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HomeMy WebLinkAboutOrdinance 6201 07/16/2007 "'.- ORDINANCE NO. 6201 (General) AN ORDINANCE AMENDING THE SPRINGFIELD ZONING MAP BY 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 (Ce). 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 16t\ 2007 the applicant/owner of the subject property initiated the following Springfield Zoning amendment: Rezone approximately 5.24 acres ofland from Light Medium Industrial to Community Commercial, Case Number ZON2007-00012, for property identified as Lane County As- sessor's Map 17-02-32-00, Tax lots 400 and 402; and 3. On June 4th, 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 18th, 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 2nd, 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 as the evidence and testimony presented at this public hearing held in the matter of adopting this Ordinance amending the Springfield Zoning Map, NOW THEREFORE, based upon the foregoing findings the City of Springfield ordains as follows: Section 1. The Springfield Zoning Map, more particularly described in Exhibit A at- tached hereto and incorporated herein by reference, is hereby amended from Light Me- dium Industrial to Community Commercial. Section 2. If any section, subsection, sentence, clause, phrase, or portion of this Ordi- nance is for any reason held invalid or unconstitutional by any court of competent juris- diction, that portion shall be deemed a separate, distinct, and independent provision and that holding shall not affect the validity of the remaining portion of this Ordinance. FURTHER, although not part of this Ordinance, the Springfield City Council adopts findings 1-4 herein above, and the findings set forth in the Staff Report which demonstrate con- formance of this amendme[1t to Section 12.030 of the Springfield Development Code and to ap- plicable Statewide Planning Goals, and is attached as Exhibit A. ORDINANCE NO. 6201 PAGE 1 OF 2 ..' '.- ADOPTED by the Common Council ofthe 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 16thday of \ July ,2007. ATTEST: ~Jmm-- City Recorde REVIEWED & APPROVED ~~R~ ~~ DATE: L.o..7~....0I OFFICE M CITY ATTORNEY ORDINANCE NO. 6201 PAGE 2 OF 2 Type II Metro Plan Map Amendment & Zoning Map Amendment Staff Report and Findings . HearinQ Date: June 4th, 2007 - Planning Commission June 18th, 2007 - Planning Commission July 2nd, 2007 - City Council Applicant Case Number: ZON 2007-00012 LRP 2007-00013 Owner Applicant's Representative Philip Farrington, AICP Director, Land use Planning & Development Peace Health Oregon Region 123 International Way Springfield, OR 97477 PeaceHealth Oregon Region 123 International Way Springfield, OR 97477 Hyland Business Park,LLC (TL 400) Attn: Shaun Hyland . 1941 - A Laura Street Springfield, OR 97477 ,Andrew Head (TL 402) 1616 Ardendale Ln. Eugene, OR 97405 Date Submitted: March 16th, 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 44th 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 LRP2007-000/3 & lON2007-000/2 ATTACHMENT .. Commercial Lands Study, there is a shortfall of commercial lands within city limits. The 1992 Industrial Land Inventory and the City's adopted Goal 5 analysis support the fact that there is a surplus of industrial land in the Metro area. The Metro Plan allows amendments such as that which is proposed to allow City's to modify land use patterns 'as demand and the community's vision change over time. The proposed Metro Plan Amendment is a Type \I 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 PlanningCQi}1mission. 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 reql:.Jest for a Metro Plan / Refinement Plan Amendment and concurrent Zoning Map Amendment from LMI to CC 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 Periodic Review) is known as a Post Acknowledgement Plan Amendments (PAPA). This same acreage on the site is being proposed for a concurrent amendment to the Springfield zoning map from LMI to Community Commercial (CC), as allowed in Springfield Development Code (SDC) 12.020 (1)(a)1. Pursuant to sac 7.110(4), approval of the requested Metro Plan diagram amendment. automatically amends the refinement plan diagram and is processed concurrently. . Findings of fact addressing the criteria of approval in -SDC 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. r 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. LRP2007-000 /3 & lON2007-000 /2 2 5-2 Commercial enterprises are located immediately south of the site across Main Street (e.g., Gray's Garden Center). While historically involved in agricultural uses, since around 1990 Tax Lot 400 was used as a storage and sales yard for landscape organics and forest by-products. The current property owners also used the site to store modular construction offices, tool trailers, construction equipment and concrete form plywood. Tax Lot 402 has had various commercial services on site since the 1950s. The properties have no jurisdictional wetlands or inventoried Goal 5 natural or historic resources. The site is within the Springfield Urban Growth Boundary, and both parcels were annexed into the City of Springfield in 1960. The East Main Refinement Plan (EMRP) diagram (adopted in 1988) currently designates the subject property for industrial uses. The abutting property to the east is designated LighUMedium Industrial in the EMRP diagram and zoned LMI. The areas immediately to the west and south of the site fronting Main Street are identified as being within Mixed-Use Area #2 in the EMRP, and are all zoned Community Commercial. Property to the west of Tax Lot 400 along 44th Street is zoned and designated Medium Density Residential. lRP2007-00913 & lON2007-000/2 3 h_ 3_ Existing & Proposed Metro Plan Designation: i I' I "'-", /' ,",,--- ~-:-~----"";. " I I i _' I,' ---I I r---i i_I!:: : ,---_.: --_.~_... ---...!_--.-- r i (- -'~ 1-11-), L_I I i r---, ' I' --~-----'Ji I ~---! ! I 1---- i: i il i - -- - - -- -~---- -lJ_J_ -----~--- I ~ Change from Light Medium Industrial to Commercial Metro Plal'J Designation _ Commercial MU D Light Med. Indust. D Low Den. Res. D Med. Den. Res. _ Heavy Industrial ~~ 1hert are no warranllO lhalac.rO/Tfxmy thisprwm:f. CA./! 1'$ aS~'llme all rc.:'ipon:ilbi/i ry for any luss Of' damage arisi ng from(lnY error, omin'jon rr {Dsitional /nacUlracyufthis prodll(.'1 100 ~o Feet June. 2007 LRP2007-00013 & ZON2007-000/2 4 Existing & Proposed Refinement Plan Designation: W Change from Light Medium Industrial (LMI) to Community Commercial (CC) Refinement Plan _ Community Commercial Low Density Residential Medium Density Residential Light-Medium Industrial III Heavy Industrial ~ Mixed Use 2 & 3 ~~ 7here are no warranties thaI acronpany this producr. Users assume all f'esf'Onsibili ry jOr any loss or damage arising from_any error, omissi on cr fDs; tional inaccuracy of this product LRP2007-000 13 & ZON2007-000 /2 - /. r:T~_3r~-~\) 100 ::cDO Feet June, 2007 5 Existing & Proposed Zoning: .. ! "I' .1 . .. 'i"-:I ::,~;~--~E]~--j=~--I~~ 'V~~\) t=o~~- ,-,_/.<' I ,_ j" /- /\ r i ,-- , L___J 1 i I i ! /' i I I' . " ~_._,L___ I , . . -I "i-..n- rr--! Iii i i I I -:-:---! : ! ! 1-----1 , ~~.--.,..L..-.J-.-J.- ...,.,1_........,1.._..__... J , I i i , 'I -- __..J..._'__ --..-L_.J ! I I.; I-'ll i I-i!/: , I IJ' , i Ii I y .----~-_LL_ ____~~! ~ O1ange from Light Medium Industrial (LMI) to Community Commercial (CC) Zoning Medium Density Residential Low Density Residential ' _ Community Ccmmercial' Light Medium Industrial _ f-'eavy Industrial ~~ Theil! are f10 warranlies thaI acc:orrpany this pl'OduCf. Users assume all respon.\'lhili ty fur any loss or damage arisi fig from any error, omission a {m'ilianal ma,'curac:yofthis product tOO . iDO Feet June, 2007 LRP2007-000/3 & ZON2007-000/2 6 Existing Site Conditions: Existing commercial uses on TL 402 Existing empty structures on TL 400 Existing modular units located on TL 400 Existing business park on property located east of TL 400 LRP2007-000 /3 & ZON2007-000 /2 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 / 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 Plan and other similar criteria. Rather than repeat these criteria for each application, they will be addressed only once and then referenced where appropriate. Criteria that are different will be addressed separately; the end result will be that all applicable criteria will have been addressed. This application was submitted to the Development.,Services Department on March 16th, 2007, and deemed as complete on April 11th, 2007. Notice for both applications was mailed to Department of Land Conservation and Development (DLGD)on April 16th, 2007. Notice of the public hearing date was mailed out on Thursday, April 19, 2007 to property owners within 300 feet of the proposed zone change per Section 14.030 (1) (a)- (n) of the SOC. Public notice of the hearing was published in the local newspaper (Register Guard) on May 1yth, 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: LRP2007-000 /3 & ZON2007-000/2 8 . 5--g - The following findings address compliance with Metro Plan criteria in SDC 7.070 (3){a). Approval of a Metro Plan diagraniamendment also correspondingly changes the applicable refinement plan diagram, as established inSDC 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 the planning process. Goal 1 addresses the need to develop a citizen involvement program to ensure citizen involvement in all phases of the land use planning process. The Planning Commission and the City Council will hold public hearings and accept testimony on the proposal. Through the procedures established by the city, citizens will receive notice of hearings in generally published local papers and have the opportunity to be heard regarding the proposed diagram amendment and zone change. Notice of the public hearings will also be given in accordance with SDC requirements to neartiy 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. STAFF'S FINDINGS RELATED fO COMPLIANCE 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 11th, 2007 to property owners within 300 feet of the proposed zone change per Section 14.030 (1) (a)-(n) of the SOC. Public notice of the hearing was published in the local newspaper (Register Guard) on May 1ih, 2007, as required in Section 14.030 (2) of the SOC. Staff concurs with the applicant's written statement related to Goal 1. APPLICANT'S NARRATIVE RELATED TO GOAL 2: Goal 2: Land Use Planning: To establish a land use planning process and policy framework as a basis for all decision and actions related to use of land and to assure an adequate factual base for such decisions and actions. Goal 2 requires that local comprehensive plans be consistent with the Goals, that local comprehensive plans be internally -consistent, and that implementing ordinances be consistent with acknowledged comprehensive plans. Goal 2 also requires that land use decisions be coordinated with affected jurisdictions and that they be supported by an adequate factual base. As required in SDC 7.050, the City is required to give referral notice of the proposed Type II Metro Plan diagram amendment to the City of Eugene and Lane County so they may determine if there are grounds to participate as parties to the hearing. The 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 go"als. 9 LRP2007-000 13 & ZON2007-000/2 !:;-1n ,. The Metro Plan and theSDC, 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. