditioned, the proposed zone change will
not significantly affect the existing transportation network. The proposed zone change
will not negatively affect existing public transit service.
LRP2007-00013 & ZON2007-00012
29
~-1n
Finding 32:' Solid waste management service is available at the subject property. The
, City and Sanipac have an exclusive franchise arrangement for garbage service inside'
the city limits. .
Finding 33: The site receives police protection from the City of Springfield, consisient
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 providesiland
, 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 to be granted. ' .
Staff have reviewed the Zone Change request and supporting information provided by
the applicant ar:Jd do not recommend any conditions of approval other than the condition
already stated for the Metro Plan I Refinement Plan Map Amendment related to trip cap ,
requirements.' .
The Planning Commission may choose to apply conditions of approval as necessary to
comply with the Zone Change criteria '
LRP2007-00013 & tON2007~0012
30
,-~:
ZONING MAP AMENDMENT (ZON2007-00012) CONCLUSION AND
RECOMMENDATION
Staff finds that the request meets the criteria of SDC 12.030. Upon review of the
evidence provided by the applicant, site visits, existing structures/uses and review of the
applicable criteria of approval, staff finds that -the applicant's request 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 ZON2007-00012 to the City Council with a recommendation for
adoption. '
.-
.
LRP2D07.DODI3 & ZON2D07.DDOll
31
~=-2~
EXHIBIT A-1
.
5.0 TRIP GENERATION AND DISTRIBUTION
5.0 TR.IP GENERATION
To determine the traflic impacts oLa development on a roadway system, the number of
vehicle moven\ents resulting from the development must be estimated. These
movements are referred to as "trips". Trip generation is the estimated volume of trips
resulting from the development. '
, .
The amount of trips expected to be generated by the propgsed development was
,determined using the information contained in the lTE Trio Generation Manual, 7th
Edition. The equations in'the mailllal predict the number 6ftrips generated based on the
gross square feet oft1oor area. Separate trip generation analyses were, performed for the
AM and PM peak hours for the development. .
Under the current Light-Medium Industrial zoning the developmel1t si,te can be built out.
to include a variety ofland uses sp'ecitied in Springtield Development Code Article 20.
The maxin1llm'trip generation of the development was determined for the allowed land
uses under the current zoning. Tables 5 and 6 illustrate the maximum development
potential and subsequently the maximum (rips generated by the development site using
the followingITE Land Use Codes:
I
.: I
. Land Use Code 760 - Research and Development
. Land Use.Code 714 - Corporate Headqllarters'
. Land Use Code 492 -,Health/Fitness Club
. Land Use Code 565 - Daycare Center
"
/Research,and
Development'
760
80 Ln(T)=0.88'Ln(x)+088 114, 0.~30.17 _9~< 19:
~~~1~i:~i~1,jl~iJ!_.!I!I1nll[. .~
, Health Fitness Club 492 4 T=1.21'x' 5 0.42 0,58 ,2 3 '
cent~j~i";ij~,'.[_;[}~i~fl~~-l~~~fl~J~f~t;:l~~~I~~jlr(t1 i~~f~~ ~!~ 1,1~i~i6~~1
Total Trips
229
168
61
JR.H TRAN\rO~TATIOCl ENGINEER.ING I Easts2'33"'ld P,e!one. Springfield, Oregon I March 6, 2007118
EXHIl:l1 t, A-'J.
.
Research and
Development", ' '
I~ti~~J~II~+mI1il~li~i~ij"
760
80, Ln(T)=0,83'Ln(x)'L06' ,110', 0.15" 0,85" '16,0, '93'
, .
..? ::;: ;:~'.
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(~:f.~", "~i,:;~t.';;; ~A~/'f~
. ',Health Fitness Club
, , 492
4
" 0.51
. .,
, - Total Trips -'243
,.' ;i::,?;:; 6,~t Y)71j.
With the zone change the development site will be built to include an approximately
3'0,000 square foot medical office building. The land use code for a fully developed
, medical ot11ce building, was 720 - Medical-Dental Oftlce 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 Jar this category ofland use
, was too small to create a reliable estimate of trips generated. Table 7 illustrates the traffic
generated by the proposed 30,000 square foot medical offtce building. Tax Lot 4,02 is
currently occupied by a commercial/specialty retail center. With the proposed zone
change, the building will remain on the property and will continue to operate as a
specialty retail center. Vehicle trips using this site have already,been accolmted for on the
roadway in the background traffic volumes: therefore, no new development trips were:
assigned to this Tax Lot. '
~l;~~f~~,~ftl~~'1~i~ i~~i;~ ~'Jj:}fif.l ~r~1~~~~;'~~f&~~;~~IAB%t
,
AM
T=2.48'x
74
79% 21 %
58
16
"Ln'('T]-o' '93"1 '(. ).1....7,">;.'1-o"'3'..~ '2"7' W' h3ir~:l'''2''8''':' ;;'7"S'o,-;:
. ". - . '~"~ ~ :"...' .:':,1 ?::...._'.,;~~~ ;,._-./~:;;.,;-t~~LQ-~; .l2.fx ~ :.;:~..,,<--:-~"
%,~)!:::,,:,::,,::t~:',:/1::,;:~'~:'.~.\i:~:~-.;~~:}; ';~~~t~:~~~_.i:~1~;9 .\~:;~1~~~ ;~';{&li;~:ij ~{~fj~~2~
There are 155 fewer AM and 140 fewer PM vehicle trips generated by the medical offtce
building when compared to the maximum potent tal of the site under the current zoning,
JP-H TP.ANSPOP-TATION ENGINEEP-ING I EastSprio9f1eld Re:ooe' Springfield, Oregon I March 6, 2007119
5-34
,.
.
5.1 TRIP DISTRIBUTION AND ASSIGNMENT
. '
After determining the trip generation, the next step in the' analysis requires distributing
and assigning the trips to the existing traffic network. Trip distribution allocates the trips
generated from the developments to generalized destinations, Trip assignment routes
trips to these generalized destinations via the actual str'eet 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 lie limitedto,a single
full-movement access from Main Street. Figures 9 and 10 shows th,e assigned vehicle
trips generated'by the 30,000 square foot medical office bllilding for the AM and PM
peak period respectivel/ " --
5.2 BUILD TRAFFIC VOLUMES
.
To detem1ine the Build trallic volumes the development trips assign~d throughout the
study area were added to the background traflic data. The year 2008 AM and PM Build
year traflic volumes are illustrated in Figures 11 and 12",respectively.The year 2023 AM'
and PM Build year trafftc volumes are illustrated in Figures \3 and 14, respectively
JIl.H TIl.ANSrOIl.TA!ION ENGINEEIl.ING I East Springfield Rezone. Springfield, Oregon 1 March 6,2007120
. 5~35
L....^nIOII J-\-,;}
~
,~
I
I
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j
I
EXHIBIT A4
.
I
7.0 TPR FINDINGS
I
I
The follo\ving discusses the Oregon Administrative Ruling 660-012-0000, the
Transportation Planning Rule, and the effect ofthe proposed development on the
transportation facilities as it applies to the ruling.
660-012-0060
I
I
Plan and Land Use Regulation Amendments
(l)JVhere em amendment to afunctional plan, an acknowledged c~,~prehensive plcm, or
'a land LIse regulation would sigliificantly aiJect an existing or planned tremspor/iltion.
, facility; the local government shall put in place meClSltreS as provided in section (2) of
this rule to ClSsure that allowed land uses ai'e consistent with the identified function,
capacity, and performance stemdel/'ds (e.g. level of service, volwne''fO capacity ratio, etc.)
of the felcility, A plan or land use regulation amendment significantly affects a
trc/I1:,portationfacility if it would:
(a) Change the fimctional classifiCCltion of em existing or planned transporlcltionfacility
(exclusive of correction of map errors in el/1 adopted plan):
. The addition of development traffic on the adjacent roadways does not cause the
change in functional classification of any of the transportation facilities.
(b) Change standards implementing afunctional classification system; or
The standards implementing a functional classification system within the project
study area are not changed by the proposed development.
I
I
I
I
I
J
1
I
(c) As measured at the end oflhe planning period identified in the adopted Iransportotion
systemplan:
(A) Allow land lIses or levels of development that would result in types or levels of travel
or fiCcess thot are inconsislent with the fimctional classijiCCltion of an existing or planned'
transportat iOIl facility:
The proposed development does not result in types or levels of travel or access
that are inconsistent with the functional classitication of the studied transportation
facilities.
. ..
J
(B) Reduce the per/orme/l1a of an existing or plwP1ed transportutionfacilil,v below the
minimum acceptable performance standard identified in the' TSf or comprehensive plan:
or
The addition of development traftic does not reduce the performance of an
existing or planned transportation facility below the minimum acceptable
performance standard.
JR.H TI\ANSPOR.TATION E~IGINEER.ING 1 East Springfield Rezone. Springfield, Oregon'l March 6,2007131
5':'36- '
.'
.
(cj Worsen the perfori7lClnc~ of an e.~isting or planned transportation fi:icililY that is
otherwise projected to perform below the miniinLlm,aCl"eptable'pelfon;l~inc; stahdard'
identified in the TSF or comprehem'ive plan.
The addition of developI)1ent traffic does not further degrade' the performance 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
"signIficant effect" on,the transportation facilities as deftned in the TPR. '
',. '
8.0 SUMMARY AND RECOMMENDATIONS
, This report provides an analysis of potential traffic impacts resulting from the proposed
redesignation/zone change and future development of the subject site in Springfteld;
,Oregon. This development will include approximately.30,OOO squareJeet ~,r medical,
office space. The parcel proposed for development is located east of 44th Street and, west
of 48th Street on Main Street.. A single unsignaliz~d 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 analysis was performed for the year2023. '
A performante analysis was completed for the intersections of Main Street and 42rid ,
Street, Main Street and 48th S'treet, Main Street at44'h Street, and Main Street at 46'h
Street. The,operational analysis of all intersections within the study area shows that
under the Build condition no degradation in volume4~-capilcity rfltio in comparison to
the No,Build condition,occ\lrs due toth'e additional trips prod~'ced by this development.
Ali study areas meet the inability ~tand~rdJo(theBuild condition. ' .
A queuing analysis was performed for the intersection within the study area: The queuing
analysis. which assumes the current lane configuration,throughout the planning horizon,
was perfoffi1ect to determine the amount of required storage length due to the construction
of the project. The results of the queuing analysis indicate that all existing sto~age lengths
will facilitate the queuing anticipated for the tratTlc demand, including the proposed
development.' '
According to the linding under Oregon Administrative Ruling 660-012-0000, the' .
Transportation Planning Rule, the proposed redesignation ~fTax Lot 400 and 402 does'
not resuLt in a"significant effect" on the transportation facilities as ddined in the TPR,
JIl.H TMNSrOIl.T,~Tlml ENGI"EEIl.ING I lOasl Springfield Rezone. Springf,eld, Oregon I March 6, 2007132
5~37
EXHIBIT A-5 l
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EXHIBIT A-6
Memorandum
Date: ' April 4, 2007
To: David Reesor, planner III
From: Gary McKenney, P.E., Transportation Planning Engineer
Subject: LRP2007 -00012 peaceHealth PAPA
~ity of Springfield
The following comments and recommendations are based on 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 T1A are attached for reference.
,
Traffic Impacts Analysis
In estimating the trip-making potential of site development under existing LMI
designation/zoning the TlA assume the land uses as depicted in Table 5 (Page 18 ).
Recommendation: Conftrm that the ,uses aSS].lITled in the "existing-designation"
development scenario are permitted, and that they represent a "reasonable worst case."
In estimating tJ:te trip-making po!ential of site development under proposed CC
designation/zoning the TlA assumed a single land use (Medici!-1. Office Building) as depicted in
Table 7 (Page 19)., .
Recommendatiofl: <;:onfirm that the use ,assumed in the "proposed-designation"
developm7nt scenario represents a "reasonable worst 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 development would not generate traffic in
excess of what is estimated in the TiA. Ifwe find that the assumed Medic'al Office use
would under-utilize the land, then we will want the TlA revised to reflect the impact of a
true "reasonable worst case." '
Goal 12 TPR AnalysisfFindings
The PAPA application refers to the Goal 12 ftndings contained in the, TiA. These are presented
on pages 31 and 32. The validity of these ftnds will depend on the details of the technical'
. analysis.andsupporting ~ssumptions.
5~38 .
EXHIBIT A-7
REESOR David,
, ,
From: MCKENNEY Gary
Sent: Thursday, A'pril 05, 20079:23.AM
'To: . R'E:ESOR 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 th~ re-zoned condition
it is clear that a 30 KSF Medical Office Building is much less ,intense than other uses that would be
. permitted in the CC zone. On a per-square-foot basis the MO is estimated to generate 2.47 vehicle
.tips/l,OOO SF and 3.:13 vehicletipsll,OOO SF during the AM and PM peak hours re~pectively. For
, comparison the,average rates for a "Fast-Food Restaurapt with Drive'Thtough Window" are 53.11
vehicle tipsll,OOO SF and34.64 vehicle tipsll,OOO SF." ' .
lnconsidenng the Goal 12 "insurance policy" issue so~e more I thought of another possible way to deal
with it, which we did not discuss yesterday. We might choose to limit the trip generation for the
rezoned land to be no greater than what would be expected from development under a reasonable worst
case with,existing zoning. "
1'd like to di~c~ss. these ideas further in, our meeting with Ed Moore. ,
Gary
:.
",
.,
I,
5~39
l....H.IIIUII
M-~
Dregon
Theodore R. Kulongoski, Governor
Department of Transportation
, ,Region 2 Tech Center
455 Airport. Road SE 'Building A.
Salem;Oregon 97301-5397
Telephone (563) 986-2990
, , Fax (503) 986:2839
File: Tl5-2
DATE:
May la, 2007 .
TO:
Ed Moore
Area 5 - Senior Planner
FROM:
Stephen B. Wilson, ,PE
Reaion 2 Senior Traffic Anatys
o . - .
SUBJECT:
East Springfield Rezone
Traffic Impnct Analysis Review
Highland Business Park - Peacehealth Medical Office.Buildfng'
McKenzie Highway,- OR 126 Bus. (Highway #15)
Milcpost 4.61- 5.00
City of Springfield
Lane County
, These are review corronents for the East Springfield fte.one Traff1c Impacf Analysis (TIA), prepared by
JRH Transportation Engineers. The focus of this review is 'the analysis methodologies a~d assumptions.
The results and conclusions of this study are in question, due to noted inconsistencies. Ilis recdmmended
this study be revised, taking into ,account these comments. Region 2 TrnJflc will need to review any
revised traffic study, to ensure it complies with ODOT requirements, before ,\5, c~n be deemed acceptable.
':';:;,:,:' ;.-i>>" Com' m" en't:: _.',<:"::i::: I
'. .. .,....- . ,; ~-~.... ':-'. .
The classification oflvlain Street (OR 126) must al~o be listed by the I
ODOThil'hway classification. . '
This study needs to demonstrate how the Seasonal Adjustment factors'
were applied to the raw traffic data. A graphic showing the raw
Iraffic volumes should also be included. . .
The peak hours assumed for this study seem reasonable; assuming the
Peak Hour Factors were calculated off data from these assumed hours,
and were the same for all intersections.
The 2006 Existing PM Peak traffic volumeS do not seem correct. As
part of this review, calculations were made using the raw traffic data
and the assumed Seasonal Adjustment factors, presented in this study.
The review calculations were unable to confirm the traffic volumes
qresented [n Figure 4. See related corronent for Page 8.
ODOT does not have a standard from which you can compare an
Intersection Crash Rale. This study cites a crash rate threshold of 1.0.
This is not an ODOT standard, and it is unclear where this standard
may have originated. The only ODOT standard for comparison is a
Segment Crash Rate, which should be calculated for the crashes .in at
least a mile of the study area roadway. l
Page ' Para gra ph
7 Table 1
8 Seasonal
Adjustment
8 Peak Hours
II
Figure 4
12
Section 3.1
. 5-40
.page
13
18
18
EXHIBIT A-9, .
Comment I
This study must deinonstrate how the 'j{j';Iorical Growth'Ra/es were
applied to the 2006 30'" Highest Houru'afflc 'volumes, Calculations to
confirm the 2008 and 2023 data were unable to,duplicate the future
volumes cited in this re1'0l1. . :
This report states the maxImum development potentml was
determined for the property, given its current zoning of Ligh/-Medium
IhdLlstrial. For this scenario, how was the maximum allowable
develoomen! determined?
" .
'The trip generation assumptions and output in this table are accurate,
This study's trip generation analysis for theproposed zoning, assumed'
a 30,000 sf !'-'[ediml q[fice, BLli/ding would be the only development'
on this site. To satisfy the requirements for a TPR-level analysis, the
trip genemtion study for Ihe proposed zoning must be for the
maximum allowable develomnen\ on that site, given the City's
development codes and reglilatio'ns.
,
The trafftc volumes for all Future Build-Out data sets will need to 'be
revised to account for" corrections made 'to address the previous
comments.
, , Para~raph
Growth F acto'rs
Existing,
Zoning Trip
Generation
Table 5
19
Proposed
Zoning Trip
Generation
n/a
Future
Build:Out
Trafftc
Volumes
I1Ja'
Section 6.0
rJa
M.anual Count
Data
rJa
S ynchro
Analysis
31
Section 7.0
- - - - -
The traffic data for this study is in question. Any analySIS made from
these data sets is also questionablc and must be revised; taking into
account'the previous comments. This commenLcan also be applied to
the:qu<:uinganalysis developed forthis study._.. --". .- - --- -
The scope of work for this TIA required 3-hvW' Manllal Classification'
Counts for all study-area intersections. However, a review .of the
m30uDl count data was unable to determine any truck volumes or
percentages. The tlUck traffic in this study area is signiflcant, and,
must be taken into account.
A review of the Synchro output has noted several l11con~istencies
throughout the analysis:
An Ideal Saturation Flow'rate of 1900 pcphpl was assumed
for both signalized intersections '(42'" & 48"'), while 1800 ,
pcphpl was assumed for the two unsignalized intersections.
