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HomeMy WebLinkAboutNotice PLANNER 7/18/2007 (2) AFFIDAVIT OF SERVICE ,'I. STATE OF OREGON County of Lane } }ss. } 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 .. ~ - -0-- ~~_._' J )'= , =,,"= -.." . oFFiCIAL SEAL r r. ,SANDRAMARX J . i NOTARY PUBLIC. OREGON i \,., ,/ COMMISSION NO, 385725 i, '~COMMISSION.~~V:.12.:?~=- b.-~-....-.:::-'--'-''''~''''''''-''-''''''~' .' dwM))A^-. !h,.CWi/ I .,;/; / . 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. ---A ~ .../ I / . y ~- / ~ ;. 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 cr 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 <;-L ". 3 Existing & Proposed Metro Plan Designation: i i I I ; ,I' ! i 'ii~~~ lJ. : j ! /: ! '~' rUi ': I ,- -1--1 ; !------ "_ c\ I,L-l , I,---_J I I' ' I __-1-_-1 .____J '_". ,I 'il. ~j:!: ------, i--- . .._L_____-1_jJ:__~__Cd_i ''':'.~~/''---- ',' --'~' i - ?/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 ~Jr4 '/;'1fNI oJ,.,,"" ..am.nl""'" 110110<::'''''''111." Utufln.><1"<" I.h,..".u""'~nll,,,,,p<lru,biUryJf),,,,,."I,,",,,.dalM);""rlJ,ng frr""'lIly.:rrur,","lw",",,,^,wno,,,,li"",,"'lF"C.i'oJIf!l.'(lrtxl""f '00 __~Feet -". J June, 2007 LRP2007-000/3 &'ZoN2001-000/2 4 Ii-Ii Existing & Proposed R~finement Plan Designation: /<.\, :.)-, I" . ,I " "j ~ ~ ~ ~ 0; ~ "I I Jc~I""I" )I~I I j , i '--J- ;.' I, r=. 1.., ,..... , , ''''_h__' 1--". I ..;,,~I 'I. '. i ' "--L-__ _. --'-. -.J 'I ):"'2.';: . ~ 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 ~~ 1~..... ar."" .."'IV""'" thoIQU::""P"".vJh"'prrxi~n U.nw;""",.al/r"'f'U"17bili'.vjO,an.~iauar""mQg.aru'''g ./rOff'JUlY rim', Oml.W 01'1 V fDS'll"""/ iMC<l<,P/:Y of /JtlS P",Ju~ I o -.oc 'lIO"Feel - -------" June, 2007 LRP2007-000/3 & lON2007.000 /2 5 <;-~ Existing & Proposed Zoning: \. :.' " i f" \ .:" :..;..:~ :-..../ i I r-~-..... ',', ....., -:-. ,/1 '- / ''''''. , "./ . ,"...... ~, - /\ . / I V . ',,' . ,.:-.__.. ._1' . . L--.-~, . I.' 'I I ! (----'-1 : I I I . " I . '. _~ ,-----L___~.-:-.._"- __!_'~._..j - 'T---' , , , ' , ,,'I,',' ,I ".'< . r=;-I ! II 1,1 " , i "I I L.. I ~ Clange from Lght Medium Industria! (LMI) to Community Commercia! (CC) Zonirg _ Medium Density Residential low Density Resj~ential ... Community Canmercial Ught Medium Industrial _ I-eavy Irdustrial ~ " ~~ Th.,.,.",..",,"''''''''''''"' <h"'''a..~",,,,,,.,,lhllp''xiw:, u..n."........<illr."pmwhllllyfi1'''''ym.arJD'''''$.''".,''!l' jrvmQ1lyrrror,"""....Q1ICTp>.lfi"""llntJ<:am'ryajiJo.up"'.J"CI '" . 2l0F",,1 June, ZJ07 lRP2 00 7-000 /3 & ZON2007-000J 2 6 "-7 Existing Site Conditions: Existing commercial uses on TL 402 Existing modular units located on TL 400 LRP2007-000J3 & ZON2007-00012 J Existing empty structures on TL 400 Existing business park on properry located east of TL 400 7 ~-A 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' , . ..? ::;: ;:~'. ......,. (~: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 I 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 M ~ (f ip, il :~ ,} ~1 :1 ~l , .~~ ,;i oj ii' ~~: i..! " ~ ;;:; ~'i " . ~ :~ I~ W.1 :~ ,. ~~ ~ ~I t' "fl! , ~ ,1 r, f$l " " rl ~1 }j '~ ~ ". r I I I I , 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" ",. ...-:...... ,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 , " '. 'i.. " 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. 5-46 Metro P ianlEMRP DiagraIu r.:.nendrnent peaceHealth Oregon Region March 15, 2007 Page 2 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. 5-47 Me\ro PlanlEMRP Diagram Amendment PeaceHealth.Oregon Region March \5 2007 Page 3 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. 