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 2: Finding 2: These applications comply with Goal 2 because the SDC requires consistency between the Statewide Planning Goals, the acknowledged Metro Plan, adopted refinement plans and special area plans and the zoning. Staff concurs with the applicant's written statement related to Goal 2. APPLICANT'S NARRATIVE RELATED TO GOAL 3: Goal 3 - Agricultural Land: To preserve and maintain 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. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 3: Finding 3: The subject property is located within the city limits on land planned and zoned for urban use. The City does not have any agricultural zoning districts, either within its city limits or within the urban growth boundary. Finding 4: Goal 3 does not apply to these applications because the subject property is within Springfield's city Iimits_ 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 to provide for recreational opportunities and agriculture. Goal 4 does not apply within urban growth boundaries, per OAR 660-06-0020, and the areas affected by the Plan amendments are inside Springfield's acknowledged UGB: STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 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 to Goal 4_ lRP2007-000 13 & ZON2007-000 /2 /0 ~-11 APPlI,CANT'S NARRATIVE RELATED TO GOAL 5: Goal 5 _ Open Spaces, Scenic and Historic Area, and Natural Resources: To conserve open space and protect natural and scenic resources. 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; (4) examine the economic, social, environmental, and energy (ESEE) consequences that could result from allowing, limiting, or prohibiting the conflicting uses; and (5) develop programs to resolve th~ 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 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 amendment does not alter the City's compliance with GoalS. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 5: Finding 6: Goal 5 does not apply to these applications because there are no inventoried resources on the subject property. Oregon Administrative Rule 660-023- 0250 establishes the 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 6: , 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 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. Though Tax Lot 400 has been used for low-value storage and quasi-industrial uses, the site is not listed on any state or local environmental clean-up list. A Phase 1 environmental assessment on the subject property was conducted and recommended additional analysis. Upon recommendations through the Phase 2 environmental assessment a nominal quantity of soil (less than 10 cy) impacted by earlier/historic use was removed from the site and properly disposed. Given the nominal impact generated by historic uses on the site, it is reasonable to conclude that future development on the site will be able to demonstrate compliance with City standards for water quality protection LRP2007-0001J & lON2007-000/2 II 5-12 through the site plan review process, thereby complying with applicable state and federal environmental quality standards. . STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 6: Finding 7: The proposed Metro Plan I Refinement Plan Amendment or Zoning Map Amendment does not modify any of the Goal 6 related policies of the Metro Plan, nor do they amend the Regional Transportation Plan, the Springfield Development Code, other applicable Goal 6 policies, or any regulations implementing those policies. The subject property is located in the Zone of Contribution and outside any of the Time of Travel Zones, which is regulated by the Drinking Water Protection Overlay District _ Article 17. Any new development on the subject property is subject to compliance with Article 17 and other applicable regulations related to Goal 6. Staff - concurs with the applicant's narrative related toGoal 6 compliance. APPLICANT'S NARRATIVE RELATED TO GOAL 7: Goal? _ Areas Subject to Natural Disasters and Hazards: To protect life and property from natural disasters and 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 of natural disaster and hazards, such as areas prone to landslides, flooding, etc. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 7: Finding 8: Staff has reviewed the natural constraints map and the FEMA Floodplain Map in relation to the subject property. 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 landslide hazards, and is located well outside of any established FEMA flood hazard area. Therefore, approval of the proposed Plan amendment and Zoning Map Amendment will not alter the City's acknowledged compliance with Goal 7 through its adopted plans, codes and procedures. APPLICANT'S NARRATIVE RELATED TO GOAL 8: Goal 8- Recreation Needs: To satisfy the recreational needs of the citizens of the state and visitors and, where appropriate, to provide for the siting of necessary recreational facilities including destinatiOn resorts. Goal 8 requires local governments to plan and provide for the siting of necessary recreational facilities to "satisfy the recreational needs of the citizens of the state and visitors," and where appropriate, provide for the siting of recreational facilities including destination resortS. The subject site is not included in an inventory 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. LRP2007-00013 & lON2007-00012 12 5-13 STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 8: Finding 9: Staff has consulted the Willamalane20-year Parks and Recreation Comprehensive Plan in relation to Goai 8 compliance. 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 8. None of the various studies inventories, and facilities plans regarding recreational facilities in the adopted Willama/ane 20-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 8 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 fhe health, welfare, and prosperity of . Oregon's citizens. Goal 9 requires the city to provide adequate opportunities for a variety of economic activities vital to the health, welfare, and prosperity of the citizens. The proposed amendment to the Metro Plan diagram will increase the city's capacity for economic development by adding 5 acres of CC in place of the existing industrial designation. Permitting the construction of future clinic facilities and allowing long-standing commercial uses on Tax Lot 402 to become conforming uses consistent with commercial zoning is consistent with numerous policies in the City's adopted plan for compliance with Goal 9, the Springfield Commercial Lands Study (SCLS). Specifically, the following SCLS policies are applicable to the proposal: Policy 1-A: "Maintain a mixed supply of large and small commercial sites through strategies such as rezoning or annexation to serve Springfield's future population." The proposal fulfills this policy objective by redesignating and - through accompanying zone change _ rezoning land from industrial to 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 redesig!lation, 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 & lON2007-000/2 ~-1.d 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 industrially designated and zoned land, but itwould help reduce the commercial lands deficit identified in the SCLS. Therefore, approving the proposal would be consistent with SLCS Implementation Strategy 3-A (1): "Evaluate inventories basedon demonstrated need for the planning period. Initiate rezoning or redesignation of surplus land uses where more appropriate for commercial, consistent with the Metro Plan." The proposal in fact consistentwith inventories for commercial and industrial lands adopted by the City Council and acknowledged byDLCD as being consistent with Goal 9. Oregon Administrative Rules concerning Goal 9 implementation (OAR 660-009-0010(4)) call for amendments to land use designations "in excess of two acres within an existing urban growth boundary from an industrial land use designation to a non-industrial use designation" to 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 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 amendment without the need for an economic opportunities analysis apart from the SCLS, which DLCDacknowledged 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 be consistent with relevant Metro Plan policies, approval of the request is consistent with the City's compliance with Goal 9 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, specifically fulfilling 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 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-term industrial demand. This portion of the supply also exceeds the twenty year demand projection." The City performed subsequent analysis of industrial land supply as part of periodic review requirements to demonstrate compliance with statewide planning Goal 5 (Natur(ll 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 1,600 and 2,122 acres metro-wide. Staff's GoalS work also calculated the changes in industrial land supplies since 1991 as a consequence of Metro Plan diagram changes (see Attachment B). This analysis demonstrated a reduction in less than 90 acres of industrial land over the past 15 years, LRP2007-000 I J & ZQN2007-000 12 /4 5':"15. suggesting that there is still an ample supply of available industrial lands to meet existing and future development needs. ' ' This analysis may also not reflect other changes withIn industrially designated land categories that would further off-set the proposed change to the site's LMI Plan designation and zoning. For example, 11.5 acres was added to the inventory of LMI zoned and designated land due to City Council approval in April 1997 for land east of the 28th/31st Street connector and north of Marcola Road (Ordinance No. 5851). Insofar as the City and metropolitan area continue to enjoy a surplus of needed Industrial land, and specifically Heavy Industrial zoned and designated land, the above-referenced change added more than enough acreage to the inventory of LMI designated and zoned land to off-set the proposal to remove only about 5 acres from the LMI inventory. , We therefore respectfully submit that the proposed Metro Plan diagram amendment and' zone change will not materially affect the inventory of needed Industrial land and will not alter the City's continued compliance with Goal 9. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 9: Finding 10: The City of Springfield has two adopted inventories which support the proposed Metro Plan Amendment I Refinement Plan Amendment and concurrent zone change request - the 1992 Industrial Land 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 need 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 to referencing the SCLS and the 1992 Industrial Land Study, the applicant also references the, adopted Goal 5 inventory work, which provides a more up-ta-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 and 2,122 acres metro-wide. As noted by the applicant, Oregon Administrative Rules concerning Goal 9 implementation (OAR 660-009-0010) call for amendments to land use 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 lands for either category of uses. As noted by the applicant, there are existing commercial uses located on TL 400 which are part of the subject property. Additionally, the applicant is seeking to develop future commercial uses on the property which will maintain the property for employment- generating activity. /5 LRP2007-000 IJ & lQN2007-000/ Z !1-16_. 