The ODOT Analysis I'rocedures Manual .equircs a saturation
flow rate of 1800 pcphpl for'all intersection analysis.
, . The truck percentages must be based on real-world data. The
Synchro default 0(2% is not acceptable.
Unless the' Yellow Time (s) entered into Synchro for the
signalized intersections is based on either an ODOT or City
timing sheets, this analysis should assume 4.5 seconds of
yellow for the: OR 126 approaches, and 4.0 seconds of yellow
for the City-street approaches. The 5.0 seconds of yellow is
generally reserved for highways with an 85'" Percentile Speed
equal to, or greater than 45 mph, '
The TPR findings from this study are in question, due to the'
inconsistencies noted in tbis review, [t is very likely they will need to j
be revised, based on the recommendations in this review,
5-41
"
L....I\I 11......11 r"'\-. V '
Ie p agO,. 'IiI P :.en gra ph ~~):t~Wit.;!;,~,F!i~}'!,\\:ti~;'!.;:':}f'iC ()mm~D:tto:iii\fj).;i1;J,j;J~,K"
",.
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,32
'Section 8.0
'Based on ,the previous comments in this review, ,the conclusionS
drawn and recommendations, proposed are inquestiori. It is very
, likely they will need to be revised, based on the, recommendatlons in
~~N. ,.' ' 1
I
If you have any questions regarding my comments, please contact me by phone at (503) 986-2857 or by
.e-mail atstenhen.h.wilson@odot.stute.or.us. ' '
Ce:
Jim Hanks - JRH
David Warren
Jane Lee
Mike Spaeth
Dennis Santos
Fill?
.-
5-42
FW: Springfield _ East SpringtlelO Kezone lJ:K.1\ll"'Y>l' ",~n~"
EXHIBIT A-11
REESOR David
From: MCKENNEY Gary
Sent: Tuesday, May 15, 20074:28 PM
To: REESOR David
Subject: RE: Springfield - East Springfieid Rezone TF?R Analysis Review
Attachments: LRP2007,00012 Trans mem01.DOC
David ---
I believe Steve Wilson is thinking in the context of an unconditioned approv~l of the PAP NZC.
Given the approach we planned to take in conditioning this approval, I think only Item #18 of his 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 the assumed existing-zoning development scenario. is no
more intense than "worst-case." . '
If we condition the PAPA to limit trips to less than or' equal to what 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: PH: Springfield - East Springfield Rezone TPR Analysis Review
. ,.....,.......
Gary-
What are your thoughts on the attached memo?
-DR
~,-,--,-.-.._---
..,....,=,~~-.....,""
.....--.-.-~_._-
From: ,MOORE Ed W [mailto:Ed.W.MOORE@odot.state.or.usj
Sent: Monday, May 14, 2007 8:06 AM
To: REESOR David; MCKENNEY Gary
Subject: FW: Springfield - East Springfieid Rezone TPR Anaiysis Review
,FYI
5-43
~ _,:;,_ A ..... ..
EXHIBIT A-13
REESOR David
From: MOORE Ed W [Ed.w:MOORE@6dot.slate.or.usj
Sent: Monclay, 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-----
From: REESOR David [mailto:dreesor@cLspringfieid.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 ODOTs position on the PeaceHealth proposal (LRP2007 -00013 &
ZON2007-00012). Based upon the meeting you and I had with Gary McKenney. we are all in agreement
that the most appropriate way to address Goal 12 compliance on this proposal is by conditioning a trip
cap to what the worse case scenario would be under existing zoning (LMI). Does this sound correct to
~u? "
Thanks. ' .
David Reesor
Planner III
City of Springfield
541.726.3783
5-44
FW: Springfield- East SpnngnelQ Kewne U'K ,"'Ul<1'P" ""''''''H
EXHIBIT A-12
--Original Message-
From: WI~ON Stephen 8
Sent: Friday, May 11, 2007 lO;03~M
To: MOORE Ed W .
Cc: jimhanks@jrhweb,com; WARr:EN David; LEE Jane 5; SPAETH Michael, A; SANTOS Dennis N
.Subject: Springfield .-East Springfield Rezone TPR Analysis Review
Ed...
This is my t~chnical review of this TIA submitted by JRH. I apologize. for the delay in
getting this review out.
<<East Springfield Rezone TPR Analysis Review.pdf>>
Stepfwt:13. Wit.,cm,!JE
Senior Transportation Analyst
ODOT - Region 2 Tech Center
455 Airport Road SE - Building 'A'
Salem. OR 97301-5397
(503) 986-2857
,
"
'.
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"
5-45
..
~' PeaceHealth
March 15, 2007
Type II Metr~ PlanlEast Main Refinement Plan
Diagram Amendments
Written Explanation ~f the Proposal
Applicant:
PeaceHealth Oregon Region
770 E. 11 th A venue
P.O..Box 1479
Eugene, Oregon 97440
Property Owners:
. Hyland Business Park, LLC (Ta.'l Lot 400)
1941-A Laura Street
Springfteld, OR 97477
Attn: Shaun Hyland
(541) 726-8081
Andrew Head (Tax Lot 402)
1616 Ardendale Ln.
Eugene, OR 97405
(541) 521-3403
Applicant's
Representative:
Philip Farrington, AICP
Director, Land Use Planning & Development
, PeaceHealth Oregon Region
123 International Way
Springfteld, Oregon 97477
(541) 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 ("LMJ") to Community Commercial ("CC") for approximately 5,24
acres identifted as Ta.'l Lots 400 and 402 on Assessor's Map No. 17-02-32-00. This same
acreage on the site is being proposed for a concurrent amendment to the Springfteld
zoning map from LMl to CC, as allowed in Springfteld Development Code ("SDC")
12.020 (l)(a)l.
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The a'rea subject to the proposed land use designation changes is mapped on Attachment
A, and is referred to collectively in this application as the "subject properties'.' or "site."
pursuant to SDC 7.110 (4), approval of the requested Metro Plan,diagram amendment
automatic~lly amends the reftnement plan diagr~m and is processed concurrently.
Findings of fact addressing the criteria of appro~al in SDC 7.070(3) are included in this
narrative statement (see Section 5 below). .'
2.0 Project Purpose, Relationship to East Main Refinement Plan I
The Applicant seeks to redesignate and rezone the subject properties to CC so they may
be developed for commercial uses (i.e., Tax Lot 40Q), including a possible future medical
clinic which could serve residentsin the growing e~st Springfield area, and to be allo>yed
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 4.00
_ a vacant and underused industrial site. The proposal would also help heautify this '
portion of Main Street from its traditional i~dustrial yard uses, and future development
would provide a superior buffer for residential uses to the west than currently exists. .
The proposal is also consistent with the East Main Refinement Plan (EMRP) criteria for
designating property as Commercial within the reftnement plan (EM,RP,pg. 12) since:
a) The proposal would not be an intrusion into a well-maintained residential
, neighborhood. The proposal would allow for higher quality development than has
historically existed on the vacant industrial site (Tax Lot 400), therefore providing
, . .
, opportunity for improved buffering between abutting residential and non- . ,
residential uses. Tax Lot 402 borders only Tax Lot 400 and two commercially
zoned parcels, so legitimizing the pre-existing commercial uses on that property
would not affect, the existing residential area nearby,
b) It does not increase conflict between,Low Density Residential and Commercial ".
uses, but in fact can provide for uses and development far superior to those that
have traditionally been located adjacent \0 the abutting residential area.
Moreover, the area abutting Tax Lot 400 to the west is zoned Medium Density
Residential, though in primarily low density residential use.
c) The criteria for designating Medium Density Residential land does not apply
because the subject properties are no't currently developed, nor have they ever
been designated, for MDR uses. '
d) Legally created commercial uses have existed on the properties, and the proposal
would facilitate higher quality commercial uses (such as medical offtces) than
have existed before on Tax Lot 400, and allow for Plan designations and zoning
to correspond with long-standing legally established commercial uses on Tax Lot
402.
e) Adequate acc'ess exists to an arterial street, with existing curb cuts directly onto
Main Street.
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f) Upon approval of this request, the site would have a Commercial designation on
the Metro Plan diagram.
The proposal is also consistent with EMRP Policy 2: "Apply site-speciftc Commercial
reftnement plan designations to clearly deftne the limits of new commercial uses where
there is not an existing, legally established, and beneftcial mixing of uses." (pg. 12) The
proposal to allow for a broader, more beneftcial range of commercial and employment-
generating uses on the subject properties. It would also improve the area and better
distinguish"and buffer adjacent residential and industrial business park uses.
3.0 Site Context
The subject properties include, a vacant, flat parcel (Tax Lot 400) and ex:isting
commercial development (Ta;'( Lot 402) east oH4th Street along Main Street in east
Springfteld. 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 Weyerhaeusermill site (Tax Lot
400) or an existing commercially zoned parcel (Tax Lot 402), and on the west py other
small-scale commercial enterprises (e.g., a cabinet shop and karate school) fronting Main
Street and residential homes along 44th Stre6t west ofTa,'( Lot 400. CommerCial
enterprises are located immediately south of the site across Main Street (e.g., Gray's
Garden Center).
While historically involved in agricultural 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 also used the site to store mod01ar construction offtces,tool trailers,
construction equipment and concrete form plywood. Tax LotA02 has had various
commercial services on site since the 19505.
. . . .
The properties have no jurisdictional wetlands o'r inventoried GoalS natural or historic
resources. The site is within" the Springfteld Urban Growth Boundary, and both parcels
were anile,'(ed into the City of Springfteld in 1960. The EMRP diagram {adopted in
1988) currently designates the subject property for industrial uses.
The abutting property to the east is designated Light/Medium Industrial in the EMRP
diagram and zoned LM!. The areas immediately to the west and southofthe site fronting
Main Street are identifted as being within Mixed-Use Area #2 in the EMRP, and are all
zoned Community Commercial. Property to the west of Tax Lot 400 along 44th Street is
zoned and designated Medium Density Kesidential.
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4.0 Type II Metro Plan Dia'gram'Amendment' ,
Amendments to the MetroPlan are classified as Type 1 or Type lI.amendments,
depending upon the speciflc changes sought. The proposed Metro Plan and EMRP
amendments are "site speciftc" and relate to property solely within the corporate limits ~f
the City of Springfteld. The Metro Plan deftnes Type II amendments as: "
"[AJny cha!)ge to the Plan diagram or Plan text that is site speciftc
and no\ otherwise a Type 1 category amendment." '
The,proposed amendment is a Type 11 site"speciflc amendmeI)t because it:
, '
. Involves a speciftc geographically identi.ftable property;
. Does not change the metropolitan lJrban Growth Bou.ndary;
. Does not change the Metro Plan jurisdictional boundary;
. Does not require a goal exception;
. Does not include a non-site-speciftc amendment of the Metro Plan text; and
.
. Applies only to property located withi~ the Springfteld City limits. .
Accordingly; the current proposal is properly characterized as a Type 1I amendment (as
deftned in SDC 7.030) that must be reviewed and'approved by the City of Springfield;
consistent with SDC 7.070 (2)(a), Per SDC7.040 (2)(b), this citizen-initiatedType 1I
Metro Plan amendment can be initiated at any time.
5.0 Applicable Approval Criteria,., .
Type 11 Metro Plan amendments are evaluated'according to the criteria of approval
contained within SDC 7.070 (3), which provides: '
, ,
"The following criteria shall be applied by the City Council iT!
approving or denying a Metro Plan amendment application:
(a) The amendment must be consi'stent with the relev'ant
Statewide planning.1goals adopted by th'e Land
Conservation and Development Commission; and
.
(b) Adoption of the amendment must not make the Metro
Plan internally inconsistent."
j:;'indings demonstrating consistency with the approv~l criteria are outlined below;
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5.1 Consistency With Statewide Planning Goals
The following ftndings address compliance withMetro plan criteria in sac 7.070 (3)(a),
Approval of a Metro Plan diagram amendment also correspondingly changes the
applicable reftnement plan diagram, as established in SDC 7.110 (4).
Goall- Citizen Involvement
Goal 1 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. N.otice of the public hearings will also
, be given in accordance with SDC requirements to nearby property owners, interested
parties requesting notice, and any established neighborhood organization. Since the
amendments comply with the City's citizen involvement program and citizens have
opportunities to be involved in the procedure, the .pr9posed 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 affect,d 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 11 Metro Plan diagram amendment to the City"ofEugene and
Lane County so they may determi~e if there are grounds to participate,as parties to the
hearing. The City also sends the statutorily required notice of the initial public hearing
45 days in advance to the state Department of Land Conser..:ation and Development,
ensuring that they are given opportunity for comment and review conformity to
applicable statewidephmninggoals:
"
The'Metro Plan and the SDC, as well as the Statewide Planning Goals and applicable
statutes, provide policies and criteria for the evaluation 'of comprehensive plan
amendments. Compliance with theserneasures assures an adequate factual base for
approval of the proposed Metro Plan diagram amendment. As discussed elsewhere in
this document, the amendments are consistent with the Metro Plan and the Goals.
, Consequently, by demonstrating such compliance, the amendments satisfy the
consistency element of Goal 2.
Goal3 - Aaricultural Lands
~
This goal is inapplicable because as 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 Springfteld's corporate limits, and have not been in
agricultural use for decades.
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Goal 4 - Forest Lands
Goal 4 does not apply within urban growth boundaries, per OAR 660-06-0020, and the
'areas affected by the Plan amendments are inside Springfteld's acknciwledgedUGB.
GoalS - Natural Resources
GoalS requires local governments to protect a variety of open space, scenic, historic, and
natural resource values. GoalS and its implementing rule, OAR Ch. 660, Division 16,
req~ire planning jurisdictions, at acknowledgment and as a part of periodic review, to
(I) 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 conflicti~g uses; and .
.
The subject properties are not on Springfteld's acknowledged Metro Plan GoalS
, inventory. No threatened or endangered species have been inventoried on the site, and no
archeological or significant historical inventoried resources are located on the site. The
National Wetland Inventory and Springfield Local Wetland Inventory maps have been'
consulted and there are no jurisdictional wetlands located on the site..Therefore, the
proposed amendment does not alter the CitY's compliance with GoalS.
(5) develop programs to resolve the conflicts.
,.
Goal 6 _ Air, Water, and Land Resources Quality
The purpose of Goal 6 is to maintain and improve the quality of the air, water and land
resources of the state. Generally, Goal 6 requires. that development comply with
applicable state andJederal.air aild 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 andfederal 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 environmental clean-up list. A Phase 1
environmental assessment on the subject property was conducted and recommended
additional analysis. Upon recommendations through the Phase 2'environmental
assessment a nominal quantity of soil (less than 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 fo(waler quality
protection through the site plan review process, thereby complying with applicable state
and federal environmental quality standards,
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Goa17 - Areas Subject to Natural Hazards
Goal 7 requires that development subject to damage from natu,al hazards and disasters be
planned andlor constructed with appropriate safeguards and mitigation. The goal also
requires that plans be based on an inventory of known areas of natural disaster and
hazards, such as areas prone to landslides, flooding, etc.
,
The site is flat and not subject to landslide hazards, and is located well outside of any
established FEMA flood hazard area. Therefore; approval ofthe proposed Plan'
amendments will not alter the City's acknowledged compliance with Goal 7 through its
adopted plans, codes and procedures.
Goal,S - 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 including
destination resorts. The subject site is not included.in an inventory ofrecreational sites,
and the proposed amendments will not have an impact on the community's recreational
facilities or needs; therefore, the proposaldo~s not implicate Goal 8. '
Goal 9 - Economic pevelopment
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 followi'ng SCLS policies are applicable to the proposal:
Policy I-A: "Maintain a mixed supply oflarge and small commercial sites
through strategies such as rezoning or annexation" to serve Springfield's
future population."
The proposal fulfills this policy objective by redesignating and - through.accompanying
zone change _ rezoning limd from industrial to commercial, for two tax lots of varying
sizes and commercial us'es,'thereby maintaining existing employment and commercia'l
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 I-C: "Maintain at least a five-year supply ofcommerciai land
within the Urban Growth Boundary (UGB) that is currently served or
readily serviceable with a fi.tll range of urban public facilities and
services,"
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The SeLS (see Table 3,8, pg. 32) found there to be a deftcit of 158 acres in the supply of
commercial Hind over demand projected through the year 2015., The ,proposal would
allow fat redesignation, and rezoning, of-ftve'acres thereby.redu,cing 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 Taxi-at 402, and future .
development on Tax Lot 400. The SCLS identifies (pg. 33) a need to support
"employment in population-dependent sectors such as retail sales and health services',' to
meet Springfleld'sgrowing,community. The SeLS also noted (pp. 27-29) state and local
trends in greater employment in retail trade and well-paying health services sectors. .
Approving the proposed redesignation and zone change would help meet Springfield's
demonstrated need for employment and commercial services.
Finding 3 in the seLS (pg,36) cited the acknowledged 1992 lridustrial Land Study as
demonstrating that "a surplus of industrial sites exists in the Metro Area." Therefore, the
, proposed redesignation (and corresponding rezoning) would nolresultin a deficit of
needed industrially designated and zoned land, ,but it would help reduce the commercial'
lands deficitidentifted in the SCLS. Therefore, approving the proposal would be
consistent with SLCS Implementation Strategy'3-A (1): "Evaluate inventories basedon
demonstrated need for the planning period. Initiate ~ezoning or redesignation of surplui
land uses where more appropriate for commer~ial, 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 DLCD as being consistent with Goal
9. Oregon Administrative Rules concerning Goal 9 implementation (OAR 660-009-
'0010(4)) call for amendments to land use desigi1ations "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 opportunitiesanalysis. The'City can find that the proposal complies
with relevant local plan policies by converting one form or employment. generating land
use to another, without negatively impacting the supply of buildable lands for either ' .
category of uses. The proposal enables continued use of the existing and long'standing
, commercia! center to continue to operate andprovid,employment opportunities, while
, also allowing higher-value employment,associatedwith future development on Tax Lot
400, These types of employment-generating ,uses are among those identified in OAR
660-009-0005(6) as eligible non-industrial employment activities that can justify
app'roval of the proposed Plan diagram amendment without the need for an economic
opportunities analysis apart from the SCLS, which DGCD ackTIowledged as fulflllingthe
City's obligations under Goal 9, '
. Because the requested rede~ignation and concurrent zo'ne 'changeimplements 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 request
is consistent with the City's compliance with Goal9 and"applicable administrative rules
regarding Goal 9 implementation.