5-48 Metro PhinlEMRP Diagram Amendment PeaceHealth Oregon Region March 152007 Page 4 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; 5...'49 ' Metro Phln7EMRP Diagram M.Il1endment PeaceHealth Oregon Region March 15 2007 Page 5 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. 5-50 Metro PlanlEMRP Diagram Amendment PeaceHealth Oregon Region March \5 2007 . Page 6 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, 5-51 Metro PlanlEMRP Diagram Amendment PeaceHealth Oregon Region March 15, 2007 Page? 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," 5-52 Metro PlanfEMRP Diagram AITlendment . PeaceHealth Oregon Region 'Morch '5 2007 Page 8 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. 5-53 ~ - Metro PlanlEMRP Diagram Amendment PeaceHealth Oregon Region March 15 2n07 Page 9 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) 5"':54' Metro PlaniEMRP Diagram Amendment PeaceHeallh Oregon Region March \ 5,2007 Page 10 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 5'-55 Metro PlaniEMRP Diagram Amendment PeaceHealth Oregon Region March 15, 2007 Page 11 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. 5-56 Page 12 , Metro PlaniEMRP Diagram Amendment PeaceHealth Oregon Region March 15,2007 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. 5-57 Metro PlaoiEMRP Diagram fVIlendment PeaceHealth Oregon Region March '5, 2007 Page 13 The proposed amendment is consistent with this policy because it will allow medical clinic uses to be developed to serve growing areas 'in east and south Springfield. As is observed in the 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. 5~58 Metro PlanlEMRP Diagram Amendment PeaceHealth Oregon Region March 15 2QQ' Page 14 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 '. /..3S/.0? 1.7.i9.8-"'~ ',' I I J I :1 , .1 .' / .' -:- 7...9C",".: S/-9,1-4" . .5"00.2 ,401 . 501 ..-. 12 322 4 '0 , "l .2 . .. ~ lJJ , .1 .'4 . .' l'-. ~ ~ ~ l' ~ . . ,'8 ~ , ~ ~ , N :" l-., ~ ~ ~ I /35/..3$0' , I>) , , Ill' ", ~' ,,' ~' t.. . ..... .: , . - '" " . .~ ~ \l' T)~ ~ , 5-'5.+' -:;..J'"..J'" .t;tirr#'~:~.', '.. , .....- I I I , I :~I Iii If OJ \ E X 1ST J[,'; r Vj'J , ' /' .!J.'f(Jch/ L I so/' /~--L26'3 '/_ ... NE COR./" ' NW COR. :;: TD EDWARDS AWHAMMIT~ D.L.C. 55 D,LC. 36 lOa . ~ ,\';.; . ,~. ~~ '<\ ~ co , to ' (\j ci z Cl .<!. o n:: ~~~.44~t: (() b.; "- ~ -... \. \t~i4'~;:fj;:'\'~~;~;~;~; c'''~~''':',,*. · : . -.:',,'... :T62- . ~ . ,y,.i~./. " "-'I:<!;~>' >- 1--- Z' :J o o . '. . ;",\<{(,,;~, ->~ !,;,~:.i~!:~\~.~_!'-~ III Community Commercial Light Medium Industrial i'f;,j Medium Density Residential PRO P 0 S E ?_.__~I so/' /W-LZ8.3 ',:=J L _ NE COR./' NW COR :: TD EDWARDS AW HAM;'m * 'D.L.C. 55 D,LC. 36 100 /3S/, 02 , -J.ojI <X8-'?"j, I ' '. I I I' .1 I I- I I I . 1\1 , '~I q, "i ~ \f ~ ~ '; I I', /35/...'J$O' . 77..9C"," = .:5""/-9./4' SOO.2:,. ' '401, ',50l, . " 2 .32 2 4 . '0 OJ ,2 ~. --, :lITH , I '<l . , 1\,' ~ ~, l' ~ . ;g ~ ~~ ~ ,- '" ... . . ~ a \1' T)~ ~ . 1<)' "" ~ ~ ;.. ... . ~ (/) 1T~+' ,-500- ' ;.:ffl3- ' . ~ , ~ " ~ ~. '" : '\i ~ ~ 'tI ... .... .~ <; Be)' 4'1- 'e --,.." ;"..:... , '" "100-, . i . co r<J N b z a c:t o '0:: >- t- Z ;:) o o .Ell! Community Commercial Light Medium Industrial Medium Density Residential , ", .-10+<., . ; Metro Plan I Refinement Plan Amendment Application #LRP2007-00013 Rezone Application #ZON2007~00012 Melro Plan Amendment from LMI to Commercial and concurrent Zoning Map Amendment from LMI to CC J,"~iii,!!..~.lil~I!,I~...1 hj~iJ.' ' i:W\:(f;i'!,}M e tra,' :i.i;Lii~~'s~,~i,;_; I ~~r "t"IoI..."",.."L. lIIII Ill! '~'e'~:,~::::~---'-'~' ::::o~:~...- ::..~,:..:.:. 11.1 "~i!~ lilli' , . . ,. _ ... ;; ,="",.",,':s,;'\ 5-67 '. '. .,1 1 CJ1 I m co N "'"f: J.I.c.':..,).... /II'llr. iii-III'" 'Ii j; ,/ ''1'' ,. P T D " " .