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 affect the City's inventory of residential lands. In fact, approval of the requested redesignation for Tax Lot 400 would enable redevelopment of an industrial site abutting existing. residential development. Through- the site plan review process, future development on that property will provide a superior buffer and a higher use that will 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. STAFF'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'S NARRATIVE RELATED TO GOAL 11: Goal 11 _ Public 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}(a)-(d) Definition of Public Facilities: (a) Water (b) Sanitary Sewer (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. LRP2007-000/3 & lON2007-00012 /6 5.17 STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 11: Finding 12: As noted by the applicant, the Metro Plan and associated facility plans have been acknowledged to conform to Goal 11 ensuring that public facilities and services are currently available to the subject site. The proposed Metro Plan / 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 / 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 to the subject property. APPLICANT'S NARRATIVE RELATED TO GOAL-~12: Goa/12 _ Transportation: To provide and encourage a safe, co.rvenient 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 not result in any changes to the type or intensity of uses on the site, and will not increase the trip generation for that parcel. As the attached Traffic Impact Analysis (TIA) demonstrates, future development of medical 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 660-012-060). . Existing development at Tax Lot 402 is not affected by the proposal, and is assumed to retain its current access points off Main Street. It is further assumed that future development on Tax Lot 400 will result in some access changes as will be reviewed through the site plan review process, thereby consolidating two existing curb cuts located on Tax Lot 400 into a single access point located approximately in the center of the parcel. The TIA demonstrates that these access points will not result in any degradation of mobility standards below acceptable 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 Refinement Plan (EMRP) Access, Circulation & Parking Element policy 1 B (pg. 17) and Commercial Element policy 3 (pg. 12). . Because the proposal, as demonstrated in the TIA, is consistent with the requirements of the TPR and with applicable policies in the EMRP, it is consistent with Goal12 and applicable local implementing policies. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 12: Finding 14: The proposed Metro Plan Amendment 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 13 & lON2007-000 /2 5-18 in any changes to the type or intensity of uses on the site, and will not increase the trip generation for that parcel. Staff does not concur with this statement in reviewing all of the potential CC uses on the site. Staff does concur, 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 for both the existing zone (LMI) and the proposed zone (CG). The applicant's TIA listed Peak Hour Trip Generation for Medical Office Building. While this is a permitted use in the CC zone and is the primary use that the applicant is seeking to use the property for, it is not the "reasonable worse case" scenario for traffic generation given other allowable uses in the CC zone. During Staffs review of the proposal, staff researched potential vehicle trips per day for potential uses in the CC zone. There are some other potential uses in the CC zone which are much more intensive uses than Medical Office. In considering what a "reasonable worst case" development scenario mig!1t be for there-zoned condi~ion it is clear that a 30,000 square 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 and PM peak hours respectively. For comparison the average rates for a "Fast-Food Restaurant with Drive-Through Window" are 53.11 vehicle tips/1,OOO SF and 34.64 vehicle tips/1,OOO SF. These calculations are taken from the Institute for Traffic Engineers (ITE) Manual. As shown on Table 6 of the TIA, a reasonable worse case traffic generation scenario for the existing zoning (LMI) is 243 trips. The proposed use of Medical Office Building is shown in Table 7 as 177 trips. While the Medical Office use trip generation is less than the reasonable worse case scenario for the existing zoning, it does not take into account other more intensive commercial uses (Le. drive thru restaurants, banks, etcl Planning Staff met multiple times with City Traffic Engineering Staff and ODOT Staff to review the submitted TIA. ODOT's review of the submitted TIA indicated that there were multiple issues that were not adequately addressed in the submitted TIA to justify compliance with Goal 12 (see attached memo from ODOT). Based upon the information provided in the submitted TIA, all reviewing parties (i.e. City Planning Staff, City Traffic Engineering Staff, and ODOT Staff) agreed on a recommended condition of approval (see attached emans 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 the reasonable worse case scenario for the existing zoning (243 trips). Because these numbers of trips are already allowed with the existing zoning, the application complies with Goal 12. 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 "reasonable worse case development scenario" under the existing zoning (LMI) as submitted by the applicant in the Traffic Impact Analysis for the subject property- LRP2007-000/J & lON2007-00012 /8 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 energy, 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 on energy conservation, though it would in fact will promote greater energy efficiency by enabling needed clinical services available to growing residential areas in east Springfield. Therefore, the proposed amendment is consistent with, and does not alter the City's continued compliance with Goal 13. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 13: Finding 15: The proposed Metro Plan I Refinement Plan Amendment and Zoning Map Amendment do not affect the Metro Plan's.compliance with Goal 13. The applicant is not proposing to amend any regulation pursuant to Goal 13 compliance of the Metro Plan. APPLICANT'S NARRATIVE RELATED TO GOAL 14: Goal 14 _ Urbanization: To provide for an orderly and efficient transition from rural to urban land use. Goal 14 requires local jurisdictions to provide for an "orderly and efficient transition from rural to urban land use." The subject property is within the UGB and the city limits of Springfield, and within an existing urbanized area of the community. Therefore, Goal 14 is not applicable to this application. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOAL 14: Finding 16: As noted by the applicant, all of the parcels affected by this application are currently within the Urban Growth Boundary and were annexed into the City of Springfield. All annexations are reviewed for compliance with the Metro Plan and the Springfield Development Code. As previously mentioned, urban facilities are available to the subject site. The proposed Refinement Plan and Zoning Map Amendment are in compliance with Goal 13. APPLICANT'S NARRATIVE RELATED TO GOAL 15: Goal 15 _ Wi/lamette River Greenway: To protect, conserve, enhance and maintain the natural, scenic, historical, agricultural, economic and recreational qualities of lands along the Wi/lamette River as the Willamette River Greenway. This goal is inapplicable because the subject 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. /9 LRP2007-000 I J & ZQN2007-000 /2 5-20 APPLICANT'S NARRATIVE RELATED TO GOALS 16-19: Goal 16 through 19: (Estuarine Resources, Coastal Shorelands, Beaches and Dunes, and Ocean Resources): The coastal goals are not applicable to this application. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH GOALS 16.;19: Finding 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)(b), APPLICANT'S NARRATIVE RELATED TO SDC 7.070(3){b): The application requests amendment of the Metro Plan diagram from LMI to CC for approximately 5.24 acres. This section of the application narrative addresses the consistency of the amendment with the applicable policies of the Metro Plan, to demonstrate that adoption of the amendment will not make the Metro Plan internally inconsistent (as required by the approval criteria in SDC 7.070(3)(b)) This narrative only addresses those policies that apply to the proposal, and does not discuss those portions of the Metro Plan that: (1) apply only to rural or other lands outside of the urban growth boundary, (2) apply to land uses other than the current or proposed designations for the site and will not be affected by the proposed Plan diagram and text amendments, or (3) clearly apply only to specific development applications (e.g., site plan review submittals or subdivisions). In many instances the goals, policies and implementation measures apply to specific development proposals that will be addressed through compliance with applicable City regulations during site plan review of a given future .development proposal. . The Metro Plan Introduction, Section 0 provides the following definitions: A goal as a broad statement of philosophy that describes the hopes of the people of the commun'ity for the future of the community. A goal may never be completely attainable, but is used as a point to strive for. 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 addresse.d in the order in which they appear in the Plan Element section of the Metro Plan. Metro Plan Elements 1. Growth Management LRP2007-000/3 & lON2007-000/2 20 5-21 Policies 1. The urban growth boundary and sequential development shall continue to be implemented as an essential means to achieve compact urban growth. Provision of all urban services shall be concentrated inside the urban growth Qoundary. The proposed amendments satisfy this policy because the subject 'property is inside the UGB and city limits and as such, encourages compact urban growth.. Also, urban services are available at sufficient levels to accommodate the existing and future infill development resulting approval of from this application. The City's site plan review processes ensure that the appropriate level of services is available to serve future development. 