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Goal 10 - Housing .
LCDC's Housing goal requires cities to maintain adequate supplies of buildable lands for
needed housing, based on an acknowledged inventory of buildable lands. The proposal
does not affect the CitY's inventory of residential lands.
In fact, approval 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 beneftt the adjoining residential properties. . Because the
proposal involves redesignation from industrial to commercial land uses, it does not
affect Springfield's continued compliance with Goal 10. .
. '
Gaul 11 ~ Public Fucilities und 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' Springfteld UGB and
city limits, and is already d'esignated 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.~
. Gouin ~ Transportation .
Goal 12 requires local govenunents to provide and encourage 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 suc,h that approval of the proposal will not result in any changes to
the type or intensity of uses on the site, and,will not increase the trip generation for that
parceL' As the attached Traffic Impact Analysis (TIA) demonstrates, future development
of medical offtce facilities on TL 400 will not degrade mobility standards below
acceptable levels and allow. for adequate queuing lengths at applicable intersections,
Therefore, the proposal will not have a "significant effect" on transportation 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
developmenton Tax Lot 400 will result in some access cha~ges 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 approximately in the center of the
parcel. The T1A demonstrates that these access points \vill not result in any degradation
of mobility standards below acceptable levels, and that safe and efftcient circulation can
be re'alized through approval ofth'e requested land use redesignation (a~d companion
zone change).
,Furthennore, 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)
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Access, Circulation & Parking Element policy lB (pg. 17) and Commercial Element
policy 3 (pg: 12).
Because the proposal, as demonstrated in the T1A, is consistent with the requirements of
the TPR and with applicable policies in the EMRP, it is consistent with Goal 12 and
applicable local implementing policies.
Goal 13 - Energy Conservation
, '
The Energy goal is a general planning goal and provides limited guidance for
site-speciftc 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 resid<<ntial areas in east Springfield.
Therefore, the proposed amendment is consistent with, and does not alter the City's
continued compliance with Goal 13.
Goal 14 - Urbanization
Goal 14 requires local jurisdictions to proyidefor an "orderly and efftcient transition'
from rural to urban land use." The subject property is within the UGB and the city limits
of Springfteld, 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 bound?-ries of the
Willamette River Greenway.
Goals 16-19 - Coastal Goals
The coastal,goals are ,not applicable to this application.
".
5.2 Metro Plan Consistency -
The application' requests amendment of the Metro Plan diagram from LMI to CC for
approximately 5.24 i>cres.. This section 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,intemally
inconsistent (as required by the approval criteria in SDC 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 th,aIl the current or
proposed designations for the site and will not be affected by the proposed Plan diagram
and text amendments, or (3) clearly apply only to specific development applications (e.g,
site plan review submittals or subdivisions) In many instances the goals, policies and
implementation measures apply to speciftc development proposals that will be addressed
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Metro PlaniEMRP Diagram Amendment
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through compliance with applicable City regulations during site plan review of a given
future development proposal.
The Metro Plan Introduction, Section D provides the following deftnitions:
A goal as a broad statement of philosophy that describes the
hopes of the people of the community for the future of the
community. A goal may never be completely attainable, but
is used as a point to strive for. '.
An objective is an.attainable target that the commlmity
attempts to reach in striving to nieet 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 of the Metro
Plan policies are addressed in the order in which they appear in the Plan Element section
of the tyletro Plan. .
S.2.A.
Metro Plan Elements
1. Growth Management
Policies
1. The Ilrban growth bOllndary clnd sequential development shall
continlle to be implemented as an essential means to achieve
compact Ilrban growth.- Provision of all urban services shall be
concentrated inside the urban growth boundary.
The Ilroposed amendments satisfy this policy because the subject property is inside the
UGB and city.limits and as such, encourages compact urban growth, Also, urban
services are available at sufficient levels to accommodate the existing and future inftll
development resultillg approval of from this application. The City's site planreview
processes ensure that the approprillte level of services is available to serve future
development.
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2. Residential Land Use and Housing Element.
policies ..
A.l1 Generally locate higher density residential development near
employment or commerc'ial services, in proximity to major
transportation systems or within transportation-efficient nodes.
The proposed redesignation does not affect the inventory or availability ofresidentially
designated or zoned land,including the single-family residential area abutting Tax Lot
400 that is zoned and designated for Medium Density Residential, or higher density
residential developments located east of the site along Main Street. .
However; approval ofthe requested redesignation to Community Commercia] would
allow for residential' areas proximate to the subject area to have close and efficient access
to existing commercial services on Ta:, Lot 402 and to future medical facilities proposed
for Tax Lot 400, consistent with the above policy. The areas proposed for redesignation
.0ffeZ existing and future employment opportunities and provide commercial services
along a major transportation system that can support the needs. of nearby residential
development. '
A.i2 Expand opportunities for a'mi.x: of uses in newly developing areas
and existing neighborhoods through iocal zoning and development
regulations.
The map amendment and concurrently proposed zone change will allow for existing
commercial uses on Tax Lot 402 to continue to serve existing neighborhoods in the mid-
and east-Springfteld area, and for future clinical facilities to be developed to serve this
rapidly growing area ofthe community. Approving the requested redesignation and zone
change would expand' commercial opportunities to serve these neighborhoods consistent
with the above policy.
..
3. Economic Element
policies
B.] Demonstrate a positive interest in existing and new industries,
especially those providing above-above wage and salary levels, and
increased variety of job opporwnities, a rise in the' standard of living,
and' utilization of our existing comparative advantage in the level of
education and skill of the resident lllborforce.
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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 Springfteld 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 t)1ereby helping raise the standard of living
and meet the needs of Springfteld citizens, consistent with the above policy. '
B.2 Encourage economic development which utilizes local and imported
capital, entrepreneurial skills, and the resident labor Jorce.
The The'construction of and the use of commercial and medical uses will utilize both
local and imported capital and will employ the 10caJlabor force in a variety of skilled,
semi"skilled, and unskilled positions, consistent with this policy.
B.6 Increase the amOfl/lt oJ undeveloped land zonedJor light industry
~nd commercial uses correlating the' eJJective sl/pply in terms oj
s,l/itability and availability with ti,e projections oj demand.
The proposal will add approximately 5.24 acres of Community Commercial land,
consistent with recorrUnendations to increase the commercial lands inventory made in the
Springfteld Commercial Lands Study. The SCLS and acknowledged metropolitan
Industria] Lands Study concluded that there is a deftcit of needed commercial land, and a
surplus of industrially zoned and designated land. Approval of the requested
, '
redesignation will not cause the inventory of nee~ed industrial land to go into a deficit,
but in fact would, consistent with the above policy. The proposa.l correlates the need and
suitability, and availability of the subject site for commercial uses with the need for such
uses as demonstrated in the adopted SCLS. '
B.ll EncOl/rage economic activities 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.l In order to promote the greatest possible degree oj diversity, a broad
variety oj commercial, residential, and recreational land l/ses shall be
encouraged when consistent with other planning policies.
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Metro PlanlEMRP Diagram Amendment
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Approval of the proposed map amendinents will add just over 5 acres into the City's
inventory of commercially designated and zoned land, thereby allowing for a variety of
needed commercial uses to occur on the subject property. Long-standing ex.isting
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 needs 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-supportive land use patternS and development,
including higher intensity, transit-oriented developmel!~ 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; arid
developmentimd redevelopment in designated areas that are or could be
well served by existing or planned transit.
The propo;ed map amendmeht 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 TD stop is located on the frontage of Tax Lot 400 (see photo, pg. 2, Appendix A of the
T1A), and will provide convenient access to existing and projected employment on the
subject site, as ,well as access for patients to future out-patient medical facilities projected
, on Tax Lot 400. '
"
. 5-45-%8
Me\ro ptanlEMRP DLagramNIlendmen\
PeaceHealth Oregon Region
March 15 2007
Page 15 (
, 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 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 applications for consistency with the
land-use regulations afthe applicable local government
jurisdiction.
b. Acceptable and reliable perforniance is defined by the following
levels of service under peak hour traffic conditions: LOS E within
Eugene's Central Area Transportation Study (CATS) area, and
LOS D elsewhere.
c. Performance standards from tlie OHP shall be applied on state
facilities in the Eugene-Springfield metropolitan area.
In some cases, the level of service may be sL!bstandard. ' The local
government jurisdiction may find that transportation system
improvements to bring performance up to'standard within the planning
horizon may not be feasible, and safety will not be compromised, and
broader community 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 constraints,
including bllt not limited to environmental conditions, lack of public
agency financial reSOllrces, or land lIse constraint factors. It is not the.
intent ofTS! Raodway Policy #2: i'dotor Vehicle Level of Service to
require deferra{ of development in Stich cases.' The intent is to defer
motor vehicle capacity increasing transportation improvements until
existing constraints can be overcome or develop an alternative mix of
strategies (such as: land use measures, TDl'd, short-term safety .
improv'ement~) to address the problem.
"
Subsection a.(2) in the above policy requires an evaluation of the proposal pursuant to, the
state Transportation Planning Rule (TPR) , The accompanying Traffte Impact Analysis
5-60
Metro PlaniEMRP Diagram Amendment
PeaceHealth Oregon Region
M,rch 15,7,007
Page 16
,prov,des the factual basis to determine that the proposed redesignatiqn would not result in
a "signiftcant effect" as defined under the TPR (OAR 660-012-0060(1)),
,-
Specifically, the proposal does not change the functional classiftcation of Main Street or
any other nearby roadway, and it does 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, the proposal also does not:
. 'Result in, types or levels of trafftc or access that-are inconsistent with the functional
classification of Main Street or any other nearby roadway;
. Reduce performance of trafftc on Main Street or other affected intersections to a level
that is below acceptable established performance ~taridards; or
. Make performance of existing facilities worse (i.e., below acceptable mobility
standards) than would be the,case other uses permitted under-existing designations or
zorimg.
Speciftc TPR ftndings are further located in the T1A, 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 E.'r:tend the minimum level andful/:rarige of key urban facilities and
I ' . ,.' .,
services in an orderly and efficient manner consistentwiththe growth ,
management policies in Chapter lI-B, relevant policies in this chapter and otller
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 Lot 402) or are available to serve future infill development onTax Lot~OO.
Therefore, the proposal is consistent with the ,above policy. ' .
,
9. Parks and 'Recreation Facilities Element policies
policies in this element of the Metro Plan are'not relevant to the requested di'agram
amendment.
10. Historic Preservation Element policies
Policies in this element of the Metro Plan are not relevant to the requested di.gram
amendment.
5-'-6.1
Metro PlaniEMRP Diagram Amendment
PeaceHealth Oregon Region
March 15 '007
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 Reftnement Plan (EMRP).
1. Mixed-Use Element
Policy 2) Area #2
A) Thefollowing land uses are allowed llnder Commllnity Commercial
zoning:
All Commllnitv Commercialllses Sllbject to Article 18 of.the
Springfield Development Code.
The proposal requests redesignating the subject properties to Community Commercial,
and concurrently rezoning the properties to CC, as is allowed by the above policy and
consistent with other EMRP policies. Approval'ofthe request would allow long-standing
existing' commercial uses on Tax Lot 402 to continue as permitted under Article 18, and
consistent with neighboring uses to the west and'south, which are also zoned and
designated for commercial uses.
2. - Commercial Element
Criteria ror Commercial Refinement Plan Desirznatio'1'
. . '
1. Generally, the Comfllunity Commercia(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 44th Street, and is therefore consistent with the above
criterion;
. 5-62
. .
Metro PlinfEMRP Diagram Amendment
PeaceHealth Oregon Region
March IS. 2007
. Page 18
B) where it does not increase conflict between Low Density
Residential and Commercial;'
Although the abutting residential area is zoned tyledium Density Residential, it is
developed in low density residential uses. Approval of the proposed
redesignation ofthe subject sites would actually result in a decrease of conflicts
. between abutting residential and non-residentia1'"landuses 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 tha~ the
industrial uses that historically abutting this"residential area.
C) where criteriaJor designating !'"fedium Density Residential
land does not apply; .
, ...
Criteria for designating MDR land does not apply to the subject site.
D) where legally created commercial uses exist;
Tax Lot402 has existing, long"standing commercial uses that were legally created
prior to development of the Metro Plan or EMRP.
E) ';'here adequate customer and service access to an arterial
street can be provided; ,.. and
The subject site has adequate legal access onto Main Street, which,is classified as
an arterial street.
, F) where designated Commercial on the Metro Plan Diagram..
Approval of this application would result in a,Commercial designation on the
Metro Plan diagram, which would also automatically modify the designation, on .
the J:;:MRP diagram.
'.
Policy 2) Apply site-specific Commercial refinement plan designations
'to clearly define the limits of new commercial uses where there is 1I0t all
existing, legally established, and beneficia,l mi.-ring 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 limits of new commercial uses between the pre-existing
commercial uses on Tax Lot 402 and others to the west, and the developed industrial
business park to the east. Tax Lot 400 does not have an existing or beneficial mix of
uses, but has historically housed industrial yard-type operations, Therefore, approval of
5-63
Metro PlaJEMRP Diagram runendment
PeaceHealth Oregon Region
March \ S. 2007
Page \9
the proposal would defmethe 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 thesite plan review process.
. Policy 3) Reduce the number of vehicular access poihts and require the
rebuilding of curbs and installation of sidelV!ilks and street trees along
ilrfain Street, through the Site Plan Review process and in'public
improvement projects.
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 access onto Main Street, dirninating one of the two existing curb
cuts on this site. Sidewalks and street trees are alr~ady located along its Main Street
frontage, consistent with the above policy. .
Policy 4) Provide buffering between commercial and residential uses
through 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. 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 sha!l encourage effo rts of various agellcies to attract
new and reta'in existing jobs and businesses.
Imolementation
The City shall maintain a current inventory of vacant commercial and
. industrial land and stl'llctures 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 400
with'higher than average wages and employment densities than the current designation
and zoning allows.
5-64
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#LRP2007-00013
Rezone Application
#ZON2007~00012
Melro Plan Amendment from LMI to
Commercial and concurrent Zoning
Map Amendment from LMI to CC
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Propel 'Planning & Development
t;PeaceHealth
March 28,2007
"
David Reesor, Planner II
City of Springfield
Development Services Department
225 Fifth Street
Springfield, OR.' 97477
Re: Plan Amendment (LRP2007-0,OOI3), Zone Change (ZON2007-00012)
Mr. Reesor,
The following and attached is supp lemental information for the. above-'referenced
applications for proposed Metro Plan diagram amendment and zone change in east
Springfield.' '
The proposal seeks to redesignate and rezone approximately 5.24 acres on two parcels
from Light-Medium Industriai (LMI) to Commercial. As noted in the application
findings submitted last week, the Springfield Commercial Lands Study demonstrates \hat
the City has a deficiency in needed corrimercially designated and zoned land, so
approving the proposal would help reduce the identified'deficitin that land use category.
The Metropolitan Industrial Lands Study (July 1993) was adopted by the local
jurisdictions and acknowledged by LCDC as being consistent with statewide planning
goals and the MetroPlan, specifically fulfilling the Eugene-Springfield area's obligations
under Goal 9 (Economic Development). The Metropolitan Industrial Lands Inv~ntory
Report associated with the MILS identified "about 1,688 constraint-free industrial
acres.. ..This supply exceeds the projected dernand over the next twenty years, which is
between 650 tol,\ 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 lOa acres
debited from the Eugene and Springfield inventories) would leave a surplus of industrial
lands of be tween 1,600 and 2,ln acres metro-wide.
S tafr s Goal 5 work also calculated the changes in industrial land supp lies since 1991 as a
consequence of Metro Plan diagram changes.(see Attachment B), This analysi? ..
demonstrated a reduction in less than 90 acres of industrial land over the past 15 years,
Phone: (541) 3:~5-2593
F,,, (541) 335-2595
RI'Ier8end Annex 1231nlemelionel Wey Springfleld.OP"97477
....."" ....."""',-""h""::I.lth nro/oreaon 5-71
Dedicated (0 Ercepliol1ol Ah:dicine
ond Compassioni/(e Care
suggesting that there is still an ample supply of available industrial lands to meet existinO'
.. - -~
and future development needs. ',. ., '
This analysis may also not reflect other changes within industrially designated land
categories that would fmther off-set the proposed change to the site's LMI Plan
designation and zoning. For example, 11.5 acres was added to the inventory ofLMI
zoned and designated land due to City Council approval in April 1997 for land east of the
28th/31" Street connector and north of Marc 01 a Road (Ordinance No. 5851). Insofar as
the City and metropolitan area continue to enjoy a surplus of needed Industrial land, and
specifically Heavy Industrial zoned and designated land, the above-referenced change
added more than enough acreage to the inventory of LMIdesignated and zoned land to
off-set the proposal to remove only about 5 acres from the LMI inventory.
We therefore respectfully submit that the proposed Metro Plan diagram amendment and
zone change will not materially affect the inventory of needed Industrial land and will not
alter the City's continued compliance with Goal 9. ..
With acceptance of the above findings and earlier findings and narrative in the prior
submitted applications, we believe the applications are complete and ready to be set for
Planning Commission hearing. Please notify' me when the hearing is set, and send me a
'copy of the required hearing notice to DLCD for my files.
Thanks for yom consideration of the above. If you need additional information, please
contact me at your convenience.
,
:&~f!EP ~
Director, Land Use Planning & Development
PeaceHealth Oregon Region
:
Attachments
5-72
A TT ACHMENT A
,11.0 Impactofthe Proposed Protections' on Buildable Limd
Inventories ' .. '
This section 'estimates the impact of therecommended program for protecting
Springfie,ld's resource areas on the inventory of buildable residential, conunercial and
industrial land. Theadmiriistrative rule quoted above is somewhat vague about ho;'" to
compute the impact. Some contend that the protected acreage shouldbe subtracted fro~
,the current inventory of buildable land. Others contend that the protected acreaoe should
~. .0. .