~l ~ .... ... r:0 0'> to I Lt) ...' -q- o r- , u:> ('-. VJ C o "" VJ UJ ::J o 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.$1 28.20 .82 0 33.83 Medium Industrial I Heavy - -, - - - - - - "-' .-'-- 13.16 (2.88) 2.01 19,15 0 34.32 Industrial - - -'- 1.631 0, \ Campus- .35 0 0 1.28, 0 Industrial Special 0 0 0 0 0 0 Heavy Industrial 01 I Quarry 0 0 0 0 0 NIinin~ 0.60 \ Booth'i<.clly- . ----- ' - .13 0 0 .47 0 MU I ' Wetland 41.84 (30,64) 6.82 21.72 0 70,38 Total' Riparian Total Site 25 ft, 50 ft. 75 ft. Total Areas Riparian Acres not. Setback Setback Setback Acres Site Protected Acreage by SQM 5-79 " Zoning Total Site 25 ft. ' 50 n: 7S It, Total District Wetland Acr'es not Setback Setback Setback Acres Site Protected Acreage ' by SQM Light- 16.48 (10.89) 2,05 4.72 1.26 24.51 Medium Industrial. I Heavy 68.31 (2.81) 1.22 8.93 0 78.46 \ Industrial . \ Campus 3.22 0 0 2.83 ' ,03 6,081 . lndustrial Special 0 0 0 0 0 01 Heavy . Industrial \ Quarry 0 0 0 0' 0 0 Mining -..- - Booth Kelly' .21 0 0 .82 0 1.03) MU lliparian 88.22 (13.70) D7 17.3 1.29 110,08 Total Gr'and Total 130.06 (44.34) 10.09 I 39.02 I 1.29 180.46 \ , '5~80 c:n I co ~ Metro Plan Diagram Changes -A(tecling"'tti-e Supply of Residential, Commercial and Industrial Land Changes In Metro Plan Desirnalions ' -...-- .--- - - -----,.- ---.- . NC CI LMI pas G&E NR AG \ j j I OA1 33.01 1 ~-;j~1~;'; ,," 1 ;\;~:~~1i~~i! ,r:'C;~a'i;','de\jjt1in?j'~\ ij~'~J~:'~~il#I~~f~~~1{t, ~~.~,,~~ill!{~,(~W{5~~'q1 :'[f~:~t:gc~gj~{)~~~:t~,~,~~~~ .-' ", '~;2'a';q; ~i,!~'HQ~3 f':q B ~o.ltpt~f!d~'bl~,,{grh'rid'j'~tr'I~I~I~~[.~~tt~(~ t>{~~J~~5~f'SP~B I I ILocal File Nu'mber 190-04-058 90-12c201 '92-04-77 \93-01-33 93-01"1:l 93-06-087 194-10-0194 \95-02-036 195-02 -03i; - '195-02-0:Ji; \95-02-0:Ji; - 195-02-036 195-08-0157 197 -05-101 199-02-038 \99-02-041 99-09-230 102-03-0062 102-03-0063 102-07-200 102-08-243 ILRP-2002-12431 , LRP-2004"00031 LRP-2005-0001 b Reside nlia I:(ohl\s 7's,inQ~;~~ ~~$_:;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;: MU -3.7 j 1 1 1 1 I \ I 9.2 72.0 ,18.0 16.5 -34.5 -22.0 6.0 J;> -l -l :t:> 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. 5-91 Page 11 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. " 5-92 Page 12 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 5-93 Zone Change/,pplication PeaceHealth Oregon Region 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; , 5-94 Page.14 Zone Change Application P eaceHealth Oregon Region 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. 5-95 Zone Changq\pplication PeaceHealth 6;egon Region 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 5-96 Page 16' 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 , 5~97 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. ' 5-98 Page 18 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. ."', ........ . . 5-99 "- ' '. ..' 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 ~--.. '['"()':~: (-'~~'c::'"" ,j/J', '~"-/tj.',:-<,-, , . r, I . ''''i''>- o . cl "-,,,' /~l'~ ' ,lUll) -....1/ >~. / .....~~ t . ~'- J ' '-~~-.' 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 P35rn..- 52 ,FedEx. US Airbil/ Express From _~_...-~ David Reesor Sende(sFedEx Oatil 7-18-2007 ACCDuntNumber fo4Ell Trooiln~ Nu",b., 8558 0671 6338 1054-6085-6 ~~::r's CITY OF SPR INGFIELD Phone I 5411726-3753 e,m"""CITY.OF SPRINGFLD/DEV S'VCS = M M M M ~ .,. 6 = = Address 225 N 5TH ST -"."".,; em, ciPR I NGF I ELD StaiR OR ~p 97477-4671 G:i = w ~ t5 3 To g Recipient's c:q Plan~dment 2 Your Internal Billing Reference rnll~ """'"<!"''''.ppt.. 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