2. Residential Land Use and Housing Element Policies A.11 Generally locate higher density residential dev~/opment near employment or commercial services, in proximity to major transportation systems or within transportation-efficient nodes. The proposed redesignation does not affect the inventory or availability of residentially designated or zoned land, including the single-family residential area abutting Tax Lot 400 that is zoned and designated for Medium Density Residential, or higher density residential developments located east of the si-te along Main Street. ' However, approval of the requested redesignation to Community Commercial would allow for residential areas proximate to the subject area to have close and efficient access to existing commercial services on Tax Lot 402 and to future medical facilities proposed for Tax 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 transportation system that can support the needs of nearby residential development. . A.22 Expand opportunities for a mix of uses in newly developing areas and existing neighborhoods through local zoning and development regulations. The map amendment and concurrently proposed zone change will allow for existing commercial uses on Tax Lot 402 to continue to serve existing neighborhoods in the mid- and east-Springfield area, and for future clinical facilities to be developed to serve this rapidly growing area of the community. Approving the requested redesignation and zone change would expand commercial opportunities to serve these neighborhoods consistent with the above policy. 3. Economic Element Policies B.1 Demonstrate a positive interest in existing and new industries, especially those providing above-above wage and salary levels, and increased variety of job opportunities, a rise in the standard of living, and utilization of our existing comparative advantage in the level of education and skill of the resident labor force. The proposed amendment is consistent with this policy because it will allow medical clinic uses to be developed to serve growing areas in east and south Springfield. As is observed in the Springfield Commercial Lands Study (pp. 27, 29), employment in health services is growing and approving the requested redesignation will enable increased job LRP2007-000 /3 & lON2007-000/2 2/ 5"':22 opportunities with higher than average wages thereby helping raise the standard of living arid meet the needs of Springfield citizens, consistent with the above policy. 8.2 Encourage economic development which utilizes local and imported capital, entrepreneurial skills, and the resident laborforce. 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. 8.6 Increase the amount of undeveloped land zoned for light industry and commercial uses correlating the effective supply in terms of suitability and availability with the projections of demand. The proposal will add approximately 5.24 acres of Community Commercial land, consistent with recommendations to increase the cO,mmerciallands inventory made in the Springfield Commercial Lands Study. The SCLS 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 of th~ requested redesignation will not cause the inventory of needed industrial land to go into a deficit, but in fact would, consistent with the above poricy. The proposal correlates the need"and suitability, and availability of the subject site for commercial uses with the need for such uses as demonstrated in the adopted SCLS. 8.11 Encourage economic activities which strengthen the metropolitan area's position as a regional distribution, trade, health, and service center. The amendment will facilitate the development of medical uses that will serve the needs of the growing residential areas in east, south and southeast Springfield, and strengthen the metropolitan area's position as a premier locale for healthcare services, consistent with this policy objective. 6. Environmental Design Element " Policies E 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 planning policies. Approval of the proposed map amendments will add just over 5 acres into the City's inventory of commercially designated and zoned land, thereby allowing for a variety of needed commercial uses to occur on the subject property. Long-standing existing commercial services on Tax Lot 402 would be allowed to continue without the specter of being considered non-conforming uses, and Tax Lot 400 could be developed with medical services that will serve the needs of the growing residential areas east and south of the subject site, consistent with the above policy. 7. Transportation Element Land Use Policies F.3 Provide for transit-supportive land use patterns and development, including higher intensity, transit-oriented development along major transit corridors and near transit stations; medium- and high-density residential development within one~quarter mile of transit stations, major transit corridors, employment centers, and downtown areas; and LRP2007-00Qf 3 & lON2007-000/2 22 fi. -? ~ 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 consi$tent with the above. policy. Approval of the proposal 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 TIA), and will provide convenient access to existing and projected employment on the subject site, as well as access for patients to future out-patient medical facilities projected on Tax Lot 400. Transportation System Improvements: Roadways Policies F.1S Motor vehicle level of service policy: a. Use motor vehicle level of service standards to maintain acceptable and reliable performance on the roadway system. These standards shall be used for: . (1) Identifying capacity deficiencies on the roadway system. (2) Evaluating the impacts on roadways of am~ndments to transportation plans, acknowledged comprehensive plans and land-use regulations, pursuant to the TPR (OAR 660-012-0060). (3) Evaluating development applications for consistency with the land- use regulati~ns 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 within the planning horizon may not be feasible, and safety will not be compromised, and broader community goals would be better served by allowing a substandard level of service. The limitation on the feasibility of a transportation system improvement may arise from severe constraints, including 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: 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 develop an alternative mix of strategies (such as: land use measures, TOM, short-term safety improvements) to address the problem. Subsection a.(2) in the above policy requires ,an evaluation of the proposal pursuant to the state Transportation Planning Rule (TPR). The accompanying Traffic Impact Analysis provides the factual basis to determine that the proposed redesignation would not result in a "significant effect" as defined under the TPR (OAR 660-012-0060(1)). Specifically, the proposal does not change the functional classification of Main Street or any other nearby roadway, and it does not change the standards for implementing the City's functional classification system of roadways, as identified in the Regional Transportation Plan. As demonstrated in the T1A, the proposal also does not: . Result in types or levels of traffic or access that are inconsistent with the functional classification of Main Street or any other nearby roadway; 23 LRP2007.000 /3 & ZON2007-000 /2 fi- 'JL1. . 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 (Le., below acceptable mobility standards) than would be the case other uses permitted under existing designations or zoning. Specific TPR findings are further located in the TIA, see pp. 31-32. Because the proposal does not result in a "significant effect" as established by applicable OARs, no further TPR analysis is required. The request is therefore consistent with the above policy. 8. Public Facilities and Service Element G.1 Extend the minimum level and lull range of key urban facilities and services in an orderly and efficient manner consistent with the growth management policies in Chapter /1-8, relevant P9licies in this chapter and other Metro Plan policies. The subject property is located in Springfield's city limits UGB. AJI necessary infrastructure and key urban facilitieslservices are present to serve existing development (Tax Lot 402) or are available to serve future infill development on Tax Lot 400. Therefore, the proposal is consistent with the above policy. 9. Parks and Recreation Facilities Element Policies Policies in this element of the Metro Plan are not relevant to the requested diagram amendment. 10. Historic Preservation Element Policies Policies in this element of the Metro Plan are not relevant to the requested diagram amendment. 11. Energy Element Policies Policies in this element of the Metro Plan are not relevant to the requested diagram amendment. STAFFS FINDINGS RELATED 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 of the Metro Plan must support these applications. Because of recognized conflicts in the Metro Plan, the proper inquiry is whether on balance the most relevant of the Plan polices support the Metro Plan Diagram Amendment. The applicant's narrative discusses 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 Transportation Policy F.15 are satisfied. LRP2007-000 /3 & lON2007-000/2 24 ..5-25 The 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 decision 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 COMPLIANCE WITH SDC8.030 (1)-(3): Finding 20: sac 8.030(1 )-(3) indicates that a Refinement Plan Amendment must be consistent with (1) The Metro Plan (2) Applicable State Statues; and (3) Applicable Statewide Planning Goals and Administrative Rules. Each of these criteria are addressed in this report as part of the Metro Plan Amendment Criteria and the Zoning Map Amendment Criteria. As noted in the applicanfs narrative, sac 7.110(4) states: "When a Metro Plan amendment is enacted that requires an amendment to a refinement plan or functional plan diagram or map for consistency, the Metro Plan diagram amendment automatically amends the refinement plan or functional plan diagram or map if no amendment to the refinement plan or functional plan text is involved. .." There is no refinement plan text amendment proposed as part of this application. Therefore, no separate refinement plan application is required. As stated in the above referenced section of the SOC, the refinement plan is automatically amended upon approval of the Metro Plan amendment. 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 in this report. METRO PLAN MAP & REFINEMENT PLAN AMENDMENT (LRP2007-00013) CONCLUSION AND RECOMMENDATION Staff finds that the request meets the criteria of sac 7.030(a) - (b) and sac 8.030. 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 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 "reasonable worse case development scenario" under the existing zoning (LMI) as submitted by the applicant in the Traffic Impact Analysis forthe subject property. LRP2007-000/3 & ZON2007:000/2 25 5-26 ZONING MAP AMENDMENT CRITERIA OF APPROVAL - SDC 12.030 et seq. SOC 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 of approval: (a) Consistency with applicable Metro Plan policies and the Metro Plan diagram (b) Consistency with applicable Refinement Plans, Plan District 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, seNices 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 TIVE: The applicant's narrative for the Zoning Map Amendment is 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 (0 Refinement Plan policies is included below. Rather than be duplicative in this report, and for ease of review, Staff has attached the remaining portions of the 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 Amendment 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: The proposed 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 with applicable policies in the East Main Refinement Plan (EMRP). 