, .be subtracted from the surolus of buildable land that was determined at the adoption 'of '
the inventory. Case'law supports subtracting the protected acreage from the surplus of
buildable land.
Tables 11-1 11-2, and 11-3 below summanze the amount of land that would be
subtracted from the Eugene-Springfield inventories -of surplus of buildable residential,
co.mmercial and industriallaiJds that were identified when each inventory was adopted:
Table 11-1. Analysis of MaximumPossible Impact on Supply of. Residential
Lands within the Eugene-Springfield Metropolitar Are~a ; . ,
. Residential Land Supply
Eugene-Springfield Metropolitan Area Residential Lands
imd Housing Study Surplus Acres
Low Demand Assumption
or
High Demand Assumption
Acres Remo-ve-d from Residential Designation by Previous
Plan Amendments' ,
Eugene
Springfield
,
Acres 1
1862:,00
or
790.00
Total.
Maximum Possible Residential Acres Impacted by
Eugene GoalS Protection Me3;sures '
. ,
Maximum Possible.Residential Acres Impacted by
Springi}eldGoal5 Protection Measures
Remaining Surplus
-14.18
1165,11
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 CommerciaJ:Land Supply
Springfield Commercial Lands Study (2000) projects a deficitof
corrirnercialland.
Acres'Removed from Commercial Designation by Previo\ls Plan
Amendments"
\ Maximum Possible Commercial Acres Impacted by S1=!ringfield's
Goal 5 Protection Measures
I RemainingS~rplus (Deficit)
Acres
-158 acres'
-2,8 acres 1
-11.56 acres 1
(-172.36 acres) i
Table 11-3,' Analysis of Maximum Possible Impact on Supply of Industrial
Lands within the Eugene-Springfield Metro~olitan Area
.,
,
Acres
, I Industrial Land Suoply
Metropolitan Industrial Lands Inventory Report Surplus Acres
Low Demand Assumption'
or
High Demand Assumption
Acres Removed from Industrial Designation by Pre'yiouS Plan
AJp.endments"
Eugene
Springfield
2954.28
or
2432.28
-642.30
-90.80
-732.80
Total
Maximum possible Industrial Acres Impacted by Eugene Goal 5
Protection Measures
-44.73
Maximum Possible Industrial Acres' Impacted by Springfield
GoalS Protection Measures
Remaining Surplus
-54.43
2122.01
or
1600.01 J
" Does not consider actions taken by Eugene to add additional lands to the surplus.
11.1 Impact on the Residential Lands Invento~y
In '1999,the Eugene-Springfield Metropolitan Area Residential Land and Housing Study
(Residential Lands Study) estimated.the amount of vacant buildable 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 Wetland Inventory as
unbuildable and were not included in the estimated supply 6fbuildable residential lands.
Other types of constraints were also considered arid classified as unbuildable and were
not counted in the buildable residential land inventory. The list of constraints iricluded:
. Floodways;
, , 5-74
. Wetlands listed on the Springfield Local Wetlands Inventory larger than .25
acres;
. Land within the ,easement of230 KV power lines;
. ' Land 'within 75 feet of a Class A stream or pond;
. Land within 50Jeet of a ClassB stream 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, itis '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 wiil
sli~htly reduce th~i~ventoried acreage ofvacant"buildable land adjacenUo wetland
features. '
Wetland Setbacks
As noted in'Table 11-4 below, about 9.95 acres oflow~density residential (LDR) and .59
acres of medium densjty residential (MDR) land will be removed from the residential
lands inventory by the 25-footsetback recommended for those wetlands not already
protected by the 50 and ]5 foot setbacks required by Springfield's stormwater quality
protection p'olicies. K,eep in mind that this is a worst case scenario and assumes that the - ,
developer is u~able 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 the inventory Of buildable residential lands. As noted in
Table 11-4, about 3.42 acres oflow-density residential (LDR)and .22 acres of medium '.
density residential (MDR) land will be removeci from the residential lands inventory by
the 25.Joot 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,
In May 2004, a Residential Lands Study Monitoring Report was published, updating the
residential lands inventory 'to reflect development through 2003. The report estimated
'that at the end of 2003 there was 1,36\ acres of remaining buildable residential land in
Springfield. The amount of land removed from the buildable inventory by the 25-foot
wetland and riparian setbacks proposed by this report represents about I % of remaining
1,361 acres.
5-75
Table 11-4, Vacant Residential Land within Proposed Protection Setbacks
Setback Distance ' Vacant Vacant . Total Acres
LDR lYID R
Acres Acres
I Wetland Setbacks
I 25 foot 9.95 .59 10,54
\ 50 foot 9.4 2.73 12.13 I
\ 75 foot 4.97 4.15 9.12
Total 24.32 7.47 31.79
'I Riparian Setbacks I
125 foot 3.42 .22 3.64 I
50 foot 6.06 2.73 8.79
I 75 foot 4.97 4.15 9.12
I Total 14,45 7.1 21.55
I Grand Total' 38,77 14,57 53.34 I
11,2 Impact on the Commercial Lands Inventory
The Springfield Commercial Lands Study (2000) listed several types of development
constraints that affected commercial properties. These development constraints included:
Major transmission lines;
Hazardous waste sites;
Slopes greater than 15%;
Lots less than 6,000 square feet in size;
Lots with poor visibility;
Lots with inadequate access;
Hydric soils;' '
Unstable soils;
Willamette'Greenway and Greenway setbacks;
Floodway and floodway fringe;'
Wellhead zone of influence;
Wetlands listed on the Springfield Local Wetland Inventory;
Other potentially regulated oatural resource sites [Natural Resources Study
Inventory];
Sites with Plan/Zone conflicts.
The Commercial Lands Study classilied sites on the on the Springlield Local Wetland
Inventory as constrained. The presence ofthese wetlands was noted and the inventory of
vacant commercial lands w~ noted to reflect the constraint. The riparian sites which are'
part.ofthis study were also included as constrained, since they were part of the draft
Springfield Inventory of Natural Resource Sites at the time Commercial Lands Study was
conducted.
5-76 -
Since the Springfield Commercial Lands Study did not remove wetlands.arid riparian,
sites, protection measures propos~d by this stUdy will have an impact on the inventoried
acreage of vacant cornrnerciallarids. The development setbacks recommended for
significant,wetland and riparian sites will further reduce the inventoried 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 Sprirlgfield. An additional 12 acres 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'acredeficit of buildable commercial land.
Wetland Impacts
Table '11-5 shows that .07 acres of vacant commercial land would be rern.oved from the
Commercial Lands Inventory if wetland sites zoned for commercial development were
fully protected. The'25-fo'ot 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 stormwater facilities or required'
landscaping within the recommended setbacks" thus reducing or eliminating lost
, development area.
The total iinpact on the Commercial Lands Inventory would be a reduction of 1.54 acres
if wetland sites and their setbacks ;vere fully protected.
Riparian Site Impacts
Table 11-5 shoWS thai about acres 2.78 of vacant commercial land iies within ih'ventoried
riparian sites that are protected by the Springfield.'s Sto!1hwater Quality Managerr'1ent
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 beTemoved from the inventory by the
proposed 25-foot setbacks.
The total' impact on the ,Commercial Lands Inventory wouldbea reduction of 1.54 acres
if wetland' and rip'arian sites and their setbacks' ~vere fully protected, This repres'ents 1.8%
of the 85 acres or:buildable commercial land described in the Springfield Commercial
Lands Study. .
Table 11-5. Vacant Commercial Land within Proposed Protection Setbacks
I Zoning District Site, , '
, Acreage
I Wetlands - ,-
, I Community - -- ,07
25 ft.
Setback
50ft.
Setback
, 75 I't.
Setback
Total
Acres
1.65
1.47
.ll
o
5-77 '
,
Zoning District Site ' 25 ft. ' 50 ft. 75 ft. Total I
Acreage, Setb ack Setback Setback Acres I
Commercial oj
\ Neighborhood 0 0 0 0
Commercial,
I General Office 0 0 0 0 0
\ Major Retail 0 0 0 0 0
Commercial I
I Wetland Total 0.07 10<\7 0,11 0 1,65
\ Riparian Areas. 5.381
'\ Community 2.78 0 0 2.6
Commercial
Neighborhood 0 0 0 0 0
Commercial
-
General Office 0 0 0 0 0
Major Retail 0 0 .24 0 .24\
Commercial
I Riparian Total 2.78 0 0.24 2,6 5,62 I
L Grand Total 2,85 1.47 .35 2,6 7,27\
11.3 Impact on the Industrial Lands Inventory
The 1992 Metro Area Industrial Lands Study assessed the supply and demand for'
industrial land in the greater Eugene-Springfield area. The study concluded that there
was about 709 acres of buildable industrial land within Springfield's DGB. Like the
Springfield Commercial Lands Study, the Industrial Lands Study noted those industrial
sites with wetland and riparian constraints but did not exclude them from the inventory.
For that reason, protection of wetland and riparian lands under the policies proposed by
this study will reduce the inventory of buildable industrial lands. The extent ofthis
impact is discussed below. , '
Wetland Impacts
. GIS analysis shows that about 30.64 acres ofvacant industrial land are affected by
wetlands that are not already protected by the Springfield Stormwater Quality
Management (SQM) program. These wetlands are recommended for p'rotection by a 25-
foot development setback under the Springfield natural Resources Study. ,These setbacks
add another 6.82 acres to the amount of industrial zoned land that would' be removed .
from the Industrial Land Inventory if wetland sites and the setbacks were fully protected
under the policies recommended by this study. The total impact to the inventory of
indusiriallandsWould be 37.46 acres. Table 11-6 shows the total acreage for land
affected by wetlands and the acreage protected by setbacks from both this program and
the existing SQM program.
Riparian Impacts
5-78
GIS analysis snows that 13.70 acres of vacant industrial land areaffested by riparian
areas are that not already protected by the Springfield Stormwater Quality Managemerit",
. (SQM)program. These riparian areas are r~commendedJor protection by a 25-foot
, development.setback under the Springfield Natural Resources Study. These setbacks add
, another 3.27 acres to the amount of industrial zoned land thai would be removed from the
Industrial Land Inventory if wetland sites and the setbacks were fully protected under the
policies recommended by, this study. The total impact to the iriventory of industrial lands
would be 16.97 acres. Table 11-6 shows 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
The lotal inipact on the Industrial Lands Inventory would be a reduction of 54.43 acres if
all wetland and riparian sites protected by this program and their 2.5-ft setbacks were fully
'protected. This represents less than 1% of the 709,aqes ofbuildabie industrial land for
Springfield in the Industrial Lands Study. '
Table 11-6, Vacant Industrial Land within Proposed Protection Setbacks
Zoning Total Site 25 ft.. ' 50 ft. ' 75 ft. ' Total
District Wetland Acres not Setback Setback Setback Acres
Site Prote'cted
Acreage by SQM -- -
I Wetl;~nds- ,.
Light- -- ..- - - -- (27076) 4.$1
28.20 .82 0 33.83
Medium
Industrial
I Heavy - -, - - - - - - "-' .-'--
13.16 (2.88) 2.01 19,15 0 34.32
Industrial - - -'- 1.631 0,
\ Campus- .35 0 0 1.28, 0
Industrial
Special 0 0 0 0 0 0
Heavy
Industrial 01
I Quarry 0 0 0 0 0
NIinin~ 0.60 \
Booth'i<.clly- . ----- ' - .13 0 0 .47 0
MU
I ' Wetland 41.84 (30,64) 6.82 21.72 0 70,38
Total'
Riparian Total Site 25 ft, 50 ft. 75 ft. Total
Areas Riparian Acres not. Setback Setback Setback Acres
Site Protected
Acreage by SQM
5-79
"
Zoning Total Site 25 ft. ' 50 n: 7S It, Total
District Wetland Acr'es not Setback Setback Setback Acres
Site Protected
Acreage ' by SQM
Light- 16.48 (10.89) 2,05 4.72 1.26 24.51
Medium
Industrial.
I Heavy 68.31 (2.81) 1.22 8.93 0 78.46 \
Industrial
. \ Campus 3.22 0 0 2.83 ' ,03 6,081
. lndustrial
Special 0 0 0 0 0 01
Heavy .
Industrial
\ Quarry 0 0 0 0' 0 0
Mining -..- -
Booth Kelly' .21 0 0 .82 0 1.03)
MU
lliparian 88.22 (13.70) D7 17.3 1.29 110,08
Total
Gr'and Total 130.06 (44.34) 10.09 I 39.02 I 1.29 180.46 \
,
'5~80
c:n
I
co
~
Metro Plan Diagram Changes -A(tecling"'tti-e Supply of Residential, Commercial and Industrial Land
Changes In Metro Plan Desirnalions '
-...-- .--- - - -----,.- ---.- .
NC CI LMI pas G&E NR AG
\
j
j
I
OA1
33.01
1
~-;j~1~;'; ,," 1
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I
I
ILocal File Nu'mber
190-04-058
90-12c201
'92-04-77
\93-01-33
93-01"1:l
93-06-087
194-10-0194
\95-02-036
195-02 -03i; -
'195-02-0:Ji;
\95-02-0:Ji; -
195-02-036
195-08-0157
197 -05-101
199-02-038
\99-02-041
99-09-230
102-03-0062
102-03-0063
102-07-200
102-08-243
ILRP-2002-12431
, LRP-2004"00031
LRP-2005-0001 b
Reside nlia I:(ohl\s 7's,inQ~;~~ ~~$_:;ij~5'~~~ :~;~Y~7.5;O
----
CC
LDR
MOR
-0.1
35,0
-5.3
0.0
0,0
-3.0
-0.9
0.1
5.0
0.0
0.0
nn
-'- -
3,0
0.9
5,3.
0.5',
3.7
'~-:'f1'f:\1l\;~i;iZ:
:1':i}:~~:~~!;f;:
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,18.0
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-34.5
-22.0
6.0
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-l
-l
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o
:r:
:s
m
z
-l
(0
LOR Low Density Residential
MDR Medium Density Resldentlal
CC Commercial Center
NC Neighborhoc;>d Commercial
CI Campus Induslrlal
LMl Light MedIum Industrial
HI Heavy Industrial
PQS Public'Open Space
G&E Government and Education
NR Natural Resource
AG Agriculture
MU Mixed Use
.:
~. peaceJ?:ealth
March 15,2007
Zone Change Application
Written Explanation of the Proposal
Applicant:
peaceHealth Oregon Region
, 770 E. 11 th Avenue .
P,O. Box 1'479
Eugene, Oregon 97440
I.
,
Property Owners:
Hyland Business Park, LLC (Tax Lot 400)
1941-A Laura Street
Springfield, OR 97477
Attn: Shaun Hyland
. (541) 726-8081
. Andrew Head (Tax Lot 402)'
1616 Ardendale Ln.
Eugene, OR 97405
(541) 521-3403'
Applicant's
Representative:
Philip Farrington, A.ICP ,
Director, Land Use Planning &. Development
peaceHealth Oregon Region .
123 International Way
'Springfield, Oregon 97477
(541) 686-3828 * Fax (541) 335-2595
P farringto n@peacehea1th.org
1.0 Land Use Request
PeaceHealth Oregon Region (the "Applicant") requests approval to change the zoning
, classification on the Clty'S zoning map from Light Medium Industrial C'LMI") to .,
Community Corrimercial ("CC':) for approximately 5.24 acres identified as Tax Lots 400
and 402 on Assessor's Map No. 17-02-32~00. This same acreage on the site is being
. proposed for a concurrent amendment to the Metro Plan diagram (which automatically
also amends the East Main Refinement Plan diagram) from LMl to CC, asallow~d in '
Springfield Development Code ("SDC") 12.020 (l)(a)l.
5-82
Page 2
Zone Change Application .
PeaceHealth ~regon Region
,March IS, 2007
The area subject to the proposed r~zoning is mapped on Attachment A,and is referred to
collectively in this application as the "subject properties" or "site."
2.0 Project Purpose
The Applicant seeks to rezone (and through concurrent applicatioil, redesig(late) the
. subject properties to CC so they may be developed for commercial uses (i.e., Tax Lot
400), including a possible future medical clinic which could serve residents in the.
growing east Springfield area, and to be allowed to continue long-standing 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 beautify 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
. . . \
Refmement.Plan (EMRP) and the Metro Plan as required by approvaLcriteria in,SDC
12.030. In particular, this request - when considered with the concurrently submitted
Metro Plan diagram amendment (and automatic EMRP diagram amendment) - complies
with EMRP Policy 2: "Apply site-specific Coml11ercial refinement plan designations to
clearly define the limits of new commercial uses where there is 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 would also improve the area and better distinguish and buffer adjacent
. residential and industrial business park uses.
3.0 Site Context
The subject properties include a currently vacant, flat parcel (Tax Lot 400) and existing
commercial development (Tax Lot 402) east of 44lh Street along Main Street in east "
Springfield.The site is bordered on the south by Main Street, on:theeast by the Hyland
Business Park,on the north by'ari 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 of Tax Lot 400. Commercial
, enterprises are.located immediately sO\lth of the site across Main Street (e.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 landscapeorgani'cs and Jorest by-products. The current
property owners also used the site to store modular construction offices, tool trailers,'
construction equipmentund concrete form plywood. Tax Lot 402 has had various
commercial services on site since the 19505.
5-83
Page 3
Zone Change.,t-pplication
PeaceHealth Oregon Region
March \ S 2007
The properties have no jurisdictional wetlands or inventoried Goal 5 mitural 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 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 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 along 44th Street is
. zoned and designated Medium Density Residential.
4.0 Applicable Approval Criteria ~,
Zone change proposals are evaluated according to the criteria cif approval contained
'withinSDC 12.030 (3), which requires: .,
I. 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
3. That the property is provided with adequate public facilities, services
and transportation networks to support the use, or will be provided
concurrent with property development. '
Legislative zone map amendments are also required to show that they meet the
criteria for Plan amendments outlined in SDC Artide 7-; and that it complies with
the state Transportation Planning Rule (OAR 660-012-0060), where applicable.
