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Home My WebLink AboutNotice PLANNER 7/18/2007 (3) ~ AFFIDAVIT OF SERVICE STATE OF OREGON } }ss. County of Lane } I, Brenda Jones, being first duly sworn, do hereby depose and say as follow_s: 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 LRP2007-00013 to 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. ~~,Mc4 Brenda Jones '-6 . Planning Secretary Date Received' '7/, ~ () 7 Planner; DR I STATE OF OREGON, County of Lane 9.JJ/l. /Y, ., 2007 Personally appeared the above named Brenda Jones, ~vaw who acknowledged the foregoing instrument to be their voluntary act. Before . ~..--_......~.~.--,:::-._.......",:".,--"-.'.-. ~~"7""~1 1'. OFFICIAL SEAL j l .' S~DAAMA~ j '. ) NOTARY PUBLIC-OREGON . './ COMMISSION NO. 385725 . L MY COMMISSION EXPIRES NOV: 12, 2008 ! ~ -:-~..=-...~..~.7'.""::"..:..~e'e~.-:--'_.~ ~lAAP' My Commission Expires: /1 /tZ/ z.. tJ 0 '5 62 Notice of Adoption THIS FORM MUST BE MAILED TODLCD WITFITN <; WO~KJNG DAYS AFTER THE FINAL DECISION PER ORS'197.6'1O; OAR CHAPTER 660 - DIVISION 18 For DLCD Use Only Jurisdiction: -.City of Springfiel(l Date of Adoption: 7/16/2007 Local file number: lRP2007 -00013 Date Mailed: 7/18/2007 Date original Notice of Proposed Amendment was mailed to DLCD: 4/16/2007 D Comprehensive Plan Text Amendment D Land Use Regulation Amendment D New Land Use Regulation .D Comprehensive Plan.Map Amendment . [g] Zoning Map Amendment D Other: Summarize the adopted amendment. Do not use technical terms. Do not write "See Attached". The applicant requested approval to change the designation on the Metropolitan "Ian diaQram from Light Medium Industrial (lM!) to Commerical with an automatic amendment to the East Main Refinement Plan for aporoximatelv 5.24 acres on subject proferty. The City Council voted unanimously to approve the proposal on July 161,2007. The adopted Ordinance has an effective date 30 days after the Council voted for approval. Describe how the adopted amendment differs from the proposed alI1endment. Ifit is the same, write "SAME". If you did not give Notice for the Proposed Amendment, write "N/A". . A condition of aoorovalwas reauired to limit the triD aeneration from the development to the '~reasonable worse case development scenario" in the LMJ . zone. Plan Man r.hHnpeo from: _'-11/11.. tu:...,Commerc:;i(lL_ '7 ,11"...,. 1 r- .r.....V.l.l.....-..yiup ....,,::1~.l""-'-....6.....~ lJ..U.lJ..L. .v. Location: 17-02-32-00 Tl 400 & 402 Specify Density: Previous: N/A A.pplicable Statewide Planning Goals: 9 & 12 Acres Involved: 5.24 New: N/A Was and Exception Adopted? DYES. [g] NO . , . Date Received:~! 07 ....'anner: LlK DLCD File No.: ~ ATTACHMENT A -~i Did the Department of Land Conservation and Development receive a Notice of Proposed Amendment....., Forty-five (45) days Ilrior to first evidentiary hearing? If no, do the statewide planning goals apply? If no, did Emergency Circumstances require immediate adoption? [g] Yes DYes DYes D No D No D No Affected State or Federal Agencies, Local Governments or Special Districts: Citv of Sorinafield & ODOT Local Contact: David Reesor Address: 225 Fifth Street Zip Code + 4: 97477- Phone: (541) 726-3783 Extension' . City: Springfield Email Addres's: dreesor{Q)cLsorinafield.or - ~ ADOPTION SUBMITTAL REQUIREMENTS This form must he maileq to DLCD within 5 workin~ davs after the final decision per ORS 197.610, OAR Chapter 660 - Division 18. 1. Send this Form and TWO (2) Conies of the Adonted Amendment tc?,: 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 [mdings 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 [mal 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 in the local hearing and requested notite of the final'decision. .7. Need More Copies? Youcan copy this form 'on to 8-1/2xlllITeen naner only: 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 A.M~1\-D~ENT SPECIALIST. . Date Received:-2 lRl157 J:lpalpaalforrnslform2word.doc Planner: DR revised: 71712005 ' I CITY OF SPRINGFIELD I 1 DEVELOPMENT SEIWICES DEPARTMENT I NOTICE OF DECISION " "1 ,. SPRINGFIELD CITY COUNCIL ..,' METRO PLAN I REFINEMENT PLAN MAP AMENDMENT & I ZONING MAP AMENDMENT DATE OF NOTICE: July 18th, 2007 July 16th, 2007 ZON2007 -00012 & LRP2007 -00013 DATE OF DECISION: JOURNAL NUMBER: , APPLICANT: PeaceHealth NATURE OF REQUEST The applicant requested approval of a Metro Plan I Refinement Plan Map Amendment to the East Main Refinement Plan 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'and Zoning Map Amendment from LMI to 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 Commission 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 Council 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 intent to 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. . I QUESTIONS If you have any questions concerning this matter, please contact David Reesor, Planner III at 541.726.3783. ~0~ l David Reesor, Planner III Date Received:i 1181D7 Planner: DR ORDINANCE NO. 6200 (General) AN ORDINANCE AMENDING THE METRO PLAN DESIGNATION OF APPROXI- MATELY 5.24 ACRES OF LAND,-IDENTIFIED AS LANE COUNTY ASSESSOR'S MAP 17. . 02,32-00, TAX LOTS 400 & 402 FROM LIGHT MEDIUM INDUSTRlAL (LMI), TO COM- MERCIAL WITH AN AUTOMATIC REDESIGNA TION TO THE EAST 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 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 ai-functional plan diagram or mop 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 16th, 2007 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 LRP2007-00013, 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 Council;. and 6. On July 20'; ,2007 the Springfield City Council held a work session 'and a public hearing to consider and to receive testimony and hear comments on this proposal. The City Council is now ready to take action on this proposal based uponthe 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,inthe matter of adopting this Ordinance amending the tyfetro 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 1. The Metro Plan designation of the subject property, more particularly de- scribed in EX-h, ibit A att~ched hereto and incorpor~ted herein by refer~n< e, i1 hereby amended from LIght MedIum Industnal to CommercIOate Received:..2. ~ Cil . Planner; DR ' '. ORDINANCE NO. Ii/OO PAGE I OF 2 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- na'1ce 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 of this Ordinance. FURTHER, although not part of this Ordinance, the Springfield City Council adopts findings 1-6 herein above, and the findings set forth. in the Staff Report which demonstrate con. 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 .Ju1 v .2007 by a vote of --2- for and ~ against. . APPROVED by the Mayor of the City of Springfield this' 16 t~ay of' July ,2007. ,\)~{/; Mayor / cr A TrEST: &x.u~ City Recorder U REVIEWED & APPROVED AS TO FORM ~O"> <"lI'''' ~ \. - ''''''1 DATE: kZ5.:n, OFFICE of CI TY ATTORNEY , Date Received' Planner: DR 1! l8fcn , I ORDiNANCE NO. /;200 PAGE 2 OF 2 .ORDINANCE NO. 6201 AN ORDINANCE AMENDING THE SPRINGFIELD ZONING MAP l?Y REZONING APPROXIMATELY 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 COMMUNITY COMMERCIAL (CC), (General) THE COMMON COUNCIL OF THE CITY OF SPRINGFIELD FINDS THAT: 1. Article 12 of the Springfield Development Code sets forth procedures for Springfield Zoning Map amendments; and 2. On March 16'h, 2007 the applicant/owner oJthe subject property initiated the following Springfield Zoning amendment: / Rezone approximately 5,24 acres of land from Light Medium Industrial to Community Commercial, Case Number ZON2007-000J2, for properly 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 Commission held a work session and public hearing to receive testimony and hear comments 011 this proposal. A second public hearing was held on June IS'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 Council; and 4. On July 2od, 2007 the Springfield City Council held a work session and a public hearing to consider 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 ~s the evidence and testimony presented at this public hearing held in the matter of adopting this 0rdinance amending the Springfield Zoning Map, NOW THEREFORE, based upon the foregoing findings tlie 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 of tile remaining portion of this Ordinance, FURTHER, although not part of this Ord'inance, the Springfield City Council adopts findings I -4 herein above, and the findings set forth in the Staff Rep0l1 which dem'onstrate 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. ... . . /. . Date Recelved:-2 ~ 01 ORDINANCE NO. 6201 Planner: DR I PAGE I OF2 '.i. ADOPTED by the Common Council oUhe City of Springfield this 16th day of July ,2007 by a vote of ~ for and'~ against. APPROVED by the Mayor of the City of Springfield this 16thdayof SJ;; .~ Mayor I ATTEST: ~. .MruJ-o.-' City Rec~rcieQ R EVI EWED I:. APPROVED .. A::i TO FO. RM ." ~~....~\...~ DATE: J.p;2l:'l'(J1.:- , OFFICE OF CITY ATTORNEY . .. l Date Received: . Planner: ~R .ORDINANCE NO, 6201 PAGE 2 OF 2 July ,2007. , lBlol I t:XHIBIT A 25p.RINQrl~ 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 2nd, 2007 - City Council Aoolicant ' . Case Number: ZON 2007-00012 LRP 2007-00013 Andrew Head (TL 402) 1616 Ardendale Ln. Eugene, OR 97405 Aoolicant's Representative Philip Farrington, AICP Director, Land use Planning & Development Peace Health Oregon Region 123 International Way Springfield, OR 97477 Owner PeaceHealth Oregon Region 123'International Way Springfield, OR 9747( Hyland Business Park, LLC (TL 400) Attn: Shaun Hyland . 1 941 - A Laura Street Springfield, OR 97477 Date Submitted: March 16"', 2007 EXECUTIVE SUMMARY: . The applicant is seeking approval of a Metro Plan Amendment 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 or proposed. The applicant is requesting these amendments in order to pursue a future Medical Office' building on the subject site, The subject site is located within the East Main Refinement Plan area, . . The subject site is located near 44'" and Main Street (Highway 126), The site consists of 'two parcels, and is located on approximately 5,24 acres identified as Tax Lots 400 and 402 on Assessor's Map No, 17-02-32-00, The majority of the site is vacant (TL 400), with some small vacant buildings on site. The smaller of the two subject lots, TL 402, has an existing commercial development on-site. Properties located to the north are zoned and designated heavy industrial. Parcels located west of the subject site are designated mixed-use on the East Main Refinement Plan, Property located east of the subject site is designated LMI. Properties located south of the subject site, across Main Street, are zoned and designated Community Commercial. . As mentioned in findings in this report, Staff supports the proposed Metro Plan I Refinement Plan and Zoning Map Amendment. As noted in the City of Springfield's 2000 .' ~- . Date Received" 7 -([ -----{j Planner' DR ~" - LRP2DD7-0D0I3 & ZON2 D07-DDD I 2 ATTACHMENT . I ( ~~c'. ) ,_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 arid the community's vision change over time, The proposed Metro Plan Amendment is a Type II Amendment, meaning it is site specific and is located within the city limits, . In order to approve these applications, the applicant must demonstrate compliance with the Statewide Planning Goals, Metro Plan, Oregon Administrative Rules, State Statutes, and demonstrate the ability to service the site with adequate public facilities and services, This Staff Report provides findings of fact relevant to each of the applicable criteria of approval and recommendations to the Planning Commission. Upon review of the evidence provided by the applicant, site visits,' existi'ng structures/uses and revi'ew of the applicable criteria of approval, staff finds that the applicant's reqlJest for a Metro Plan / Refinement Plan Amendment and concurrent Zoning Map Amendment from LMI to GC is appropriate for the subject property and recommends 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 Pe'riodic Review) is known as a Post Ackno..yledgement 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, Pursuant to SDC 7.110'(4), approval' of the requested Metro Plan diagram amendment automatically amends the refinement plan diagram and is proc'essed concurrently, . Findings onact 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 400) and existing commercial development (Tax Lot 402) east of 44th Street along Main Street in east Springfield, The site is bordered on the south by Main Street, 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.- . I ': " ' 'iJ~'" . , ;J' ~.- i- . \ . LRP2007,OOOl3 & ZON2007,OOOI1 5-2 I. 2 Commercial enterprises are located immediately south of the site across Main Street (8.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 desi9nates 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 Ah~a #2 in the EMRP, and are all zoned Community Commercial. Property to the west of Tax Lot 400 along 44'" Street is zoned and designated Medium Density Residential. lRP2007-000 13 & ZON2007-00011 "-3 _ - ~ ". 3 . Existing & Proposed Metro Plan Designation: / , /\ '! ,.' '. (.... '-'" ,~ /~'U ._1 i '--------4 , // '( i:'11 J. ~ ! i I ! Tir--i .'~ i - ) Ii. I. i, j ',---"--- I I 1'-"-', !'-' : I , -, I :-_J n: J I !J!~ . I .J___,~_lt_______~ I' I ,--_. -1-1 , ' "\ ' ~ Change from Light Medium Industrial to Commer~ial Metro Plan Designation .. Commercial MU D Light Med, Indus! D Low Den Res, D Med, Den, Res, l1li Heavy Industrial , . ~~ Ih.",af'l'nu..""",,,,,...rItiJlau::''''f'<'''y/h'spro.J''.'1 Ur"""m'm.(!II"""p<J,ulhiJii'!jO'<l"yl~J(Vd","ll.!:<Ur",,,g /",,,,uny<nvr. "",U>-'u"" pmnooo(11IQl:w,acYUjll",rprodt,"'r "" :00 Feel June, 2007 LRP2007,OOO 13 & lON2007-00012 4 "-,, , Existing & P , .. . roposed Refine ,.. ment PI '. , ' . ..' an DeSignation' . . . IW\INST ) "1':--.< '<IP>,J--~ . I' I-"~ . h , I ' ..' I "1 ,,~ "" ~ ange from L' h ' Ref' '9 t M d' Inement PI e lUm Indust 'a\ . _ an n (LMI) to __ Commun . Community C Low 0 Ity Commeraal . ommeraa\ (CC) ens,y R 'd Med' eSl entia! . lum Density R . Ught-M d' eSldential m He e lum ledustrial :[,'e1l M' avy ledus!rial ..'" Ixed Use 2 & 3 .. I r ("/C',"'.... - \' 'X"-' \;) :';XiJl'; ~ . ~~ 1''''''"''''' U'r7a:i~U"",.arru"''':~m<J{''<X'' ]i-om;;""~ mt all rUf'<'''tID'r. '.Yfo;;::'~ /Jus prod""- ._ _"""',""'US'OI'IlrfW1IIO",;/,,,..or,Ja"'''!l'rafUI1l8 """"vc.vafliluprod"r:r ~" "",... June, 2007 LRP2007000 - /3 & ZON2007,OOOJ 2 5 ~-R Existing & Proposed Zoning: .1,;!1~tI -'. "'.'- ,... - '<::::~'>~';:'~-'f:~:;li ;~-.,; .,..;.,., ~..:...__. __I '1., . ..... 'R'" .. , Ii,' . [' I I; I . f-'--"-,, ~ Olange from Light Medium Industrial (LMI) to Community Commercial (CG) Zonirg . Mecium Density Residential . Low Density Residential .. Community Canmercial Light Medium Industrial _ l-'eavy Il'dustrial ~~ T/kno"",,,,,..u""""''''' /Jw'cxr''''pOIIylhul'''Jdut:1 thrJ 4Ut>,.",,1l rO;po<U'h,bl)'p "~y hu or """'f1!t. """'~1 f"''''Q1IY''''''', ""'".,,,,, " fZ'S"""'<1/,,,tN:{I""cy"fdu:rpm<iuel '" . ~c Fuc June, 2007 LRP2007-0001J & ZON2007-0001 2 6 .t:;_ ' Existing Site Cond.itions: Existing commercial uses on TL 402 Existing modular units located on TL 400 LRP2007-00013 & ZON2007-000/2 Existing empty structures on TL 400 . Existing business park on pro percy located east of TL 400 7 ~-~ 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 ZON2007~00012 (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 Application LRP2007-00013, 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 Pla~ 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 Development,Services Department on March 16'", 2007, and deemed as complete on April 11'", 2007, Notice for both applications 'was mailed to Department of Land Conservation and Development (OLGD) on April 16'", 2007. Notice of the public hearing date was mailed out onTh'ursday, April 19, 2007 to . property owners within 300 feet of the proposed zone change per Section. 14.030 (1) (a)- . (n) of the SDC, Public notice of the hearing was published in the local newspaper (Register Guard) on May 17", 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 LMI on the Refinement Plan Diagram,' Specific Findings related to the Metro Plan and EMRP Street Refinement Plan Designation are written in this report. METRO PLAN DIAGRAM AMENDMENT CRITERIA OF 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 the relevant 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. " CRITERIA OF APPROVAL - SDC 7.070 (3)(a) APPLICANT'S NARRATIVE: . ' Consistency with Statewide Planning Goals: LRP2007,OOO/3 & ZON2007.00012 5-1) , '. 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: Goal 1 _ Citizen Involvement: To develop a citizen involvement program that insures the opportunity for citizens to be involved in all phases of tfie planning process. Goal 1 addresses the m!ed'to develop a citizen' involvement program to ensure citizen involvement in all phases of the land use planning process. The Planning Commission and the City Council will hold public hearings and accept testimony on the proposal. Through the procedures established by the city, citizens will receive notice of hearings in generally published local papers and have the opportunity to be heard regarding the proposed diagram amendment and zone change. Notice of the public hearings will also be given in accordance with SDC requirements to neart5y property owners, interested parties requesting notice, and any established neighborhood organization. Since the amendments comply with the City's citizen involvement program and citizens have opportunities to be involved in the procedure, the proposed amendments are consistent with Goal 1. ST AFF'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 previously mentioned in this report, notice for both applications was mailed to Department of Land Conservation and Development (OLCO) on April 16th, 2007, Notice of the public hearing date was mailed out on Friday, May 11 th, 2007 tD 'property Dwners within 300 feet of the proposed zone change per Section 14.030 (1) (a)-(n) of the SDC, Public notice Df 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 CDncurs with the applicant's written statement related tD 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. 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. Goal2 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 Departmentof Land Conservation and Development, ensuring that they are given opportunity for comment and review conformity to applicable statewide planning goals. ' LRP2007-000 13 & ZQN2007-000/2 9 S-1r.. 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 these measures assures an adequate factual base lor approval of the proposed Metro Plan diagram amendment. As discussed elsewhere in this document, the amendmen'ts are consistent with the Metro Plan and the Goals. Consequently, by demonstrating such compliance, the amendments satisfy the consistency,element 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 acknDwledged Metro Plan, adopted refinement plans and special area plans and the zoning, Staff concurs with the applicant's written statement related tD G9al 2, APPLICANT'S NARRATIVE RELATED TO GOAL 3: . . "' GOfll3 _ Agricultural Land: To preserve and maintain agnculturallands. This goal is ina'pplicable because as provided'inOAR 660-15-000(3), Goal j 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 '. agricultural use for decades. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 3: . Finding 3: The subject property is located within the city limits Dn land planned and zDnea for urban use, The City does nDt have any agricultural zDning districts, either within its city limits or within the urban growth boundary,' Finding 4: GDal3 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 _ Forest Land: To conserve forest lands by maintaining the forest land'base and to protect the state's forest economy'by making possible economically efficient . forest practices that assure the continuous growing and harvesting of forest tree' species.as the leading use on forest land consistent with sound management of soil, air, water, and fish.'and wildlife resources and io provide for recreationa/'opportunities and ~griculture; Goal 4 does not apply within urban growth boundaries, per.OAR660-06-0020, 'and the areas affected by the Plan amendments are inside Springfield's acknowle'dged UGB.. STAFF'S FINDINGS RELATED TO COMPLlANC,EWITH GOAL 4: '. Finding 5: The subject property is located'within an acknowledged urban growth boundary, Goal 4 does not apply within urban 'growth boundaries. Staff concur with the applicant's written statement related tei' Goal 4, ' LRP2007,OOO /3 & lON1007-00011 , J 0 0_11 APPLICANT'S NARRATIVE RELATED TO GOAL 5: Goal 5 _ Open Spaces, Scenic and Historic Area, and Natural Resources: To conserve open sface and protect natural and scenic resources. Goal5 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, require planning jurisdictions, at acknowledgment and as a par! of periodic review, to (1) identify suchresources; (2) determine their quality, quantity, and location; . (3) identify conflicting uses; (4) examine the economic, scicial.-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 GoalS inventory. No threatened or endangered species have been inventoried on the site, and no ' archeologi~al or significant historical inventoried resources' are located onthe 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 amendmentdoes not alter the City~s compliance with GoalS. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 5: Finding 5: 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 applicability of Goal 5 rules to Post 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.5: Goal 6 -'Air,Water and Land Resources Quality: To maintain and improve the quality of the air, water and land resources of the state, The purpose of Goal 6 is \0 maintain and improve the quality of the ai'r, water and land resources of the state, Generally, Goal 6 requires that deveiopment comply with applii:ablestate and federal air and water quality standards. In the context of the proposed Metro Plan diagram amendment, Goai 6 requires that the applicant demonstrate that it is reasonable to expect that applicabie state and federal environmental quality standards can be met. Thou'gh 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 addit,ional analysis. Upon recommendations through the ~hase 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 that future development on the site will be able to demonstrate compliance with City standards for water quality protection LRP1007-00013 & ZON1007.0001 1 II 5-12 ,\ through the site plan review process, thereby ~omplying with applicable state and federal e'nvironmental quality standards.-' " . STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 6: Finding 7: The proposed Metro Plan /Refinem,ent Plan Amendment or Zoning Map Amendment does not-modify any of the Goal6 related policies of the Metro Plan nor do they amend the Regional Transportation Plan, the Springfield Developme'nt Code other applicable !3oal 6 policies, or any regulations implementing those policies, ' The subject property is located in the Zone of Contribution and outside any of the Time of Travel Zones, which is regulated by the Drinking Water 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 applicanfs narrative related tDGoal 6 compliance, . APPLICANT'S NARRATIVE RELATED TO GOAL 7: Goa/7 _ Areas Subject to Natural Disasters and Hazards: Toprotect life and property from natural disasters and hazards. , ' Goa'l 7 requires that development subject to damage fr~m mituralhazards and disasters be planned.and/orcorystructed 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 tl? landslides, flooding, etc: . I ,. 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. As noted by the applicant, the subject site is not included in the City's inventory of known areas of natural hazards. Staff concurs with the applicant's narrative related to Goal 7 compliance, . The site is flat and not subjeCt to landslidehazards, and is located well outside of any established FEMA flood hazard area, Therefore, approval of the proposed Plan amendment and Zoning Map Amendment will not alter the City's acknowledged compliance with Goal 7 through its adopt~dplans, codes and procedures. , APPLICANT'S NARRATIVE RELATED TO GOAL 8: Goal 8 _ Recreation Needs: To satisfy the recreational needs of the Citizens oOhe state and visitors and, where appropriate, to provide for,the siting of necessary recreational facilities including destination resorts. ' ", ' Goal ~. requires local governments to plan and provide for the siting of nece,ss'ary recreational facilities to "satisfy the recreational needs of the citizens of the state and visito'rs," and where appropriate, pr~vide for the' siting of recreational facilities including destination resorts, The subject site is not included in an inventory of recreational sites, and the proposed amendments will not have an 'impact"on'the community's r.ecreational facilities or needs; 'therefore,- the proposal does n,:,t implicate Goal'B. /2 LRP2007,OOOl] & ZON2007-00012 .5-13 STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 8: Finding 9: Staff has consulted the Willamalane 20-year Parks and Recreation Comprehensive Plan in relation to Goal 8 complia!,!ce, The Willamalane 20-year Parks and Recreation Comprehensive Plan was adopted by the City of Springfield as part of the Metro Plan's compliance with Goal B, None of the various studies inventories, and facilities plans regarding recreational facilities in the adopted ,Willamalane 2Q-year Parks and Recreation 'Comprehensive Plan have designated the subject site for parks and open space in an adopted inventory, declared it a significant resource, or slated it for acquisition. Staff concurs with the applicant's narrative related to Goal B compliance, APPLICANT'S NARRATIVE RELATED TO GOAL 9: Goal 9 _ Economic Development: To provide adequate opportunities throughout the. state for a variety of economic activities vital to ihe health, welfare, and prosperity of Oregon's citizens, Goal 9 requires the city to provide adequate opportunitie~ for a variety of economit 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 p,lace of'the existing' industrial designation. Permitting the construction of future clinic facilities and allowing long-standing . commercial uses on Tax Lot 402 to become conforming uses consistent with commercial zoning is consistent with numerous policies in the City's adopted plan for compliance with Goal 9, the Springfield Commercial Lands Study (SCLS). Specifically, the following SCLS policies areapplicable to the proposal: Policy 1-A: "Maintain a mixed supply,of large and small commercial sites through strategies such as rezoning or an~exation to serve Springfield's future population." The proposal fulfills this policy objective by redesignating and - through accompanying zone change _ rezoning land from industri.alto commercial, for two tax lots of varying sizes and commercial uses, thereby maintaining. existing employment and commercial use in Tax Lot 402 and providing the ability for growth in medical sector employment by allowing future clinic uses on Tax Lot 400. ' Policy 1-C: "Maintain at least a five-year supply 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 158 acres in the supply of commercial land over demand projected through the year 2015. The proposal would allow for redesignation, and rezoning, of five acres. thereby reducing the. deficit of commercial land, 'The subject site has a full range of urban 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 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. 