1. Mixed-Use Element LRP2007-000/3 & ZON2007-00012 26 F,. 2I __ Policy 2) Area #2 A) The following land uses area1l0wed under Community Commercial zoning: A1I 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 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 Desianation 1. Generally, the Community Commercial refinement plan designation sha1l be applied under the f01l0wing circumstances: A) where iUs not an intrusion into we1l-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. B) where it does not 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. Approval 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 Residential land does not apply; Criteria for designating MDR land does not apply to the subject site. 0) where legal/y 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 I J & ZON2007-000' 2 ~28 , 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) Applysite-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. . Approval of the requested redesignation would apply Commercial plan designations to the subject properties, allowing the existing, legally established commercial uses on Tax Lot 402 to continue. It would also enable commercial uses to be established on Tax Lot 400, thereby defining the limits of new commercial uses between the pre- existing commercial uses on Tax Lot 402 and others to the west, and the developed industrial business park to the east. Tax Lot 400 does not have an existing or beneficial mix of uses, but has historically housed industrial yard-type operations. Therefore, approval of the proposal would define, the limits of new commercial uses as called for in the above policy, and also provide the ability to make ~uperior 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 Main Street, through the Site Plan Review process and in public improvement projects. The proposal would result in reducing the number of existing access points as required above. Through the Site Plan Review process, future development on Tax Lot 400 will have a single driveway access onto Main Street, eliminating one of the two existing curb cuts on this site. Sidewalks and street trees are already located along its Main Street frontage, consistent with the above policy. Policy 4) Provide buffering between commercial and residential uses through Article 31 of the 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 th.e 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 and retain existing jobs and businesses. Implementation The 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 LRP2007-000/3 & ZON2007-000/2 28 ~ -')0. 400 with higher than average wages and employment densities than the current designation and zoning allow$. STAFF'S FINDINGS RELATED TO COMPLIANCE WITH SDC 12.030(3)(b): Finding 22: As previously mentioned in this report, the subject property is located within the East Main Street Refinement Plan area. The applicant's narrative above discusses refinement plan Elements and Policies. Finding 23: The applicant references policies in the Mixed Use Element I Area 2. This area (Area 2) is located south of the subject property (across Main Street), and is not part of the subject property. Reference to this policy is not applicable to this application. ) Finding 24: The applicant discusses specific criteria listed in the refinement plan for commercial and industrial uses. Staff concurs with the applicant's narrative related to the commercial criteria. Finding 25: Criteria of approval for consistency with all applicable City of Springfield functional plans have been previously addressed in this report. As noted in the findings . in this report, the proposal is in compliance with all applicable functional plans. Conclusion: Based on the above findings, the proposed zone change is in compliance with SDC 12.030 (2). STAFF'S FINDINGS RELATED TO COMPLIANCE WITH SDC 12.030(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. 29 lRP2007-000 13 & lON2007-000 /2 ~-:3Q_ Finding 32: Solid waste management service is available at the subject property. The City and Sanipac have an exclusive franchise arrangement for garbage service inside the city limits. Finding 33: The site receives police protection from the City of Springfield, 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 jurisdiction. Finding 35: Qwest and Comcast currently provide telephone and cable communication service in this area for and an array of wireless companies provide a number of different communication services. The City has no exclusive franchise arrangements with telecommunication or wireless companies. The field is competitive and therefore guarantees a wide selection currently. . Conclusion: All key urban facilities and services required for the proposed rezone are available to the site. Any specific public and private improvement requirements and utility connection points will be determined when the property is developed. The proposal meets 12.030(3)(c). ZONING MAP AMENDMENT CONDTIONS OF APPROVAL: SDC12.040 SDC Article 12 allows for the Approval Authority to attach conditions of approval to a Zone Change request to ensure that the application fully meets the criteria of approval. The specific language from the code section is listed below: 12.040 Conditions of Approval The Approval Authority may attach conditions as may be reasonable necessary in order to aI/ow 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 approval 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 & ZON2007-000/ 2 30 h 3--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 fora zone change from LMI to CC is appropriate for the subject property and recommends the Planning Commission approve the attached Order and forward the proposed Zoning Map Amendment Application lON2007-00012 to the City Council with a recommendation for adoption. 3/ LRP2007-000/3 & ZON2007-00012 1::.1)1') EXHIBIT A-1 + 5.0 TRIP GENERATION AND DISTRIBUTION 5.0 TRIP GENERATION To determine the traftic impacts of a development ana roadway system, the number of vehicle movements resulting from the development must be estimated. These movements are referred to as "trips". Trip generation is the ~stimated volume of trips resulting from the development. The amount of trips expected to be generated by the propgsed development was determined using the information contained in the ITE T~ip Generation Manual, ih Edition. The equations in the manual predict the number oftrips generated based on the gross square feet of Hoar area. Separate trip generation analyses were, performed for the AM and PM peak hours for the development. Under the current Light-Medium Industrial zoning the develomnent s~te can be built out to include a variety ofland uses specitied in Springtield 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 ITE 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 Table 5: AM Peak Hour Trip Generation-Maximum Potentia,' of Site for Existing Zoning . ] Research and , Development '2~\~c3't'~r~~.illlt:~~~~~~~~.iI~ Health Fitness Club j[l~lliijl~f~f"IiWC" 492 4 T=1.21'x 5 0.42 0.58 .' 2 3 ., Total Trips 229 168 61 JR.H TMNSPOR.TATION ENG1NEER.ING I East5':'3:r~ld Rezone - Springfield, Oregon I March 6,2007118 + Table 6:' PM Peak Hour Trip Generation-Maximum Potential of Site for Existing Zoning \\lith the zone change the development 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 Oftlce Building. This was used in place of Land Use Code 630 - Medical Clinic becallse, after close inspection of the Trip Generation Manual, itwas detemlinedthat the sample size forthis 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 bee~ accounted for on the roadway in the background trat1lc volumes; therefore, no new development trips were assigned to this Tax Lot. . Table 7: Peak Hour Trip- Generation-Medical Office Building .' AM T=2.48*x 74 79% 21% 58 ;;,t1~!J=~,:}~I~g).lJ-.~:7~:~ {;!~4~ '1;'1~~~~;\]'f~~::;~~J There are 155 fewer ANI and 140 fewer PM vehicle trips generated by the medical oftlce building when compared to the maximum potential of the site under the current zoning, jR.H TP-ANSrOR.TATlON ENGINEER.ING 1 East Springfield Rez.one. Springfield, Oregon I March 6,2007119 5-34 EXHIk:S11 A-"J,. , 16 + 5.1 TR.IP DISTR.IBUTION AND ASSlGNMENT After determining the trip generation, the next step in the analysis requires distributing and assigning the trips to the existing traffic network. Trip distribution allocates the trips generated from the developments to generalized destinations. Trip assignment routes trips to these generalized destinations via the actual street network. The trip distribution for this project was based on the existing distribution pattern of the study area roadway network, where applicable. Access to Tax Lot 400 is assumed to be limited to a single full-movement access from Main Street. Figures 9 and 10 shows the assigned vehicle trips generated by the 30,000 square foot medical office building for the AM and PM peak period respectively.. q. 5.2 BUILD TRAFFIC VOLUMES To determine the Build traftic volumes the development trips assign~~ throughout the study area were added to the background traffic data. The year 2008 AM and PM Build year traftlc volumes are illustrated in Figures 11 and 12, respectivelY.qThe year 2023 AM and PM Build year traffic volumes are illustrated in Figures 13 and 14, respectively JRH TRANSrOR. TATION ENGINEER.ING I East Springfield Rezone. Springfield, Oregon I March 6, 20071 20 5...,.35 J::^MICII /-'I.-,j w -, .1 . \1.'. 'I 1 ~J Ij i ~; ~ I I EXHIBIT A-4 + I 7.0 TPR FINDINGS I I The folIo\.ving discusses the Oregon Administrative Ruling 660-012-0000, the Transportation Planning Rule, and the effect ofthe proposed development on the transportation facilities as it applies to the ruling. 