Findings demonstrating consistency with the approval criteria are outlined below.
.
-
'~.1 Consistency with rvletro 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 will not be affected by the
proposed Plan diagram and text amendments, or (3) clearly apply only to specific
development applications (e,g., site plan review submittals or subdivisions). In many
instances the goals, policies and implementation measures. apply to specific development
proposals tfiat will be addressed through compliance with applicable City regulations
during site plan review of a given future development proposal.
Except for the Growth Management Goals, which are addressed below, each of the Metro
Plan policies are addressed in the order in which they appear in the Plan Element section
of the Metro Plan,
5~84
Page 4
,
"
Zone Change Application
peaceHealth 'Oregon Region
March IS, 2007
"
4,P Metro Plan Elements
1, Growth \Y1anag:ment
policies
. i
], The urbcm growth boundalY and se,quential development shall
continue to be implem'ented as an essential means to achieve
compact urban growth. Provision of all urban services shall be
cOllcentrated inside the urban growthl,bOtmdary, " .
The proposal satisfies this policy because the subject propertyis inside the UGB and city
limits and as such, encourages compact urban gro,wth. Also, urban semces are available
at sufficient levels to accommodate the existing and future inflll development resulting
approval of from this application. The City's site plan reviewprocesses ensure that the"
appropriate level of services is available to serve,future development.' '
2, Residential Land Use and Housing Element-.
policies
A.ll' Generally .locate higher density residential development near
employment or commercial services, in proximity to major'
transportation systems or within transportati~n-eJficient no.des.
The proposed redesignation dbesnot affecttheihventory or availability of residentially
designated or zoned land, including the singre~familyresidential are;\. abutting Tax Lot
400 that is zoned and designated for Medium Density Residential; or higher density
residential developments located east of the site along Main Street.' . , '
. . -" ,.' ,. , '
However,. approval of the requested rsdesignation to Community cc):nmercial would.
allow for residential areas proxirriateto the subject area to have close and efficient access
to existing cornrriercial services on Tax Lot 402 and to future medical facilities proposed
for Tax Lot' 400, consistent with the above policy, The areas proposed for redesignution '
offer existing and future_.employment opportunities and provide commercial serVices
alorg a major transportation system that can S\)Pport the needs of nearby residential
development. '
<. .
i~
A,22 Expand opportunities for a mix of uses in rleWly developing.areas
and existing neighborhoods through local zoning' and dev.elopment
regulations. ' ". '
The proposedmap'ameridment and zone change will allow for. existing commercial uses
on Tax Lot 402 to continue to serve existing neighborhoods in the)nid- and east-
Springfield area, and for future clinical facilities to be developed to serve this rapidly
growing area of the community, Approving' the request would expand commercial
, opportunities to serve these neighborhoods consistent with the above policy.
5-85.
Page 5
. ZODe Change ,b-pplication
PeaceHealth Oregon R.egion
March \5 2QO"
3, Econoniic Element
Policies
E.1 Demonstrate a positive interest in e.:dsting andnew industries,
especially those providing above-above wage and salary levels, and
, increased variety oJjOb opportunities, a rise in the stalIdard oj living,
and utilization of our existing comparative advantage in the level oj
education and skill oJ the resident labor Jorce.
, The proposal is consistent with this policy because it will allow medical clinic uses to be
developed to serve growing areas in east and south ~pringfield. As is observed in the
Springfield Commercial Lands Study (pp. 27, 29), employment in health services is
growing and approving the requested redesignation ar',d zone change will enable
increased job opportunities. with higher than average wages thereby raisin!?; the standard
of living and meeting the needs' of Springfield citizens, consistent\vith the above policy.
. ,- , '
B.i Encourage economicdevelopmellt which utilizes local and imported
capital, entreprenwrial skills, alId the resident labor Jorce.
The construction of and the use of commercial and medical uses will utilize both local
and imported capital and will employ the local labor force in a variety of skilled,
semi-skilled, and unskilled positions, consistent with this policy. '
B.6 Jllcrease the al;lOunt oj undev.eloped lalId zoned Jor light illdustlY .
and commercia/useS correlating th~ effective supply in terms of '
suitability lllld availability with the projections ofden/allrL
The proposal will add approximately 5.24 acr'es ofCornrininity Commercial land,
.' .- .
consistent with recommendations to increase the commercial lands inventory made in tne
,
. Springfield,Comrnercial Lands Study. The SCLS and acknowledged metropolitan
IndustriaLLandsStudy concluded that there is a deiicitofneeded commercial land, and a
surplus of industrially zoned and designatedlapd, Approval of the request~d
redesigriation ,and zone change will not cause the inventory'of needed industrial land to
go into a deficit, but in fact would be consistent\vith the above policy. The proposal
correlates the need, suitability, and availability of the subject sitdor cornmercial uses
with the neeq for such uses as demonstrated in the adopted SCLS.
B.ll Encourage economic aC(ivities lvhich strengthen the metropolitall
area's position as a regional distribution, trade, health, and service
center.
The arnendIT;ent will facilitate the development of medical uses that will serve the needs
of the growing'residential areas in ea:st, south and southeast Springfield, and strengthen
the metropolitan area's position as a premier locale forhealthcare services, consistent
with this policy objective.
5-86
Page 6
Z~ne Change Application
peaceHealtlr Oregon Region
March IS, 2007
6. Environmental Design'Element
policies
E,I In order to promote the greatest possible degree of diversity, a broad
variety of commercial, residential, and nicreationalland uses shall be
encouraged when consistent with othe~ plaflning policies,'
Approval of the proposed map amendments will add just over5 acres into the City's
inventory of commercially designated and zoned land, 'thereby allowing for a variety of
needed commercial uses to occur on the subject property. Long-standing exi~ting
, commercial services on Tax Lot 402 would be allowed to continue without the specter of
being considered non-conforming uses, and Tax Lot 400 could be developed with
medical services that will serVe the needs of the growing residential areas east and south
of the subject site, consistent with the above policy. '
7, Transportation Element
Lund Use policies '
F.3 Providefor t~ansit-supportive land ,;se patterns and development;
including higher intensity, transit-oriented development along major
transit corridors and near transit stations; medium- and high-density
residential developrnellt within one-quarter mile of transit stations,
, '
majar transit corridors, employment cen!ers, and downtown:areas; and
development and redevelopment in 4esignated areas that are or could be
well served by existing or planned transit,
The proposal will enable land use pattems and develOPment consistent with the above
policy, Approval of the requested zone change (and concurrent redesignation) will allow
for higher intensity development along Main Street, a major transit corridor. An existing
L TD stop is located on the frontage ofTax Lot 400 (see photo, pg. 2; Appendix A ofthe
TIA), and will provide convenient access to existing and projected employment on the
subject site, as well as access for patients to future out-patient medical facilities projected
on Tax Lot 400. ' '
Transportation System Improvements: Roadways policies
F.I5 J'Ylotor vehicle level a/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 dejiciencies on the roadway ,system,
(2) Evaluating the iinpacts o'n roa'dways of amendments to
transporiation plans, acknolvledged comprehensive plans and
5-87
Page 7
Zone Change.,App\ication
PeaceHeilth Oregon Region
Marco 15 2007
land-use regulations, pursuant to, the TPR (OAR 660-0;2-
0060), '
(3) EvalLwting development applicatio,ns for consistency with the
land-use regulations oftheizpplicable local government"
jurisdictio,n.
b. Acceptable and reliable performance is defined by the following
levels of service under peak hour traffic conditions: LOS E within
Eugene's Central Area Transportation Study (eA TS) area, and
LOS D elsewhere. '
c, pelformance standards fro,m the OHP~ohall be applied on state
facilities in the Eugene-SpringJield metropolitan area. '
In some cases, the level of service may be substandard. Th~ local
govemmentjtlrisdiction may find that transportarion system
improveinents to bring performance up to standard within the planning
horizon may not befeasible, and safety will not be compromised, and
bro,ader community goals would be better served byaliowing a
substandard level of service. The limcitation on the feasibility o,f a c
transportatioll system imp,rovement may arisefrom severeco,nstraintsi
includillg but not limited to environmental conditions, lack of public
agency fintlncial resources, or land use co/lstrai/!tfactors, It is not the
intent ofTSI Raodway Policy #2: iYJotor Vehicle Level of Service to
require deferral of development in stlch cases., The intellt is to defer
motor vehicle capacity increasing tmnsportation' improvements until
existing constraints can be overcome or develoian al/'emative mb: of
striLtegies' (such as: land tlse measures, TDlYJ, short-term safety ,
improvements)'to address the problem.
Subsection a.(2) in the above policy requires an evaluation of the proposal pursuant to the
state Transportation Planning Rule (TPR)c The, accompariying Traffic Impact Analysis
provides the factual basis to detennine that the proposed redesignation would not result in
a "significant effect" as defined under the TPR (OAR 660-012-0060(1)).
Specifically, the proposal does not change the functional classification of Main Street or
, any other nearby roadwaY, nor does it chang'e the standards for implementing the City's
functional classification system of roadways, as identified in the Regional Transportation
Plan. As demonstrated in the TIA, the proposal also does not:
. Result in types or levels of traffic or access that are inconsistent with the functional
classification of Main Street or any other nearby roadway; .
. Reduce'perfonnance of traffic on Main Street or other affected intersections to a level
that is below acceptable established perfonnance standards; or
5-88
, page 8
Zone Change Application
PeaceHealth 'Gregon Region
March IS 2007
.
Make performance of existing facilities worse (i.e" below acceptable mobility
standards) than would be the case other uses permitted under existing designations or
. '
zonmg.
Additional TPR fmdings are further located in theTlA, see pp. 31-32: Becausethe
proposal does not result in a "significant effect" as established by applicable OARs, no
further TPR analysis is required. The request is therefore consis~ent with the above
policy.
8. Public Fadlities and Service Element
policies
G.1 Extend the minimflm level andf~ll.r';lnge of key urban
facilities and services in all orderly. and efficient manner consistent
with the growih management policies 'in Chapter II-B, relevant
policies inJhis chapter and other Metro Plan policies,
The subject property is located in Springfield's city limits UGB. Al1'necessary'
infrastructure and key urban facilities/services are present to serve existing development
(Tax Lot 402) or are available to serve future infill development on Tax Lot 400." -
Therefore, the proposal is consistent with the above policy.
9. Parks and Recreation Facilities Element policies
policies in this element of the Metro Plan are not relevant to the requested zone" change.
. ;\
10. Historic Preservation Element policies
policies in this element of the Metro Plan are not relevant to' the' requested zone change.
." no. '>
11. Energy Element policies
policies in thiS,element ofthe Metro Plan are not relevant to the requested zone change.
5-89
. Page 9
Zone, Chonge f-pplicotion
PeoceHeol\h Oregon Region
March \ S, 2007
4,2 Consistency with East Main Refinement Plan
The following demonstrates how the proposal is consistent with applicable policies in the
East Main Refinement Plan (EMRP).
1. Mb;ed-Use Element
Policy 2) Area #2
A) Thefollowing land <tses are allowed under Community Commercial
zonLng: .
All Comm"nin Commercial. uses subject to Article is of the
Springfield Development Code.
.
The proposal requests rezoning the subject properties from LMI to .Commuriity
Commercial (and concurrently redesignating the properties to CC),'as the above policy.
and other EMRP policies allow. Approval of the request would allow long-standing
existing cOJ:Ill11ercial uses on Tax Lot 402 to continue as permitted under Article 18, and
consistent with neighboring uses to the west and south, which are also zoned and
designated for commercial uses. '
2.
Commercial Element
Criteria for Conlliurcial Refinement Plan DeSi!!nation'
,. "
J: Generally, the Commi",ity Commercial refiitementplan designation
shall be applied <tnder the following ~irc.ul1;:Stances:"
, A) where it is not an intrusion into ;vell-maintaiized residential
neighborhoods; ,
The area proposed for rezoning does not intrude into the existing residential area
west of the subject site along 44th Street, and is therefore consistent with the
above criterion,
B) where it does no/ increase conflict between Low Density
Residential undCommerci~I;' '
Although theabutting residential area is zoned lY1edium Density Residential, it is
develope.d in low-density residential uses. Approval of the proposed rezoning of
the subject sites would actually result in a decrease of conflicts between abutting
residential and non-residential land uses ,by allowing future irifill developrrient 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, '
5-90
Page, 10
Zone Change Application
PeaceHe,lth Oregon Region
March IS 200"
C). where criteria for designating i'Yfedium Density Residential
lanq does/1ot apply;
Criteria for designating MDR land does notapply to the subject site.
D) wl;ere legaJly created commercial uses e.:r:ist;
Tax Lot 402 has existing, long-standing commercial uses that were legally created
prior to'development of the Metro Plan or EMRP.'Ta.x Lot 400 has had a variety
, of commercial services located on-site over'the years.
E) where adequate customer and sen,ice acceSS to an, arterial
stre,et can be provided; ,., and
The subject site has adequate legal access onto Main Street, which is dassified as
an arterial street.
Approval of the concurrently submitted Plan dia~am amendment application
would result in a Commercial designation on the Metro Plan diagram, which
would also automatically modify the designation on the EMRP diagram.
F) where designated Commercial an the MetroPlan Diagram,
, '
Policy 2) Apply site-specific Commercial refillement plan designations
to clearly defill~ the limits of new cO/71I1;ercial uses where there is notan
existing, legally ~stablished, and benefiCial mL-cing of uses.'
Approval of the concurrently requested redesignation would apply Commercial,plan
designations to the subject properties, allowing the existing, legally established,
commercial use. on Tax Lot 402 to continue. ItwQuld also enable commercial uses to be
established on Tax Lot 400, 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 park to the east. Tax Lot 400 does not have an existing or
beneficial mix of uses, but has historically housed industrial yard-type operations. .
Therefore, approval of the proposal would define the limits of new commercial uses as
called for in'the above policy, and also provide the ability to make superior buffering and'
other improvements associated with future development on Tax Lot 400 through the site
plan review process,
Policy3) Reduce the Iwmber of vehicular access points and require the
rebuilding of curbs and illstallatioll of sidewalks alld street trees along
Maill Street, through the Site Plall Review proceSS and ill p'lblic
improvement projects.
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Zone Change.Ap'p\ication
PeaceHealth Oregon Region
March '5 2.007
The proposal would result inreduc\ng 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 accesS onto Main Street, eliminating one of the two existing curb
'cuts on this site. Siciewalks and streettrees are already located along its Main Street
frontage, consistent with the above policy.
Policy 4) Provide buffering between commercial and residentialllses
through Article 31 o/the Springfield Development Code, Site Plan
Review process,
Existing residential uses along the east side of 44'0 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 c.onsistent with the above policy.
3, Industrial Element
Policy 1) The City shall encourage efforts o/various agencies to attract
Ilew arid retain existing jobs ana businesses.
lnwlemwtatio/l
The City shali maintaill a cllrrent. inventory oj vacant commercial a/ld
indiLstrial lalld a/ld structures with ill the East Main area. '
Consistent withthe above policy, approval oftherequested,z()ne ch~nge and
redesignation will enable existing, long-standing jobS and businesses on Tax Lot 402 to
remain as legal, conforming land.uses, and allow future development of new employment
on Ta.'( Lot 400 with higher than average wages and employment densities than the
current designation and zoning aliows. "
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Zone Change Application
PeaceHealtll Qregon Region
March'rS 2007
4.3 'Proyision 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 Lot400. Specifically, sanitary sewer, stormwater, and water lines
are all located along the site's Main Street frontage - all of which are adequate to serve
the needs of existing and/or future development onthe subject site. Transportation
services are also readily available to serve existing and future development, as Main
Street is fully improved witb curb, gutter, etc. '
As indicated in the Traffic lrppact 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 transportationsy~tem, and t.l.erefore is consistent
with the state Transportation Planning Rule: The'TlA further demonstrates that existing
and future development under the proposed zone change has safe. and efficient access and
circulation for vehicles, and also will benefit from the sidewalks, bike ianes, and transit
service existing ciri 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 inSDC Article 7
The proposed zone change is submitted concurrently with an applicaFon to amend the
Metro Plan diagram., The following findings are contained in the Plan diagram "
amendment application, and also demonstrate that this proposal complies with Metro
Plari policies asrequiredinSDC 7.070 (3) and with zone change approval criteria in SDC
12.030. Both the findings below relative to Goal 12 and those above pursuantto Metro
Plan Transportation Element policies address consistency with the state TPR, as. called '
for in SDC 12.030. '
"
It should also be noted that approval of a Metro Plan diagram amenqment also
correspondingly changes the applicable refmement plan (East Main',Refmement Plan)
diagram, as established in SDt 7.110 (4).
Goal 1 - Citizen Involvement
Goal i addresses the need to dev'elop a citizen involvement program to ensure citizen
involvement in all phases of theland 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 nearby property owners,interested
parties requesting'notice, and any established neighborhood organization. Since the
process complies with the City's citizen inVOlvement program and citizens have
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March 1. 5 Z007
Page 13
opportunities to be involved in the procedure, the proposed plan and zone map
amendments are consistent with Goal I.
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 Cityalso sends the statutorily required notice of the initial public hearing
45 days in advance to the state Department of Land C6nservation and Development,
ensuring that they are given opportunity for comment and review ~onforroity to
applicable statewide planning goals. '
The Metro Plan and the SDC, as well as the Statewide Planning Goals and applicable
statutes, provide policies and criteria for the evaluation of comprehensive plan
'amendment and zone change proposals. Compliance with these, measures assures an
adequate factual base for approval of the proposals. As discussed elsewhere in this
document, the Plan diagram and zone map amendments are consistent with the Metro
Plan and the Goals. Consequently, by demonstrating such compliance, the proposal
satisfies the consistency element of Goal 2. "
Goal 3 _ Agricultural Lands '
This goal is inapplicable because as provided in OAR 660-15-000(3), Goal 3 applies of)ly
to rural agricultur'al lands. The subject properties are located within an acknO\vledged
urban growth boundary, are inside Springfield's corporate limits, and have not been in
agricultural use for decades. ' '
Goal4 - Forest Lands
Goal 4 does not apply within urban growth boundaries, per OAR 660-06-0020, and the
areas affected by the Plan amendments are inside Springfield's acknowledged UGB.