13 LRP2007-000 /3 & ZON2007-000/2 ~-~ 4 i , Finding 3 in the SCLS (pg. 36) cited the acknowledged 1992 Industrial Land Study as demonstrating that "a surplus of industrial sites exists in the Metro Area.;' Therefore; the proposed redesignation (and corresponding rezoning) would not result in a deficit of needed industrialiy designated and zoned land, but it would help reduce the commercial lands deficit identified in the SCLS. Therefore, approving the proposal would be consistentwith.SLCS Implementation Strategy 3-A (1): "Evaluate inventories basedon demonstrated need for th~ planning period. Initiate rezoning or redeSignation of s'urplus land uses where more'appropriate for commercial, consistent with the Metro Plan." The proposal in fact consistent with inventories fpr commercial ahd industriallarids 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)) cali for amendments to land use designations "in excess of two acres within an existing urban growth boundary from an industrial land use designation to a non-industrial use designation" to have to address applicable planning requirements - such as consistency with the Metro Plan and other local plan policies (Le" 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. The proposal enables continued use of.the existing and long-standing commercial center to continu'e to operate and provide employment opportunities, while also aliowing higher-value employment associated with future, developmenton 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 ,approval of the propos'ed Plan diagram amendment without the need for an economic opportunities analysis apart from the SCLS, which DLCDacknowledged as fulfiliing the <;:ity's obli!jations 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 request is consistent with the City's compliance with GoalS and applicable administrative 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 LCDC as being consistent with statewide planning goals and the Metro Plan, specificaliy fulfiliing the Eugene-Springfield area's obligations under'Goal 9 (Economic Development). The Metropolitan Industrial Lands Inventory Report associated with the MILS identified "about 1,688 constraintifree industrial acres....This supply exceeds the projected demand over the next twenty years, which is between 650 to 1,1.72 acres," (pg, 73) The Inventory Report also stated: "The 1,688 constraint-free acres may be the best suited to meet short-term industrial demand. This portion of the supply also exceeds the twenty year'demand projection," , The City performed subsequent analysis of'industrialland supply as part of periodic review requirem~nts to demonstrate compliance with statewide planning Goal 5 (Natural Resources). As shown in Attachment A, that analysis indicated that even removing the' possible industrial acreage affected by Goal 5 protection measures,(about 100 acres debited from the Eugene and Springfield inventories) would leave a surplus of industrial lands of between 1,GOOand Z,1ZZ 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 reauction in less than 90 acres of industrial land over the past 15 years, LRP1007-000/J & ZON1007,OOOl1 /4 _ 5'-15, ,,' s~ggesting 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 l.MI Pla'n designatjon and zoning, For exampl,e, 11.5 acres was added to the inventory ,of LMI z~ned and designated land due to City Council approval in April 1997 for land east of the 28'"/31" Street CDnnector and north of Marcola RDad (Ordinance No. 5851). Insofar as the City and metropDlitan area continue tD enjoy a surplus of needed Industrial land, and speCifically Heavy Industrial ZDned and designated land, the above-referenced change added more than el10ughacreage to the inve~tory Df LMI designated and zoned land to off-set the proposal to remove only about 5 acres from the LMI inventory. We therefDre.respectfully submitthat the proposed Metro Plan diagram amendment and' ZDne change will not materially affect the inventory of needed Industrial land and will not alter the City's cDntinued cDmpliance with Goal 9. STAFF'S FINDINGS'RELATED TO COMPLIANCE WITH GOAL g: Finding 10: The City of Springfield has two' adopted inventories which support the proposed Metro Plan Amendment / Refinement Plan Amendment and concurrent zone change request- the 1992 Indus.trial La,nd Study and the 2000 Commercial Land Study, The applicant references both of these adopted inventories and sites specific polices which support the 'proposal. As noted by the applicant, Finding 3 in the Springfield, Commercial Land Study (SCLS) cited the acknowledged 1992 Industrial Land Study as , demonstrating, that "a surplus of industrial sites exists in the Metro Area," The applicant also references Strategy 3-A(1) of the SLCS which states: "Evaluated inventories based on demonstrated mied. for the planning period, Initiate rezoning or redesignation of surplus land uses where more appropriate for commercial,' consistent with'the Metro Plan." Staff finds that these referenced policies and adopted strategies support the applicant's proposal. . In addition tei referencing the SCLS and the 1992 Industrial Land Study, the applicant also references the adopted Goal 5 inventory work, which provides a more ,up-io-date analysis of industrial'lands in the Metro area, As noted in the City of Springfield Goal 5 analysis, even with a reduction of inventoried industrial land affected by Goal 5, there is a still a surplus of between 1,600 and2, 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 designations "in excess of two acres within an existing urban growth boundary from an industrial land use designation to a non-industrial use designation" to have to address applicable planning requirements --: such as consistency with the Metro Plan and other' local plan policies (I.e, SCLS) or 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 lilnds for either category of 'uses, As noted by the applicant, there are existing commercial uses located on TL 400 which are part of the subject property. Additionally, the applicant is seeking to develop. future commercial uses on the property which will maintain the property for employment- generating activity, ' 15 LRP2007,QOO 13 & ZON2007-000/2 <;-lh Given the information provided in the adopted commercial and industrial lands inventories (a shortfall of commercial and an inventoried excess of Industrial land) compared with the size of the proposed Plan Amendment and Zone Change, staff find that the proposal is consistent with Goal 9 requirements. Staff finds that the proposal. does not represent a "significant change" to the adopted EOA, APPLICANT'S NARRATIVE RELATED TO GOAL 10: Goal 1 0 _ Housing: To provide for the housing needs of 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 buildable lands. The proposal does'not affectthe City's inventory of residential Jands. 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 benefit the adjo\[1ing residential properties. Because the proposal involves redesignation from industrial to commercial land uses, it does not affect Springfield's continued compliance with Goal'10, 5T AFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL .10: Finding 11: The proposed Metro Plan I Refinement Plan Amendment and Zoning Map Amendment does not affect. the Metro Plan's residential buildable lands inventory because no residentially designated properties are involved in this . proposal. The City of Springfield is currently working with a consulting company on a . residential land inventory and land supply analysis, When complete, this study will update the City's inventory and provide a clear picture of residential land supply, Staff concurs with the applicant's response"to Goal 1 0 compliance, '. APPLICANT' 5 NARRATIVE RELATED TO GOAL 11: Goal 11 _ PiJblic Facilities and Services: To plan and develop a timely, orderly and efficient arrangement of public facilities and services as a framework for urban and rural " development. . OAR 660,011-0005(7)(aHd) Definition of publicFacilities: (a) Water ' (b) Sanitary Sew,er (c) Storm sewer (d) Transportation This goal requires the provision of a timely, orderly and efficient arrangement of public facilities and services.' The subject property is located within the Springfield UGB and city limits, and is already designated for urban levels of use, The proposed amendment to the Plan map designations from LMI to CC will not.affect the ability to provide needed services since all the required urban services are available to support existing or future commercial , uses on the subject site. /6 lRP1007,OOO I J & lON2007-000 12 ~-17 5T AFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 11: Finding 12: As noted by the applicant,'the Metro Plan and associated facility plans have beeri acknowledged to conform to Goal 11 ensuring that public facilities and services are currently available to the subject site. The proposed Metro Plan} 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 Goa111. 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 Goal 11 because there are urban level public services available tei the' subject property, APPLICANT'S NARRATIVE RELATED TO GOAi..~12: Goa/12 _ Transportation: To provide and encourage a safe, CO[lvenient and economic transportation system, Goal 12 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 and. long-standing commercial uses occur on Tax Lot 402 such that approval of the proposal will n,<t 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 (riA) 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 Transportation Planning Rule (OAR 660.-0.12-0.60.)_ . . Existing development at Tax Lot 40.2 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 levels, an'd that safe and efficient circulation can be realized through approval of the requested 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 objective~ found in East Main Refinement Plan (EMRP) Access, Circulation & Parking Element policy 18 (pg. 17) and Commercial Element policy 3 (pg. 12). Because the proposal, as demonstrated in the TIA, is consistent with the requirements of the TPR and with applicable policies in the EMRP, it is consistent with Goal12 and applicabie local implementing policies. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 12: Finding 14: The proposed Metro Plan Arnendment is from LMI to Commercial, and Refinement Plan Amendment I Zoning Map Amendment is from lMI to CC. The applicant indicates in the submitted narrative that approval of the proposal will not result /7 LRP2007-000/J & lON1007-000/2 5~18 in any changes to the type or intensity of uses on the site, and will not increase the trip generation far that parcel. Staff-does not concur with this statement in reviewing all of the potential CC uses on the site. Staff does coricur, 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 TIA list Peak Hour Trip Generation far bath the existing. zone (LMI) and the proposed, zone (CC), The applicant's TIA listed Peak HourTrip Generation for Medical Office Building While this isa permitted use in the CC zone and is the primary use that the applicant is seeking \9 use the property for, it is not the "reasonable worse case" scenario far traffic generation given other allowable uses in the CC zone. During Staffs review of the proposal, 'staff researched potential vehicle trips per day for potential uses in the CC z:one: The're are some' other potential uses in the CC zone which are much more intensive uses than Medical Office, In considering what a "reasonable worst case" development scenario mig):1t be for the re-zoned condi.tion 'it is clear that a 30,ooosquare'foot Medical Office Building is .much less intense than other, uses that would be' permitted in the CC zone, On a per-square:foot basis the Medical Office is estimated to generate 2.47 vehicle tips/1 ,000 SF and 3,43 vehicle tips/1 ,000 SF .during the AM ancj 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 ~1,64 vehicle tips/1 ,000 SF, These calculations are taken from the Institute for Traffic Engineers (ITE) Manual. As shown on Table 6 of the TIA, a reasonable 00rse case traffic generation scenario for the existing zoning (LMI) is 243 trips. The proposed.use of Medicarpffice 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 metmultiple times with City Traffic Engineering Staff and ODOT Staff to review the submitted TIA, ODOTs' review of the submittedTIA indicated t,hat there were multiple issues that were not adequately addressed in the submitted TIA to"justify compliance with 'Goa112 (see attached memo from ODOT), Based upon the information provided in the submitted TIA, all reviewing parties (i,e, City Planning Staff, Ci\y Traffic Engineering Staff, and ODOTStaff) agreed on a recommended condition of approval (see attached emai'is 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 tl're re'asonable worse case scenario for the existing zoning (243 tri'ps), Because these' numbers of trips are already allowed with the e,dsting zoning, the application complies with Goal 12. ' , ., .> Recommended Condition of Approval: 1. Trip generation from development on the subject property shalLbe limited to a maximum of 243 PM Pe'ak-hour vehicle trips, which is based on a "re,asonable worse case development scenario" under the existing zoning (LMI) as submitted by the applicant in the Traffic Impact Analysis for \he subject property. ~ 18 LRP2007-0001 J & lON2007-00012 5-19 APPLICANT'S NARRATIVE RELATED TO GOAL-13: . Goal 13 _ Energy Conservation: To conserve energy, Land and uses developed on the land shall be managed and controlled so as to maximize the conservation of all forms of energjl, based upon sound economic principles. ' The Energy goal is a general planning goal and provides limited guidance for'site-specific map amendments. The proposed amendment has no direct impact oneriergy conservation, though it would'in fact will promote greater energy efficiency by enabling needed clinical services available to growing residential areas in east'Springfield. Therefore, the proposed amendment is consistent with, and does not alter the City's continued compliance with Goal 13, ' . STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 13: Finding 15: TJ:le proposed Metro Plan I Refinement Plan Amendment and Zoning Map Amendment do not affect the Metro Plan's compliance with.Goal13, The applicant is not proposing to amend any regula~on pursuant to Goal 13 compliance of , the Metro Plan, . , ' , APPLICANT'S NARRATIVE,RELATED TO GOAL 14: . Goai 14 _ Urbanization: To provide for an orderly and efficient transition from rural to urban land use. Goal14 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.' STAFF'S FINDINGS RELATED TO COMPLlANCEWITH GOAL 14: Fi~ding 16:' As noted by the applicant, all oHhe parcels affected by this application are curreritly 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 previou,sly mentioned, urban facil'ities are available to the subject site. The proposed Refinement Plan and Zoning Map: Amendment are in compliance with Goal 13. ' APPLI~ANT'S NARRATIVE RELATED TO GOAL 15: Goa/15 _ Willamette River Greenway: To protect, conserve, enhance and maintai;-1'the natural, scenic, historical, agricultural, econom'ic and recreational qualities of lands along the Wi/lamette River as the Wi/lamette River Greenway, This goal is inapplicable because the subje~t property is not within the boundaries of the Willamette River Greenway. . STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 15: Finding 17: As noted'by the applicant, the subject property is not located within the Willamette River Greenway. Goal 15 does not apply to the subject Refinement Plan and Zoning Map Amendment applications, LAP.l007-0001] & ZON2007-00012 /9 5-20 APPLICANT'S NARRATIVE RELATED TO GOALS 16-19: Goal 16 through 19: (Estuarine Resources, Coastal Shore/ands, Beaches and Dunes, . and Ocean Resources): The coastal goals are not~pplicable to this appli~ation. STAFF'S FINDINGS RELAJEDTO COMPLlANCEWITH GOJ\LS 16'19: . ' ' Finding 18: As noted by the applicant, the subject site is not located within any .coastal, ocean, estuarine, or beach and dune resources related area, Goals 16~19 do not apply to these Refinement Plan and Zoning Map Amendment applications. . CRITERIA OF APPROVAL - SDC 7.070 (3)lb) , , APPLICANT'S NARRATiVE RELATED TO SDC 7.070(3)(b): The application requests amendment of the Metro Plan diagram fromLMI to CCfor approximately 5:24'acres. This section of the application narrative addresses the consistency of the amendment with the applicacle policies of the Metro Plan, to , demonstrate that adoption of the amendment will not make the Metro Plan interl)ally inconsistent (as required by the approval criteria in SDC 7.070(3)(b)) . -, Tti'is narrative only addresses those p6licies tha! 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 growthboundary,.l2l 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. . . I 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 ttie community. A goal. may never be c'ompletely attainable, but is u's~d as a point to strive for" . An objective is an attainable target that the community attempts to reach in striving to meet a goal. An objective may also be considered as an intermediate point that will help fulfill the overall goal. '. A policy is a statement adopted as part of the Plan to provide a consistent course of action moving the community towards attainment of its goals_ Except for the Growth Management Goals, which are addressed below, each of the Metro Plan policies are addressed in the order in which triey appear in the Plan Element section of the Metro Plan. . Metro Plan Elements 1. 'Growth Management lRP2007-000 I J & ZON200).iJ00/2 20 1-21 Policies 1. The urban grawth baundary and sequential development shall cantinue ta be Implemented as an essential means ta achieve campact urban grawth. Pravision .of all urban services shall be cancentrated inside the urban grawth b.oundary: The prapased amendments satisfy this palicy because the subject praperty is inside the UGB and city limits and as such, encaurages campact urban grawth. Alsa, urban services are available at sufficient levels to accommodate the existing and future infill develapment. resulting approval .of fram this applicatian. The City's site plan review processes ensure that the appropriate level .of services is available .1.0 serVe future d,:velapment. 2. Residential Land Use and H.ousing Element Policies A.11 Generally locate higher density residential dev!,/apment near emplayment .or cammercial services, in proximity to majar transportatian systems or within transpartatian-efficient nades.. The proposed'redesignatian daes not affect the inventory or availability .of residentially designated .or zoned land, including the single-family residential area abutting Tax Lot 400 that is zaned and designated far Medium Density'Residential, or higher density residential develapments lacated east .of the site alang Main street. ' However, approval .of the requested redesignatian ta Cammunity Cammercial wauld allaw far residential'areas praximate ta the subject area ta have clase and efficient access to exi~ting cammercial services on Tax Lat 402 and to future medical facilities prapased far Tax Lot 400, cansistent with the abave palicy, 'The areas prapased for redesignatian.affer existing and future emplaynient oppartunities and provide cammercial services alang.a major transpartatian system that can suppart th'e needs .of nearby residential . develapment. ' A.22 Expand appartunities far a mix .of uses in newly devel.opingareas and existing neighbarh.oads thraugh lacal zaning and develapment regulatians. ' . . The map amendment andcancurrently p'ropas,ed zane change will allow far existing cammercial uses an Tax Lat 402 ta continue ta serve existing neighb.orhoads in the mid- and east-Springfield area, and for.future clinical facilitie~ ta be develaped ta serve this rapidly grawing area .of the cammunity. Appraving the requested redesignatian and zane change wauld expand cammercial oppartunities ta serve these neighborhaads cansistent with the abave palicy. . 3. Ecanomic Element Palicies B.1 Demanstrate a pasitive interest in existing and new industries, especially thase praviding abave-abave w,age and salary levels, and increased variety of jab oppartunities, a rise in the standard .of living, and utilizatian of our existing comparative advantage in the level .of educatian and skill .of the resident lab6r farce, . The prap.osed amendment is consistent with this p.olicy because it will allaw medical clinic uses to be develaped to serve growing areas in east and south Sprin'gfieid. As is observed in the Springfieid Commercial Lands Study (pp. 27, 29), employment in health services is growing and approving the requested redesignation will enable increas'ed job LRP1007,OOO/3 & ZON1007-000/2 1/ 'j-22 ~, ,opportunities with higher than average wages thereby helping raise the standard ofliving 'and.meet the needs of Springfield citizens, consistent with the above policy. . " .. B.2 Encourage'economic development which utilizes local and imported capital, entrepreneurial skills, and the resident labor .force. .. The construction oland 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 Increase the amount of undeveloped land zoned for light industry and commercial uses correlating the effective supply in terms of s,uitability and availability with the projections of demand. . .The proposal will add approximately 5,24 acres of C'ommunity COl1)mercialland,. consistent with recommendations to increase the cO,mmercial lands inventory made in the Springfield Commercial Lands Study, The SCLS and acknowledged metropolitan (ndustrial Lands Study concluded that there is a deficit of needed commercial land, and a surplus of industrially zoned and designated land. Approval of th!, requested redesignaiion willliDt cause the inventory of needed industrial land to go into a deficit, but in fact would, consistent with the above policy. the proposal correlates the need-and suitability, and availability of the subject site for commercial uses with the need for such uses as denionstrated in the adopted SCLS. ~ ' B.11 Encourage economic activities which strengthen. the metropolitan area's position as a regional distribution, trade, health, and service:c'enter, . The amendmeni will facilitate the development of medic?1 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 uses shall be encouraged when consistent with other plann,ing policies, .' Approvai'of the proposed map amendments will add jusi aver 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 coniinercial 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 wilfserve the needs of the growing residential areas east and south of the subject site, consistent with the above policy, " 7. Tfanspa,\ation Element ;.1 , Land Use policies, ' F,~ Provide for transit-supportive land use patterns and development, including higher intensity, transit-oriented deve/opr:nent along major transit corridors and near transit stations; medium- and high-density residential development within one-quarter mile of transit static;,ns, major transit corridors, employment centers, and downtown areas; and 22 LRP2007,OOOlJ & ZON2007-00012 ~-)< development and redevelopment in designated areas that are or could be well served by existing or planned transit. ..... ' " .' .' The proposed map amendment and concurrent zone change will enable land use patterns and development consistent with the above. policy. Approval of.theproposal will allow for higher intensity development along Main Street, a major transit corridor. An existing L TO stop is located on the frontage of Tax Lot 400 (see photo, pg, 2, Appendix A of the 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. Transportation System Improvements: Roadways Policies F.15 Motorvehicle level of service policy: a. ' . Use motorvehii::le 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) Evaiuating the 'impacts on roadways of amendments to transportation plans, acknowledged comp;ehensive plans and land-use regulations, pursuant to the TPR (OAR 660-012-0060). (3) Evaluating development applications for consistency with the land- , use regulations of the applicable local government jurisdiction. ' 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 (CA TS) area, and LOS D elsewhere. . . c. Performance standards from the OHP shall be applied on state. facilities in the Eugene-Springfield metropolitan ,area. In some cases, the level of service may be substandard. The local government jurisdiction may find that transportation system improvements to bring performance up to standard wii:hinthe 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 but not limited to 'environmental conditions, 'lack of public agency financiafresources, or land use constraint factors. It is not the intent ofTSI Raodway Policy #2:' Motor Vehicle Level of Service to require deferral of development in such cases. The intent is to'defer motor vehicle capacity increasing transportation improvements until existing. constraints can-be overcome or <;Jeve/opan alternative mix of strategies (such as: land use measure~, TDM, 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 (TPRj, The accompanying Traffic Impact Analysis provides the factual basis to determine thatthe proposed redesignation would notresult, 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 also does not: Result in types or levels of traffic or access that are inconsistent with th~ functional classification of Main Sheet or any other nearby roadway; . 23 ,LRP2007.-000 J 3 ,& -ZON2007,OOO/2 fi-?d . Reduce performance of traffic on Main Street or other affected intersections to a level that is below acceptable established p~rformance standards; or Make performance of existing f~cilities worse (Le" below acceptable mobility standards) than would be the case other uses permitted under existing designations or zoning. .1 . Specific TPR findings are further located in the TIA, see pp. 31-32. Because ttie proposal does not result in a "significant effect" as established by applicable OARs, no further TPR analysis is required. The request is therefore consistent with the above policy. 8, Public Facilities and Service Element G.1 Extend the minimum level and fu/l range of key urban facilities and services in an orderly and efficient manner consistent with thegrowth management policies in Chapter /I-B, relevant policies in this chapter and other Metro Plan policies. The subject property is located in Springfield's,city limits UGB. .An necessary infrastructure and key urban facilities/services are present to serve existing development (Tax Lo1402) or are available to serve future infill development on Tax Lot 400. Therefore, the proposal is consistent,with the above \D-olicy, 9. Parksand Recreation Facilities E.:lement Pol,icies 'Policies in this element of the Metro Plan are not relevant to the requested diagram amendment. .' . 