660-012-0060 I I Plan and Land Use Regulation Amendments (lrWhere an amendment to a jimctional plan. an acknotvledged cOl~prehensive plan, or -a land use regulation would significantly ajfect an existing or planned transportation . facility, the local government shall put in place measures as provided in section (2) of this rule to assure that allowed land uses are consistent 'rvith the identified function, capacity, and performa/1ce standards (e.g. level of service, volwne -to capacity ratio, etc.) of the facility. A plan or land Zlse regulation amendment significantly affects a transportation facility if it would: I I I (a) Change the fimctional classification of an existing or planned transportation facility (exclusive of correction of map errors in a/1 adopted plan): I . The addition of development traffic on the adjacent roadways does not cause the change in functional classification of any of the transportation facilities. (b) Change standards implementing afimctionnl classification system: or - I The standards implementing a functional classification system within the project study area are not changed by the proposed development. I I I (c) As measured at the end of the planning period identified in the adopted transportation system plan: (.4) Allow land Llses or levels of development that would result in types or levels aftravel or access that are inconsistent with the fimctional classijkation of an existing or planned transportation facility; The proposed development does not result in types or levels of travel or access that are inconsistent with the functional classification of the studied transportation facilities. (B) Reduce the performance of an existing or planned transportation facility below the minimum clcceptable performance standard identified in the TSP or comprehensive plan: or The addition of developm~nt traffic does not reduce the performance of an existing or planned transportation facility below the minimum acceptable performance standard. JR.H TRANSPOR.TATlON ENGINEER.ING I East Springfield Rezone - Springfield, Oregon \ March 6,2007\ 31 5':'36- + (C) Worsen the performctnce of an e"~isting or planned transportation facility that is othenvise projec.ted to perform below theminimwn acceptable pelformcmce standard identified in the TSP or comprehem,:ive plan. . The addition of development traffic does not further degrade the performance of intersections projected to perform below the minimum acceptable performance . standard. As shown, the proposed redesignation of Tax Lot 400 and 402 does not result in a "signiticant 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 change and future development of the subject site in Springfield, Oregon. This development will include approximate ly 30,000 square feet of medical ot1ice space. The parcel proposed for development.is located east 61' 44th Street 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 completion amilysis, year 2008, for the roadway network within the study area. In addition, a horizon year analysis was performed for the year 2023. A performance analysis was completed for the intersections of Main Street and 42nd Street, Main Street and 48th Street, Main Street at 44th Street, and Main Street at 46th Street. The operational analysis of all intersections within the study area shows that under the Build condition 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 Build condition. A queuing analysis was performed for the intersection within the study area. The queuing analysis, which assumes the current lane configuration throughout the planning horizon, was 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 anticipated for the traffic demand, including the proposed development. According to the tinding under Oregon Administrative Rul ing 660-012-0000, the Transportation Planning Rule, the proposed redesignation of Tax Lot 400 and 402 does not result in a "'signiticant effect'. on the transportation facilities as detined in the TPR. jRH TRANSPORTATION ENGINEERING I East Springfield Rezone" Springfield, Oregan I March 6,2007132 5-37 EXHIBIT A-5 :~ III A :!1 , ~I ~~ 2~ ;] ~~ ~ I~' ~1 -~?! 11~ ~.:~ ,J) ~:r ..' ~j r~ ~~] ~1\ I[~ ;11 '{i ;3 I',~ .J~ )1'1 J 'f.t .-I~ :~ ~ d ..~ _:i .~ F' t I t. i I' I I 1.. i i I i I I f \ ! I I I EXHIBIT A-6 -Memorandum City of Springfield Date: - April 4, 2007 To: David Reesor, Planner III From: Gary McKenney, P.E., Transportation Planning 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 TIA are attached for reference. Traffic Impacts Analysis In estimating the trip-making potential of site development under existing LMI designation/zoning the TIA assume the land uses as depicted iu" 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). Recommendation: 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 TIA. If we find that the assumed Medical Office use would under-utilize the land, then we will want the TIA revised to reflect the impact of a true "reasonable worst case." Goal 12 TPR AnalysislFindings The PAPA application refers to the Goal 12 Endings contained in the TIA. 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 Building is much less intense than other uses that would be permitted in the CC zone. On a per-square-foot basis the MO is estimated to generate 2.47 vehicle tipsll,OOO SF arid 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 tips/l,OOO SF and 34.64 vehicle tips/l,OOO SF. 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. I'd like to discuss these ideas further in our meeting with Ed Moore. Gary 5-39 5/2512007 t:AnIDII J-\-? regon 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 File: T15-2 DATE: May 10, 2007 TO: Ed Moore Area 5 - Senior Planner FROM: Stephen B. Wilson,PE Region 2 Senior Traffic Analys East Springfield Rezone Traffic Impact Analysis 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 SUBJECT: These are review comments for the East Springfield Re'[,one 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 question, due to noted inconsistencies. ltis recoinmendcd this study be revised, taking into account these comments. Region 2 Tr~f.tic will need to review any revised traffic study, to ensure it complies with ODOT requirements, before is can be deemed acceptable. Page Paragraph 7 Table 1 8 Seasonal Adjustment 8 Peak Hours 11 Figure 4 Comment The classification of Main Street (OR 126)inust a1~0 be listed by the ODOThi hwa classification. . ' This study needs to demonstrate how the Seasonal Adjustmentfactors were applied to the raw traffic data. A graphic showing the. raw traffic volumes should also be included. . The peak hours assumed for this study seemreasonable; assuming the Peak Hour Factors were calculated off data from these assumed hours, and were the same for all intersections. The 2006 Existing PM Peak traffic volumes do not seem correct. As part of this review, calculations were made using the raw traffic data and the assumed Seasonal Adjustment factors, presented in this study. The review calculations were unable to confinn the traffic volumes resented in Fi!!Ure 4. See related comment for Pa e 8. ODOT does 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 least a mile of the stud area roadwa . 12 Section 3.1 5-40 EXHIBIT A-9. Page Paragraph Comment This stuqy must demonstrate how the Historical Growth Rates were 13 Growth Factors applied to the 2006 30111 Highest Hour traffic volumes. Calculations to confilm the 2008 and 2023 data were unable to duplicate the future volumes cited in this report. Existing. This report states the maximum development potential was determined for the property, given its current zoning of Light-Medium 18 Zoning Trip Industrial. For this scenario, how was the maximum allowable Generation development determined? 18 Table 5 The trip generation assumptions and output in this table are accurate. This study's trip generation analysis for the proposed zoning, assumed Proposed a 30,000 sf lv!edical O,/Jice Building wOllld be the only development on this s~te. To satisfy the requirements for a TPR-leve! analysis, the 19 Zoning Trip trip generation study for the proposed zoning must be for the Generation maximum allowable develooment on that site, given the City's development codes and regulations. Future The traffic volumes for all Future Build-Out data sets will need to be Build-Out nJa Traffic revised to account for corrections made 'to address the previous Volumes comments. The traffic data for this study is in question. Any analysis made from n/a Section 6.0 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 study. The scope of work for this TIA required 3-houl" Manual Classification -- Manual Count Count.s for all study-area intersections. However, a review of the rJa Data manual count data was unable to determine any tluck volumes or percentages. The tluck traffic in this study area is significant, and must be taken into account. A review ,of the Synchro output has noted several inconsistencies- throughout the analysis: . An Ideal Saturation Flow rate of 1900 pcphpl was assumed for both signalized intersections (421\d & 48110), while 1800 -,-. pcphpl was assumed for the two unsignalized intersections. .. The ODOT An.alysis Procedures Manual requires a saturation flow rate of 1800 pcphpl for all intersection analysis. rJa S ynchro . The truck percentages must be based on real-world data. The Analysis 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 126 approaches, and 4.0 seconds of yellow for the City-street approaches. The 5.0 seconds of yellow is generally reserved for highways with an 85111 Percentile Speed equal to, or greater than 45 mph- The TPR findings from this study are in question, due to the 31 Section 7.0 inconsistencies noted in this review. It is very likely they will need to be revised, based on the recommendations in this review. .5-41 t:^nll::1I1 r\-IU, , ,P:i;e" ,)fparll.graph '. ,,., "',,/,)::""-' '" .- ::'.:"',, :-,,"', .:,. Based on the previous comments in this review. . the conclusions 32 Section 8.0 drawn and recommendations proposed are in question. It is very likely they will need to be revised, based on the recommendations in this review, If you have any questions regarding my comments, please contact me by phone at (503) 986-2857 or by e-mail at stephen. b,'vvilson(W.odot.state, or. us . Cc: Jim Hanks - JRH David Warren Jane Lee Mike Spaeth DelU1is Santos File .- 5-42 FW: Springfield - East Springtield Kezone l1"'K }\IW.1Y::il::i L\.C:;V1C:;VY -- -'0" EXHIBIT A-11 REESOR David From: MCKENNEY Gary Sent: Tuesday, May 15,20074:28 PM To: REESOR David Subject: RE: Springfield - East Springfield Rezone TPR Analysis Review Attachments: LRP2007 -00012 Trans memo1.DOC David --- I believe Steve Wilson is thinking in the context of an unconditioned approval of the PAP NZC. Given the approach we planned to take in conditioning this approval, I think only Item #18 of his noted issues is relevant to ensuring Goal 12 compliance. This issue was discussed in my April 4, 2007 memo to you (copy attache,d). I assume you can respond to Steve's question on how we conclude that the assumed existing-zoning development scenario is no more intense than "worst case." If we condition the PAPA to limit trips to less than or equal to what would be generated by the "worst case," all the other issues appear moot. Gary . ,. -- .,.... -.~-'" .-....... ,- ---"'------_._--------..........-~.,.---~..""-- From: REESOR David Sent: Monday, May 14,2007 10:34 AM To: MCKENNEY Gary Subject: PH: Springfield - East Springfield Rezone TPR Analysis Review Gary- What are your thoughts on the attached memo? -DR . . ~-_h.,..,...,....-.........--,.,......,.-'---....,..,_.~--~..~-:_---,--,.",...~--..,..--.--.~.~-----..:,........,..---,...-:-------"'""'...,~~~.~,-...,-.,.."..-.-...,-,......,...~,:---..,-.-.-.-...,.~-:-.~~~-.~'"."..,..~'--.,..-~..,..--:~.~".."",.~ From: MOORE Ed W [mailto:Ed,W.MOORE@odot.state.or.us] Sent: Monday, May 14, 2007 8:06 AM To: REESOR David; MCKENNEY Gary Subject: PH: Springfield - East Springfield Rezone TPR Analysis Review FYI 5-43 5/25/2007 . -::>- . ~. . , EXHIBIT A-13 REESOR David -- From: MOORE Ed W [Ed.w.MOORE@odoLstate.or.usl Sent: Monday, May 21, 2007 3: 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 21,200711:49 AM To: MOORE Ed W (OR) Cc: MCKENNEY Gary .. Subject: PeaceHealth Plan and Zoning Map Amendment- Hi Ed- I just wanted to clarify with you ODOTs position on the PeaceHealth proposal (LRP2007 -00013 & ZON2007-00012). Based upon the meeting you and I had with Gary McKenney, we are all in agreement that the most appropriate way to address Goal 12 compliance on this proposal is by conditioning a trip cap to what the worse case scenario would be under existing zoning (LMI). Does this sound correct to you? Thanks, David Reesor Planner III City of Springfield 541.726.3783 5-44 5/25/2007 FW: Springfield - East Springtield KeZone TPK A1lalY~l~ Kl::YICW .