Goal 5 - 1'1 atural Resources
GoalS requires local govemments to protect a variety of open space, scenic, historic, and
natural resource values, GoalS and its implementing rule, OAR Ch. 660, Division 16,
require planning jurisdictions, at acknowledgment and as a partofperiodii;.review, to
(I) identify such resources;
(2) determine their quality, quantity, and location;'
'(3) idenlify conflicting uses;
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Zone Change Application
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March IS, 2007
t.
(4) examine the economic, social, environmental, and energy
(ESEE) consequences that could result from allowing,
'limiting, or prohibiting the conflicting us.es; and
(5)' develop programs to resolve t\1e conflicts.
The subject properties are not on Springfield'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 Springfteld Local,Wetlapd 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 Goal 5.
Goal 6 -Air, Water, and Land Resources Quality
The purpose of Goal 6 is to maintain and improve the quality of t\1t air, water and land
resources of the state. Generally, Goal 6 requires that development comply witli.
applicable state and federal air and water ,quality" standards. In the'context of the
proposed Metro Plan diagram amendment and zopechange, Goal 6 requires that the
applicant demonstrate that it is reasonable 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 environmental clean-up list. . A Phase I '
environmental assessment on the subject property was conducted andrecomrnended'
additional analysis. Upon recommendations thr6u'gh the Phase 2 environmental
assessment a nominal quantity of soil (less than 10 cy) impacted by earlier/historic use
was removed from the site' and properly,disposed. Given the nominal impact generated
by historic 'uses on the site, it is reasonable to conclude thatfuture development on the
site will be able to demonstrate compliance with City standards for water quality
protection through tne'site plan review process, thereby complying with applicable state
and federal e~vironmental quality standards.
Goal7 _ Areas Subject to Natural Haiards
Goal 7 requires that development subj~~t 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 known areas of natural disaster and
hazards, such as areas prone to landslides, flooding, etc.
The site is flat and not subject to landslide haza,rds, and is located well outside of any
established FEMA flood hazard area. Therefore, approval of the proposal will not alter
the City's acknowledged compl,iance with Goal 7 through its adopted plans, codes and'
procedures.
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March IS, 2007
,Page 15
Goal 8 - 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.ofrecreational facilities including
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.
Goal9 _,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 tlJ.e city's capacity for economic
development by adding 5 acres ofCC designatedlzonei:lland in place of the existing
industrial designation and zoning. Permitting the construction of fu,ture clinic facilities
on Tax Lot 400 and allci>ving longcstm'lding commercial uses on Ta:-( Lot 402 to continue
and become conforming uses consistent with commercial 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). ..'.
Specifically, the following SCLS policies are applicable to the proposal:
PoliC;y I-A: "Maintain a mixed supply of large and small commercial sites
through strategies s}lch as rezoning or annexation to serve Springfield's
future population." .
The proposal fulfills this policy objective by rezoning (and redesignating)land from"
industrial to commercial use, for two tax lots of varying sizes and commercial uses;
thereby maintaining existing employment and commercial use in TaxLot 402 and
providing the ability for growth in medical sector employment by allowing future clinic
uses on Tax Lot 400.
Policy.l-C: "Maintain at least a five-year supply of commercial land
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 I 58 acres in the supply of
commercial land over demand projected through the year 2015. The pr~posal would
allovi for redesignation and rezoning of five acres thereby reducing the deficit of
coinrriercialland. The subject site has a full range of urban public facilities and services
available to support existing commercial development on Tax Lot 402, and ,future
development on Tax Lot 400. The SCLS identifies (pg. 33) a need to support
"employment in population-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
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Zo~e Change Appllcation
PeaceHealUiDregon Region
March 1 S, 2.007
trends in greater employment in retail trade and well-paying health services sectors.
Approving the proposed'redesignation and zone'change would help meet Springfield's
demonstrated 'need for employment and corrimercial services.
Finding 3 in the SCLS (pg. 36) cited the acknowledged 1992 Industrial Land Study as
demonstrating that"a surph!s of industrial sites exists in,the Metro Area." Therefore, the
proposed redesignatjon (and corresponding rezoning) .would not result in a deficit of
needed industrially designated and zoned land, but it would help reduce the commercial
lands deflcit identified inthe SCLS. Therefore, approving the proposal would be ' '
consistent with SLCS Implementation Strategy 3-A (I):, "Evaluate inventories based on
'demonstrated need for the planning period. Initiate rezoning or redesignation of surplus,
land uses where more appropriate for commercial, consistent with the Metro Plan." , '
",
The proposal in fact consistent with inventories for commercial ahd industrial lands
adopted by the CIty Counciland'acknoWledged by DLCD as being consistent with Goal
9. Oregon Admi~istrativeRules concerning Goa) 9 implemenfition (OAR 660-009- , '
00 I 0(4)) call for amendments to hind 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 req)lirements - 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 flnd that the proposal complies
with relevant local. plan policies by converting one form or employment-generating land
use to another, without negatively impacting the,supply of buildable lands for either
category of uses. The proposal enables continued use of the existing'and long,standino
. 0
commercial center to continue to operate and provide employment opportunities, while
also allowing,higher-val)le employment associated with future development on Tax L~t " ,
400. These types of employment-generating uses are among those identified in OAR '
660-009-0005(6)as eligiblenon-indusl1ial employment activities that canjuslify, .
approval of the proposed Plan'diagram amendment without the need for an economic,
opportunities analysis apart from the SCLS, which DLCD acknowledged as fulf1l1ing the
City's obligations under Goal 9, : .,," ,", ' '
Because the requested redesignation and z.one change implements SCLS policies and.
does not result in a deJiciency of needed industiia1' lands, ~nd 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, '
Goal 10 - Housing
LCDC's Housing goal requires cities to maintain adequate supplies of buildable lands for
needed housing, based on an acknowledged inventory of buildable lands, The proposal
does not affect the City's inventory of residential lands, ';
In fact, approval of the requested redesignatioI) for Tax Lot 400wQuld enable
redevelopment of an iildustrial site abutting existing residential development. Through
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Zone Chang~__Application
PeaceHealthOregon Region
March 15, 20Q"
Page 17
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 theamount.of residentially designated
or zoned land, it does not affect Springfield's continued compliance with OoallO.
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 t~e Springfield UGB and
city limits, and is already d~signated for urban levels of use: The proposed amendment to
the Plan map d,signations arid zone map classifications from LMI to C'C 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 ect site.
Goal 12 - Transportation
00al12 requires local governments to provide and encourage a safe, convenient and
economical transpo_rtation ~ystem. The proposed map amendments and zone change.
involve approximately 5.24 acres of property, though existing and long-standing
commercial uses occur on Tax Lot 402 such that approval of the proposal will not result
in any changes to the type or intensity of uses on the site, and will not increase the trip
generation for that fully developed parcel. As the attached Traffic Impact Analysis (TIA)
demonstrates, future development of medical office facilities on TL 400 will not degrade
mobility standards below acceptable levels and allow for adequate queuing lengths at
applicable intersections. Therefore, the proposal will not have a "sigriificanieffect" on
transportation facilities as defmed in the Transportation PlanningRule (OAR 660-012-
060)'-
"
Existing development at Tax Lot 402 is not affected by the proposal, and\sassumed to
retain its current access points. off Main Street. It is further assumed that fuhJre ,
development on Tax Lot 400 will 'result in 'some access changes as ,vill 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 approximately inthecenter of the
parcel. The TIA demonstrates that these access points will not result in any degradation
of-mobility standards:below acceptable levels, and that s.afe and efficient circulation can
be realized through approval of the requested land use redesignation and 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 I 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 Goal 12 and
applicable local implementing policies. '
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Zone Change Application
PeaceHealtlr0regoo Region
March 1), ?007
r
Goal 13 - Energy'Conseryation
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 would 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: "
Goal14 - U~banization
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 application. " <
Goal IS _ Willamette River Greenway
This goal is inapplicable because the subject prop~rty is not within the boundaries of the
Willamette River Greenway. .' '
Goals l6-I9 - Coastal Goals
The coastal goals are'not applicable to this application.
."', ........
. .
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"- '
'.
..'
StaffRespo~seto written comments to Applications
ZON 2007-00012J LRP2007-00013
SPRINC1Fl~LD
Iii.: Jt4.
EXECUTIVE SUMMARY:.
S taff re~eived one written testimony from Lauri Segel, Goal One Coalition Planner, on,
June 12 ,2007. A wntten 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 Corrunission public hearing on June, 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
review by the Planning Commission. Copies of the ty.'o letters in their entirety are ..
attached foneference and review in addition to the excerpts and Staff respon~es in this
report.
Ms. Sepel's Submittal _ Issue #1: "ApplicanlRelies heavily on the acknowledged
2000 Springfield Commercial Lands Study (SCLS), which does not address the
entire Me'tro UGB area, and is 1I0t a refinement plan of the Metro Plan... The
proposed fill dings rely on reports and other documents containing inventories,
assumptiolls, and data that have 1I0t been established for the entire Metro UGB
area, but rather only for the Springfield portion of the UGB area... "
Anolicant's Rebuttal:. "The cities of Eugene and Springfield have separately
adopted and acknowledged commerciallands studies fulfilling the requirements
of Goal 9. As such, the SCLS serves as the City of Springfield's "most recent
economic opportunities analysis, " as Ms, Segal notes above by her own
admission... There is no reqtdrement that the Applicant or the City perform a
metro~wide allal.vsis of commercia/lands in order to adopt findings satisfying,
compliance with Metro Plan policies and Goal 9... "
ST AFF RE5'PONSE: The SCLS 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 Review process; As such, it is a valid document to reference related to this Post
Acknowledgement Plan Amendment (PAPA) proposal. The SCLS was adopted by
Resolution No. 00-13 as the "policy document guiding the provision of commercial lands
within the Springfield Urban Growth Boundary." The SCLS was revie'wed by DLCD and
found to be consistent with the Periodic Review Order and Statewide Planning Goals.
The SCLS was not adopted as a specific amendment to the Metro Plan. The City
undertook a supply and demand analysis to determine if there was adequate commercial
land in the adopted inventory to accommodate projected demand and, based on these
con~lusions, identify what the City could do to address these conclusions. Chapter 4 of
the SCLS, which includes policies and implementation strategies, all recommended
actions are already in the Metro plan or TransPlan; are a recommendation to amend the
Code; or are suggestions to improve business practices, The City and DLCD concluded
5-100
,it was not necess'ary to adopt the SCLS as anamehdment to the Metro,Plan because all
recommendations regarding inventory adjustments contained in the Study could be
implementedthrougb the PAPA process as increases in the commercial lands inventory;
the SCLS would De used at that time as part of the findings, reasons and conclusions for
those PAPA actions.
Best available data was used in the analysis of these applications, which included the
.SCLS. There are no com'prehensive studies (i.e. commercial lands inventory) available
for the entire UGB related to commercial lands within one specific time period. Rather
_' . . .. 7
there is a conglomeration of various studies that are reviewed. For example, the 1992
Industrial Lands study is UGB-wide. Th~ Reside'fltial La'nds'Inventory which is used by
the City is not UGB-wide. Likewise, the SCLS is not Metro-wide.' '.' '
,Ms. S~~el's Submittal- Issue #2:. ;'Thead@pted SpringfieldNatural Resource
Study (adopted by Ordinance #6150) shows little or no impact 011 the commercial
" lands inventory from Goal protection n;?asw-es, and prr;"ide:lirrle if any analyses
of land availability.within the entire Metro UGB area, rtitherthalljus( the
Springfield UGB area, The allalysis shows an impact of 11.56 acres on
Springfield's (flot theurball growth bOL",dary 'area ill its elltirety)... Th~
referen~ed studies / analyses referenced by the applicant do notwke ill to account
the 1.00 acres of new commercial land designated'! rezoned to commercial in the
Gateway area. .. .
Aoolicant's Rebuttal: "Considering that the SCLS identified a deficit of 158
acres ill the supply of commercial land pver demand, accounting for this
additional redesignated/rezoned land, this w'ould still result 'in a deficit of more
, ihan 61 acres of needed commercial land, Approving the requested Plan
amendmellt/zone change would still leave a deficit of approximately 55 acres of
needed commercial/and... Therefore, even considerillg impacts to commercial
lallds illventoriesfrom other adopted and acknowledged pll!~s (i.e. the City's plall
for Goal 5 compliance) and aclmowledgedPlan amendments / zone changes,
approval of the proposal will not result in there beillg all exces~ of needed
commercially zoned and designated land. To the contrary, thisallalysis
demollstrates that there will remain a deficit of approximately 66 acres after
approval of the requested redesigllati;n / rezollillg,"
STAFF RESP'ONSE:The Springfield Natura,lResource Study (SNRS)is referenced by
the applicant and staff as related'to this PAPA because'it providesamore updated view
of the city's commercial & industrial lands in:;entory, It is not meant to be ~ll inclusive in
and of itself. Reference to the SNRS In conjul\ction with other referenced documents (i.e.
the ,SCLS & 1992 industrial Lands Study) is provided to give thdnost accurate
information possible given aI/the available data at this time.
,
Again, the applicant's report and staffs analysis reference the most recehtly adopted
'documents / inventories available. The City currently does not have an' ongoing database
5-101
~
that keeps track of inventories based upon Plan Amendments andJor Zoning Map'
Amendments on anongoing basis.
The applica~t's rebuttal references' numbers of acres related to the City's deficit of
commerciai land. Staff concurs with the applicant's rebuttal related to number of acres'of
commercial.l<mds. The redesignation and rezoning of up to 99 acres ofresidentiall'and
within the Gateway MDR site (as referenced by Ms. Segel) still, does not negate the
deficit of commercial land within Springfield's city limits. .
Ms. Sepel's Submittal- Issue #3:. "The applicant has notjusrified the
conversion of scarce, shovel ready industrial land, especially land desigtwteda~d
zoned light medium illdustrial inside the Metro UGH, even though the Metro Plan
, (comprehensive plall) Economic Element pplicy #12 establishes that the cities are
to 'discourage,filture Metropolitan Area Ge~eral Plan amend[llents that would
change developrnelltready industrial lands (sites defined as shorHerm in the
metropoliiall Ind~st;.ial Lands SpeCial Study, 1991) to nOh-industrial, '
designations. ' The applicant and staff findings do not address how the loss of
these 5.24 acres impacts the short-term supply of LM1 designated land... "
Annlicant's Rebuttal: "Ms.S.egel 's'citatioll ofEco~omic Elemellt Policy 12
ignores the faCt that the subject site was not included ampng the sites "defined as
, short-term in the metropolitan Industrial Lands Special Study, 1991). ;',...casting
doubt on the applicability of Metro Plan Economic Element Policy 12... Even if '
Policy 12 were rdevant, it's language is clearly not prohibitive to approval of an
application for redesigllation/rezonillg of an industrial site, particularly when
considering it in the,colltext ofiildustrial.commercialland inventories. ...even if
all of the acreage redesignated in .springfield were from the LM1 designation-
which is 110. doubt not the case - there would still be asurplilS ofneai"ly 50 acres
of LMJ designated land even after approval of the requested Plan amendment.
This does not accoulltfor the n.5 acres of land added tfJ the inventory of LMJ
zoned and designated land referenced in my March 28, 2007 supplemental
informatioll. ... Therefore, the removal of 5.24 acres of LM1 zoned and designated
land will not result in a deficit of needed land ill thai industrial desigllation.
...Moreover, although Economic Element Policy 12 "discourages"Plan
arnelldmellts for cerlaill induSlriallands, there are countervailing policies in the
lvIetro Plall (i..e,. Economic Element Policy 6) and SCLS (i.e.. policies I-A and I-
e) that are dire clive to providillg an adequate supply of needed commercial
lands..." .
STAFF RESPONSE: Staff concurs with the applicant's rebuttal to the issue raised. The
applicant has cited numerous acreage. calculations based off of adopted inventories which
support the proposal. As noted by the applicant, the subject site was not included among
the sites defmed as short-term in the metropolitan Industrial Lands Special Study, 199\,
, '
As noted in the applicant's rebuttal and as previously noted in this'report'and the original
Staff Report, a deficit oi commerclal land and surplus of ind Llstri al land will still exist
5-102
even after an approval of the proposed Plan Amendment and concurrent Zoning Map
Amendment. . .
,..'
jyls.'Sezel's Submittal- Issue #4:. "The Applicant's analysis ofthepl'oposals'
consistency with comprehensive plan Economic Element poliCies found in the
Metropolitan General Plan, Chapter IlJ,B-I - B-7 is insliffic'ient and does not
address the most significant policies that'must be considered'"
'Aoolicant's Rebuttal:. "...there are cowltervailing policies in the Metro Plan
(i.e., Economic Element Policy 6) and SCLS (i.e., Policies I-A and I-C) that are
directive to providing an adequate sl'pply of needed commercial la II ds. The Metro
Plan recognizes such conflicts: "The respective jurisdictions recognize thatthere
are ~pparent confliCts and inconsistencies between and among some goals,
objectives,.and policies. Whell ma/dng decis-ions based on thePlall, not all the
goals, objectives, 'and policies can be met to 'the same degree in evelY instance.
Use of the Plan requires a 'balancing' of its various cornponentson a case-by-
case basis, as well as a selectioll of those goals, objectives, alldpolicies most
pertinent to the issue at hand" (pg 1-4, Metro Plan).., The applicant's original
March 15, 2007 submittal includedfindings address'i~g relevant Metro Plan
policies (see pg. 5 of the submittal, pg, 4-5 of the Commission's June 4,2007
" I'
hearillg packet). Clearly not all of the 32 Metro Plan Economic Element policies
. '1 '
are relevallt to the proposal. MallY are aspirational ill nature andnot directive to
a specific quasi-judicial applicatioll... .