10. Historic Preservation Element Policies ' Policies in this element of the Met'ro Plan are not relevant to the requested diagram amendment. 11. Energy Element Policies Policies in this element of the Metro Plan are not relevant to the requested diagram amendment. '. STAFFS FINDINGS RELATED TO SDC 7.070(3}(b): Finding 19: The requirement of this criterion that adoption of these proposed applications not make the Metro Plan internally inconsistent does not mean that every goal, objective, finding and policy 6f 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 discus~es nUmerous Metro Plan Policies and Elements related to the proposal. Staff has reviewed the applicant's choice of applicable Metro'Plan Policies and Elements and concur that the noted 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 this report related to Goal 12 compliance, the Metro Plan Transportation Element and ljransporta'tion Policy f,15 are satisfied, . . LRP1007-000/3 & ZON2007-00012 24 5-25 1;he stated Policies and Elements have been reviewed by staff and are found to be applicable and consistent with the proposal. . REFINEMENT PLAN MAP AMENDMENT CRITERIA OF APPROVAL - SDC 8.030 et seq. In reaching a deci~ion on these actions, the Planning Commission and the City Council shall adopt findings which demonstrate conformance to the following: (1) The Metro Plan; (2) Applicable' State statutes, (3) Applicable State-wide Planning Goals and Administrative Rules. STAFF'S FINDINGS RELATED TO COMP.L1ANCE 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 applicant:s narrative, SDC 7,110(4) states: . "When a Metro Plan amendment is enacted that requires an amendment to a refinement plan or functional pian 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 this application, Therefore, no separate refinement plan application is required, As stated,in the above referenced section of the SDC, the refinement plan is automatically amended upon approval of the MetroPlan amendment. . The applicant's narrative related to consistency with specific refinement plan policies is most appropriately addressed as part of the Zoning Map Amendment criteria, later iri this re~ . . METRO PLAN MAP & REFINEMENT PLAN AMENDMENT (LRP2007-00013) CONCLUSION AND RECOMMENDATION' Staff finds that the request meets the criteria of SDC 7,030(a) - (b) and SDC 8.030. Upon review of the evidence provided by the applicant, site visits, existing . structuresluses and review of the applicable criteria of approval, staff finds that'the applicant's request for a Metro Plan & Refinement Plan Map Amendment is appropriate for the subject property with the following recommended condition of approval: .1. Trip generation from development on the subject .property shall be limited to a maximum of 243 PM Peak-hour vehicle trips, which is based on a "reasonabl~ worse' case development scenario' under the existing zoning (LMI) as submitted by the applicant in the Traffic Impact Analysis for the subject property, . lRP2007-00013 & lON2007-000/2 25 5-26 ZONING MAP AMENDMENT CRITERIA OF APPROVAL - SDC 12.030 et seq. SDC 12,030, (1) _ Quasi-judicial Zoning Map Amendments - The Planning Commission or Hearings Official may approve, approve with conditions or deny a quasi-judicial Zoning Map amendment based upon approval criteria (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 Metro Plan diagram amendment. . . SDC 12,030(3) Zoning Map amendment criteria cifapproval: (a) Consistency with applicable Metro Plan policies and the Metro Plan diagram (b) Consistency with applicable Refinement Plans, Plan DJstrict maps, Conceptual Development Plans' and functional plans; and ' " (c) The property is presently provided with adequate public facilities, services and transportation networks to support the use, or these facilities, services and transportation networks are planned to be provided concurrently with the development of the property. NOTE FROM STAFF REGARDING APPLICANT'S ZONING MAP AMENDMENT, . NARRA T1VE: The applicant's narrative for the Zoning Map Amendmenfis 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 revie"'f, Staff.hasattached the remaining portions of the applicant'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 Amtfldment 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'proRosed rezone request is consistent with Metro Plan policies and the Metro Plan Diagram. APPLICANT'S NARRATIVE RELATED TO COMPLIANCE WITH SDC 12.030(3)(b): The following demonstrates how the proposal is consistent wit~ applicable policies in the East Main Refinement Plan (EMRP), 1. Mixed-Use Element LRP2007.000/3 & lON2007-000/2 26 S-2L Policy 2) Area #2 ' A) The following land uses are allowed under Community'Comrnercial zoning: All Communitv Commercial uses subject 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 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 Commercial Refinement Plan Desic;nation 1. Generally, the Community Commercial refinement pial] designatiori shall be 'applied under the following circumstances: A) where itis tiot 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 crit~rion, B) where it does J;lot increase conflict'between Low Density Residential and Commercial; Although the abutting residential area is zoned Medium Density Residential, it is developed in low density residential uses. Approyal of the proposed redesignation of' the subject sites would actually result in a decrease of conflicts between abutting residential and non-residential land uses by allowing future infill development on Tax Lot 400, and through the site plan review process establishing improved landscaped buffers and a use more compatible than the industrial uses that historically abutting this residential area, C) where criteria for designating Medium Density.Residentialland does not apply; . Criteria for designating 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. LRP2007-000 13 & ZQN2007-000/1 ~-'28 ,I , 27 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 EMRP diagram.. Policy 2) Apply site-specific Commercial refine';"ent plan designations to clearly define the limits of new commercial uses where there is not an existing, legally established, and beneficial mixing of uses, ' Approval of the requested redesignation would apply Commercial plan designations to the subject properties, allowing the existing, legally established commercial uses on Tax Lot 402 to continue, It would also enable'commercial uses to be established on Tax Lot 400, thereby defining the 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 pa'rk to the east. Tax Lot 400 does not have an existing or beneficial mix of uses, but has historically housed'industriaJ'yard-type operations. Therefore/approvai of the proposal would define th~ 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 <;In Tax Lot 401i.through the site plan review process, Policy 3) Reduce the num'ber of vehicular access points and require the rebuildin'g 6f curbs and installation of sidewalks and street trees along Main Street, through the Site Plim Review process and in public improvementprojects. 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, 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 abov.e 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 hav~ 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 con'sistent with the above policy, 3. Industrial Element Policy 1) The City shall encourage efforts of various agencies to attract new and retain existing jobs and businesses, . Imo/ementation The City shall maintain a current inven'tory of vacant commercial and industrial land and structures within the. East Main area, ,Consistent with the above policy, approval of the requested redesignation will enable existing, long-standing jobs and businesses on Tax Lot 402 to remain as legal, conforming land uses, and allow future development 6f new employment on Tax Lot LRP2007.000/J & ZON2007,OOOJ 2 28 <;-?9 400 with higher'lhan 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 EastMain 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 of the subject property, Reference to this policy is not applicable to this application, . Finding 24: The applicant discusses specific criteria'listedin 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(3)(c): Finding 26: As previously noted in this report and as stated by the applicant, the subject 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 44th Street which is under City of Springfield jurisdiction and Main Street, which is under ODOT jurisdiction, Finding 31: The proposed zone change is from LMI to CC. The subject lot has existing development on all sides, and is located on 18th 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. LRP2007-000 /3 & ZON2007-000J 2 29 ~_1() Finding 32: Solid waste management service is available at the subject property, The City and Sanipac have an exclu~ive franchise arrangement for garbage service inside the city limits, Finding 33: The site receives police protection from the City of Springfield, consistent with service provision throughout the city and with service that is now provided to adjacent properties, . . Finding 34: The City of Springfield Development Services Department.provides land , use control for property within the City's jurisdi,ction. . Finding 35: Qwest and Comcast curreritly provide telephone and cable commu~ication service in this area for and an array of w,ireless companies provide a number of different communication services, The City has no exclusive franchise arrangements with telecommunication or wireless companies, Th~ field is 'competitive and therefore' guarantees a wide selection currently, ' , Conclusion: All key urban facilities and servjces 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 allowsforthe Approval Authority,to attach conditions a/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 reasonabJenecessary 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 and do not recommend any conditions of approv.al other than the condition already stated for the Metro Plan / 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, LRP2007.000/3 & ZON2007,OOO/2 30 'i-, ~1 , ZONING MAP AMENDMENT (ZON2007-00012) CONCLUSION AND RECOMMENDATION . Staff finds that the request meets the criteria of SDC 12.030, Upon review of the evidence provided by the applicant, site visits, existing structures/uses and review of the applicable criteria of approval, staff finds that the applicant's request for a zone change from LMI to CC is appropriate for the subject property and recommends the Plarl~ing Commission approve the attached Order and forward the proposed, Zoning.' Map , Amendment Application ZON2007-00012 to the City Council with a recommendation for adoption,. ' . . , . . LRP2007-000 13 .& ZON2007-iJ0012 31 t:;~'1". EXHIBIT A-1 .. . 5.0 TRIP GENERATION AND DISTRIBUTION 5,0 TR.IP GENERATION To determine the traftic impacts of a development o,n;a roadway system, the number of vehicle movements resulting from the developmen(mllst 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 prop()sed development was . determined using the infonnation contained in theITE Jrio Generation Manua10 7th Edition, The equations in the manual predict the nurpber of trips generated based on the gross square feet of no or' area, Separate trip generation analyses were peri'onned for the AM and PM peak ho~rs for the deveiopment,' '. ," .. I '. " Under the current Light-Medium Industrial zoning the developmentsite can be built out to include a variety of land uses specified in Springfield Development Code ArtiCle 20. The maximum 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 trips generated .by the development site using the following lTE Land Use Codes: ' i .: i . Land Use Code 760 - Research and Development . Land Use Code 714 - Corporate Headquarters' . Land Use Code 492 - Health/Fitness Club . . Land Use Code 565- Daycare Center ,..: . f(esearch and Development' 760 80. Ln(T)=O,88'Ln(x)+O,88 . 114,'; O,~3 :.0:17 .)5 '., 19' ~I~I 3 ,. .'lw~~~~\f~~I~l&'lt"t'iIlffl~! . Health Fitness Club 492 4 T=1.21'x 5 0.42 0.58 2 , ' i~i~:,1~~:~~~~:i~e:0;t:t~i.~J~~i~'S5r~~j~J~(~1;:~,I{jU~~f~t~~~~'~t~;~I~f*! i~{~~ .~~~~~ ::f:fii~!1 Total Trips 229. 168 61 jl\.H Ti\.ANIPOI\.TATlml ENGINEEI\.ING I East'g'::33"'ld P.e!OM - Spn~gfield..Ore9on IMarch 6, 2007118 . Table 6:' PM Peak Hour Trip Generation-Maximum Potential of Site for Existing Zoning ',' f~~- ~ ~ ; -.'''''IF .,: t1~~lY"~''''''''.'''''~.'' .,_. -,""~'--"';;".~"1"I".~i. tl:'!t' . (;\.,.CorporateHeadquarters;-i, ",;;;:'1 ~~;,::Y.l't~,. \t;,~,;,-j".,>w~ro;~l"~';"'~:;'~ >:" "',:,ot:~:~t' ,{-,,~. .".rJ-i; ....:It .~..,.....,I<",.,' ,(,.,d,") -~.t' ''''i i"<"'"/ '. "'" :!Z~~;~1Et4i~~~:@~%~~~~jJ~~il ~J]; ~~'-nJr'" ~'$'~~1"Jl :~}JifA~ ' _~l~~,~~~~~~ r hf":~~\lf;!'~~~ i..J~!.II',;tl'I"l',~.::IQ '.'0,51 O:4:~,\ ;~,;:.!::.t ~;j;~/~;i .4 ":, Health Fitness Club . . 492 .;; . ," . '. .~ ", '" .....'.. :..-- ~ ' ';,;:;,:.....~. '~;O,47., .<:",l,~\~~;c:j~ tili:*~i,\\if., l..'~\:I,~.~JJ . . ' Total Trips O:243.){~ ':', '. ~A!565"f~~ ~ ~~~ >~fi';~6.6tY:17]~'! With the zone change the developnient site will be built to include an approximately " . , 30,000 square foot medical office building.' The land use code for a fully developed . medical office building was 720 ~ Medical-Dental Office Building. This was used in place of Land Use Code 630 - Medical Clinic because, after close inspe~tion o{the Trio Generation Manual. itwas detemlined that the sample size for,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 office building, Tax Lot 402 is currently occupied by a commercial/specialty retail center. With. the proposed zone change, the building will remain on the property and will continue to operate as a specialty retail center. Vehicle trips using this site,have already been accounted for on the roadway in the background traffic volumes; therefore, no new development trips were assigned to this Tax Lot. . . , ,Table 7: Peak Hour:Trio Generation-Medical Office Building. ;t.'r~';"lc.:r' ~~}~@{~~~~l~!~ji~~~~~~~~:~ ~~~iJWj,~:~wf~I;('fi~~*~~fJ~~~:: 79% 21% 58 AM T=2.48'x' 74 ":~:i;0'.:~0.f;7~i~j4J .. ~t~1~J~j'0~il;Y!)!t~i/: .[~~~ t~[~ ~l~~jll'l~~~,l ~~};~ii~ There are 155 fevier A!vIand \40 fewer PM vehicle trips generated by the medical oftice building when compared to the maximum potential of the site under the current zoning, ]P,H TPJNSrOI'-TATION ENGINEEI'-ING 1 East Springfield Reoone' Springfield O,egon I March 6. 2007119 5-'-'34 EXHII:lII A-'L. , 16 " . 5.1 TR.Ir DISTRIBUTION AND ASSIGNMENT After detennining the trip generation, the next step in th~ analysis requires distributing alld 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 streetnetwork. The trip distribution for this project was based on the existing distribution pattern of the study area roadway network, where applicable, Access to Tax Lot 400 is assumed to be limitedto. a single full-movement access from MainStreet. Figures 9 and 10 shows th.e assigned vehicle trips generated by the 30,000 square foot medical office Sl;iL~ing for the AM and PM peak period respectively.' ,'.. 5.2 BUILD TRAFFIC VOLUMES To detemline the Build tramc volllmes the development trips assigned thraughout the. study area were added to the background traflic data, The year 20QsAM!illd PM Build year traflic volumes are illustrated in Figures II and 12: resjJectively.-Th~ year 2023 AM' and PM Build year traffic volumes are illustrated in Figures 13 and' 14, respectively jRH TRANSPORTATION ENGINEERING I East Springfield Rezone - Springfield. Oreg;n 1 March 6, 2007120 . 5~35 -1""....11 ~-~ I ~ I J ~ ~ ~ :j I - 1 I I I I ,I , I , I i I , I 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 Planand Land Use Regulation Amendments (1) Where an amendm~ntto ajimctional plan, an acknowledged cOI~prehensivepl,;~, or '-0 1~l1Lhlse regulation worild significantly ajfect an existing or planned tmrisp'ortation' , . facility; the local government shall put in place measLrres as provided in section (2) of this rule to assure that allowed land uses a;'e consistent with the identifiedfunciion, . capacity, and performance standards (eg. level of service, volume''(Q capacity ratio, etc.) oftlie facility. A plan or land lIse regulation amendment significantly affects a tmnsporti:LIionfacility if It would: . (a) Change the fllnctional classificdtiori of an existing or planned transportation facility (exclusive of correction of map erroi's in an adoptedplan): . The addition of development traffic on the adjacent roadways does not cause the change in functional classitication of any of the transportation facilities. . (b) Change standards implementing ajimctional 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 I (c) As.measured al the end oJthe planning period identified in the adopted Ircmsportation system plan: I (A) Allow land lIses or levels oj developmenlthat would result in types or levels of travel or access that are inconsistent with the JlInctional classification of an existing or planned transportat ion facil ily; The proposed dev.elopment does not result in types or levels of travel or access that are inconsistent with the functional classitication of the studied transportation facilities, I J (B) Reduce the perjormance of an exiSling or planned transportationfacilit,\' below the minimum acceptable perjomlClnce standard identified in the TSf or comprehensive plan, or The addition of development trat1ic does not reduce the performance of an existing or planned transportation facility below the minimum acceptable performance standard, ' JRH TRANSPORTATION ENGINEERING,I East Springfield Rezone - Springfield. Or.gon I March 6, 200; 131 5-'-36- . EXHIBIT A-S ] ~ ~ N ~ ;\1 ,0: ~ ?1 ~i ~ ., .' ".1 ~l ;~ ;J s, ~ ~ .j ~ j:; k~ ~i~ ~ ~ ~ '4 .~ ~; t~ !~ ~ ril ~ ~1 j '1 ~ It rl ,1 " , 1 ;l :~ '.' (C) Worsen the perf~rmanci of em e,~isting or planned trclI1sportatiorifacility that is otherwise projecled 10 perform below the miniinwi1 accepIClble pelfonnanc'e standclrd identified in the TSP or comprehens'ive plan. . The addition of development traffic does not further degrade the perfom1anceof . intersections projected to perform below tlle;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 defined in the TPR. . ' 8.0 SUMMARY AND RECOMMENDATIONS .' -This report provides an analysis of potential traffic impacts resulting from the proposed . redesignation/zone changeand future development of the subject site in Springfield, Oregon, This development will include approximately 30,000 squarefeet of medical office space, The parcel proposed for development"is located east 61' 44thSireel and west of 48th Street on Main Street. A single unsignalized full-movement access point on Tax Lot 400 and existing driveway access to Tax Lot 402 is assumed, . Completion of the proposed development is anticipated for the year 2008. This report ' inCludes year of tompl~tion analysis, year 2008. for. the roadway network within the study area, In addition, a horizon year analysis was performed for the year 2023, A perfonnante analysis was completed for the intersections of Main Street and 42nd Street, Main Street and 48th Street, Main Street atA4lh Street, and Main Street at 46th Street. The operational analysis of all intersectioris within the study area shows that under the Build conditio~ no degradation in volume-to-capacity ratio in comparison to .the No-Build condition occurs due to the additional trips produced by this development. , . All study areas meet the mobility standard for the' Bllild condition. A queuing analysis was performed for the interse~tion within the study area, The qlleuing analysis, \vhich assumes the current lane configuration throughout the planning horizon, was performed 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 storage lengths will facilitate the queuing antjcipat~d for th~ trafflc demand, including the proposed development. . According to the fmding Lmder Oregon Administrative Ruling 660-012-0000, the Transportation Planning Rule, the proposed redesignation of Tax Lot 400 and'402 does not result in a ~'signilicant elIect'. on the transportation facilities as delined in the TPR. )I'-H Tf\ANSrOI'-TMlm~ ENGH'EEI'-ING I East Spnngfield Rezone, Springfield. Oregon I March 6, 20071 32 5-37 EXHIBIT .11.-6 '. 'Memorandum City of Springfield Date: ' April 4, 2007 To: ' David Reesor, Planner III From: Gary McKenney, P.E" Transportation Plannin~ Engineer Subject: LRP2007 -00012 PeaceHealth PAPA 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 ~IA are attached for reference. Traffic Impacts Analysis In estimating the trip-making potential of site development under existing LMI designatio~zoning the rIA assume the land uses as depicted in Table 5 (Page 18): Recommendation,: Confirm that the uses assumed in the "existing-designation" development scenario are permitted, and that they represent a "reasonable worst case.". In estimating the trip-making potential of site development under proposed CC designation/zoning the TIA aSsumed a single .land use (Medical Office Building) as depicted in Table 7 (Page 19), Recommendatio'l: Confirm that the use assumed in the "proposed-designation" development 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 TlA. Ifwe find that the assumed Medical' Office use wo~ld under-utili~e the land, then we will want the rIA revised to reflect the impact of a true "reasonable worst case." Goal 12 TPR AnalysislFindings The PAPA application refers to.the Goal 12 findings contained'in theTIA. These are.presented on pages 31 and 32, The validity of these finds will depend on the details of the technical' analysis and supporting assumptions. . 5~38 ", EXHIBIT A-7 REESOR David From: MCKENNEY Gary Sent: Thursday, April 05, 2007 9:23 AM . To: REESOR David. Subject: PeaceHealth PAPA Traffic Analysis Follow Up Flag:. Follow up Flag Status: Red David, In considering what a "reasonable worst case" development .scenario' might be for the re-zoned condition it is clear that a 30 KSF Medical Office Buildin'g 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 tipsll,OOO SF and 3.43 vehicle tips/l,OOO SF during the AM and PM peak hours respectively. For comparison the average rates for a "Fast-Food Restaurant with Drive-Thtough Window" are 53.11 vehicle tipsll,OOO SF and 34,64 vehicle tips/l,OOOSF., . In considering the Goal 12 "insurance policy" issue some 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 discuss these ideas further in our meeting with Ed Moore. . Gary ( 5-39 '-J''\I,lIUII M-P Dregon . Theodore R. Kulongoski. Governor Department of Transportation Region 2 Tech Center 455 Airport Road SE Building A Salem, Oregon 97301-5397 Telephone (503) 986-2990 Fax (503) 986-2839 . These are review corrunents for tbe East Springfield -Retone Traffic Impact Analysis (TIA), prepared'by JRH Transportation Engineers, The focus of this review is-the analysis methodologies and assumptions, The results and conclusions of this study are in qucstion, due to noted inconsistencies. Itis recommended this study be revised, taking into account these comments. Region 2 Trajfic will, need t~ review any revised traffic study, to ensure it complies with ODOT requirements, before ;is;can be deemed acceptable, Page . Par. gr. ph 7 Table 1 8 Seasonal Adjustment 8 Peak Hour.; DATE: TO: FROM: SUBJECT: File: T15-2 May 10, 2007 Ed J:Y1oore Area 5 - Senior Planner Stepben B. Wilson, PE Region 2 Senior Traffic An.Iys " East Springfield Rezone, Traffic Impact p.nalysis Review Highland Business Park - peacehealth Medical Office Building McKenzie Highway - OR 126 Bus. (Highway #15) Milepost 4.61 -:- 5.00 City of Springfield Lane County ..j oj. 11 Figure 4 " . ,';' r~ Commeri(-"';~;:. l The classification of Main Street (OR 126) must also be listed by the ODOThighway classification. . '.'. This study needs to demonstrate how the Seasonal Adjustment factors were applied to the raw traffic data, A graphic showing the raw traffic volumes should also be included, . . The peak hours assuined for this study seemteasonable; assuming the I Peak Hour Factors were calculated off data from these assumed hourn, and were the same for all intersections. The 2006 Existing PM peak traffic volum.sdo not seem correct. As part of this review, calculations were made using the raw traffic dnt. .nd the assumed Seasonal Adjustment factors, presented in this study, The review calculations were unable to confirm the traffic volumes '2.r~sented in Fi re 4. See related corrunent for Pa e 8. uuOT ~oes not have a standard from which you can compare an Intersection Crash Rate. 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 j least a mile of the study area roadway. 12 SeC\ion 3.1 5-40 !Page 13 18 18. I:.XHIt:l11 A-'d. Comment I This study must demonstrate how the iiisWrical Growth Rates .were applied to the 2006 30!":Hlghest Hour traffic volumes, Calculations to confirm the 2008 and 2023 data were unable to duplicate the future volumes cited in this renort. This report states the maximum development .potentla! was determined for the property, given its current zoning of Ligh{,Medium Industrial. For this sc~nario, how was the maximum allowable development determined? , The trip generation assumptions and output in this table are accurate. This study's trip generation analysis for the proposed zoning, assumed a 30,000 sf l'vledical Office Buildil1g would be the only development on this site. To satisfy the requirements for a TPR-level analysis, the trip generation study for the proposed zoning must be. for the maximum allowable de'veloomen~ on that site, given the City's development'codes and regtilatio'ns. The traffic volumes for all Future Build-Out data sets will need tobe revised to account-' for corrections made 'to address the .previous comments. Paragraph Growth Factors Existing Zoning Trip Generation Table 5 \9 Proposed Zoning Trip Generation n/a Future Build-Out Traffic . Volumes nla Section 6,0 n/a Manual Count Data n/a S ynchro Analysis 3 I Section 7.0 The traffic data for this study is in question, AllY analYSlSmade from these data sets is also questionable and must be revised; taking into . account the previous comments. This comment can also be applied to the queuing analysis developed for this stud/- The scope of work for this TIA required 3-ho",' Munuall.'lassifiCCltion Counls for all study-area intersections. Howevcr, a review .of the manual count data was unable to determine any uuck volumes or percentages, The tluck traffic in this study area is significant, ane must be taken into account. A review of the Synchro output has noted several inconsistencies throughoulthe analysis: . An [deal 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 Arialysis Procedures Manual ,equires a saturation flow ,'ate of 1800 pcphpl for all intersection analysis, . The truck percentages must be based on real-world data, The Synchro default of2% 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 \ 26 approaches, and 4.0 seconds of yellow for the City.street approaches. The 5.0 seconds of yellow is generally reserved for highways witb an 85'" Percentile Speed ec,ual to. or ~reater than 45 mph. . The TPR findings from this study me in question. due to the inconsistencies rioted ,in this review. It is very likely they will need to be revised, based on the recommendations in this review. I " 5-41 1/. Pa~t'. H'-..