&. -0"" ""- VJ,. .. EXHIBIT A-12 ---Original Message----- From: WILSON Stephen B Sent: Friday, May 11, 2007 10:03 AM To: MOORE Ed W - Cc: jimhanks@jrtlweb.com; WARREN David; LEE Jane S; SPAETH Michael A; SANTOS Dennis N Subject: Springfield - East Springfield Rezone 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>> Stepfien $. W~cm, :fE Senior Transportation Analyst ODOT - Region 2 Tech Center 455 Airport Road SE - Building I A' Salem, OR 97301-5397 (503) 986-2857 5-45 5/25/2007 .-, j II PeaceHealth March 15, 2007 Type II Metro PlanlEast Main Refinement Plan Diagram Amendments Written Explanation of the Proposal Applicant: , PeaceHealth Oregon Region th . 770 E. 11 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 Representati ve: Philip Farrington, AICP Director, Land Use Planning & Development PeaceHealth Oregon Region 123 international Way Springfield, Oregon 97477 (541) 686-3828 * Fax (541) 335-2595 pfarrington@peacehealth.org . 1.0 Land Use Request PeaceHealth Oregon Region (the "Applicant") requests approval to change the map designation on the Metropolitan Area General Plan ("Metro Plan") diagram from Light Medium Industrial ("LMI") to Community Commercial ("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 (l)(a)1. 5-46 Metro PlanfEMRP Diagram Amendment PeaceHealth Oregon Region March 15. 2007 Page 2 The area subject to the proposed land use designation changes is mapped on Attachment A, and is referred to collectively in this application as the "subject properties" or "site." Pursuant to SDC 7.110 (4), approval of the requested Metro Plan diagram amendment automatically amends the refinement plan diagram and is processed concurrently. Findings of fact 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 to East Main Refinement Plan The Applicant seeks to redesignate and rezone the subject properties to CC so they may be developeci for commercial uses (i.e., Tax Lot 409), 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 empfoyment and existing viable' commercial operations on Tax Lot 402, and create stable family-wage employment opportunities on Tax Lot 400 _ a vacant and underused industrial site. The proposal would also help beautify this. ;' portion of Main Street from its traditio~1a1 industrial yard uses, and future development would provide a superior buffer for residential uses to the west than currently exists. The proposal is also consistent with the East Main Refinement Plan (EMRP) criteria for designating property as Commercial within the 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 Lot 402 borders only Tax Lot 400 and two commercially zoned parcels, so legitimizing the pre-existing commercial uses on that property would not affect the existing residential area nearby. b) It does not increase conflict between Low Density Residential and Commercial uses, but in fact can provide for uses and development far superior to those that have traditionally been located adjacent ~o the abutting residential area. Moreover, the area abutting Tax Lot 400 to the west is zoned Medium Density Residential, though in primarily low density residential use. c) The criteria for designating Medium Density Residential land does not apply because the subject' properties are not currently developed, nor have they ever been designated, for MDR uses. d) Legally created commercial uses have existed on the properties, and the proposal would facilitate higher quality commercial uses (such as medical offices) than have existed before on Tax Lot 400, and allow for Plan designations and zoning to correspond with long-standing legally established commercial uses on Tax Lot 402. e) Adequate access exists to Cin arterial street, with existing curb cuts directly onto Main Street. 5-47 -- Metro PlanJEMRP Diagram Amendment PeaceHealth Oregon Region March 15.2007 Page 3 f) Upon approval ofthis request, the site would .have a Commercial designation on the Metro Plan diagram. The proposal is also consistent 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 beneficial range of commercial and employment- generating uses on the subject properties. It would also improve the area and better distinguish and buffer adjacent residential and industrial business park uses. 3.0 Site Context- The subject properties include a 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; o~ the east by the Hyland Business Park, on the north by un 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 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 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 LMl. The areas irriIDediately to the west and south of the site fronting Main Street are identified as being within Mixed-U se Area #2 in the EMRP, and are all zoned Community Commercial. Property to the west of Tax Lot 400 along 44th Street is zoned and designated Medium Density Residential. 5-48 Metro PlanlEMRP Diagram Amendment PeaceHealth Oregon Region March 15.2007 Page 4 4.0' Type II l\''letro 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 s~te-specific amendment because it: . Involves a specific geographically identi.fiable property; . Does not change the metropolitan Urban Growth Bou,ndary; . Does not change the Metro Plan jurisdictional boundary; . Does not require a goal exception; . Does not include a 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 defined in SDC 7.030) that must be reviewed and approved by the City of Springfield, consistent with SDC 7.070 (2)(a). Per SDC 7.040 (2)(b), this citizen-initiated Type II Metro Plan 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 provides: "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." Findings demonstrating consistency with the approval criteria are outlined below. 5...;49 - .. Metro PlanJEMRP Diagram Amendment PeaceHealth Oregon Region March 15.2007 Page 5 5.1 Consistency 'Vith Statewide Planning Goals The following findings address compliance with Metro Plan criteria in SDC 7.070 (3)(a). Approval of a Metro Plan diagram amendment also correspondingly changes the applicable refinement plan diagram, as established in SDC 7.110 (4). Goall - Citizen Involvement Goal 1 addresses the need to develop a citizen involvement program to ensure citizen . involvement in all phases of the land use planning process. The Planning Commission and the City Council will hold public hearings and accept testimony on the proposal. Through the procedures established by the city, citizens will receive notice of hearings in generally published local papers and have the opportunity to be heard regarding the . proposed diagram amendment and zone change. Notice of the public hearings will also be given in accordance with SDC requirements to nearby property owners, interested parties requesting notice, and any ~stablished 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. Goal2 - Land Use Planning Goal 2 requires that local comprehensive plans be consistent with the Goals, that local comprehensive plans be internally consistent, and that implementing ordinances be consistent with acknowledged comprehensive plans. Goal 2 also requires that land use decisions be coordinated with affected jurisdictions and that they be supported by an adequate factual base. As required in SDC 7.050, the City is required to give referral notice of the proposed Type II Metro Plan diagram amendment to the City of Eugene and Lane County so they may determine if there are grounds to participate as parties to the hearing. The 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 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 for approval of the proposed Metro Plan diagram amendment. As discussed elsewhere in this document, the amendments are consistent with the Metro Plan and the Goals. Consequently, by demonstrating such compliance, the amendments satisfy the consistency element of Goal 2. Goal3 - 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 PlanlEMRP Diagram Amendment PeaceHealth Oregon Region March 15.2007 Page 6 Goal 4 - Forest Lands Goal 4 does not apply within urban growth boundaries, per OAR 660-06-0020, and the areas affected by the Plan amendments are inside Springfield'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; (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 Goal 5 inventory. No threatened or endangered species have been inventoried on the site, and no archeological or significant historical inventoried resources are located on the site. The National Wetland Inventory and Springfield Local Wetland Inventory maps have been consulted and there are no jurisdictional wetlands located on the site. Therefore, the proposed amendment does not alter the City's compliance with Goal 5. Goal 6 - Air, Water, and Land Resources Quality The purpose of Goal 6 is to maintain and improve the quality of the air, water and land resources ofthe 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. Though Tax Lot 400 has been used for low-value storage and quasi-industrial uses, the site is not listed on any state or local environmental clean-up list. A Phase I environmental assessment on the subject property was conducted 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 reasonable to conclude that future development on the site will be able to demonstrate compliance with 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 PlanlEMRP Diagram Amendment PeaceHealth Oregon Region March 15.2007 Page 7 Goal7 - Areas Subject to Natural 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 r~quires that plans be based on an inventory of known areas of natural disaster and hazards, such as areas prone to landslides, flooding, etc. The site is flat and not subject to landslide hazards, and is located well outside of any established FEMA flood hazard area. Therefore, approval of the proposed Plan amendments will not alter the City's acknowledged ~ompliance with Goal 7 through its adopted plans, codes and procedures. Goal 8 - Recreational Needs -Goal 8 requires local governments to plan and provide for the siting of necessary recreational facilities to "satisfy the recreational needs of the citizens of the state and visitors," and where appropriate, provide for the siting ofrecreational facilities including destination resorts. The subject site is not included in an inventory of recreational sites, and the 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 of CC in place of the existing industrial designation. Permitting the construction of future clinic facilities and allowing long-standing commercial uses on Tax Lot 402 to become conforming uses consistent with commercial zoning is consistent with numerous policies in the City's adopted plan for compliance with Goal 9, the Springfield Commercial Lands Study (SCLS). Specifically, the followi'ng SCLS policies are applicable to the proposal: Policy I-A: "Maintain a mixed supply oflarge and small commercial sites through strategies such as rezoning or annexation to serve Springfield's future population." The proposal fulfills this policy objective by redesignating and - through accompanying zone change _ rezoning land from industrial to 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 I-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." 