,ST AFF RESPONSE: As noted in the applicant's rebuttal, policies in the Metro.f'lanare
sometimes conflicting to one another. As states! on page 1-4 of the Metro Plan, "The
respective jurisdictions recognize that there are apparent conflicts and inconsistencies
, '
between and among some goals, objectives, and policies, When making decisions based
on the Plan, not all the goals, objectives, and policies can be met to the same 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." The,applicant submitted written statements rel~tive to the
policies which supported the proposal. As noted in" the original Staff Report, Staff
concurred with the applicant's narrative related to the referenced Metro Plan policies
which support the proposal, given the relationship of those stated Metro Plan policies as
reviewed concurrenUv with the referenced commercial and industrial adopted inventories.
, '
1 . . -
Ms. Se\!el's Submittal.- Issue #5:. "The appl{wlI/ is not specific about what uses
, will be cited should the proposal be approved, and there is no way /0 know if in
fact above wagejobs and salaries... ti,ere is 110 way to establish if the applicant
will infac/u/ilize local and imported capital, skills e/c. as. no commitmellt to a use
has been established... "
Aoolicant's Rebuttal; "...Ms. Segel'sassertion that [he !ipplicdtion was
unspecific as to /heftl/lIre lIses 011 TQ.~ Lot 400 is inaccurq/e, The application
lIal7ative clearly stales the illlended purpose of the redesignatioll/re:ollillg is to
5-103
"
allow/or ajilture medical clillic on Tax Lot 400 and 10 allow the long-standina
~ .' 0
commercial operations on Tax Lot 402 to continue (pg. 2, pg. 4-2 in the
Commission's Jlme 4 hearing packet). Such clinicalllses are not permitted in any
industrial zoning district, thus promopting the need to rezone (and Redesignate)
Tax lot 400 to allow a medical clinic. Average wages and benejits for medical
workers tends to be higher than average local wages, andjilrther substantiating
data call be entered into the record at the City Council level...
ST AFF RESPONSE: The applicant has noted the intent of the Plan Amendment and
concurrent zone change 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 Traffic
Impact Analysis. In fact, the referenced table in the TlA (Table 7, pg. 19) specifically
calculates trip generation for the orollosed medical office buildinr;. However, 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 ~surance for any neW use that might go on
the property with the existing zoning and Plan designation either:-Given the fact that the
applicant is a medical service provider (i.e. Peace Health); that they are pursuing these
applications; and that they have indicated on their appiication that the purpose of these
applications is to develop a future medical office clinic, it is highly likely (in Staffs
opinion) that they will pursue the medical office use as they've specified. As noted in the
,applicant's rebuttal,average wages and benefits for medical workers tends to be higher
than average local wages. Staff concurs with the applicant's rebuttal statement and '
. affirms the original Staff Report findings indicating that the proposal is in compliance
with applicable Metro Plan policies.
Ms: Segel's Submittal -Issue #6: "The applicant makes the argumenuhat the
proposed plan amelldment and zone change would have the effect of correcting
existing non-conforming uses on TL #402. (map 17-02-32); however, the 2000
SCLe, atAppendix C, "Sites with Plall/Zone ConflictS." does not include the
'subject property, It appears that the existingnoncollformillg uses were ~ctually
established AFTER adoptioll of the 2000 SCLS, indicating.that the existing uses
were actually permitted by the City with the knowledge that these uses woidd
create ploll/zOlle conflicts-" . "
Applicant's Rebuttal:, "The applicant does not allege that there is a Plan/tone
cOllfllct on Tax Lot 402; clearly the existing Plall designations and zollillg are
LlvIl. Rather, the poillt made in our application narrative is that commercial L1ses
, have existed for d~cades, pre-existing the establishment of the Metro Pian and the
application of the LMI designation 011 the subject properties. Ms. Segel provides
no evidence to back Lip her accusation that the City wittingly allowed commercial
uses on Tax Lot 402 after adoption of the SCLS. The applicant and owner of Tax
Lot 402 will provide additiollal evidence and testimony at the City COLlncil
. hearing on July 2 which willji,rther demonstratefactually thatcommercial uses
and employment have been in the building on Tax Lot 402 for nearly 50 years... "
, 5-104
STAFF RESPONSE: The existin~ zoning; for TL #402 is Li~ht Medium Industrial
(LMI).The existin~ PIan Desirnatior; for TL #402 is Li~ht Medium Industrial (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 conflict. Ms. Segel alleges that the City permitted the
. ".
exlstinguses on TL #402 "AFTER adoption of the 2000 SCLS..." and further states that
the uses were ".. .permitted by the City with the knowledge that th'ese uses would create
plan/zone conflicts." This allegation has not merit for multiple reasons. Article 5 of the
Spririgfield 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 allowed as a "new use"
under the existing zoning. The existing commercial uses on TL #402 are most likely
considered non-conforming uses (i.e. commercial uses on industrial zoned property). The
2000 SCLS does not list TL #402 as a Plan/Zone conflict because it is not a plan zone
conflict. '
Ms. Se~el's Submittal- Issue #7:. "The proposed challge is' not 'logical and
,harmonious' because it is not consistent':with the developmellt pattern envisioned
in the Metro Plall ...Compliance with statewide planning goals, including goals
2,6,9,10.12 and 13 has not been established In particular, it has 1I0t been
established that the Eugene-Springfield Metro UGS area's supply of campus
industrial land will be protected purslwnt to the PAPA and zone change
, proposal... StafJ has failed to address the impact that this proposal will have on
the dwindling supply oj shovel ready industrial land inside the Sprillgfield city
limits, inchldingprior actions approving lalld use code amendments to the
campus illdustrial zone that established more 'flexibility'jor what uses are
allowed in the city.'s campus industrial zOlles."
Aoolicant's Rebuttal:: "It shouldfirst be noted that the application does not
involve or in any way afJect the 'metro area's supply oj campus illdustrialland. '
Moreover, the applicatioll has no efJectupon Goal 10 (Housing), and has
elsewhere demonstrated compliance with Goal 12 and other applicable statewide
planning goals, My guess is that Ms. Segel and Nancy Falk, 'who appeared at the
June 4 hearillg and reques'ted the written record be lefi opelljor a week, both
vigorously appose the Plall amelldmentlz'one changeproposedjor the J'o/farcola
Meadows project, and are borrowing arguments to also object to this modest
request bejore the City... The contention that the proposal would not result ill a
'logical and harmoniolls' land use pattern is without substance or basis infact,
and is nol an approval criterion. As noted above and elsewhere in the record, chis
proposal is. consistent wich policies and provisions ill the Metro Plan, its
Economic Element, supporting refinemellt plans (i.e., the SCLS and MILS) to the
Aietro Plan, alld Goal 9 and other applicable statewide planning goals ..' "
".
ST AFF RESPONSE: Ms. Segel refers to the existing zoning of the subject site as
"Campus Industrial" multiple times in her letter. The subject property is zoned and
designated Li~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 criteria 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 and balanced with the relevant Metro
Plan policies to formulate the recommendation for approval with conditions. Specific
findings related to the Statewide Planning Goals have also been included in the original
Staff Report.
.
5-106
GOAL ONE COALITION
~'
Goal One is Citizen Involvement
City of Springfield Planning Commission
David Reesor
City of Springfield
225 Fifth,Street
Springfield., OR 97444
'0 J.:i".;-:-":;,:/''''- r-.-'::-"
.l-:~," ,. '" ~ ;\, H .' .
~ __ .~ ,__"II.. .~ ,::':"-' 2L..J'
.JUN 12 lDD7,
BY:')/ K...'
June 12,2007
RE: ZON 2007.{)00121LRP2007.{)0013, Plan Amendment & Zone Chanoe
, 0
Dear Members of the Commission:
The Goal One Coalition (Goal One) is a nonprofit 6r~anization whose' mission is to provide
assistance and support to Oregonians in matters affecting their communities. Goal One is
participating in these proceedir\gs at the request orand on behalf of its membershlp residing in
Lane County. This testimony is presented on 'behalf of Goal One' and its membership,
including Nancy Falk, 2567 Marcola Road, Springfield Oregon 97477, ,as an individual.
1. Introduction
This proposal is for a site-specific Metro Plan Affiendment I Refinement Plan Amendment and
a concurrent Zoning Map Amendment from Light Medium Industrial (LMI) to Community
Commercial (CC) within the Springfield city limits.
The subject site is located near 44th and Main Street (Highway 126).;The site consists of two
parcels under separate ownerships, and is located on approximately 5.24 acres identified as
Ta.'{ Lots 400 and 402 on Assessor's Map No. 17-02-32-00. TL 400 (5.01 acres) has several
vacant buildings on site, lncludmg portable trailer type strUctures. The smaller of the two
subject lots, TL 402 (.24 acres), has an existing commercial development on-site, although the
plan designation and zone are LMI. 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 Main Refinement Plan. Properly'located east and adjacent to TL #402 is built
out as a business park, and designated LMI. Properties located south of the subject site, acrosS
Main Stree~ arezoned,and'designated Community C.ommerciaI..
II. Criteria applicable to the request
Local approval criteria are found i!l the following 'documents: Springfield Development
Code, Metro General Plan, and East 1>'lain Refiflement Plan, as indicated in the staff
report.
The proposed plan amendment must also be found to be consistent with applicable statewide
planning goals. ORS 197.175(2)(a) Applicable goals include Goall, Citizen Involvement,
Goal 2, Land Use Planning; Goal 9, Economy of the State; and Goal 12, Transportation. The
Eugene office: 641 Chameleon Sui", 1'00 . Eugene OPO 9740 I . 541-431-7059 ' fax 541-431.7078
Lebanon offlte: 39625 Almen Drive' Lebanon OPO 973S5 ' 541-258-6074 ' fax 541,258.6810
V("#W.goaJ 1.org
5- 107 "
GOAL ONE COAUTION
proposed plan amendment must also comply with administratIve rules implementing
applicable statewide planning goals.
Ill. Analysis
COMPRFHEN~IVE PLAN CONSISTENCY AND COMPLIANCE WITH
ST A TEYV1DE GOALS.
All comprehensive plan amendments are reviewable for compliance with the statewide
planning goals. Residents of Rosemon! v. Metro, 173.Or App 321 (2001); 1000 Fnends of
Oregon v. Jacksoll County, 79 Or App 93, 97, 718 P2d 753 (1986),.rev den 301 Or 445
(1987); OpllS Development Corp. v. City of Eugene, 141 Or App 249, 254, 918 P2d 1\6
(1996).
Goal 2 _ Land Use Planning is: "To establish a land use planning process and policy
framework as a basis for all decisions and actions, ,elated to use of land and to assure an
adequate factual base for decisions and actions." Specifically, local land use actions "shall be
consistent with the comprehensive plans." Goal 2, Part L Furtj1er, the infonnation upon
which land use decisions are made "shall be contaiI}ed in the plan document or supporting
documents." Goal 1 , Part I.
In this case, the applicant relies heavily on the ac~owledged 2000 Springfield Commercial
Lands Study (SCLS), which does not address the entire Metro UGH area, and is not a
refinement plan of the Metro Plan. 1t is the 1992 Metropolitan Industrial Lands Study, that
does address the entire Metro UGB area, is part of.the Metro Plan, and is reflected in the
Economic Element of the Plan.
The proposed findings rely on reports and other documents contaUlillg inventories,
assumptions~ and data that have not been established for the entire Metro UGB area, but rather
only for the Springfield portion of the UGB area. This material includes data used to justify
findings of compliance with goal 9. Any decision:relying on such findings would not comply
\vith Goal 2.
GoalS
"
Concerning applicability of land, inventories pursuant to Ordinance #6150 that
adopted the Springfield Natural Resource Study, staffs position is that inventories
established pursuant to Goal 5 are relevant considerations in considering availability
of commercial and industrial land. However, that analysis (applicant's Attachment
"A" _ tables 11-1, 11-2 and 11-3) actually 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 thaJ1 just the Springfield
UGB area. Table 11-2, Analysis of Maximum possible Impact on Supply of
Commercial Lands within the Springfield Urban Growth Boundary shows an impact
ofl1.56 acres on Springfield's (not the urban growth boundary area in it's e'ntirety)
commercial land supply.
Metro Plan/East Main P,eflnemenl Plan, ZON 2007 -DOO 12 - LRP 2007 -DOOn
5-108
2
GOAL ONE COALITION
Additiomilly, the analysis pursuant to Ordinance #61'50 fails to account for lands ADDED TO
the cOrI)IT1ercial :iiwentory since 2000, including but not bruited to the Gateway.MDR site's
'100 acres, providing a skewed picture of the actual commercia1'1and inventory.
To skew the ,picture even further, the analysis ofm:L,<imum possible impact from Goal 5
protection measures on supply of indlistriallands "(Ordinance #6150, \abie 11-1) considers
ALL industrial lands within the entire Metro UGB area, rather than just the Springfield portion
of the UGB, and does noLprovide a breakdown of number of industrially zoned acres in
Springfield vs. Eugene. The 2000 SCLS, however (Table 3-2) shows that the number oflight
medium industrial (LMI) acres by plan designation' in the Springfield VGB area is 198:77,
while the number' Of LMI acres within the Eugene VGB is shown to be 1230.78. The
applicant fails to establish the r,levancy ,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 adequa.te opportunities throughout the
state for a variety of ecorlomic activities vital to the health, welfare, and prosperity of Oregon's
citizerl.?" ,
The Staff Report's Goal 9 findings are based upon the 1992'Industr1al Land Study and the
2000 Commercial Land Study. Goal 2 requires that information upon which land use
decisions are made be contained in the plan document or supporting documents.
, .
OAR 660-015,0000(2), Part I Planning establishes that city, county, state and federal agency
and special district plans and actiorlS related to land ~e shall be consistent with,the,
'comprehensi 'Ie pl~ of cities and counties and regiorlal plans adopted under ORS Chapter
268. . .. ','
Goal 9 _ 660-009-0010 (4) establishes that for;a,post_acknowledgement plan amendment
under OAR ch~pter 660, division 18, thai changes the plan designation ofland in'excess
of two acres within 'arl existing urban growth boundary from an industrial use designation
to a rlon-industrial use designation, or arl other" employment use designation to any other ,
use designation, a city or county must .address all applicable planning requirements, and:
(emphasis added)' " "
(a) Demonstrate that the proposed amerldment is consisterlt with its most recent ecorlomic
opportUnities arlalysis alld (emphasis added) the parts of its acknowledged
comprehensive p'l:m which address the requiremerl'ts of this division;.
The applicant appears to rely. heavily on inventory and policy statements established by the
2000 SCLS in establishing that the proposal is consistent with the Goal 9 rule. However, the
applicant's analysis of the proposals' consistency with compreherlsive plan Ecorlomic
Element po[i'cies t~und in the Metropolit~ General Plan, Chapter!ll, B-1 - B-7 is insufficient
and does not :lddiess the most significant polici<;s that must be considered.
, '
The proposal would di:crea$e the City's campus industrial land inventory by yet another 5.24
acres, The applicant has not justified the cOrlversion of scarce, shovel ready industrial land,
Metro Plan/East Main P,efinement Plan. Zm12007-00012'. LRP 2007-00013
5-109 "
3
GOAL ONE COAUTION ,
especially land designated and zoned light ITledium industrial inside the Metro UGB, even
though Metro Plan (comprehensive plan) Economic Element policy # 12 establishes that the
clties are to "discburage 'future Metropolitan Ivea General Plan amendments that would
change development ready industrial lands (sites defined as short -term in the metropolitan
Industrial L.ands Special Study, 1991) to non-industrial designations." The applicant and staff
,findings do riot address how the loss ?fthese 5.24 acr'es impacts the short-tenn supply ofLMl
designated land. . '
The applicant makes the argument that the p~oposed plan amendment and zone change would
have the effect of correcting existing non-confof1!1ing uses on TL 1!402. .(map 17-02-32);
howe,!er, the 2000 SCLC, at Appendix C, "Sites with Plan/Zone Conflicts" does not include
the subject propertY. It appears that the existing nonconforming uses w~e ac~ally established
AFTER adoption of the 2900 SCLS"indicating that the existing uses' were actually permitted
by the City with the knowledge that these uses would create plan/zone conflicts.
. .
in addressing applicability of the Springfield 'Cormnercial Lands Study (2000 SCLS), the
. applicantappe~ to try to separate the Metro Area by jurisdi~tional boundary. However,
Eugene and Springfield have a shared and adopted UGB', Comprehensive Plan, and industrial
Lands study. The jurisdictionally focused SCLS does not analyze supply arid demand for the
entire Metro UGB area and cannot be relied upon on it's own to establish consistency with'the
.requirements of OAR 660-009-0010 (4), which establishes that the proposed PAPA be
consistent with both (emphasis added) tbe most recent economic opportunities analysis (i.e.
the 2000 SCLS) and the comprehensive plan.
A related problem with p\acingsuch heavy reliance' on the 2000 SCLS to establis)J Goal 9
compliance'is that in analyzing supply and 'demand, the study fails to consider or othervrise
account for \'U1ds added to the commercial inv'entory 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 100-acre Gateway Medium Density Residential site
that had the dfect of rezoning ';"d ~edesignating 100 acres of residential land to commercial.
The applicant provides a spreadsheet (their. AttaclUTIent B) that supposedly accounts for all
Metro Plan diagram changes affecting the supply of residential, commercial and industrial
Lan.ds in the city of Springfield between \991 and the present, but ~as 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 omission raises doubt as to the accuracy of applicant's Attachment B in supposedly
account\na 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 #6\50 on November 28, 2005.
While those inventories may be rel'evant to.this proposal in that possible 'impacts' resulting
from Goal 5 protection measures were considered for all, zoning classifications, the analysis of
maximum possible' impact on supply of commercial lands, pursuant to ,the study is limited to
the area within the Springfield portion of the lv'1etro 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 establish an accurate picture'of the supply of commercial lands.
Melro Plan/East"Main Refinement Plan,' ZON 2007-00012 - LRP 2007--00013
, 5-110
4
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
"commercial acres."
LOSS OF INDUSTRlAL LAND
. .
The proposed plan amendments and zone changes would remoye 5.24 acres of shovel ready
light medium industrial land from the Metro UGB .area indusmallands 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 f9r plaI; and zone ch~ges. 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 ,,vould contribute even
furiller 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 l!I, Section B) of the Plan as relevant to the proposed PAPA.