~iP, ara2raph .':'" ...en '" -,' . . ~ 32. Section 8.0 .....1\1 111...11 I r"\- I V " .".....-'\ . Based on .the' previous comments in this review, the conclusions drawn and recommendations .-proposea are in question. It is very likely they will.need to be revised, based on therecommendations in this review, :\ If you havc any questions regarding my comments, please contact meby phone at (503) 986-2857 or by c-mail at slefJhen,b. wilson((Uodol,sIUleorus: Cc: Jim Hanks - JRH David Warren Jane Lee 'Mike Spaeth D=is Santos File. " 5-42 FW: Springfield - East SpringtJelO Kezune H'K Nl"'J>".~'"""" EXHIBIT.A-11 REESOR David From: Sent: To: Subject: RE: Springfieid - East Springfield Rezone TPR Analysi~ Review Attachments: LRP2007-00012Trans mem01.DOC MCKENNEY Gary Tuesday, May 15,20074:28 PM REESOR David , ' David --- I believe Steve Wilson is thinking in the context of an unconditioned approval of the P AP: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 P API.\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: PN: Springfield - East Springfield Rezone TPR Analysis Review _..;..._.t'''.''."' 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: PN: Springfield - East Springfield Rezone TPR Analysis Review FYI 5-43 ... -,::1- .. ....... .. EXHIBIT A-13 . REESOR David From: MOORE Ed W [Ed,W.MOORE@cidot.state,or.usj ,Sent: Monday, May 21,20073:14 PM . , To: REESOR David Subject: RE: PeaceHealth Plan and Zoning Map Amendment Dave, that is what we agreed to at our meeting and it still hold for us, Ed .----Original Message----- ,From: REESOR David [mailto:dreesor@ci.springfield.or.us) Sent: Monday, .May 21, 2007 11 :49 AM To: MOORE Ed W (OR) Cc: MCKENNEY Gary Subject: PeaceHealth Plan and Zoning Map Amendmen{ . Hi Ea- I just wanted to clarify with you OOOTs position on the PeaceHealth proposal (LRP2007-D0013 & ZON2007-00012). Based upon the meeting you and I had with Gary McKenney, we are all in agreement that the most appropriate way to address Goal 12 compliance on this proposal is by conditioning a trip cap to what the worse case scenario would be under existing zoning (LMI). Does this sound correct to you? Thanks, David Reesor Planner 111 City of Springfield 541,726,3783 5-44 FW: Springfield'- East SpnngnelO t\.cwuc H "- ru'~'JO'O .w.,-" EXHIBIT A-12 ---Original "Message-- From: WlL?o.N Stephen B Sent: Friday, May 11, 2007 10:03 AM To: MOORE Ed W . Cc: )nihanks@jrhweb,com; WARREN ?avid; LEE Jane ~; SPAETH Michael. A; SANTOS Dennis N .Subject: SpringfIeld - East Springfield Rez.one TPR Analysis Review Ed.., This is my technical review of this TIA submitted by JRH. I apologize for the delay in getting this review out, <<East Springfield Rezone TPR Analysis Review,pdf>> Srepfien :13. Wi16O-n, P[ Senior Transportatio,n Analyst ODOT - Region 2 Tech Center 455 Airport Road sE - Building 'A' Salem, OR 97301-5397 (503) 986-2857 " " " 5-45 ... m PeaceHealth March 15, 2007 Type II Metro PlanlEast Main R,efinement Plan . Diagram Amendments Written Explanation of the Proposal' Applicant: PeaceHealth Oregon Region th . . 770 E. II Avenue P.O, Box 1479 Eugene, Oregon 97440 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, AICP Director, Land Use Planning & Development . PeaceHealth Oregon Region 123 International Way Springfield, Oregon 97477 (541) 686-3828 * Fax (541) 335-2595 pfarringto n@peacehealth,org I,D 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 ("LMl") 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 Springfield zoning map from LMI to CC, as allowed in Springfield Development Code ("SDC") 12.020 (1)(a)1. 5-46 Metro PlarrlEMRP Diagr;,., ' JIlendment PeaceHealth Oregon Region Maich 15 2007 Page 2 The area subjecno 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 automatically amends the refinement plan diagram and is processed concurrently. findings offact addressing the criteria of'approval in SDC 7,070(3) are included in this narrative statement (see Section 5 below). . 2.0 Project Purpose, Relationship toE'ast Main Refinement Plan The. Applicant seeks to redesignate and rezone the subj ect properties to CC so they may be'develope<i for commercial uses (i,e" Tax Lot 40IJ), 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 operatio~s on Tax Lot 402, 'and create stable family-wage' employment opport1;mities of! 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 wesi tlian currently exists. The proposal is also consistent with the East Main Refinement Plan (EMRP) ~riteri~ for designating property as Commercial within the refinement plan (EMRP, 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 Lot402 borders only Tax Lot 400 andtwo commercially zoned parcels, so legitimizing the pre-existing conunercial 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 inJact can provide for uses a!1d development far superjor 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 primarilylow density residential use. c) The criteria for designating Medium Density Residenlialland does not apply because the,subject properties are not currently developed, nor have they ever been designated, for MDR uses,' . " : d) Legally created commercial uses have' existed on the'properti~s, and the pr'oposal would facilitate higher quality commercial uses (such as medical .offices) than have existed'before on Tax Lot 4.00, and allow for Plan designations and zoning to -correspond with long-standing legally established commercialuses on Tax Lot 402, ' e) Adequate access exists to an arterial street, \villi existing curb cuts directly onto Main Street. . 5-47 Melro PlanlEMRP Diagram Amendment PeaceHealth Oregon Region March ]5 2007 Page 3 f) Upon approval of t~is request, the site, would have a Commercial designation on the Metro Plan diagram. . . The proposal is also consistent with EMRP Policy 2:' "Apply site,specitic C~:m1Jnen;ial 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 andemployment-, generating uses on the subject properties, 1t would also improve the area and better distinguish and buffer adjacent residential and industrial business park uses. 3.0 Site Context The subjectproperties include a vacant, flat parcel (Tax Lot 400) and existing . commercial development (Tax Lot 402) east of 44th Street alon-g,Main.Streetin east Springfield, The site is bordered on the south by Main Street, o~ the east by the Hyland Business Park, on the .north by an open area south of the Weyerhaeuser milL site (Tax Lot 400) or an existing commercially zoned parcel (Tax Lot 402), and on the west by other small-scale commercial enterprises (e,g" a cabinet shop and karate school) fronting Main Street and residential homes along 44th Street west of Tax 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 arid forest by-products, The current property oviners also used the sit~to store modular construction offices, tool trailers, construction equipment and concrete form plywood. Tax LotA02 has had various commercial services on site since tl1e 1950s, The' properties have no jurisdiction~l wetlands or inve~toried Goal 5 natural orhistoric 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 Light/Medium lndustrial in the EMRP diagram and zoned LM!. The areas immediately to the west and south of the site fronting Main Street are identified as being within Mixed~Use Area #2 in the EMRP, and are all zoned Community Commercia!. Property to the west of Tax Lot 400 along 44th Street is zoned and designated Medium Density Residential. 5-48 Metro PhiJEMRP Diagran. .-unendment PeaceHealth Oregon Region March 15,2007 Page 4 4.0. Type II Metro Plan Diagram Amendment Amendments to the Metro Plan are classified as Type I or Type II amendments, . depending upon the specific changes sought. The proposed Metro Plan and EMRP amendments are "site specific"-and relate to property solely within the corporate limits of the City of Springfield. The Metro Plan defines Type II amendments as: "[A]ny change to the Plan diagram or Plan text that is site specific and not otherwise a Type I category amendment." 'The proposed amendment is a Type II site-specific amendment because it: . Involves a specific geographically identifiable property; . . Does not change the metropolitan Urban Growth Boundary;.. ... Does [lot change the Metro Plan jurisdictional boundary; . Does not require a goal exception; . Does not includea non-site-specific amendment of the Metro Plan text; and . . Applies only to property located within the Springfield City limits, Accordingly, the current proposal is properly characterized as a Type II amendment (as defmed in sbc 7.030) that must be reviewed and approved by the City of Springfield; consistent with SSC 7.070 (2)(a), Per SDC 7,040 (2)(b), this citiz~n-initiated Type ir MetroPlan amendment can be initiated at any time, . 5.0 Applicable Approval Criteria Type II Metro Plan amendments are evaluated according to the criteria of approval contained within SDC 7'.070 (3), which provid~s: ' ' "The following criteria shall be applied by the City Councilrin approving or denying a Metro Plan amendment application: (a) The amendment must be consistent with the relevant 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." Findings demonstrating consistency with the approval criteria are outlined below: 5-49 . Metro P\anJEMRP Diagram I'illleridmen\ PeaceHealth Oregon Region March 15 2007 Page S 5.1 Consistency WithState,vide Planning Goals The following findings address compliance with Metro Plan criteria in SOC7.070 (3)(a), Approval of a Metro Plan diagram amendment also. correspondingly changes the applicable refinement plan diagram, as established inSDC 7,110 (4). Goal 1 - Citizen Involvement Goal I addresses the need to develop a citizen involvement program to ensure citizen . involvement in all phases of the land use planning process, The Planning Commission . .and the City Council will hold public hearings and accept testimony on the proposal. Through the procedures established by the city, citizens will receive notice of hearings in generally published local papers and have the opportunity to be heard regarding the , proposed diagram amendment and zone change, Notice of the public hearings will also be given in accordance with SDC requirements to 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 proced~re, the proposed 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 adequ'ate factual base, As required inSDC 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, The Metro Plan and the SOC, as well as the Statewide Planning Goals and applicable statutes, provide policies and criteria for the evaluation of comprehensive plan amendments, . Compliance with these measures assures an 'adequate factual base for . approval of-the proposed Metro Plan diagram amendment. As discussed elsewhere in this document the amendments are consistent with the Metro Plan and the Goals, , Consequently, by demonstrating such compliance, the amendments satisfy 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 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 agricultural use for decades, '5-50 Metro Planll:MRP Diagram /'I.mendment PeaceHealth Oregon Region March 15, 2007 Page 6 . 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. GoalS - Natural 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 part of periodic review, to , (I) identify such resources; (2) determine their quality, quantity, and location; (3) identify conflicting uses; I (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 the conflicts, The subject properties are not on Springfield's acknowledged Metro Plan GoalS inventory. No threatened or. endangered species have been inventoried on the site, and no archeological or significant historical inve'ntoriedresources are located on the site, The National Wetland Inventory and Springfield Local Wetlandlnventory maps have been' consulted and there are no jurisdictional wetlaI)ds located on the site. Therefore, the proposed amendment does not alter the City's compliance with GoalS. Goal 6 _ Air, Writer, 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 and federal air and water quality standards, In the context of the proposed Metro Plan diagram amendment, Goal 6 requires that the applicant demonstrate that it is reasonable to expect that applicable state and federal environmental quality standards can be met. '. Tho~gh 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 earlier/historic use was removed from the site and properly disposed. Given the nominal impact generated by historic uses on the site, it is reasoriable to. conclude that future development on the. site will be able to demonstrate compliance \Vith City standards for water quality protection through the site plan review process, thereby complying with applicable state and federal environmental quality standards. 5-51 Metro Plan/EMRP Diagram Amendment PeaceHealth Oregon Region March i5. 7007 Page 7 Goal 7 -Areas Subject to Natural Hazards Goal 7 requires that development subje:;t to damage from natural hazards and disasters be planned ancllor 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 olitside of any established FEMA flood hazard area, Therefore, approval of the proposed Plan amendments will not alter the City's acknowledged compliance with Goal 7 through'its adopt~d plans, codes and procedures, Goal 8 - Recreational Needs Goal 8 requires local govemments to plan and provide for the siting of necessary recreational facilities to "satisfy the recreational needs of the citi:;:ens 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 proposed amendments will not have an impact on the community's recreational facilities or needs; therefore, the proposal does not implicate Goal 8, Goal 9 - Economic Development Goal 9 requires the city to provide adequate opportunities for a variety of economic . activities vital to the health, welfare, and prosperity of the citizens, The proposed amendment to the Metro Plan diagram will increase the city's capacity for economic development by adding 5 acres ofCC in place of the existing industrial desigmition, 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). Specific'ally, the following SCLS polici~s are~pplicable to the proposal: ' Policy I-A: ':Maintain a mixed supply of.large and imall commen;ial sites through strategies such as rezoning or annexation to serve Springtleld' s future population," The proposal fulfills this policy objective by redesignating and - through accompanying zone change _ rezoning land from industrial to commercial, for two tax lots of varying sizes and commercial uses,'thereby maintaining existing employment and commercirr\ 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 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 . 11 . services, 5-52 Page 8 Metro PlanfEMRP Diagraa.. .mendment PeaceHeallh Oregon Region March 15 2007 - ---- - -'.- --- - The SCLS (see Table 3~8, pg, 32) found there to be a deficit of158 acres in the supply of commercial land over demand projected through, the year 2015, The proposal would allow for redesignation, and rezoning, of five acres thereb'y reducing the deficit of commercial land, The subject site has a full range of urban 'public facilities and services available to support existing commercial development on TaxLot 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 sets 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 SCLS (pg. 36) cited the acknowledged 1992 Industrial Land Study as demonstrating that "a surplus of industrial sites;exists in the Metl'O 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 ~ommercial lands deficit identified in the SCLS. Therefore, approving the proposal would be consistent with SLCS ImplementationStrategY3-A (1): "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 prop'osal in fact consistent with in"entories 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 desigi1.ations "in excess of two acres within im existing urban growth boundary from an industrial land use designation to a non- industrial use designation" to have to address applicable planning requirements ~ such as consistency with the Metro Plan 'and other local plan policies (i,e., SCLS) or be consistent with an economic opportunities analysis, The, City can 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 existingand long,standing commercial center to continue to operate and provide employment opportunities, while also allowing higher-value employment associated with future development on Tax Lot 400, These types of employment-generating 'uses are among those identified in OAR 660-009,0005(6) as eligible non-industrial employment activities,that can justify approval of the proposed Plan diagram amendmer,t without the need for an economic opportunities analysis apart from the SCLS, which DUCD acknowledged as fulfilling the City's obligations under Goal 9, . Because the requested redesignation and concurrent zone change implements SCLS policies and does not result in a deficiency of needed industrial lands, and is otherwise demonstrated .to b'e 'consistent with relevant !vletro plan policies, approval of the request is consistent with the City's compliance with Goal 9 ilnd applicable administrative rules regarding Goal 9 implementation, 5-53 Metro PlanlEMRP Diagram Amendment PeaceHealth Oregon Region March 15 2007 Page 9 GoullO -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 ofresidentiallarids. In fact, approval of the requested redesignation for Tax Lot 400 would enable redevelopment of an ind\)strial site abutting existing residential development. Through the site plan review process, future development on that property will provide a superior buffer and a higher use that will benefit the adjoining residential properties, Because the ,proposal involves redesignation from industrial to commercial land uses, it does not affect Springfield's continued compliance with Goal 10, Goal 11- Public Facilities and Services This goal requires the provision of a timely, orderly and efficient.arrangement of public facilities and services. The subject property is located within the SpringfieldUGB and city limits, and is already designated for urban levels of use, The proposed amendment to the Plan map designations from LMl to CC will. not affect the ability to provide needed services since all the required urban services are available to support existing or future corrunercial uses on the subject site, Goal12 - Transportation Goal 12 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 and long-standing corrunercial'uses occur on Tax Lot402 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'thi: 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 "significant effect" on transportation facilities as ' defined in the Transportation Plannin~ 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 sO!lle access changes as will be reviewed through the Slte 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 levels, and that safe and efficient circulation can' be realized through approval of the requested 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 Relinement Plan (EMRP) 5---'54' Metro PlanlEMRP Diagram Mffiendment PeaceHealth Oregon Region March 15 2007 ,Page 10 Access, Circulation & Parking Element policy IB (pg, 17) and Commercial Element policy 3 (pg, 12). ' Because the proposal, as demonstrated in t~e 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. Goal 13 - Energy Conservation The Energy goal is a general planning goal and provides' limited guidance for site-specific map amendments. The proposed ainendmenthas no' direct impact on energy conservation, though it would in fact will promot~ greater energy efficiency by enabling needed clinical services available to growing i-esid~.ntial areas in east Springfield, Therefore, the proposed amendment is consistent with, and does not alter the City's continued compliance with Goall3. Goal 14 - U rbattization Goal 14 requires.local jurisdictions to provide for an "orderly anq 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 15.- Willamette River Greenway This goal is inapplicable bec'ause the subject property is not within the boundaries of the Willamette River Greenway. Goals 16-19 - Coastal Goals The coast'al goals are,not applicable to this application, '. 5.2 Metro Plan Consistency The application requests amendment of the Metro Plan diagram from LMl to 'cC for approximately 5.24 <ocres, This sectio!'t' ofthe application na:rativ~addr~sses the consistency of the amendment with the applicable policies of the Metro Plan, to demonstrate that adoption of the amendment ,will not make the Metro Plan internally '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 la~ds 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 dev~lopment proposals that will be addressed c 5-55 Metro PlaniEMRP Diagram Amendment PeaceHealth Oregon Region ,March 15. 2007 . Page 11 tlu'oughcompliance with applicable City regulations during site plan review of a given future development proposal. '. '." The Metro Plan Introduction, Section D provides the. following definitions: A goal as ,a broad statement of philosophy that describes the hop~s 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. . Anobjectiv,e is an attainable target that the community attempts to reach in striving to meet a goal. An objective may also be considered as an intermediate point that will help. fulfill the overall goal. : . A' policy is a statement adopted as part of the Plan to provide a consistent course of action moving the community towards attainment of-its goals. Except forthe 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, 5.2,A. Metro Plan Elements 1. Growth Management . Policies 1. The urban growth boundary and sequential development shall continue to be implemellled as an essen~ial means to achieve . compact urban growth. Provision of all urban services shall be ,. . . concentrrited inside the urban growth boundary. 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 sitep\an review processes ensure that the appropriate level of services is available to serve future development. . '.' 5~56 Metro PI~niEMRP Diagram AIDendment P eaceHealth Oregon Region March i5 2007 Page 12 2. ResidentialLand Use and Housing Element / policies A.ll Gen,erally 'locate higher density residential development near' employment or commercial services, in proximity to major' transp.ortation systems or within transportation-efficient nodes, ' The proposed redesignaticin does not affect the inventory or availability of residentially designated or zDned land, including the single-family residential area abutting Tax Lot 400 that is zoned and designated fDr Medium Density Residential, or higher density residential developments located east of the site alo,Ilg Main Street. HDwever, approval Df the requested redesignatiDn .tD Community Commercial would allow fDr residential areas prDximate to the subject area to have close and efficient access to existing commercial services Dn Tax LDt-402 and to futu~e medical facilities proposed fDr Tax Lot 400, consistent with the above policy, The areas proposed for redesignation offer existing and future employment opportunities and provide commercial services along a major transpDrtation 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. regulatiolls. The map amendment and cDncurrently proposed zone change will allDw fDr existing commercial uses on Ta;<: Lot 402 to coritinueto serve existing neighborhoods in the midc and east-Springfield area, and fDr future clinical facilities to be devdoped to serve this rapidly growing area of the community, Approving the requested redesignation and zone change would expand cDmmercial opportunities to serve these neighborhoods consistent , with the above policy. ' 3. Economic Element policies E.] 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 ai/vantage in the level of education and skill of the resident labor force. .5-57 Metro PlaniEMRP Diagram Amendment PeaceHealth Oregon Region March IS, 2007 Page 13 The proposed amendment is consistent with.this policy because it will allow medical clinic uses to, be developed to serVe growing areas in east and south Springfield. As is observed in the Springfield Commercial Lands Study (pp, 27,29), employment in health services is growing and approving the requested redesigna\ion will enable increased job opportunities with higher than average wages thereby helping raise the standard of living and meet the needs ~of Springfield citizens, consistent with the above policy. . B.2 Encourage economic development which utilizes local and imported capital, entrepreneurial skills, and the resident labor force. The 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 Increase the amount of undeveloped land zonedfor light indl,lstry and commercial uses carl-elating the effective supply in terms of suitability and availability with the projections of d~mand. The proposal will add approximately 5,24 acres of Community-Commercial land, consistent with recommendations to increase the commerciai lands inventory made in the SpriI)gfield Commercial Lands Study. The SCLS and acknowledged metropolitan Industrial Lands Study concluded that there is a deficit of needed commercial land, and a surplus of industrially zoned and designated land, Approval ofthe requested redesignation will not cause the inventory of needed industrial land to go into a deficit, but in fact would, consistent with the above policy. The proposal correlates (he need and suitability, and availability of the subject site for commercial uses with the need for such uses'asdemonstrated in the adopted SCLS, ' B.ll Encourage economic activities which strengthen the metropolitan area's position as' ci regional distribution, trade, health, and service', . ' center. , The amendment will facilitate the development of medical uses that will serve the needs of the growing residential areas in east, south and southeast Springfield, and strengthen " . the metropolitan area's position as a premier locale for healthcare services, consistent with this policy objective. 6. Environmental Design Element policies E.1 III order to promote the greatest possible degree of diversity, a broad variety of commercial; residential, and recreational land Llses shall be encouraged when consistent with other planning policies. . 5-'-58 Metro PlaniEMRP Diagram NIlendment PeaceHealth Oregon Region March 15,2007 '. Page 14 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 deyeloped 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 developmwt, including higher intensity, transit-oriented developmel1~ along major transit corridors and near transit stations; mediilm- and high-density residential development within one-quarter mile of transit stations, major transit corridors, employment centers,and downtown areas; and development and redevelopment in designated areas that are or could be well served by existing or planned trans,it. The proposed map mD.