The four Plan policies considered by the applicarit as relevant to the s~pply of industrial land
are policies 1,2,6, 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 stilldard of living, and ,utilization of our existing comparative advantage in the level of
education and skill of the resident labor force. 'However, the applicant is not specific about
what uses will be cited should the proposal be approved, and there is no way to know if in fact
above wagejobs iilldsalaries.
.,
Policy 2 is to'encourage economic development~which utilizes local apd imported
capital, entrepreneurial skills, and t~e 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 :oned (emphasis added) for
light industrial ~d commercial uses correlating the effective supply in terms of suitability and
availabiliry with the projections of demand." .
Tills policy-addresses zoning only, not plan designation, and concerrls'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 PlaniEaslfllain P,efinemenl Plan, ZON2007-D0012 -,LRP 200HIOO,13
b-l11 .
s
GOAL ONE CO-:'-UTION
Policy i I 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) ,,,ill facilitate the development of medical ).lSes 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 medical facility development is the wave of the
future, arid 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 PAP A proposal must be consistent with the Economic Element of the Comprehensive
plan in it's entirety. A majoromission found in the application and staff report is an analysis
of all the Metro Plan Economic Element policies other than t~e four: addressed by the,
applicant. The rerpaining 28 policies should be addressed in some manner. More
specifically, the following policies are directly relevant to the inventory of industrial lands
throughout the Eugene-Springfield Metro UGB area. "
5 _ Provide existing industrial activities sufficient adjacent land for future expansion.
This 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 Economic
element, and if approved would have the effect of lirniting 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, '
E~onomic Element of the Metro Plan, Finding #17 establishes: "Special light industrial fums"
"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
lfJe 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 efficient energy use.
. Metro Plan/East flla'ln Refinerr:ent Plan. ZON 2007 -D0012 - LRP 2007 -Doon
5-112
,
6
GOAL ONE COAUTlON
Neighbors have expressed no concern about their quality oflife from t".~ting industrial uses.
The applicant has notaddresse? why or how the existing light medium industrial zoning and
. plan designation is incompatible wi\lJ the adjacent neighborhood zoning,?Jld plan designation,
16 _ Utilize processes' and local co[)trols which encourage rei~ntion of large parcels or
consolidation. of small parcels ofindustrially 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 LlvU. Staff
is directed by this policy to encourage retention of this parcel of mdustrially zoned and
designated land, which is one of the few rernaining parcels of LMI land within the Springfield
city limits.
21 _ Reserve several areas within the UGS 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 industri al land inside the Springfield C;ity limits, inc1udir]g prior actions
approving land use code amendments to the campus indLlStrial 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 community tommercial zoning
within a node, or explained why neighborhood commercial zoning is being ignored for higher
intensity uses in this existing neighborhood.
All the Metro Plan Eco[)omic Element policies are applicable to this application, and should
have bee[) addressed by the applicant.
".
111. Conclusion
The proposed pla[) ame[)dment is not logical and harmonious with,the bnd use pattem for
th~ greater area. The proposed change is not "logical and harmonious" because it is not
consiste[)t with the development pattern envisioned in the Metro P,la[).
As ex.plained above, the proposed amendment is lnconsistent with the inte[)t of the Economic
Element of the Metro Plan, and does not comply with Metro Plan policies. Therefore it carinot
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 PlanlEast Main Refinement Plan, zml 2007.00012 -LRP 2007 -00013
5~1l3
7
GOAL ONE COAUTlON
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 riot benefit the public and are not
appropriate.
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.
-'.
Respectfull y submitted,
Lauri Segel
. Community Planner
.\
Metro Plan/East Main Refinement Plan, ZON 2007-00012 - LRP 2007-00013
5-114
8
m Pet eHealth
June 13,2007
Springfield Planning Commission
Attn: David'Reesor, Planner
City of Springfield
Development Services Dep,artment
,225 Fifth Street .
Springfield, OR 97477
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Re: ZON 2007-00012, LRP 2007-00013 - Plan AmendmentiZone Change
Dear Chaim1anCro,ss and,Commissioners,
The Commission considered the above-referenced applications on June 5 at a duly
noticed work session and public hearing. The folJowing rebuts written testimony
submitted by Lauri Segel of the Goal One Coalition at the close ofthe extended record
yesterday. '
Ms. Segel suggests that the applications do, not comply with statewide
planning Goal 9 (Economic Development) - and by extension with Goal 2
(Land Use Planning) - because the 2000 Springfield Commerciall:ands
Study (SCLS) "does [lot address the entire Metro UGB area, and is not a
refinement plan of the Metro Plan." (pg..,2; June 12,2007 Segel letter) ,
She further states that "Eugene and Springfield have a'shareq and adopted
UGB, Comprehensive Plan, and Industrial Lands studY. The
jurisdictionally focused SCLS does not analyze supply and demand for the
entire Metro UGB area and cannot be relied upon on it's [sic] own to
establish consistency with the requirements of OAR 660-009-0010 (4),
which establishes that the proposed PAPA [Plan amendment] be
consistent with ,both ,( emphasis added) tre most recent econ9mic
opportunities analysis (i.e., the 2000 SCLS) and the compreherisive plao."
(pg. 4, Segel letter) -
"
Aoolicart's R,esoonse: The SCLS was developed by the City and a.dopted by the
Springfield Ci!y Council (Resolution No, 00-13 and included in the end pages of the
,SCLS) to comply with Goal 9 and applicable OARspursuantto periodic review
requirements established by the Oregon Land Conservation and Development
Commission. Prior to the SCLS, the City of Eugene had an acknowledged plan for
complying with Goal 9, the 1992 Eugene Corrimercial Lands Study (ECLS), The ECLS
states: "The study includes solely the Eugene,portion of the metropolitan urban growth
boundary," (pg. 1-3, ECLS)
Pban~: (541) 686.3660
f:l~: (541) 686']699
PO Box 1479 Eugene OR 97440-_1479
",,,,,;,j"',,"',.,,h':",,lrh....rn
Oed/celled 10 Exceprional Medicine
and C umpassiqnflle Care
5-115
Re: ZON 2Q07-00012, LRJ 17-000\3 - Plan Amendment/Zone Change
Applicant's Reburral
JHn~ 1: 2007
Page 2
, . '
Although,ihere is in fact an ackno\vledged study covering both communities' industrial
lands (the 1993 Metropolitan Industrial Lands Policy Report, and companion Inventory
Report), the cities of Eugene and Springfield have separately adopted and acknowledged
commercial lands studiesfulfLlling the requirements of Goal 9. As such, the SCLS serves
as the City of Springfield's "most recent economic opportunities analysis," as Ms. Segel
notes above by her own admission. The SCLS also complies with Metro Plan PoliCY 31
which called for the City to conduct a commercial lands study, and fulfills the'City's
_ Goal 9 requirements pursuant to the periodic review work order, now accepted as
'complete,by DLCD. There is no requirement that the Applicant or the City perform a
metro-wide analysis of commercial lands in order to adopt findings satisfying compliance
with Metro Plan policies and Goal 9.
Ms. Segel states that the analysis provided does not account for additions
to the inventory of commercial lands, notably "the Gatew.'\y MDR site's
100 acres." (pg. 4, Segel letter) ,
Aoolicallt's ResQonse: The City previously adopted amendrnents to 'the Gateway
Refinement Plan (Jo. No. 2002-08-244), including GRP, Implementation Action 12.1,
which limited redesignution and rezoning of up to 99 acres ofresidentiai land within the
Gateway MDR site., Subsequent Plan diagram amendments and zone changes of 96.2
acres and 3.5 acres resulted in redesignationlrezoning of96.2 acres to Mixed Use
Commercial or Medical Services of the possible 99 acres available under the GRP.
Considering that the SCLS identifled adeflcit of 158 acres in the supply of commercial
land over demand, accounting for this additional redesignated/rezoned land, this would
still result in a deficit of more than 61 acres of needed commercial land. Approving the
requested Plan amendment/zone change would still leave a. deficit of approximately 55
acres of needed commercial land.
The supplemental information submitted into the record by the Applicant included the
City's analysis of impacts to ~he cornmerciallands inventory pursuant to the City's
acknowledged compliance with Goal S periodic review requirements. Table 11-2 of this
analysis (see pg: 3-25 in the Commission's June 4, 2007 hearing packet) identifies that as'
a consequence of the City's Goal 5 protection measures that approximately 11.5 acres
would be removed from the inventory o'f needed commercial lands, thus further adding to
the commercial lands deficit established lU the SCLS.
Therefore, even considering impacts to commercial lands inventories from other adopted
and acknowledged plans (i.e" the City's plan for Goal 5 ~ornpliance) and acknowledged
Plan amendments/zone changes, approval Qfthe proposal will not result in there being an
'excess of needed commercially zoned and designated land. To the contrary, this analysis
demonstrates that there'will remain a deficit of approximately 66 acres after approval of
the requested redesignation/rezoning.
5-116
Re: ZOt-! ~07-000iZ, LR D7-00013 -Plan Amendment/Zone Change
Applicant's Rebuttal
June 13, 2007
Page 3
. , Ms. Segel states that the application relies"heavily on inventory and
policy statements established by the 2000SCLS in establishing that the
proposal is consistent with the Goal 9 rule. However, the applicant's
analysis of the proposals' consistency with comprehensive plan Economic
Element policies found in the Metropolitan General Plan, Chapter Ill, B-1
_ B-7 is insufficient 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 Ele'ment policy #12 establishes that
the cities are to 'discourage future Metropo'lltan Area General Plan
amendments that would change development ready industrial 'lands (sites,
defined as short-term in the metropo]itanlndustrial Lands'Special Sludy,
]991) to non-industrial designations'.' The applicant and staff findings do
not address how thdoss of these 5.24 acres impacts the short'term supply
ofLMI designated lillld.'" '
f,.oolicant's Response:, The Applicant's original March 15,2007 submittal included
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 all of the 32 Metro Plan
Economic Element policies are relevant to the proposal. Many are aspirationill in nature
and. not directive to a specific quasi-judicial application, for example Policy 28~
"Recognize tl;1e vital role of neighborhood commercial facilities in providing services and
g09ds to a particular neighborhood." (pg. lll-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 Commercial, Lands Study prior to
the next major plan update." (pg. IIl-B-7, ibid) Nonetheless, to demonstrate that all.
policies were considered irrespective Mtheir applicability, the Applicant will provide
supplemental'find,ngs and enter them into the record prior to the Cit{Council hearing on
these applications. However, this does not suggest lhat the Applicant's findings are
presently inadequate or that the Metro Plan polici~s cited are not on point.
Ms. Segel's citation of Economic Element POlicy 12 ignores the fact that the subject site
was not included among the sites "defined as short-term in the metropolitan Industrial
Lands Special Study, 1991)." The adopted and ackriow\edged Metropolitan illdustrial
Lands Policy and inventory Reports identify the S\lbject site as' being included in .
"Subregion #8 ~ East Springfield." Maps and tabular information in these reports (pp.
42-44, tables pp. 18-26; 1993 ~lIL Policy Report) do not identify the subject site among
the "short-term sites" in the industrial lands study; presumably because both were
considered developed. The abutting property now developed with the Hyland Business
Park was, however, identified in the study as site #7 in this subregion. While the Hyland
property was included in the matrix of "short-term sites," it was also identified as being a
"developed" site. The MIL Policy Report states that "sites developed during the study
;',
5-117
Re: ZON 2007-00012, LR. 07-00013 - Plan AmendmentlZoneChange
App l,cant' 5 'Rebunal
June 13 ?007
Page 4
were not included in the short-terin supply of sites. '.Staff projected a five year need for
industrial sites based on development trends in Eugene-Springfield during the previous
,two year period, a time of economic growth. This short term demand was compared to
the existing supply of sites, excluding those already developed. [emphasis in original
report]" (pp. IS, 16) Therefore! the subject site was not included in the inventory' of
short-term industrial sites in the industrial lands study casting doubt on the applicability
of Metro Plan Economic Element Policy 12.
Even if Policy 12 were relevant, itslanguage is clearly not prohibitive to approval of an
application for redesignation/rezoning of an industrial site, particularly when considerino
,.' ~
it in the context of industrial and commercial land' inventories. As stated above and
established in the record, there is a demonstrated need for additional commercial land
which the proposal helps address.'~ '
'The record also includes evidence demonstrating that there is a surplus of needed
industrial land. The acknowledged metro industrial lands study identified ~ surplus of
, buildable light medIum industrial acreage, arid overall industrial acreage, in Eugene,
Springfield, and combined in the metro UGB. Table 5 in the MIL Inventory Report (pg.
47) identifies supplies of buildable ,industrial land as follows:
Eugerie
Springfield
Metro UGB
LMI Acres
1,230.78
198.77
1,429.55
Total Industrial Acres.,
2,895.49
703.80
3,604.29
The report further states that the study "identifies about 1,688 constraint-free industrial
acres.... This supply exceeds the projected demand over the next twenty years, which is
between 650 to 1,1 nacres," (pg. 73, MIL Inventory Report)
As noted in the City's GoalS analysis entered into the record: the maximum impact of
industrial acreage from GoalS protection measures in Springlleld is 54.43 acres (Table
11.3, pg, 3-25 of the Commission's June 4 hearing packet). The analysis also found that
there were 90.80 acres removed from the industrial designation by prior Plan
amendments in Springfield. Therefore, even if all of the industrial acreage impacted by
GoalS and ill.! of the acreage redesignated in Springfield were from the LMI designation
_ which is no doubt not the case - there IVould still be a surplus of nearly 50 acres of LMI
designated land even after approval of the requested Plan amendment. This does not
accOlmt for the 11.5 acres of land added to the inventory of LMI zoned and designated
land referenced in my March 28, 2007 supplemental information.
Therefore, the removal of 5.24 acres ofLMJ zoned and designated land will not result in
a deficit of needed larld in that ind'ustrial'designation.
Moreover, although Economic Element Policy 12 "discourages" Plan amendments for
certain industrial lands, there are countervailing policies in the Metro Plan (i.e.,
5-118
Re: ZON" t~07-00012, Uti _J07-000l3 - Plan Amendment/Zone Change
.Applicant's Rebuttal
Tnn... 11 ?On7
Page 5
Economic Element Policy 6) and SCLS (i.e., Policies I-A and l-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, not all'the goals, objectives, and policies can be met
to the same degree in every instance, Use of the Plan requires a 'bal'ancing' 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 is;;ue at hand," (pg, 1-4, lvietro Plan) The Applicant
contends that findings and evidenc'e in the record from adopted and acknowledged
sources demonstrate that approval of the requested redesignationlrezoning is consistent
with applicable policies and fulfills the City's employment-generatirig objectives and
requirements under Goal 9.
I
Ms. Segel's letter states that "the applicant is riot specific. about wharuses
will be cited should the proposal be' approved, and there is no way toknow
ifin fact [sic] above wage jobs and salaries." (pg. 5, Segel letter)
She also states that while "the 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
nonconforming uses were actually established AfTER adop}ion of the
2000 SCLS, indicating that the existing uses were actually permitted by
the City with the knowledge that these uses would create plan/zone
conflicts." (pg. 4, Segel letter)
Aoolicant's Resoonse:, The Applicant does not allege that there is a Plan/zone conflict on
Tax Lot 402; clearly the existing Plan designations and zoning are LML 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 LMl
designation on the subject properties. Ms. Segel provides no evidence to back up her
accusation that the City wittingly allowed commercial 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 lLlly 2 which will further demonstrate
factually that commercial uses and employment ha,ve been in the building on Tax Lot 402
for nearly SO years,
Ms. Segel's assertion that the application was unspecific as to the future uses on Tax Lot
400 is inaccurate. The application narrative clearly states the intended purpose of the
redesignationlrezoning is to allow for a future:medical clinic on Tax Lot 400 and to allow
the long-standing commercial operations on Tax Lot 402 to conlinue (pg, 2, pg, 4-2 in the
Commission's June 4 hearing packet), Such clinical uses are not permitted in any
industrial zoning district, thus prompting the need to rezone (and redesignate) Tax Lot
400 to allow a medical dlllic. Average wages and benefits for medical workers tends to
5-119
.Re: ZON 2007-00012, LRP 2007-00013 - Plan Amendment/Zone Change
Applicant's Rebuttal
June 13 2007
Page 6
be higher than average local wages, and further substantiating data can be entered into the
record at the'City Council level.,
Ms. Segel contends that the proposal is not "logical and harmonious" with
, land use pattems in the greater area, inconsistent with the intent of the
Economic Element of the Metro Plan, doesn't comply with Metro Plan
policies, and hasn't demonstrated compliance with statewide planning
goals 2, 6,9,10,12, and 13. "In particular, it has not been established that
the Eugene,Springfield metro area's supply of campus industrial land will
be protected pursuant to the PAP A..ind zone change proposal."
, '
Aoolicant's ReSDonSe:. ,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
app lication has no effect upon Goall 0 (Housing), and haselse\vhere demonstrated
compliance with Goal 12 and other applicable statewide planning goals. My guess is that
Ms. Segel and Nancy Falk, who appeared at the June 4 hearing and requested the written
record be left open for a week, both vigorously oppose the Plan amendment/zone change
proposed for the Marcola Meadows project, and are borrowing arguments to also object
to this modest request before 'the'City.
,The contention that the proposal would not result in a "logical and harmonious" land use
pattern is without substance or basis in fact, and is not an approval criterion. As noted
above and elsewhere in the record, this proposal is consistent with policies and provisions
in the Metro Plan, its Economic Element, supportiJ).g refinement plans (i.e., the SCLS and
MILS) to the Metro Plan, and Goal 9 and other applicable statewide planning goals.
On the basis of the record and arguments before you,we urge you to sUPP9rt the Staff
, recommendation and forward to the City Council your recommendation approving the
pending applications.
,~
Philip Farringt
Director, Land Use Planning &- Development
PeaceHealth Oregon Region
cc: Jim Werfelmann
Andrew Head
Shaun Hyland
5-120
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