(mdment and concurrent ~onechange 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 LTD stop is located on the frontage of Tax Lot,400 (see photo, pg, 2, Appendix A of the TIA), and will provide convenient access to existing and proj ected employment on the subject site, as well as access for patients to future out-patient medical facilities projected. , on Tax Lot 400. '- l . 5-4!i~8 Metro PlaiJEMRP Diagrarn'NTIendrnent PeaceHealth Oregon Region March 15 2007 Transportation System Improvements: Roadways policies F.1S' 'Motor vehicle level of service policy: ' a. Use motor vehicle level of service standardsto maintain acceptable and reliable performance on the roadway system. These standards shull 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 <;nd land_useregulations,pursuant to"the TFR (OAR 660-012- . 0060). . (3)'Evaluating development applications for consistency with the land-use regulations of the appli~able local government jlirisdiction. 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 the OHP shall be applied on state facilities in the Eugene-Springfield metropolitan area. ' In some cases, the level of service may be substandard, . The local government jurisdiction may find that transportation system improvements to bring performance up to' standard within the planning horizon m'ay 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 but not limited to environmental conditions, lack of public agency financial resources, or land use constraint factors. It is not the intent of TSI Raodway Policy #2: jy!otor Vehicle Level of Service to . require deferral of development in such cases. The intentis to defer motor vehicle capacity increasing transportation' improvements until existing constraints can be overcome or develop im a/ternatiye mix of strategies (such as: land use meaStlres, TDjY!,S}lOrt-term safety improvement~) to address the problem. Page 15 " Subsection a,(2) in the above policy requires an evaluation of the proposal pursuant to the state Transportation Planning Rule (TPR), The accompanying Traffic Impact Analysis '5-60 Metro P\;niEMRP Diagram ,vnendment PeaceHealth Oregon Region M;rch 15 2007 Page 16 provides the factual basis to determine that the proposedredesignation would not result in a "significant effect" as defined under the TPR(OAR 660-01z'-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 ofroadways, 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 classiflcation of Main Street or any other nearby roadway;. . .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 would be the case other uses permitted under_existing designations or : . ' zoning, I' Specific TPR findings are further located in theTIA, see pp,'3l-32, Because the proposal does not result in a "significant effect" as established by applicable OARs, no further TPR analysis is required, The request is therefore consistent with the above policy, 8. Public Facilities and Service Element G.1 Extend the minimum level and full range of key urban facilities and services in an orderly and efficient manner consistent with the growth management policies in Chapter lI-B, relevant policies ill this chilpter ulid other Metro Plan policies. The subject property is located in Springfield's city limits UGB. All necessary infrastructure and key urban facilities/services are present to serve existing development (Tax Lot 402) or are available to serve future infill.development onTax Lot400, 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 diagram amendment. 10. Historic Preservation Element.Policies ,. Policies in this element of the Metro Plan are,not relevant to the requested diagram amendment. 5-61 Metro P laniEMRP 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 am~~~ . 8.0 East Main Refinement Plan Consistency The following demonstrates how the proposal is consistent with applicable policies in the East Main Refinement Plan (EMRP), 1. Mixed-Use Element Policy 2) Area #2 A) Thefollo~ing land uses are allowed LInder Community Commercial zoning: All Community Commercial uses subject 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 othe,r 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 Commercial Re.fi.nement Plan Desif!nation.' 1. Generally, the Community Commercial refinement plan designation shall be applied under the following circumstances: A) where it is not an intrusion into well-maintained residential neighborhoods; The proposed redesignation does not intrude into the existing residential area west of the subject site along '44th Street, and is therefore consistent with the above , ' criterion, 5-62 Melro PlanlEMRP Diagran. .illleildmenl PeaceHeallh Oregon Region March IS 2007 'Page 13 B) where it does not increase conflict betwee.n Low De'nsity Residential and Commercial; Although the abutting residential area is zoned Medium Density Residential, it is developed in low density residential uses, Approval of the proposed redesignation of the subject sites would actuallyresult in a decrease of conflicts . between abutting residential and non-residential 'land uses by allowing future. infill development on Tax Lot400,"and through the site plan review proc'ess establishing improved landscaped buffers and a use more compatible than the industrial uses that historically abutting this residential area, ' C) where criteriaJor designating !v!edi;,m 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 Lot 402 has existing, long-standing commercial uses that werelegally created prior to development of the Metro Plan or EMRP, , E) where adequate cllstomer and service qccess to an arterial , ,street can be provided; .... and The subject site has. adequate legal access ont~Mai~ 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-specijic Commercial refinement plan designations to clearly define the limits of new commercialllses where there is 1I0t an existing, legally established, alld b~neficial mixing of uses. Approval of the requested redesignation would apply Commercial plan designations to the subject properties, allowing the existing,.legally established commercial uses on Tax Lot 402 to continue: It would also enable commercial uses to be established on Tax Lot 400, thereby defining the limits of new comrp.ercial 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 Llses, but has historically hOLlsed industrial yard-type operations, Therefore, approval of 5-63 Metro PlanJEMRP Diagram N11endment PeaceHealth Oregon Region March 15. 2007 Page 19 the proposal would define the limits of new commercial uses as. called for in the above policy, and also provide the ability to make superior buffering and other improvements associated with future development on Tax Lot 400 through the site plan review process. . Policy 3) Reduce the number of vehicular access points and require the rebuilding of curbs and installation of sidewalks and street trees along 111 ain Street, through the Site Plan Review process and in public improvement projects. The proposal would result in reducing the number of exi?ting 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, etilTIinating 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) Provi~e 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 shall encourage efforts of various agencies to attract new (l1ld retain existing jobs and businesses. . . l,nDlementation Tlie City shall maintain a current inventory of vacant commercial and industrial land and structures within the East Main area. Consistent with the above policy, approval of the requested redesignation will enable existing, long-standing jobs and businesses on Tax Lot 402 to remain as legal, conforming land uses, and allow future development of new employment on Tax Lot 400 with higher than average wages and employment densities than the current designation and zoning allows,. 5-64 ;}i~~)"~~Jt4~~f~~1:~;~~JZ~ .. . ...~f!i; . ,. . , ., .',. .:,<:,.,:,..,;::,~.:.~,-"..:,',-:..,~,:,::~.~~..,:!,',',:~-',:,' ;,\j'_~.'. ..:",':-,:':(:~;F,'-::: .". ,- - '-- . .. . , '.... .'.. ..'.' >7*.,.";"':':;~"'-"::\--'1e+'<' .;i":::"\;i:~~~,~i)TB~l]~~~l.i'(~,;i;;:;!{',",,, ".!..~({:,it;,:" ,. 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TD EDWARDS AW HAMMIT ~ D.L.C. 55 D.Le, 36 100 ......~.. ;.i,;,,;ii),:~~iJ"':'~' '.--. .' -. ,. ~,>':t'-,~~;':SEE;::MAP,,:;,'17-02-32-4:-2. ........ ..,.,.. .. . .,":;;:~}J~;1]it;;"'~j,f;:c1,:it~~t~,~.~,~~\.rtIi(\r;i::r~1~fi;i,;t&,~t.l,:t,~,;.:,7: .'.:. .... ......,.:7*:,'" 2 32 2 4 - /-.:i'S/. 02 77.9("'''''' .:5'/-9-.14' SOO.2 " ..7.... 9, 6'.:? . I 401 .501,...., I I .. I I " '0 OJ I I .2 I I " I ft). I I.j ,,' \.. I , ~ t\,' : J to. I ... . "~l ~ " I ' . - '" t-, ,,8 ~ ... . . ~ 'll I,i ~~ ~ ,,' ~ l/- ~ l)<>. ~ ~ t-= ~ I/J :::T6.+' ..r--' I /.35~.!!Jo' I M1TH <;\l,,,"44'e , ~ , ~ , ~~ , 'r\ 'l.l ~ ~ ..... ... ~ '- co t<) N o .z Cl <C o 0:: >- f- ;Z. ~ o o II Community Commercial Light Medium Industrial Medium Density Residential -,.,. "...., J: Metro Plan I Refinement Plan Amendment Application #LRP2007 -00013 Rezone Application #ZON2007 -00012 Metro Plan Amendment from LMI to Commercial. and concurrent Zoning Map Amendment from LMI to CC I. : .JJ",!,"':" ."l,~ i.~.;, I g~'E~;:':::-.--.'_. ....~~...,.- ...-0_>_ _0_>_ 5-67 .' " . i 'ft__'..___......~.-.... :.-s=_ ..,,:::'".=..:::- --'-. '5-68 2 3 5-69 .' .' '<T -..' C> r--- I 'LD C'-' (/) C o :;::; (/) ill ':J o Propel, ,'Planning & Development ~PeaceHealth March 28, 2007 David Reesor, Planner. II City of Springfield' Develop'mentServices Department 225 Fifth Street' . Springfield, OR 97477 Re: Plan Amendme\lt,(LRP2007-00013), Zone Change (ZON2007-00012) Mr. Reesor, The following and attached is supplemental information for theabove-reference'd applicationsfor proposed Metro Plan diagram ~mendment and zone change in east Springfield. The prop'osal seeks to redesignate and rezone approximately 5 .24a~res on 0,,0 parcels from Light-Medium Industrial (LMI) to c:;oinmercial. As note.din the application findings submitted last week, the Springfield Commercial Lands Study demonstrates that the City has a deficiency in needed corrimercially designated and zoned land, so approving the proposal would help redu~e the identified deficit in 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 Metro plan, specifically fulfilling theEugene-Springfield area's obligations under Goal 9 (Economic Development), The Metropolitan Industrial Lands Inventory Report associated with the MILS identified "about 1,688 constraint-free industrial . acres.. ..This supply exceeds the projected demand over the next twenty years, which is between 650 to 1,172 acres." (pg,73) The Inventory Report also stated:. "The 1,688 constraint-free acres may be the best suited to meet short-tenn industrial demand. This portion of the supply also exceeds the twenty ,year demand projection," The City perfonned subsequent analysis of industrial land supply as' part of periodic review requirements to demonstrate compliance with statewide planning GoalS (Natural Resources), As shown in Attachment A, that analysis indicated that even removing the .possible industrial acreage affected by GoalS protection measures (about 100 acres debited from the Eugene and Springfield inventories) would leave a.surplus of industrial , ' lands of between 1;600 and 2,122 acres metro-wide, Staffs GoalS ,york also calculated the changes in industrial land supplies since 1991 as a consequence of Metro Plan diagram changes (see Attachment B), This analysis demonstrated a reduction in less than 90 acres of industrial land over the past 15 years, Phone: (541) 3:~5-2593 Fox: (541) 335-25'95 Ri'ler8end Anne, 123 Inlernational Way Springfield. OR 97477 www ne~ceheallh.orqloregon 5":' 7r Dedicu{ed [0 Erceplio/1o( AIr:dicinr! and Compossiol1l1le C(1re suggesting that t~ere is still an ample supply of available industria:! lands to meet existino- ." . ~ 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 inventory of LMl zoned and designated land due to City Council approval in April 1997 for land east of the 28th/31st Street connector and north of Marc 01 a Road (Ordin'ance No. 5851). Insofar as the City and metropolitan area continue to enjoy a surplus of needed Industriall~nd, 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 nO,t 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 Commissiori hearing, Please notify me when the hearing is set, and send me a copy of the required hearing notice to DLCD for my files, . Thariks for your consideration of the above. If you need additional information, please contact me at your convenience. . :'J!!f:if,licp t--- Director, .Land Use Planning & Development PeaceHealth Oregon Region' . : Attachments 5-72 A TT ACHMENT A ,11.0 Impact of the Proposed Protections on Buildable Land Inventories . This section.estimates the impact of the recommended' program for protecting Springfield's resource areas on the inventory ofbul1dabn~ residential, commercial and industrial land, The administrative mle quoted above is somewhat vague about how to compute the impact. Some contend that the protected acreage should be subtracted from the current inventory of buildable land, Others contend that the protected acreage should 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 bllildable land, .' Tables 11-1, 11-2, and 11-3 below summarize the amount of land that would be subtracted from the Eugene-Springfield inventories -of surplus of-buildable residential; commercial and industrial lands that were identified when each inventory was adopted. Table 11-1. Analysis of Maximum Possible. Impact on Supply of Residential Lands within the Eugene-Springfield Metropolitan Area . I Residential Land Supl)ly - - -, - - - .,- . - .- Eugene-Springfield Metropolitan Area Residential Lands and Housing Study Surplus Acres Low Demand Assumption or High Demand Assumption Acres Removecl from Residential Designation by Previous Plan Amendments' ' " Eugene Springfield I Acres 1862,00 or 790,0'0 -84.90 -52.03 -136.Q3 Total '. Nlaximum Possible Residential Acres Impacted by Eugene Goal 5 Protection Measures -445,77 Maximum Possible Residential Acres Impacted by Sprin!Cfield GoalS Protection Measures Remaining Surplus -14.18 1265;12 or 193.12 J 5-73 Table 11-2. AnalYsis of Maximum Possible Impact on Supply of Commercial Lands within the Springfield Urban Growth Boundary , Acres 1 -153 acres . -2.8 acres I I Commercial.Land Supply Springfield Commercial Lands Study (2000) projects a deficit of commercial land,. Acres Removed from Commercial Designation by Previous Plan Amendments* \ Maximum Possible Commercial Acres Impacted by Springfield's Goal 5 Protection Measures . I Remaining Surplus (Deficit) -11.56 acres (-172.36 acres) i Table 11-3. Analysis of Maximum Possible Impact on Supply of Industrial Lands within the Eugene-Springfield Metropolitan Area I Industrial Land SupolY Metropolitan Industrial Lands Inventory Report Surplus Acres Low Demand Assumption or High Demand Assumption Acres Removed from Industrial Designation by Previous Plan Amendments* Eugene Springfield , Acres 2954.28 or 2432,28 .642.30 -90.80 -732.80 Total Maximum Possible Industri.al Acres Impacted by Eugene Goal 5 Protection Measures :44.73 Maximum possible Industrial Acres Impacted by Springfield Goal 5 Protection lYIeas tires ' Remaining Surplus -54043 2122.01 'or 1600,01 I * Does not consider actions taken by Eugene to add additional lands to the surplus. 11.1 Impact on the Residential Lands Inventory 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 inc\lId~J! in the estimated supply of buildable residential lands, Other types of constraints were also considered and classified as unbuildable and were not counted in the buildable residential land inventory. The list of constraints included: . 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 50 feet of a Class B stream or pond; and Smail irregularly shaped lots~ . . . . . Since the Residential Lands Study did not include wetlands listed on the Local Wetlands Inventory in the buildable lands inventory, it is assumed that protecting these wetland sites from conflicting residential development will not reduce that inventory. The development setbacks recommended for significant wetland sites in this study will slightly reduce the inventoried acreage of vacant" buildable land adjacent to wetland features. Wetland Setbacks As noted in Table 11-4 below, about 9,95 acres oflow-density residential (LDR) and ,59 acres of medium density residential (MDR) larid will beremoved from the re'sidential lands inventory by the 25-foot setback recommended for t~ose wetlands not already protected by the 50 and 75 foot setbacks required by Springfield's stormwater quality protection policies, Keep in mind that this is a worst case scenario and assumes that the developer is unable to locate required stormwater facilities within the recommended setbacks and that subdivision design cannot arrange for the',yard areas of affected dwelling units to be placed adjacent to the wetland, thus reducing or eliminating lost development area. Riparian Setbacks In addition to wetland setbacks, recommended riparian setbacks will also result in the removal of vacant acreage from the inventory of buildable residential lands, As noted in Table 11-4, about 3.42 acres 'of low-density residential (LDR) and ,22 acres of medium '. density residential (MDR) land will be remove~ from the residential lands inventory by the 25-foot setback recommended for those wetlands not already protected by the 50 . and 75 foot setbacks required by Springfield's sto~water quality prot~ction 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 ,087acres'ofbuildable residential,land described in the 1999 Residential Lands Study; , .. . In May 2004, a Residential Lands Study Moni~oring Report was published, updating the residential lands inventory to reflect development through 2003. The report estimated that at the end of.2003 there was 1,361 acres of remaining buildable residential land in Springfield, The amount of land removed from the buildable inventory by the 25-foot wetland an&riparian setbacks proposed by this report represents about 1.% of remaining 1,361 acres, 5-75 Table 11-4. Vacant Residential land within Proposed Protection Setbacks Setback Distance . Vacant LDR Acres Vacant IYIDR I Acres .' Total Acres I Wetland Setbacks I 25 foot I 50 foot I 75 foot, I 'I Riparian Setbacks I 25 foot I 50 foot I 75 foot I I 10.54 12.13 I 9.12 I 31.79 I I 3.64 I 8.79 I 9.12\' 21.55 53.34 I Total .9.95 904 4,97 24.32 .59 2.73 4,15 7.47 .22 2.73 4,15 7'.1 14.57 Total Grand Total 3.42 6.06 4.97 14.45 38.77 " 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 \vith poor visibility; Lots with inadequate access; Hydric soils; Unstable soils; Willamette Greenway and Greenway setbacks; Floodway and floodway fringe; . Wellhead zone of influence; Wetlands listed on the Springfield Local Wetland Inventory; Other potentially regulated natural resource sites [Natural Resources Study Inventory]; Sites with Plan/Zone conflicts, The Commercial Lands Study classified sites on the on the Springfield Local Wetland Inventory as constrained. The presence of these wetlands was noted and the inventory of vacant commercial lands was noted to reflect the constraint. The riparian sites which are " part of this study were also included as constrained, si~ce they were part of the draft Springfield Inventory of Natural Resource Sites at the time CommercialLands Study was' conducted. ' 5-76 - Since the Springfield Cotnmercial Lands Study did,not remove wetlands and riparian. sites, protection measures proposed by this study wil1have an impacton the inventoried acreage of vacant corornerciallands, The development setbacks rec'ommended for 'significant wetland and riparian sites will further reduce the inventoried acreage of vac~nt buildable corornercialland 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 corornercialland.in SpringfIeld, 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 \vas 2'55 acres, The 2000 Commercial Lands Study concluded that there was a 158 acre deficit of buildable commercial land. Wetland Impacts Table 11-5 shows that ,07 acres of vacant corornercialland would be removed from the Commercial Lands Inventory if wetland sites zoned for commercial development were fully protected. The 25-foot wetland setback recommended by this study would remove, an additional 1.47 acres of vacant commercial land from development. This figure assumes that the developer is unable to locate required storrnwater facilities or required landscaping within the reco'rornimded setbacks, thus reducing or eliminating lost . development area. The total impact on the Commercial Lands Inv~ntory would be a reduction of 1.54 acres if \yetland sites and their setbacks were fully protected, Riparian Site Impacts Table 11-5 shows that about acres 2,78 of vacant commercial land lies within inventoried riparian sites that are protected by the Springfield'S Stormwater Quality Management program, Therefore, no commercial acreag~ is removed from the ~ommercial Lands inventory by the implementation of proposed protections in this study, As'noted in Table 11-5, no vacant commercial land will be removed from the inventory by the proposed 25-foot setbacks, The total impact on the Commercial Lands Inventory would be a reduction of 1.54 acres 'if wetland and riparian sites and their setbacks'were fully protected, This represents 1,8% of the 85 acres of buildable commercial land described in the Springfield Commercial Lands Study. Table 11-5, Vacant Commercial Land within Proposed Protection Setbacks I Zoning District Site 25ft. 50 ft. 75 It Total Acreage Setback . Setback Setback Acres I Wetlands I Community .07 1.47 ,11 OJ 1.65 5-77 . \ Zoning District Site ' 25 ft. 50 ft. . 75 ft. I Total I Acreage Setback Setback Setback I Acres Commercial 0\ Neighborhood 0 0 0 0 Commercial j I General Office 0 0 0 0 0 \ Maj or Retail 0 0 0 0 0 Commercial I Wetland Total 0.07 1.47 0.11 0 1.65 I Riparian Areas , \ Community 2,78 0 0 2.6 5.38 Commercial \ Neighborhood 0 0 0 0 0 Commercial I General Office 0 0 0 0 o 1 I Major Retail' 0 0 .24 0 .24\ Commercial 1 Riparian ~ .2.78 0 0.24 7..6 5.62 I I Grand Total 2.85 1.47 .35 2.6 I 7.271 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 g;.eater Eugene-Springfield area, The study concluded that there was about 709 acres of buildable industrial land within Springfield's UGB. Like the Springfield Commercial Lands Study, the Industrial 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 of this impact is discussed below, ' Wetland Impacts' GIS analysis shows that about 30,64 acres of vacant industrial land are affected by wetlands that,are not already protected by the Springfield Stormwater Quality Management (SQM) program. These wetlands are recommended for protection 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 industrial lands would 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 il" GIS analysis shows that 13.70 acres of vacant industrial land are affected by riparian areas are that not already protected by the Springfield Stormwater Quality Management (SQM)progr~. These riparian areas are recomri1ended for protection by a 25-foot deve]opmenf.setbackunder the Springfield Natural Resources Study.' These setbacks add another 3.27 acres to the amount of industrial zoned lana 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 ii:1dustriallands would be 16.97 acres" Table'll-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 total impact on the Industrial Lands Inventory would be a reduction of 54.43 acres if all wetland and riparian sites protected by this program an<f their 25-ft setbacks were fully . protected. This represents less than 1% of the 709'actes of buildable industriallaild for. Springfield in the Industrial Lands Study. ' . . ".. Table 11-6: Vacant Industrial Land within p~op6sed Protection Setbacks Zoning District I Wetlancts-C - Liaht- ~ Medium Industrial I Heavy Ind ustrial I Campus , Industrial Special Heavy Industri al I Quarry Mining lBo, othKelly - . MU . I Wetland Total Riparian Areas Total ,"Yelland Site Acreage , Site Acres not Protected by SQM 25 ft.. 50 ft. Setback,' : Setback . 75 ft. Setback . Total Acres , - --- 28.20 (2V6) 4,81 .82 o 33,83 13.16 (2.88) 2,01 19,15 o 34,32 \ . . ,35 o o 1.28 o 1.63 o o o o o o o o o o o 0\ 0,60 I ,13 o o .47 o 41.84 (30.64) 6.82 21.72 o 70.38 Total Riparian Site , Acreage Site Acres not Protected . by SQM 25 It; Setback 50 ft. Setback 75 ft. Setback Total. Acres 5-79 " Zoning Total . Site 25 ft. . 50 ft. 75 ft. ,Total ,District Wetland Acres not Setback Setback Setback Acres . Site Protected Acreage by SQM , Light- 16.48 (10.89) 2,05 . 4.72 q6 24.51 Medium Industrial \ Heavy 68.31 (2.81) 1.22 8.93 ' 0 78.461 Industrial Campus 3.22 0 0 2.83 .03 6.08 \ Industrial Special 0 0 p 0 0 0 Heavy IndustriaL \ Quarry 0 0 O. 0' 0 0 Mining \ ~th Kelly. .21 0 0 .82 0 1.03 1 \ Riparian 88.22 (13.70) 3.27 .17.3 1.29 110.08 Total I Grand Total 130.06 (44_34) I 10.09 39.02 1.29 180.46 I , 5-80 I~Oi Re-sld-ential, Commercial and Industrial Land Changes in Metro Plan Desi,nations . MD~0.1 cc 0, 1 \NC ~~!fq~!lJiLMl HI POS' GiE NR 35,0 5.0 -5,3 0.0 0,0 0.0 0,0 0.0 -3,0 3.0 -0,9 0.9 >.':'i?:~~~~~~}~{ ::~~;r{3' 8 ~.1 :-i\:-:.:i:~i~t~:,f'; ~ ;;t::_:;i~:~ 9;,2 ,; ~!?ni:f"f:\sj~~)~ en 1 co ~. I I I Local File Number. 190~04-058 '190-12-201 192-04-77 193-01-33 193-01-12 193-06-087 194-10-0194 \95-02-036 195-02-036 195-02-036 195-02-036 195-02-036 ' 195-08-0157 197-05-101 199-02'038 . \99-02C041 99-09-230 102-03-0062 102-03-0063 02-07 -200 02-08,243 LRP-2002-12431 LRP-2004-00Q31 ~f1.~1pJi t;\lfJMk)tr~\ ;trY~'J\ LRP-2005-00015 ~~I~\iff';:~ r~,7,1.6 ~~~~i\ I" \ ResideJltiaIJotals;'sini::eA995i~:[I,!'i' 'i~':;'75;O 1~'!i:i~~'!Q i?i~!k;f1,I~i./.I;:~~;;":;';'~!;' 1;ot'l d.~lts forR.slde.itlal!',';,!'\l :,'iJ;i!.:;;'52.,0 "i'iifi,i;,~:~W!!':'i!"iJndustilalto~a 15slncB Mari;It:199.11rl\11[~:'i;~1\\j~1&i!1i~ili~:~i~I;~~~;~;"~~;;~r1~=:~~'~!~~~,i!,ik~\!;\'1~(j;B' Metro PlariDiagram, Changes Affecting the S-u AG MU I \ LDR ~:itf:M~~~. -:)Yi"Jjr:~Q'ili ~~'f-ltf.'Kb.' ~~~~di~,~:;C?v ~-iY~11!W!\;,C. '?fflft?z~~~\~\~,[~4,~~,,~~1(ij_~1t,;l ""~"""i\k"""0'2'1'''HW'''' i'N:~~Mw:;t,' ;~1rf\~L, :,1i'i~:tl:i:J:(~1i;' , - 'B5jjfi#J~~?~\\;\(!j~fi~I-V :;t'i):'~':;flj}'~"; ,','/- -'t, '",'>(!'~it~r;;:'f- ,;\:',.1P:,w,m~~;IJ.,};;,:3,QI,O'.i~f,f:{H~d ~~~~~~;I"!(~~Yatii.ttiG- ~~~~~;;Wt: -3,7 5.3 0.5 3.7 6,5 ~;~'~7f,~~;7;--5 ";;:\;:iij,~f'7\5 . i~;~1'::I::~:-5;:$ ;iW1'f~~,~~{~~;; I no 1B.0 .16,5 ,34,5 -22,0 6,0 I 0) 33,0\ 1 LOR Low Density Residential MOR Medtum O~ns1ty Resldenllal CC Commercial Center Ne Neighborhood Commercial CI Campus Industria', LMI Light MedIum IndustrIal HI Heavy Industrial PQS Public Open Spa~e G&E Government and Education NR Natural Resource AG Agriculture MU Mixed Use )::> --l --l )::> o :r: 3': m z --l OJ .: ~. PeaceHealth March 15,2007 Zone Change Application Written Explanation of the Proposal Applicant: peaceHealth Oregon Region . 770E. 11th Avenue , P.O. Box 1479 . Eugene, Oregon 97440 i' , Property Owners: Hyland Business Park, LLC (Tax Lot 40D) 1941-A Laura Street Springfield, OR 97477 Attn: Shaun Hyland (541) 726-8081 Andrew Head (Tax Lot 402) , 1616 Ardendale Ln.. EugeI)-e, OR 97405 '(541) 521-3403 Applicant's Representative: . . . ,Philip Farrington, A1tp Director, Land Use Planning &. DeveloPTIlent PeaceHealth Oregon Region l23lntemational Way' . Springfield, 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 zoning classification ~n the City's zoning map from Light' Medium lndustrial. CLMI") to . Community CorriIDercial ("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, as allowed in Springfield Development Code ("SDC") 12.020 (I)(a)l. 5-82 Zone Change Application PeaceHealth :Oregon Regim ,March 15.2007 Page 2 The area subject to the proposed rezoning is mapped on Attachment A, and is referred to collectively in this application as the "subject properties"or "site." , . 2.0 Project purpose The Applic,ant seeks to rezone (and through concurrent appllcation, redesignate) the subject properties to CC ~o they may be developed for commercial uses (i,e., Tax Lot 400), including a possible future medical dinic which could serve residents in the . . growing east Springfield area, and to be allo'wedto continue long:standing commercial operations (i,e., Tax Lot 402). Approval ofthis land use request would preserve employment and existing viable commercial oper~tions 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 fut)lre 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 c'onsisten't with East Main Refmement Plan (ElvlRP) and the Metro PI;n as required by approval criteria 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 Commercial 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 beneficiil range of commercial and employment-generating uses on the subject properties, It would also improve the area and better distinguish andbuffer adjacent residential and industrial business park uses, 3.0 Site Context The subject properties inclucle a currently vacant, flat parcel (Tax Lot400)and existing commercial development (Tax Lot 402) east of 44th ~treet 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 W eyerhaeuser mill site (Tax Lot 400) or an existing commercially zoned parcel (Tax Lot 402), and on the west by other srriall-sca'le commercial enterprises (e.g" a cabinet snop and karate school) fronting Maih Street and residential homes along 44'h Street west of Tax Lot 400, Commercial enterprises are located immediately south of the site across Main Street (e,g., Gray's Garden Center), While, historically involved in agric~ltural uses, si~c~ 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;' constructio'n equipment and concrete fOrID plywood, Tat Lot 402 has had various coml1)ercialserviceson site since the 1950s, 5-83 Zone Change.-t-ppiication PeaceHealth Oregon Region March \ 5 Z007 Page 3 , ' The properties have no jurisdiction~l wetlands .or in~entoried Goal'S 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 Lightftv1edium ln~ustrial in the EMRP . diagram and zoned LM!. The areas immediately to the west and south of the site fronting '. Main Street are identifted as being within Mixed-Use Area #2 in the EMRP,'and are all . zoned Community 'cbmmercial. 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: . ", 1, Consistency with applicable Metro Plan policies and the Plan .:Diagram; .' 2, Consistency with applicable Refinement Plans, Plan District maps, Conceptual Development Plans and functional plans; and 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 developme(lt. Legislative zone map amendments are also required to show that they meet the criteria for Plan amendments outlined in SDC ArtiCle 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, 4.1 Consistency withlYletro Plan Text and Diagram Consisterrt, with SDC ]2,030 (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 [Ural 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. . 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 Applicatlon . ,PeaceHealth Bregon Region March \5, 2007 4.1.1 .Metro Plan Elements 1. Growth Management Polici~ .. 1.' The' urban growth boulldalY and sequential development shall . continue to be implemented as an.essential means to achieve . compact urban growth. Provision of all urban services shall be collcelltrqted illside the urball growth boundary. The proposal satisfies this'policy because the subject property is inside the UGB and city limits and as such, encourages compact urban grovith, Also, urban,services are available at sufficient levels to accommodate the existing and' future infill development resulting approval offnim 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.ll Generally IDcate higher density residential development near emplDyment or commercial services, in proximity to major transportatiDn systenis or within transpDrtatiDn-efficient noaes. The proposed redesignation does not affect the inventory or availability of residentially. designated or zoned iand, including the single-family residential area abutting Tax Lot 400 that is zoned and designated for Medium Density Residential, or higher density. residential developm;nts located east of the sitealongMain Street., However, approval of tl~e requested redesignation to Community Commercial wO\lld allow for residential areas proximate to the subj,ect area to have close and efficient access to existing comrriercial services on Tax Lot 402, and to future medical facilities proposed for Tax Lot 400, consistent with the above policy, The area.s proposed for redesignation offer existing and future employment opportunities and provide corhmercial services along a major transportation system that can support the needs of nearby residential d~e~pmffit. . " A.22 Expand oppDrtunities fDr a mix DJ uses in newly developing areas and existing,neighborhoods thrDugh IDcal ZDning and dev~IDpment regulatiDns. The proposed map amendment and zone change will allow for existing commercial uses on Tax Lot 402 to continue to serve existing neighborhoods in the mid- and east- Springfield area, and for future clinical facilities to he- 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 Z:one Change bpplication PeaceHealth Oregon Region ~larch 15, 20Q7 , 3. Economic Element policies B.l D~monstrate a positive interest in existing and new industries, especially those providing above-above wage and salary levels, and increased variety ofJob opportunities, a risdn the standard oj living, and utilization oj our existing comparative advantage in ,the level oj education and skill oJth'e 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 Springfield. As is observed in the Springfield Commercial Lands Study (pp. 27,29), employment in health services is growing and approving the requested redesignation rir,d zone change will enable increased job opportunities with higher than average wages thereby raising the.standard of living and meeting the needs of Springfield citizens, consistent with the above policy, B.2 Encourage eco/lomic developme/lt which utilizes loealand imported capital, eIltreprellwrial skills, and the resident labor Jorce. . The constrUction of and the use of cominercial and medical uses will utilize both local and imported capital and will employ the local labor force in a variety of skilled, semi-skille~, and unskilled positions, consistent with this policy, B.6 Increase the amount oJzwdeveloped land zonedJor light industry 'and commercial uses correlating the efJective supply. in terms oj 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 commercial lands inventory made in the Springfield Commercial Lands Study, The SCLS and acknowledged metropolitan Industrial LandsSttidy wncluded that there is a detcitof needed commercial land, and a surplus of industrially zoned and designated land, Approval of the requested redesignation and zone change will not cause the inventory of needed industrial land to go into a deficit, but in fact would be consistent with the above policy: The proposal correlates the need, suitability, and availability of the subject site for commercial uses with the need for such uses as demonstrated in the adopted SCLS. B.ll Encourage economic activities )Vhi~h strengthen the metropolitan area's position as a regio/lal distributio/l, trade, health; and service center. The amendment will facilitate the development of medical uses that will serve the !feeds of the growing residential areasin east, south'and southeast Springfield, and strengthen the metropolitan area's position as a premier locale for healthcare services, consistent with this policy objective. 5-86 Page 6 Zone Change Application PeaceHealth'Gregon Region March 15, 2007 6. Environmental Design'Element policies E.l In' order to promote the greatest possible degree of diversity, a broad variety of commercial, residential, andrecreationallalld uses ~hall be ellcouraged 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 occuron 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-supportive land use patterns and development, including higher intensity, transit-oriented development alon.g major transit corridors alld near transit stations; medium- and hig~-derisity residential development with ill one-quarter mile of transit stations, major transit corridors, employment Clillters,and dowlltown areas; and development alld redevelopment in desiglH'ded areas that are or could be . well served' by e.~isting ~r planned transit The proposal will enable land use patterns and development consistent with the above policy. Approval ofthe requested zone change (and concurrent redesignation) will allow for higher intensity development along Main Street, a major transit c9rridor. An existing L TD stop is located on the frontage ofTax Lot 400 (see photo, pg, 2, Appendix Aof the TlA),- and will provide convenient access to existing and projectecl employment on the subject site, as well as' accessJor patients to future out-patient medical facilities projected on Tax Lot 400," ' Transportation'System Improyements: Roadways policies . F.15 iYIotor vehicle level of service policy: a. Use motor vehicle level ofservice.stalldards'(o maintain acceptable and reliable performance on tzle roadway system. These standards shall be used for: (1) Identifying capacity deficiellcies on the roadway system. (2) Evaluating the impacts on roadways of amendments to trallspoi.trition plalls, ackno,vledged comprehensive plans and 5,-87 Page 7 ZDne Ch;nge,ApplicatiDn PcaceHealth Oregan Region. Marc!' 1. 5 2007 land-use regulations, pursuant to the TPR (OAR 660-012- 0060). (3) Evaluating development applications for consistency with the land-use regulations of the applicable local government jurisdiction. 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 standardsfrom the OHrshall be applied on state facilities in the Eugene-Springfield metropolitan area. . In some cases, the level of service may be substandard. The local govemmentjtIrisdiction 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'arisejrom severe constraints, including but not limited to environmental conditions, lack of public agency financial resources, orland use constraint factors. It is not the intent ofTSI Raodway Policy #2: Motor Vehicle Level of Service to require deferral of development in such cases.. The intent is to defer motor vehicle capacity increasing transportatiim: improvements u(!lil existing constraints can be overcome or d~VelOPllfl alternative mix of strategies (such as: land use measures, TDlvf, short-term safety improvements) to address the problem. Subsection a.(2) in the above policy requires an evaluation'ofthe proposal pursuant to the state Transportation Planning Rule (TPR), The accompanying Trafflc 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, nor does it 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 also does not: . . Result in types or levels of traffIC or access that are incoDsistent with the functional classification of Main Street or any other nearby roadway; . Reduce performance of traffic pn Main Street or other affected intersections to a level that is below acceptable established performance standards; or 5-88 ,page 8 Zone Change Application PeaceHealth Bregon Region March 15 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 , . , . zomng. Additional TPR fmdings are further located in the TlA, see pp. 31-32. Because the proposal does not result in a "significant effect" as established .by applicable OARs, no further TPR analysis is required, The request is therefore consistent with the above policy. 8. Public Facilities and Service Element Policies G.1 Extend the minimum level andfl.lll,r{lnge of key urban facilities alld services in all orderly and efficient mallne~ consistent with the growth management policies 'in Chapter 11-13" relevant policies in this chapter and other M etfo Plan policies. . The subject property is located in Springfield's city limits.UGB, All ~ecessary infrastructure and key urban facilities/services are present to serve existing development (Tax Lot 402) or are available to serve future infill development on Tk Lot '400, . Therefore, the proposal is consistent with the above policy, 9. Parks and Recreation Facilities El,ment 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 oftheMetw Plan are not relevant to the requested zone change. 11. Energy Element policies policies in this element of the Metro' Plan are not relevant to the requested zone change. . . ' . l , ' 5-89 , Page 9 Zone Change~pplication PeaceHealth Oregon Region March 15, 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. MLxed-Use Element Policy 2) Area #2 A) The following land uses are allowed under Community Commercial r,onLng: All Communitv Commercia! lIses subject to Article 18 of the Springfield Development Code." The proposal requests rezoning the subject properties from LMI to .Community 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 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 Commercial Refine17lel1't Plan Desif!l1atiol1. . . 1. Generally, the Commil11ity Commercial refine/lIent plan designation shall be applied u/lder the following circu-'nstalIces: ' . . . " .....,-... .", ,'- ", . . . A) .vhere it is not an intnlsio/l ilI/O ;';eLl_maii,tained residelIlial fleighborhoods; . . The area proposed for rezoning does not intrude iht6 the existing residential area west of the subject site along 44th Street, and is therefore consistent with the . above criterion, B) where it does /lot i/lcrease conflict between Low,Density Residential and Commercial; Although the abutting residential area is zoned JVledium Density Residential, it is developed 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 inflll 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. 5-90 Page 10 Zone Change Application PeaceHealth Oregon Region. March 15 2007 ' C) where criteria for ddig'nating tvIedium Density Residential land does not apply; .. ' . Criteria for designating MDR land does notapplyto the subject site. . f ." Tax Lot 402 has existing, long,standing comnierciaiuses that were legally created . ,- \ . pnor to development ofthe Metro Plan or ElvlRP;. Tax Lot 400 has had ~ variety of commercial services located on-site over the years. " D) where legally createdcommercial uses exist;' E) where'adequate customer and sen'ice access to an arterial .street can be provid~d; .-. ~,:4 I I , I ! i - '." The subject site has adequate legal access onto Main Street, which isdassified as an arterial street. F) where designated Commercia,l on the Metro Plan Diagram. I: .. Approval oftheconcur'rently submitted Plan 'diagram amendment application would result in' a Commercial designation on the:Metro Plan diagram, which would also automatically modify the designation on the EMRP diagram. " Policy 2) Apply site-specijic Commercial refinement plan designations to clearly defin,e the limits oJllew C0l1111Jercial-ldes where there is not an existing, legally establisher!, and beneficial mb:ing oj tiSes. Appro'val of the concurrently requested redesigrption would.apply commercial plan designations to the subjec! properties, allowing the existing, legally established commercial uses on Tax Lot 402 to cbntinue,' It wbuld also enable commercial uses to be established on Ta;, Lot 400, thereby defining the limits of new commer'cial uses between the pre-existing commercial uses on Tax Lot 4Q2 arid others to the w,est, 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 calledfor 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 nllmber oJvehicular access points a!,d require the. rebuilding oj curbs and inSlallatioll oj sidewalks and street trees along lYIain Street, through the Sire Plan Review process and in public improyement projects. 5-91 Page 11 Zone Chonge_Application PeoceHeolthOreg;n Region Marc" 15 -:007 The proposal would result in reducing the numberofexisting 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 o~ 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 ~nd residential rIses through Article 31 of the Springfield Deve,loj)/nent Code, Site Plan Review process. Existing residential uses along the east side of 44th Street have had no real buffer from pre-existing indus"trial 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 betweer the future use and ex.isting residential area to the west _ as required by Code, and consistent whh the above policy, 3. Industrial Element Policy 1) The City shall encourage efforts of va' ria US agencies to attract new alid retain e..-dsting jobs and businesses. Imolemelltatiol; The, City shall main'tain a current inventory-of vacant commercial and industrial land and stri/ctures within the East Main area. ' . . ", . .,. . Consistent with the above policy, approval ofthe~equested,tone change a~d . redesignation will enable existing, long-standing jobs and businesses on Tax. Lot 402 to remain as legal, confonning land'uses, and allow future dev,elopment of new employment on Ta:< Lot 400 with higher th~n average wages and emp'loyinent densities tnan the current designation and zoning allows, . ' 5-92 Page 12 Zone Change Application PeaceHealtlt Qregon Region. Ma'e" 1.5 ZQ07 4.3 Provision of Adequate Public Facilities The subject properties were annexed into the Springfteld corporate limits in 1960, and therefore are provided with City police, fIre, and other government services. Other basic infrastructure is in place to serve existing development on Tax Lot 402 and any future development on Tax Lot 400. Speciftcally, 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 andlor future development Of) the subject site. Tr'ansportation services are also readily available to serve existing and future development, as Main Street is fully improved with curb, gutter, etc> ' . " As indicated in the rrafflclmpact Allalysis accompanying the concurr.ently SUbmitted zone change and Metro Plan diagram amendment; approval ofthe proposaLwould not result in a "signifIcant effect" to the transportatiol) sY1tem, and therefore is consistent with the state Transportation Planning Rule. The TiA further demonstrates that existing and future development under the proposed zone change has safe, and efficient access and circulation for vehicles, and also will beneftt from the sidewalks, bike lan~s, and transit service existing on Main Street. '. Therefore, the proposed zone change complies with the requirement for having adequate public facilities and services to serve development, as established in SDC 12.030 (3).' .' 4.4 Consistency with Approval Criteria inSDC Article.7 The proposed zone change is submitted concurrently with anapplica\ion to amend the :. . Metro Plan diagram. The following ftndings are contained in the Plan diagram amendment application, and also demonstrate that this proposal complies with Metro Plan policies as requiredihSDC 7.070 (3) and with zone ~hange approval criteria in SDC 12.030. Both the ftndings below relative to Goal 12 and those above pursuant to Metro' Plan Transportation Elementpolicies address consistency with the state TPR, as called furinSDCI2.000. . . . It should also be noted that approval of a Metro Plan diagram amendment also correspondingly changes the applicabl~ reftnefl!ent plan (East MaintRefinementPlan) diagram, as established in SDC 7.110 (4). . " . ." Goall- Citizen Involvement . . Goal 1 addresses the need to develop a citizen involvement progrum to' ensure citizen involvement in all phases of the land use plann;llg 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 Page 13 Zone Change.}..pplication PeaceHeai'th Oregon Region March 15 2007 . opporturtities to be involved in the procedure, the proposed plan and zone map amendments are consistent with Goal 1. G0;112 - Land Use Planning' Goal 2 requires that lo.cal c'omprehensive plans be consistent withJhe 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 . adequatefactual 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 Lime.County so tliey 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 iri advance to the state Department of Land Conservation and Development, ensuring that they are gIven opportunity for comment and review yonfonnity 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. " .., .' , Goal3 - Aoricultural Lands o . . This goal is inapplicable because as provided in OAR 660-15-QOO(3), Goal 3 applies only to rural agricultural lands. The subject properties are located v;iithin an acknowledged" urban growth boundary, are inside Springfield's corporate limits, and have not been in agricultural use for decades. . . Goa14 - Forest Lands Goal 4 does not apply within urban growth boundaries, per OAR 660-.06-0020, arid the areas affected by the Plan amendments are inside Springfteld's acknowledged UGB. 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, 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; 5-94 Page 14 Zone Change Application PeaceHea1t1:i Oregon Region March 15,2007 " (4) examine the econofI)ic, social, 'environmental, and energy (ESEE) consequences that ,could result from allowi,ng, limiting, or prohibiting the conflicting uses; and " (5) develop programs to resolve the conflicts. . The subject properties are not on Springfield's acknowledged Metro Plan Goal"S 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 loventory and Springfield Local Wetland loven'tory lnapshave been , consulted and there are no jurisdictional wetlands located on the site. Therefore, the . ' . I proposal does not alter the City's compliance with Goal 5. .' OJ ,;. Goal 6 -Air, Water, and :Cand Resources Quality The purpose of Goal 6 is "to maintain and improve the quality of t~~ air, water and'land resources of the state. Generally, Goal 6 requires that development comply with applicable state and federal air and water quaJity standards. In the context of the proposed Metro Plan diagram amendment and zone change, 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 aI\Y state or local environmental clean-up list. A P.hase 1 environmental 'assessment on the subject property,was conducted'and,recommended' additional analysis. Up~n recommendations through the Phase 2'environmental assessment a nominal quantity of soil (less than 10 cy) impacted by earlierlhistoric use wasremoved from the site' and properly,disposed. Given the nominal impaCt generated by historic uses on the site,it is reasonabie to conclude that future development on the site will be able to demonstrate compliance wi\hCity standards for \vater quality protection through the site plan review process, thereby complying with applicable state and federal environmental quality standards. " ,Goal7 -: Arens Subject to Nntural Hazards Goal 7 requires that development subject to damage from natural hazards and disasters be planned and/or constructed with appropriate safeguards and mitigation. The goal also requires that plans be based on an inventory of known areas ofnat1,lral 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. Therefor~, approval of the proposal will not alter the City's ackno,yledged compliance with Goal7 through its adopted plans, codes and ,procedures. 5-95 Zone Change!'-pplication PeaceHealth Oregon Region . March 15 2007 Page 15 GoalS - Recreational Ne~ds Goal 8 requires local governments to plan and provide 'for the 'siting of necessary recreational facilities to "satisfy the recreational needs ofthe citizens of the state and visitors," and where appropriate, provide forthe siting of recreational 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 conununity's recreational facilities or needs; therefore, the proposal does not implicate Goal S. , Goal 9 - Economic Development , .' Goal 9 requires the city to provide adequate opportunities for a variety of economic activities vital tothe health, welfare, and prosperity of the citizens. The proposed amendment to the Metro Plan diagram will increase tl'1e city's capacity for economic development by adding 5' acres of CC designatedlzonea land in place of the existing industrial designation and zoning. Permitting the constructio.n of future clinic facilities on Tax Lot 400 and'allo\ving long-standing 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 Springfteld Commercial Lands Study (SCLS) .' , Specifically: the following SCLS policies are applicable to the proposal: Policy I-A: "Maintain a mixed supply oflarge and sm~ll commercial sites through strategies such as rezoning or annexation to serve Springfteld's future population." ' , . The proposal fulfills this policy objective by rezonil1g (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 Tax' Lot 4()2 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 servi~es." The.SCLS (see Table 3-8, pg. 32) found there to be a deftcit of 158 acres in the supply of commercial.land over demand projected through the year 2015. The proposal would. allow for redesignotion and rezoning of five acres .thereby reducing the deficit of comrnercialland. 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 Springfteld's growing community. The SCLS also noted (pp. 27-29) state and local 5-96 Page 16' Zone Change Application PeaceHealth'Oregon Region March 15 2007 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 SCLS (pg. 36) cited the acknowledged 1992 Industrial Land Study as demonstrating that "a surplus of industrial sites exists in the Metro Area." Therefore, the proposed redesignation (and corresponding rezoning) would' not resul6n a deficit of needed industrially designated and zoned land"but it" would help reduce the commercial lands deftcit id~ntified in the SCLS. Therefore, approving the proposal would be consistent with SLCS Implementation Strategy 3-A (1): "Evaluate inventoriesbased on demonstrated need for the planning period. Initiate rezoning or redesiSnation of surplus land uses where more appropriate for commercial, consistent with.the ;Metro Plan." The proposal in fact consistent with inventories for commercial and if)dustriallands adopted by the City Council and acknowledged by DLCD as being copsistent with Goal 9. Oregon Administrative Rules concerning Goal 9 implementation (OAR 660-009- 001 0(4)) call for amendments to land usedesign~tions "in excess of tfo 'acres within an ex.isting urban growth boundary from an indu.strialland u'se designation to ? non, ' irdustrial use designation" to have to address applicable planning requirements- such as consistency w;th the Metro Plan and other local plan policies (i.e., SCLS) or be consistent with an economic opportunities analysis. The City can ftnd 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 ex.isting and long-standing comm~rcial center to continue to operate and provide employment opportunities, while also allowing higher-value employment associated with future development on Tax Lot 400. These types of employment-generating uses are among those identified in OAR 660-009-0005(6) as eligible non-industrial employmehtactivities that can justify aRproval of the prop'osed Plan diagram amendm~nt without the need for an economic opportunities analysis apart from the SCLS, which DLCD acknowledged as fulfilling the City's obligations under doal9, Because the requested redesignqtion and zone change implements SC.LS policies and does not result in a defIciency of needed industrial'lands, and is otherwise d.emonstrated to be consistent with relevant Metro Plan policies, approval.of the ptoposal'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 redesignation for Tax Lot 400 would enable redevelopment of an industrial site abutting ex.~sting residential development. Through 5-97 Zone Chang~, Application PeaceHealth,Oregon Region March 1 5 2007 'Page 17 the site plan review process, fu.tun~ development on that property can provide a superior buffer and a hig.l-ter use that will beneftt the adjoining residential properties. Because the proposal does not involve directly any change in the amount of residentially designated or zoned land, it does not affect Springfteld's continued compliance with Goal 10. Goulll- Public Facilities und Services This goal requires the provision of a timely, orderly and efficient aITangement of public facilities and services. The subject property is located within the Springfteld UGB and city limits, and is already designated for urban levels of use. The proposed amendment to the PI~n map designations and zone map classifications from LMI to CC will not affect the ability to provide needed serVices since all the required urban services are available to support existing or future commercial uses on the su~J ect site. Gaul 12 - Trunsportation ' Goal 12 requires local governments to provide and encourage a safe, convenient and economical transportation system. The proposed map amendments and zone change involve approximately 5.24 acres of prop~rty, 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 al10\v 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, afidisassumed to retain its current access points off Main Street. It is further assumed that future development on Tax Lot 400 will result in some acce'ss 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 11>\ demonstrates that these access points will not result in any degradation, of mobility st~ndards below acceptable levels, and that safe and efficient circulation can be realized through approval of the requested land use redesignation andione 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 T1A, is consistent with the requirements of the TPR and with applicable policies in the ENIRP, it is consistent with Goal 12 and applicable local implementing policie~. 5-98 Page 18 Zone Change Application PeaceHealth"l9regbo Region Marco 1) ?007 Goall3 - Energy 'Conserv-ation The Energy goal is a general planning goal and provides limited guidance for site-speciftc 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 doe~ not alter the City's:continued' compliance with Goal 13. Goal 14 - Urbanization Goal 14 requires local jurisdictions to provide for an "orderly and efftcient trartsition 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. . Go'allS _ Willamette River Greenway ", This goal. is inapplicable because the subject property is not within theboundaries of the Willamette River Greenway. Goals 16-19 - Coastal Goals The coastal goalS are not applicable to this application. " ". '" 5-99 SPRINCFID..D Staff Respo~se to written comments to Applications ZON 2007-00012 / LRP2007-00013 'EXECUTIVE SUMMARY: Staff received one written testimony from Lauri Segel, Goal One Coalition Planner. on June 12th, 2007. A written rebuttal to Ms. Segel's letter was then submitted by the applicant the following day, June 13th, 2007. Both letters were received within the specifted deadlines as noted in the Planning Commission public hearing on June 5th, 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 for reference and review in addition to the excerpts and Staff responses in this report. Ms. Se~el's Submittal - Issue #1.: "Applicant Relies heavpy on the acknowledged 2000 Springfield Commercial Lands Study (SeLS). which does not address the entire Metro UGB area, and is not a refinement plan of the Metro Plan... The proposed findings rely on reports and other documents containing inventories. assumptions. and data that have not been establishedfor the entire Metro UGB area. but rather only for the Springfield portion of the UGB area... " Aoolicant's Rebuttal:. "The cities of Eugene and Springfield have separately adopted and acknowledged commerciallands studies fulfilling the requirements of Goal 9. As such. the SeLS serves as the City of Springfield's "most recent economic opportunities analysis. .. as Ms. Segal notes above by her own admission... There is no requirement that'the Applicant or the City perform a metro-wide anal.vsis of commercial lands in order to adoptfindings satisfying compliance with Metro Plan policies and Goal 9... " 5T AFF RESPONSE: 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 (P AP A) 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 reviewed by DLCD and found to be consistent with the Periodic Review Order and Statewide Planning Goals. .r The SCLS was not adopted as a speciftc amendment to the Metro Plan. The City undertook a supply and demand analysis to determine if there was adequate comrnercial land in the adopted inventory to accommodate projected demand and, based on these conclusions, 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 orTransPlan; are a recommendation to amend the Code; or are suggestions to improve business practices. The City and DLCD concluded 5-100 ,it was not.necessary to adopt the SCLS as an amendment to the Metro Plan because all recommendations regarding inventory adjustments contained in the Study could be implemented through the PAP A process as increases in the commercial lands inventory; the SCLS would be used at that time as part of the ftndings, reasons and conclusions for those PAPA actions. Best availabledata was used in the analysis ofthese applications, which included the SCLS. There are no comprehensive studies (i.e. commercial lands inventory) available for the entire UGB related to commercial lands within one speciftc time period. Rather there is a conglom'eration of various studies thature reviewed. For example, the 1992 ' Industrial Lands study is UGB-wide. The Residential.Lands Inventory which is used by the City is not UGB-ivide. Likewise, the SCLS is not Metro-wide. I' Ms. S'egel's Submittal-Issli'e #2:. "The ad@pted Springfield Natural Resource Stlldy (adopted by Ordinance #6150) shows little or no impa'ct on the commercial lands inventOlY from Goal protection measures, and pro"ide,liitle if any analyses of land availability within the entire Metr~ UGB area, rather than just the Springfield UGB area. The analysis shows an impact of 11.56 acres on' Springfield's (not the urban growth boundary area in its entirety)... The referenced studies / analyses referenced by the applicant do 'not take into account the 100'acres of new commercial land designated / rezoned to commercial in the Gateway area. .. " i Aoolicant's Rebuttal:. "Considering that the SCLS identified a deficit 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 ihan 61 acres of needed commercial land. Approving the requested Plan amendment/zone change would still leave a deficit of appro;ciriwtely 55 acres of needed commercial land... Therefore. even considering impacts to commercial lands invenroriesfrom other adopted and acknowledged plans (i.e. the City's plan for Goal 5 compliance) and ackno.;vledged Plan amendments /zone changes, approval of the proposal will notiesult 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 / reconing." ' '. STAFF R:F:,SPONSE:. The Springfield Natural Resource Study (S,NRS) is referenced by the applicant and staff as related to this PAPA because it provides a more updated view of the city's comniercial & irtdustriallands inventory. It is not meimt to be all inclusive in and of itself. .Reference to the SNRS in conjunction with other referenced documents (i.e, the SCLS & 1992 Industrial Lands Study) is provided to give the most accurate information possible given all the available data at this time. ' Again, the applicant's report and staffs analysis reference the mqst recently adopted documents / inventories available, The City currently does not have an ongoing database 5-101 . that keeps track of inventories based upon Plan Amendments andlor Zoning Map Amendments on an ongoing basis. The applicant's rebuttal references numbers of acres related to the City's deficit of commercial land. Staff concurs with the applicant's rebuttal related to number of acres of commercial lands. The redesignation and rezoning of up to 99 acres of residential land within the Gateway MDR site (as referenced by Ms. Segel) still does not negate the deficit of corpmercialland within Springfteld's city limits. Ms. Se~el's Submittal - Issue #3: "The applicant has not justified the conversion of scarce, shovel ready industrial land, especially land designated a~d zoned light medium industrial inside the Metro UGB. even though the Metro,Plan (comprehensive plan) Economic Element policy #12 establishes that the cities are to 'disCourageji,wre Metropolitan Area General Plan amendments that would change development ready industrial lands (sites definedas short-term in the metropolitan Industrial Lands Special Study, I991).to non-industrial designations. . The applicant and stafffindings do not address how the loss of these 5.24 acres impacts the short-term sllpply of LMI designated land... H Auolicanl's Rebuttal: "Ms. .Segel's citation of Economic Element Policy 12 ignores the fact thaI the subjecI site was not included among the sites "defined as short-term in the metropolitan industl-ial Lands Special Study, 1991). "...casting doubt on the applicability of Metro Plan Economic Element Policy 12... Even if Policy 12 were relevant, it's language is clearly not prohibitive to approval of an application for redesignation/rezoning of an industrial site, particularly when considering it in the context of industrial commercial land inventories. ...even if all of the acreage redesignated in Springfield were from the LMI designation,- which is no.doubt not the case -there would still be a surplt1s of nearly 50 acres of LMI designated land even after approval of the requested Plan amendment. This does nolaccounl 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 of LMI zoned and designated land wilinol result in a deficit of needei land in that industrial designation. ...Moreover. although Economic Element Policy 12 "discourages" Plan amendments for cerlain industrial lands. there are countervailing policies in the idetro Plan (i,e.. Economic Element Policy 6) and SeLS (i.e., policies ]-A and ]- e; that are directive to providing an adequate supply of needed commercial lands,.. " STAFF ~J<:SPONSE: 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 propos:!!. As noted by the applicant, the subject site was not includedamong the sitesdefmed as short-term in the metropolitan Industrial Lands Special Study, 1991. As noted in the applicant's rebuttal and as previously noted in this report and the original Staff Report, a deftcit of commercial land and surplus of industrial land will still exist 5-102 , even after an approval of the proposed Plan Amendment and concurrent Zoning Map Amendment. ' Ms. Ser!el's Submittal - Issue #4: ";The,Applicant's analys'is oftheproposals; consistency with comprehensive plan Economic Elel11;ent policiesfound in the Metropolitan Genera/Plan, Chapter Ill. B-] - B-7 is insufficient and do~s not address the most significant policies that "!ust be considered:" Aoolicant's Rebuttal:, "...there are countervailing policies in the Metro Plan (i.e.. Economic ElementPolicy 6) and SCLS (i.e" policies 1,1 and I-C) that are directive to providing an ,adequate supply of needed commerciallan1s. The Metro Plan recognizes such conflicts: "The respective jurisdictions recognize that.there are apparent conflicts and inconsistenc'ies'beiWeen and among some goals, objectives, and policies. When maA.-ingdecisions based on the Plan, not all the goals. objectives. and policies can be m~t to the same degre,e in evelyinstance. Use of the Plan requires a 'balancing: of its various components on a case-by- case basis, as well as a.selection of those goals, objectives, and policies most pertinent to the issue at hand. " (pg. 1-4, Meti.o Plan)... 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 thd2 lyletro Plan Economic Element policies are relevant to the proposal. Many are:aspirational in nature and not directive 10 a specific quasi-judicial application... . ,ST AFF RESPONSE: AS noted in the applicant's rebuttal, policies in the'Metro Plan are sometimes conflicting to one another. As stated on page ]-4 of the Metro Plan, "The respective jurisdictions recognize that there ate apparent conl1icts and inconsistencies between and ,among some goals, objectives, and' policies. When making decisions based on the Plan, not all the goals, obj~ctives, imd policies can be met to the same degree in every instance. Use of the Plan requir.es a 'balancing' of its various components on a case~by-case basis, 'as, well as a selection oftl1~se goals, objectives, and policies most pertinent to the issue at hand." The applicant submitted written statements rel'ative 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 concurrentlv with the referenced comr,nercial and,industrial adopted inventories. Ms. Se2el's Submittal - ]ssue #5:. 'The 'applicant is not specific, about what uses wilfbe cited should the proposal be approve.d, and.rhere i~ no way to know if in fact above wagejobs and salaries... there is no wayto,escablis'h if the applicant , will infact utilize local and imporied,capital. skills etc. as no commitment to a use has been escabiished... " . .1 '. .' ,; Aoolicant's Rebuttal:" ...Ms.' Segel'sasserliol1 that the ~pplication was unspecific as to Ihefulllre uses on Tax Lol 400 is inaccurate, The application nan-alive clearly stares Ihe inrended purpose of the redesignarion/re:oning is to 5-103 >. allow for afuwre medical clinic on Tax Lot 400 and 10 allow the 10ng-standinC7 ,. no .'~ commercial operations on Tax Lot 402 to continue (pg. 2, pg, 4-2 in che Commission's June 4 hearing packet). Such clinical uses are not permitted in any industrial zoning distcict. thtlS ptomopting the need to"rezone (and Redesignate) Tax lot 400 to allow a medica/clinic. A verage wages and benefits for medical , workers tends to be higher than average local wages. and further substantiating data can be entered into the record ilt the City Council level... ' ST AFF R:Fc5DONSE: The applicant has nqted the intent Of thePlan AmendTI)ent and . concurrent zone change is forthe eventual development of a medical office building. This is mentioned not only in the apIJlicant's narrative, but also in the applicant's Traffic Impact ATIalysis.ln fact, therefer~nced table in the TlA(Table 7, pg. 19) specifically calculate~ trip generation for !he Droqosed medical offtce building. Hay/ever, as noted by Ms. Segel, there is no certainty as to what the salaries will be, if it will utilize local '- .". .' capital, etc. With that said, there is no such assurance .for any new use that might go on th"e 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 h<\ve indicated on' their application that the purpose ofthese applications is to develop a future medical office clinic, it is highly likely (in Staff's opinionj that they will pursue the medica] office use as they've specifted. As noted in the . applicant's rebuttal,average wages and beneftts for medical workers tends to be higher than average local wages. Staffconcurs with the applicant's rebuttal statement and ,affirms the original Staff Report ftndingsindicating that the proposal is in compliance with applicable Metro Plan policies. , Ms. Se~el's Submittal -Issue #6:, "The appl,icant makes the argumentthaUhe , proposed plan amendment and zone change would have the effect of correc(ing existing non-conforming, uses on TL #402. (map J 7-02-32); however, the 2000 SCLc.titAppehdix C, "Sites with Plan/Zone Conflicts" does not include the. subjecrproperty. It appears that the existi~g 'nonconforming ,Llses were actually established )j'TER adoption of the 2000 SeLS. indicating,that che existing uses were acwally permitted by' the City with the knowledge that these uses woule( create plan/zon-e conflicts." . Ano\icant's Rebuttal:, "The applicant does nor'allege that there is a Plall/tone conflict on Tax Lot 402; clearly the existing Plandesigllations and zOlling are LivIl. Rather: the point made in our application narrative is that commercial Llses . have existedfor decades, pre-existing the establishment of the Metro Plan and the application of the U,;f] desigllation on the subject properties. Ms. Segel provides no evidence to back up her accusaiion 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 July 2 which willfiirther demon~tratefaclL<ally that'commercial uses , and employment have"been in the building on Tax Lot 402 for nearly 50 years... .. .' . 5-104, ....:. STAFF RESPONSE: The existin~ zonin" for TL #402 is Li~ht Medium Industrial (LMI), The existing Plan Designation for TL #402 is Light Medium.lndustrial (LMI). Therefore, there is no Plan/zone conflict as allege~ by Ms. Segel. Anon-conforming use' is not the same as a plan/zone conflict. Ms. Segel alleges that the City permitted the existing uses on TL #402 "AfTER adoption of the 2000 SCLS..." and further states that the uses were "...permitted by the City with the knowledge that these uses would create plan/zone conflicts." This 'allegation has not merit for multiple reasons. Article 5 of the' Springfield Development Code provides provis;ons to allow existing non-conforming. uses to modify or expand based upon speciftc criteria. A "non-conforming use" is a use that was legally created when ftrst 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 SeLS 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 change is not 'logical and ,harmonious' because it is not consistent with the development pattern envisioned in the Metro Plan ... Compliance with statewide planning goals. in eluding goals 2:6,9.10.12 and 13 has not been established. In particular, ii 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... Stajfhasfailed to address the impact that this P/;oposal will have on the dwindling supply of shovel ready industrial land inside the Springfield city limits. in elL/ding prior actions approving land use code amendments 10 the camp;'s industrial zone that established more 'flexibility 'for what uses are allowed in the city's campus industrial zones. " Aoolicant's Rebuttal:. "It shouldjirst be noted that the application does not involve or in any way ajfect the 'metro area.'s supply of campus in'dustrialland. ' Moreover, the applicarion has no ejfect upon Goal 10 (HOI/sing). 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 hearing and requested the writ/en record be left open for a week. both vigorously appose the Plan amendment/zone changeproposedfor the Marcola Meadows project. and are borrowing arguments 10 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 substctnce 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 Elemen!, supporting refinement plans (i. e,. the SCLS and MILS) to the Metro Plan, and Goal 9 and other applicable statewide planning goals ,.. " , STAFF 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 , ". I"., not 'logical and harmonious.. .' is not a criterion of approval for these applications. Staff have reviewed the proposal based\i.pon the applicable criteria of approval, and found thit it meets'the criteria (with conditions) aswntten in theSt'affReport. The inveqtories of commercial and industrial land ~ave been evaluated and balanced with the relevant Metro Plan policies to formulate the recommendation for approval with conditions. Speciftc 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 IlwoIvement City of Springfield Planrung Commission David Reesor City of Springfield . 225 Fifth Street Springfield, OR 97444 June \2,2007 , '1::;'l'~..4"""r":::;,l'- 7-'..:0--", ~.. '_':'-' ~.:... it ~". H ~ ') ", - ,'_'2-J JUN 12 2007 B,['j-'l:.. RE: ZON 2007-ll00121LRP2007-ll0013, Plan Amendment & Zone Chanoe o Dear Members of the Commission: .The Goal One Coalition (Goal One) is a nonprofit 6r'gani~ation whose mission is to provide assistance, and, support to Oregonians in matters affecting their communities. Goal One is participating in these prciceedillgs at the request of'and on behalf of its membership residing in Lane County. This testimOl\Y is presented on behalf of Goal One' and its membership, including Nancy Falk, 2567 Marcola Road, Springfield Oregon 97477, as an individual. , l.lntroduction This proposal is for a site-specific Metro Plan Amendment I Refinement Plan Amendment and a concurrent Zoning Map Amendment from Light Medium Industria! (LMl) .to Community Commercial (CC) within the Springfield city limi'ts. " . The subjectsite is located near 44th and Main Street (Highway 126). The site consists of two p,arcels under separate ownerships, and is locate,d on approximately ?.24 acres identified as Tax Lots 400 and 402 on Assessor's Map No. 17-02-32~00. TL 400 (5.01 acres) has several vacant buildings on site, including portable trailer type stroctures. 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 LMl. Properties located to the north (Weyerhauser) are zoned _. and designated heavy industrial. Parcels located west of the subject site are designated mixed- use on the East Main Refinement Plan. property located eaSt and adjacent to TL #402 is built , out as a business park, and designated LML Properties 19cated south of the subject site, across Main Street, are zoned and designated CommunitY commerciaL. 11. Criteria applicable to the request" Loc,al approval criteria are found in the follO:win'g documents: Springfteld Development Code, ' Metro General Plan, and East t-,'laih Refmement 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 Goal 1, Citizen Involvement, Goal 2, Land Use Planning; Goal 9, Economy of the State; and Goil.'! 12, Transportation. The Eugene office: 642 Charnelcon 5ui'" 1.00 . Eugene 01\ 9740 I . 541-431-7059 . Fax 541-431.7078 Lebanon office: 39625 Almen Drive' Lebanon 01\ 97355 " 541-258-6074 . Fax 541-258-68 I 0 WV'I"'N,goall.org 5-107 GOAL ONE COAUTION proposed plan amendment, must also comply with administratlve rules implementing . applicable statewide planning goals. Ill. Analysis COMPRF;H.~N5IVE PLAN CONSISTENCY AN!) COMPLIANCE W1TH. STATE'vV1DE 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. JacksO/lCOLLnty, 79 Or App 93, 97,718 P2d 753 (1986), rev den 301 Or 445 (1987); Opus Development Corp. v. City of Eugene. 141 Or App 249, 254, 918 P2d 116 (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 related to use of land and to assure an adequate factual base for decisi~ns and actions." Specifi~ally, local land use actions "shall be consistent 'with the comprehensive plans." Goal 2, Part I. ' Furtj1er, theinfotmation upon which land use decisions are made "shall be contained in the plah documerit or supporting documents." Goal I, Part 1. .' m this case, the applicant relies heavily on the acknowledged 2000 Springfield Commercia] Lands Study (SCLS), which does not address the entire Metro UGB area, and is not a refin~erit plan of the Metro Plan. It is the 1992 Metropolitan Industrial Lands Study, that does address the entire Metro UGB area, is part of the Metro Plan, and is reflected in the Economic Element of the Plan. ,The 'proposedfindings rely' on reports and other documents containing 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 materia] includes data used to jwtify. tindingsof compliance with goal 9. Any decision relying on such findings would not comply with Goal2, GoalS Co~ceming applicability of lal1dinventories pursuant to Ordinance #6150 that adopted the Springfteld 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 amilyses of land availability within the entire Metro UGB area, rather, than just the Springfield UGB area. Table 1 \-2, ADalysis of Maximum possible Impact on Supply of Commercial Lands within the Springfteld Urban Growth Boundary shows an impact of 11.56 acres on Springfield's (not the urban growth boundary area in it's entirety) commercial land supply. Metro Plan/East Main Refinement Plan, ZON 2007-00012 - LRP 2007.00013." 5-108 .' .. 2 GOAL ONE COALITION Additionally, the analysis pursuant to Ordinance #MSO"fails to account for lands ADDED TO the commercial inventory since 2000, including but not limited to the qateway MDR'site's '100 acres, providing a skewed pictl.\fe of the actual commercial land inventory. " To skew the picture even further, the analysis of maximum possible ,impact from Goal S protection m'easures onsupply of industrial lands (Ordinance #61S0, table 11-1) considers ALL industrial lands within the entire Metro UGB area, rather than just the Springfield portion ' of the UGB, and does not provide a breakdown of number of industrially zoned acres in Springfield vs. Eugene. The 2000 SC).-S, however (Table 3-2) shows that the number oflight medium industrial (LMl). acres by plan designation in the Springfield'UGB' area is. 198.77, while the number of LMl acres within the Eugene UGB is shown ,to be 1230.78. The applicant fails to establish the relevancy of these tables to the current PAPA and zone change proposal, considering that oiUy about 16% of the Metro area ugb industrial land supply is within the Springfield city limits. . .".-. :o::t'=',..: Goal 9 _ Economic Development is: "To provide adequate opportunities throughout the 'state for a variety of economic activities vital to the health, welfare; fudprosperity of Oregon's citizens.": The Staff Report's Goal 9 findings are based upon the 1992 Industrial 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 Plannlng'establishes that city, county, state and federal agency and special district plans and actions related to land use shall be ~onsistent with the 'comprehensi ve plans of cities and counties and regional plans adopted ,!lnder ORS Chapter US. ' ' - Goal 9':' 660-009-0010 (4)-establishes that for a post_acknowledgement plan amendment under OAR chapter 660; division 18, that changes the plan de?ignation oflandin excess of two' acres within an existing urban growth boundary from an industrial use designation - ' ' to a non-industrial use designatiOn, or an other employment use desigf!ation to any other use designation, a.city-or county must address all applicable planning requirements, and: (emphasis added) (3) Demonstrate that the proposed amendment is consistent with its most recent economic opportUnities analysis a!ldJemph~sis added) the parts of its acknow1'edged comprehensive plan which address the requirements of this divisiOn;' The applicant appears to rely heavily on inventory and policy statements established by the 2000SCLS in.establishing thatthe 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 GeI}eral Plan, Chapter 111, B-l- B-7 is insufficient and does not addresS the most significant policies that must be considered. The proposal' would decrease the City's campus industrial land inventory by yet another 5.24 acres, The applicant has not justified the conversion of scarce, sh?vel ready industrial land, Metro Plan/East Nlain P,efw,ement Plan. ZON 2007-00012 - LRP 2007-00013 5-109 1 3 GOAL ONE COAUTlON espec;iaily land designated and zoned light medium industrial inside the Metro UGB, even ,though Metro Plan (comprehensive plan) Economic Element policy 1/ 12 establishes that the 'cities are to "discow-age future Metropolitan Area General Plan amendments that would change development ready industiiallands (sites defined as short - term in the metropolitan Industrial Lands Special Study, 1991) to non-industrial designations." The applicant and staff ftndings do not address how the loss of these 5.24 acres impacts the short-term supply ofLMI designated land. . , ~ The applicant makes the argument that the proposed plan amendment and zone change would have the effect of correcting existing non-conforming uses on TL #402. (rriap 17-02-32); however, the 2000 SCLC, at Appendix C, "Sites with Plan/Zone Conflicts" does not include the subject property. [t,appears that the existing nonconforming uses were actually established AFTER adoption 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. In :addressing applicability of the Springfield Comrilercial Lands Study (2000 SCLS), the applicant appears to try to separate the Metro Area by jurisdictional boundary. However, Eugene and Springfield have a shared and adopted UGB, Comprehensive Plan, and Industrial Lands study. The jurisdictionally focused SCLSdoes not analyze supply and 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) the 'most recent economic opportunities analysis (i.e. the 2000 SCLS) and the comprehensive plan. . ' A related problem with placing .such heavy reliance on the 2000 SCLS to establish Goal 9 compliance is that in analyzing supply and demand, the study fails to consider or.otherwise , account for lands added to the commercial inventory ,via applicant initiated and city approved zone changes and plan amendments. One very obvious example of an addition. to the . Springfteld 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 effect of rezoning and redesignating I 00 aCr~ of residential land to commercial. 'The applicant provides a spreadsheet (their Attachment B) that supposedly accounts for all Metro Plan diagram changes. affecting the supply of residential, commercial and industrial Lands in the city of Springfield between199 1 and the present, but has 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 commerciallnnd 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 accounting for additions to and subtractions from the .various land inventories.. TJ:le appl(cant also relies in part on inventories established in conjunction with adoption of Springfield's Natw'al Resource (NR) Study, by Ordinance 116150 on November 28, 2005. While those inventories may be relevant to tJ'ljs propo'sal'in that possible 'impacts' resulting from GoalS protection measures were considered for:all zoning classifications, the nnalysis of ma,imum possible impact on supply of commercial lands pursuant to the study is limited to the area within the Springfield portion of the Metro UGB (table 11-2). Again, because Eugen~ and Springfield share a UGl? and a comprehensive plan, an analysis of the entire UGB area is necessary to establish an accurate picture of the supply of commercial lands. . ' . Metro Plan/East M2in Refinement Plan, ZON 2007 .{J0012 - LRP 2007.{J0013 5-110 4 GOAL ONE COAUTION . . In any case, the NR Study found that the ma;<imum possible impact ,of Goal 5 protection, measures on the Springfield Coinmercial Lands Inventory would be the loss of 11.56 "commercial acres." . LOSS OF INDusTRIAL LAND The proposed p'lan amendmerrts and zone change~ would rerriove 5.24':acres of shovel, ready light medium industrial land from the Metro UGB area industrial lands inverrtory. This is in addition to an additional 56 acre conversiorr of campus industrial tocqmmunity 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 oftlie subject properties proposed for p\ah'andzorie changes. Given this fact,- the applicant. has not jUstified the removal of shovel ready lightrriedium industrial land for commercial uses. This area within the. Springfield city limits. is a,lready inundated with commercial zoning and coinmercial uses, and approval of this proposal would contribute even fur-cher to over commercialization within the city of Springfteld'. The applicant cites 4 of the 32 Economic Element policies pursuant to the comprehensive plan (Metro Plan) (Chapter lll, Section B) of the Plan as relevant to the proposed PAPA. The four Plan policies considered by the applicant as relevant to the sUpply of industrial land are policies 1,2,6, and ] J , Policy 1 is to Demorrstrate 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 standard ofliving, and utilization of our existing comparative advantage.in the level of education and skill of the resident labor force. 'However, the applic;mt is not specific about what uses will be cited should the proposal be ap,proved, w,d there is no way to know if in fact above wage jobs'and salaries. " " Policy 2 is to encourage economic development which utilizes local and imported. capital, entrepreneurial skills, and the resident labor force. Again, there is no way to establish if the appliC:JIlt will irr fact utilize local,and imported capital ,skills etc. as no commitment toa use has beerr established. Policy 6 merely states: "Increase the amount of undeveloped land ;oned (emphasis added) for light industrial arrd commerci:J1 uses correlating the effective supply in terms of suitability and availabilirj with the projectiorrs of demand." Tnis policy addresses zoning oruy, not plan design:Jtion, and corrcef!1s the nec~ssity of having adequate supplies of land of both commercial and industrial designatiorrs. It says nothing concemirrg the applicability of favoring one plan designation over the other. lvIelroPlaniEasllvlain P,efinemenl Plan, ZON,2007-00012 - LRP 2007-00013 ~-111 5 GOAL ONE COAUTION -, Policy 11 is to encourage economic activities which strengthen the metropolitan area's position as a regional distribution, trade, health, and service center. The applicant asserts that the amendment (sic) \yill facilitate the development of medical uses that will serve the needs of thegrowing residential areas in east, south and southeast ,Springfteld, and strengthen the metropolitan area's position as a premier locale for hea\thcare se'ryices, 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, and that the applicant already has established their dominance in the health care market within the city limits, it has hard to fathom why they think ariother5.24 acres will somehow strengthen Springfield's position as a premier locale for healthcare servIces. The PAPA proposal must be consistent 'with the Economic Element of the Comprehensive . plan in it's entirety. A major omission found in the application and staff report is an analysis of all the Metro Plan Economic Element poljcies other than the four: addressed by the applicant. The remaining 28 policies should hi': 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 limiting future growth and expansion of the existing campus 'industrial uses. 7 _ Encourage industrial park development, including areas for warehousing and distributive industries and research and development activities. Economic Element of the Metro Plan"Finding #17 establishes: "Special light industrial firms" . "have varied site l.ocation requirements, prefer alternative sites to choose from, and usually benefit from location of other special light industrial ftrms within the community and within the same industrial development." The subject site is located adjacent to an existing light medium industrial site. ,- 9 _ Encourage the expansion of existing and the location of new manufacturing activities which are characterized bylow levels of pollution and efficient energy use. Staffhas not discussed effort.s to attract andlor encourage expansion of manufacturing activities that could be sited on campus industrial zoned and designated lands. The only reference to this issue from staff is that there hasn't been much interest in the site from the _ industrial development sector. IS _ Encourage compatibility between industrially zoned lands and adpcent areas in local planning program. Metro Plan/East Nlain Refinement Plan. ZON 2007-D0012. LRP 2007-D0013 5~112 6 GOAL ONE COALmON Neighbors have expressed no' concern about their quality oflife from eXIsting industrial uses. The applicant has not addressed why or how the existing light medium industrial zoning and plan designation is incompatible with the adjacent neighborhood zoning and plan designation. 16 _ Utilize processes and local controls which encourage retention oflarge parcels or consolidation of small parcels of industrially or commercially zoned landJo 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 LMl. Staff is directed by this policy to encourage retention of this parcel of industrially zoned and designated land, which is one of the few remaining parcels of LM! land ';"ithin the Springfield city limits. 21 _ Reserve several areas within the UGB for large scale, campus type,light manufacturing uses. Staffhas failed to address the impact that this proposal will have on the dwindling supply of shovel ready industrial land inside the Springfield city limits, includirlg prior actions approving land use code amendments to the campus industrial zone that'established more 'flexibility' for what uses are allowed in the city's campUS industrial zones. 28 _ Recognize the vital role of neighborhood commercial facilities in providing services and goods to a particular neighborhood. . ' This PAPA proposal requests community commercial plan designation'and zoning yet has not considered or otherwise addressed the applicability of neighborhood commercial zoning vs. , the requested community commercial zoning. Staff and applicant have not addressed the applicability of community commercial zoning within a node, or e:<.plained why neighborhood commercial zoning is b,eing ignored for higher intensity uses in this existing neighborhood. All the Metro Plan Economic Element policies are applicable to this application, and should have been addressed by the applicant. . "' Ill. Conclusion The proposed plan amendment is not logical and harmonious witht.he land 'use pattern for the greater area. The proposed change is not "logical and harmonious" because it is not consistent with the development pattern envisioned in the Metro Plan. As explained above, the proposed amendment is inconsistent with the intent of the Economic Element of the Memi Plan, and does not comply with MetrO Plan policies. Therefore it cannot be found to be compatible with these Plans, , Compli:JJlce with statewide planning goals, including goals 2, 6, 9, 10, 12, and 13, has not been established. in particular, it has not been established that the Eugene-Springfield Metro UGB area's supply of campus industrial land will be protected pursuant to the PAPA and zone change proposal. Metro Plan/East Main Refinement Plan, ZON 2007 -D0012 - LRP 2007.00013 5"'113 7 GOAL ONE COAUTION ,The requested plan amendment does not comply ,with policies of the Metro Plan and Metropolitan Industrial Lands Special Study. -'. . ' The requested plan amendment and zone change does not benefit the public and are not 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. ' Respectfully submitted, Lauri Segel , Community Planner 'l, Metro Plan/East Main Refinement Plan; ZON 2007-00012 - LRP 2007-00013 5-114 8 . .'. ~Pe(.~:.,~Health June 13,2007 , Sprin'gfteld Planning CommissioIl Attn: David'Reesor, Planner' City of Springfield' Development Services Department 225 Fifth Street Springfield, OR 97477. t.:." '.~'~ ... ~'/.:.:(..1:;:.:;:.... il}; ': ':'/'(}:'c,. -,:' I ......,'- , .'f _) '_.":" .l'-:~'-~ )h~' , oJ )ul]l~""'1 ...... ' .. I "C:::::: " ' .........~ . I ._~ ' ,-'.,,-., J' , --~- -.'-. Re: ZON 2007-00012, LRP 2007-00013 .:. Plan AmendmentlZon~ Change Dear Chairman CrosS and Commissioners, The Commission considered the above~referenced applications onJLlne 5 at a duly noticed work session and public hearing. The following rebuts written testimony submitted by Laun Segel of the Goal One Coalition aHhe close of the extended record yesterday.' Ms. Segel suggests th~t the applications:.do not comply with statewide planning Go~l 9 (Economic Development) - and by extensio'n with Goal 2 (Land Use Planning) - because the 2000 Springfteld Commercial Lands Study (SCLS) "does not address the entire Metro UGB area, and is not a refmement plan of the Metro Plan." (pg. 2; June 12, 2007 S~gelletter) ... Ii .' She furth,r states that "Eugene and Springfield hav~ a shared arid adopted UGB, Comprehensive Plan, and Industrial Lands study. The jurisdictionally focused SCLS does not analyze suppl)i and demand for the entire Metro UGB area and cannot be rdied 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 bali, (emphasis added) the most recent economic opportunities analysis (i.e., the 2000 SCLS) and the comprehensiveplan." . (pg. 4, Segel,letter) Aoolicant's ReSDonse:, The SCLS was developed by,the.City and ~dopted by the Springfield.City Council (Resolution No, 00-13 and included in the end pages ofthe SCLS) to comply wiLl] Goal 9 and applicable Q,A.Rs pursuant to periodic review requirements established by the Oregon'LandConservation and Development Commission. Prior to the SCLS, the City of Euge,ne had an acknowledged plan for complying with Goal 9, the' 1992 Eugene Commercial Lands Study (ECLS). The ECLS states: "The'study includes solely the Eugene portion of the inetr~'politan urban growth boundary," (pg.I-3, ECLS) Phane: (541l6B6.3660 F:lJ.: (541) 686.3699 PO Box 1<179 Eugene OR 9;440.,1479 Dedicared ro E~cep[iona'llvledicine and C umpGssi';lnure Care 5-115 ,..,....."..""<>11.."1111 I'lrn .. Re: ZON 2Q07-00012, LRP _ ,1-000\3 - ~lan AmendmenUZone Change Applicant's Rebuttal June I J 2007 Page 2 ,; ", Although there is in fact an ackrlo\vledged study covering both communities' industrial lands (the '1993 Metropolitan Industrial Lands Policy'-Report, .and companion Inventory Report), the cities of Eugene and Springfteld have separately adopted and acknowledged commercial lands studies fulftlling the requirements of Goal 9. As such, the SC::LS 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 co'mmerciallands study, and fulftlls the City's _ Goal 9 requirelnents 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 corrunerciallands in order to adopt findings satisfying compliance with Metro Plan policies and Goal 9. M~. Segel states that th~ analysis provided does not account for additions to the inventory of commercial lands, notably "the Gatew,,\y MDR site's 100 acres." (pg. 4, Sege!.letter) , Aoolicant's Resoonse~ The City previously adopted a'mendments to the Gateway' Refinement Plan (10. No. 2002-08-244), including GR.P Implementation Action 12.1, which limited redesignation and rezoning of up to 99 acres of residential land within.the Gateway MDR site. Subsequent Plan diagram amendments and zone changes of 96.2 . acres and 3.5 acres resulted in redesignation/rezoning of 96.2 acres to' Mixed Use Commercial or Meqical Services of the possible 99 acres available under the GRP. Considering that the SCLS identified a deficit 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 commercia:! land. Approving the requested Planamendmentlzone change would still leave a deftcit 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 the com'merciallands inventory pursuant to the City's acknowledged compliance with GoalS periodic review requirements. Table 11-2 ofthis analysis (see pg. 3-25 in the Commission's June 4, 2007 hearing packet) identifies that as ' a consequence of the City's GoalS protection measures that approximately 11.5 acres would,be removed from the inventory of needed commercial lands, thus further adding to the, commercial lands deficit.'established in the SCLS. Therefore, even considering iinpaCts to commercial lands inyentories from other adopted and acknowledged plans (i.e., the City's plan for Goal 5 compliance) 'and acknowledged Plan. amendmentslzone changes, approval of the proposal will not resultin there being an excess of needed comm~rcially 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: ZOM 2))07-00012, U.. 07-00013 -Plan Amendment/Zone Change Applicant's Rebunal June ll, 2007 Page 3 Ms. Segel states that the application relies ~'he'avily on'inventory and policy statements established by the 2000 SCLS in establishing that the ..proposal is consistent with the Goal 9 rul:. 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 signi'ftcant policies that must be considered." (pg. 3, Segel letter) . She further alleges that the application hasn't "justifted the conversion of scarce, shovel ready industrial land" especially land designat~d and. zoned ," light medium industrial inside the Metro UGB, ,even tho'ugh the Metro Plan (comprehensive plan) Economic Element 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 metropolitan Industrial Lands"Special Study, 1991) to non-Industrial designations.' Tl)e applicant and staff findings do not address how the loss of these 5.24 acres impacts the shoI1-term supply' ofLMI designated limd." ' Aoolicant's ResQonse: The Applicant's original March 15,2007 submittal included findings addressing relevant Metro Plan policies (se~ pg. 5 of the submittal, pg. 4-5 of the Commission's June 4, 2007 hearing packet). ,Clearly not all of the 32 MetroP.lan Economic Element policies are relevant to the proposal. Many are aspirational in nature and not directive to a specific quasi-judicial aPlllication, for example Policy 28: "Recognize the vital role of neighborhood commercial facilities in providing services and goods' to a particular neighborhood." (pg, 1II-B,6, Metro Plan) Others are directed to actions that the publIC sector jurisdictions are to undertake, such as Policy 31, which Springfteld did in conducting in the SCLS: "Conduct a Commercial Lands Study priqr to the next major plan update." (pg. Ill-B-7, ibid) Nonetheless, to demonstrate that all policies were ,considered irrespective of their applicability, the Applicant will provide " supplemental fiJ1dings and enter them into the record prior to the City Council h~aring on these applications: However, this does not suggest that the Applicant's findings are presently inadequate or that the Metro Plan policies cited are not o~ point. Ms. Segel's citation of Economic Element Policy 12 ignores the fact that the subject site was not iricluded among the sites "defmed as short-term in 'the metropolitan indus/rial Lands Special Siudy, 199\)," The adopted and ac~owledged Metropolita"n Industrial Lands Policy and Inventory Reports identify the subject site as being included in "Subregion ~8 _ East Springfield" Maps and tabular information in these reports (pp. 42-44, tables pp. 18-26; 1993 [vEL Policy Report) do not identify the subject site among the "short-term sites" in the industrial lands stuc)y, 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 M]L Policy Report states that "sites developed during the study 5-117 Re: ZON 2007-00012, LRJ J7-00013 - Plan Amendment/Zone Change Applicant' 5 -Rebuttal June \ 3,2007 Page 4 were not included in the short-term supply of sites. Staff projected a five,year need for industrial sites based on development trends in Eugene-Springfteld 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. 15, 16) Therefore, the"subject site was not included in the inventory of short-term industrial sites in the industrial lands study casting doubt on the applicability of Metro Plan Economic Element Policy 12. ' Even if Policy 12 were relevant, its language is clearly not prohibitive to approval of an application for redesignation/rezoning of an industrial site, particularly when considerinD .' ~ 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 iand 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 a surplus of buildable light medium industrial acfeage; and overall industrial acreage, in Eugene, Springfield, and combined in the metro UGB. Table 5 in the MIL lnventory Report (pg. 47) identifies supplies of buildable industrial. land as follows: Eugene Springfield Metro UGB 'LM! Acres. 1,230.78 198.77 1,429.55 Totallndustrial Acres 2,895.49 708.80 3,604.29 'l 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 1,172 acres.~' (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 Springfield is 54.43 acres (Table 11.3, pg, 3-25'ofthe 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 ill of the industrial acreage impacted by GoalS and all of the acreage redesignated in Springfield were from the LM! designation _ which is no doubt not the case - there would still be a surplus of nearly 50 acres of LMl 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 ofLM! zoned and designated land will not result in a deficit of needed land in that industrial 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 tC07-000\2, LRl' "007-00013 - Plan Amendment/Zone Change Applicant's Rebuttal June 13 2007 Page 5 . Economic Element Policy 6) and SCLS (i.e., Policies I-A and I-C) that are directive to providing an adequate supply of needed commercial lands, The Metro Plan recognizes such conflicts: "The respective jurisdictions recognize that there are'apparent conflicts and inconsistencies between and among some goals, objectives, and policles, When making decisions based on the Pla~, not all the goals, objectives, and policies can be met to the same degree in every instance. Use of the Plan requires a 'balancing' of its various components on a case:by-case basis, as well as a selection of those goals, objectives, and policies most pertinent to the issue at hand." (pg. I-4, Metro Plan) The Applicant contends thatfindin'gs and evidence in the recorCl from adopted and acknowledged sources demonstrate that approval of the' request~d redesignation/rezoning is consistent with applicable policies and fulfills the City's employment-generating objectives and requirements under Goal 9. Ms. Segel's letter states that "the applicant is not speciftc.about what uses' will be cited should the proposal be approved, and there is no way to kI)ow Ifin fact [sic] above wage jobs and salaries." (pg.S: Segel letter) , She also states that while "the applicant argues that the proposal would have the effect of correcting existing non-conforming uses cin TL'#402" that the property is not inCluded in the "Sites with Plan/Zon, Conflicts" 'in the SCLS. She goes on to state that "it appears that the existing nonconfomling~uses were actually established AfTER adoption of the 2000 SCLS, indicating that the existing uses were actually permitted by the City with the knowledge that these 4ses would create plan/zone conflicts." (pg. 4, Segel letter) ~. Aoolicant's Resoons~ The Applicant does not allege that there is a plan!zone conflict 'on Tax Lot 402; clearly the existing Plan designations and zoning ar,e LMl. Rather, the point made in our application narrative is that commercial uses have existed for decades, pre-exishng the establishment of the Metro Plan and the application of the: LMI designation on the subject properties, Ms. Segel proyides no evideflce to back up her accusation that the City wittingly allowed commercial uses on Tax Lot 402 afteradoption of the SCLS, The Applicant and owner of Tax Lot 402 will provide additional evidence . ' ' , ;1, and testimony at the City Council hearing on J'uly 2 whlch willfu~her demonstrate factually that commercial uses and employment have been in the building on Tax Lot 402 for nearly 50 years. Ms. Segel's assertion that the application was,unspecific as to.the future uses on Tax Lot 400 is inaccurate, The appEcation narrati ve clearly states the intended purpose of the redesignation/rezonlng is to allow for a future' medlcal clinic on Tax Lot 400 and to allow the long-standing commercial operations on Tax Lot 402 to continue (pg, 2, pg. 4-2 lrl 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 ,\edesignate) Tax Lot ,400 to allow a medlcal clinic. Average wages and benefits for medical workers tends to 5~119 Re: ZON 2007-00012, LRP 2007-00013 - Pion 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 patterns 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 PAPA and zone change pro'posa1." Aoolicant's ResDonse:, It should first be noted that the application does not inyolve or in any way affect the "metro area's supply of campuS industrial land." Moreover: the application has no effect upon.Goall 0 (Housing), and has else\vheredemonstrated compliance with Goal 12 and other applic,able statewide planning goals. My guess is that Ms. Segeland Nancy Falk, who appeared at the June 4 hearing and requested the written reco'rd 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 infact, and is not an approval criterion. As noted above and elsewhere in the record, this proposaris consistent with policies and provisions in the Metro Plan, its Economic Element, supportillg reftnement 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 support theSt,!ff recommendation 'and forward to the City Council your recommendation approving the pend,ingapplications. Pnilip FamIigt n, rJCP Director, Land Use Planning & Development PeaceHealth Oregon Region cc:' Jim Werfelmann Andrew Head Shaun Hyland 5~120 I CITY OF SPRINGFIELD I I DEVELOPMENT SERVICES DEPARTMENT I NOTICE OF DECISION SPRINGFIELD CITY COUNCIL . ," METRO PLAN I REFINEMENT PLAN MAP AMENDMENT & ZONING MAP AMENDMENT DATE OF DECISION: July 18th, 2007 July 16th, 2007 ZON2007 -00012 &' LRP2007 -00013 DATE OF NOTICE: JOURNAL NUMBER: APPLICANT: PeaceHealth I NATURE OF REQUEST The applicant requested approval of a Metro Plan I R.efinement Plan Map Amendment to the East Main Refinement Plan 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 and Zoning Map Amendment from LMI to CC. The applicantsought 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 Council 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 appe,al with the LUBA no later than 21 days from the date thedecision 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. . I QUESTIONS If you have any questions concerning this matter, please contact David Reesor, Planner III at 541.726.3783. Date Received:M!()7 "':J~~~ Planner: DR . David Reesor, Planner III r- a C>o '35T-------- FedEx. US Airbill Express From PftHHprl<!fondprnolwd. 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