5-52 Metro PlaniEMRP Diagram Amendment PeaceHealth Oregon Region March 15.2007 Page 8 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 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 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. finding 3 in the SCLS (pg. 36) cited the acknowledged 1992 Iridustrial Land Study as demonstrating that "a surplus of industrial sites exists in the Metro Area." Therefore, the proposed redesignation (and corresponding rezoning) would notresult in a deficit of needed industrially designated and zoned land, but it would help reduce the commercial lands deficit identified in the SCLS. Therefore, approving the proposal would be consistent with SLCS Implementation Strategy 3-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 proposal in fact consistent with inventories for commercial and industrial lands - adopted by the City Council and acknowledged by DLCD as being consistent with Goal 9. Oregon Administrative Rules concerning Goal 9 implementation (OAR 660-009- 0010(4)) call for amendmerits to land use designations "in excess of two acres within an existing urban growth boundary from an industrial land use designation to Ii 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 existing and 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 amendment without the need for an economic opportunities analysis apart from the SCLS, which DLCD acknowledged as fulflllingthe 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 be consistent with relevant Metro Plan policies, approval of the request is consistent with the City's compliance with Goal 9 and applicable administrative rules regarding Goal 9 implementation. 5-53 - Metro Plan/EMRP Diagram Amendment . PeaceHealth Oregon Region March 15,2007 Page 9 Goal 10 -Housing LCDC's Housing goal requires cities to maintain adequate supplies of buildable lands for needed housing, based on an acknowledged inventory of buildable lands. The proposal does not affect the City's inventory of residential lands. In fact, approval of the requested redesignation for Tax Lot 400 would enable redevelopment of an industrial site abutting existing residential development. Through the site plan review process, future development on that property will provide a superior buffer and a higher use that will benefit the adjoining residential properties. Because the proposal involves redesignation from industrial to commercial land uses, it does not affect Springfield's continued co~pliance 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 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. Goal 12 _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 commercial 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 the attached Traffic Impact Analysis (TIA) demonstrates, future development of medical office facilities on TL 400 will not degrade mobility standards below acceptable levels and allow for adequate queuing lengths at applicable intersections. Therefore, the proposal will not have a "significant effect" on transportation facilities as ' defined in the Transportation Planning Rule (OAR 660-012-060). Existing development at Tax Lot 402 is not affected by the proposal, and is assumed to retain its current access points off Main Street. It is further assumed that future 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 ofthe 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 Ref1l1ement Plan (EMRP) 5"':54- " Metro PlanlEMRP Diagram Amendment 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 cfemonstrated in the TIA, is consistent with the requirements of the TPR and with applicable policies in the EMRP, it is consistent with Goal 12 and applicable local implementing policies. Goal 13 - Energy Conservation The Energy goal is a general planning goal and provides limited guidance for site-specific map amendments. The proposed amendment has no direct impact on energy conservation, though it would in fact will promote greater energy efficiency by enabling needed clinical services available to growing resid~ntial areas in east Springfield. Therefore, the proposed amendment is consistent with, and does not alter the City's continued compliance with Goal 13. Goal 14 - Urbanization Goal 14 requires local jurisdictions to provide for an "orderly and efficient transition from rural to urban land use." The subject property is within the UGB and the city limits of Springfield, and within an existing urbanized area of the community. Therefore, Goal 14 is not applicable to this application. Goal 15 - Willamette River Greenway This goal is inapplicable because the subject property is not within the boundaries of the Willamette River Greenway. Goals 16-19 - Coastal Goals The coastal goals are .not applicable to this application. 5.2 Metro Plan Consistency The application requests amendment of the Metro Plan diagram from LMI to CC for approximately 5.24 acres. This section of the application narrative addresses the consistency of the amendment with the applicable policies of the Metro Plan, to demonstrate that adoption of the amendment will not make the Metro Plan internally inconsistent (as required by the approval criteria in SDC 7.070(3)(b)) This narrative only addresses those policies that apply to the proposal, and does not discuss those portions of the Metro Plan that: (1) apply only to rural or other lands outside of the urban growth boundary, (2) apply to land uses other than the current or proposed designations for the site and will not be affected by the proposed Plan diagram and text amendments, or (3) clearly apply only to specific development applications (e.g., site plan review submittals or subdivisions). In many instances the goals, policies and implementation measures apply to specific development proposals that will be addressed 5-55 Metro PlarJEMRP Diagram Amendment PeaceHealth Oregon Region March 15,2007 Page 11 through compliance with applicable City regulations during site plan review of a given future development proposal. The Metro Plan Introduction, Section D provides the following definitions: A goal as a broad statement of philosophy that describes the hopes of the people of the community for the future of the community. A goal may never be completely attainable, but is used as a point to strive for. An objective is an attainable target that the 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 they appear in the Plan Element section of the Metro Plan. S.2.A. IVletro Plan Elements 1. Growth Management , Policies }. The urban growth boundary and sequential development shall continue to be implemented as an essential means to achieve compact urban growth. Provision of all urban services shall be concentrated inside the urban growth 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 resulting approval of from this application. The City's site plan review processes ensure that the appropriate level of services is available to serve future development. 5-56 Metro PlarJEMRP Diagram Amendment PeaceHealth Oregon Region March 15.2007 Page 12 2. Residential Land Use and Housing Element Policies A.ll Generally locate higher density residential development near employment or commercial services, in proximity to major transportation systems or within transportation-efficient nodes. The proposed redesignation does not affect the inventory or availability of residentially designated or zoned land, including the single-family residential area abutting Tax Lot .400 that is zoned and designated for Medium Density Residential, or higher density residential developments located east of the site along Main Street. However, approval of the requested redesignation to Community Commercial would allow for residential areas proximate to the subject area to have close and efficient access to existing commercial services on Tax Lot 402 and to future medical facilities proposed for Tax 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 transportation system that can suppo,rt the needs of nearby residential development. A.22 Expand opportunities for a mi.--c of uses in newly developing areas and existing neighborhoods through local zoning and development regulations. The map amendment and concurrently proposed zone change will allow for existing commercial uses on Tax Lot 402 to continue to serve existing neighborhoods in the mid- and east-Springfield area, and for future clinical facilities to be developed to serve this rapidly growing area of the community. Approving the requested redesignation and zone change would expand commercial opportunities to serve these neighborhoods consistent with the above policy. 3. Economic Element Policies B.l Demonstrate a positive interest in existing and new indllstries, especially those providing above-above wage and salary levels, and increased variety of job opportunities, a rise in the standard of living, and utilization of our existing comparative advantage in the level of education and skill of the resident labor force. 5-57 .- Metro PlaniEMRP Diagram Amendment PeaceHealth Oregon Region March 15.2007 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 redesignation 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 locaJ 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 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 Lands Study concluded that there is a deficit of needed commercial land, and a surplus of industrially zoned and designated land. Approval of the 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 the need and suitability, and availability of the subject site for commercial uses with the need for such uses as demonstrated in the adopted SCLS. B.ll Encourage economic activities which strengthen the metropolitan area's position as a regional distribution, trade, health, and service center.- The amendment will facilitate the development of medical uses that will serve the needs of the growing residential areas in east, south and southeast Springfield, and strengthen the metropolitan area's position as a premier locale for healthcare services, consistent with this policy objective. 6. Environmental Design Element Policies E.] 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 planning policies. 5-58 Metro PlaniEMRP Diagram Amendment 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 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 developmen~ along major transit corridors and near transit stations; medium- and high-density residential development within one-quarter mile of transit stations, major transit corridors, employment centers, and downtown areas; and 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 the proposal will allow for higher intensity development along Main Street, a major transit corridor. An existing L TD stop is located on the frontage of Tax Lot 400 (see photo, pg. 2, Appendix A ofthe T1A), and will provide convenient access to existing and projected employment on the subject site, as well as access for patients to future out-patient medical facilities projected on Tax Lot 400. 5~8 Metro Plan/EMRP Diagram Amendment PeaceHealth Oregon Region March IS. 2007 Page 15 Transportation System Improvements: Roadways Policies F.l5 NIotor vehicle level of service policy: a. Use motor vehi~le level of service standards to maintain acceptable and reliable performance on the roadway system. These standards sh(zll be used for: (1) Identifying capacity deficiencies on the roadway system. (2) Evahwting the impacts on roadways of amendments to transportation plans, acknowledged comprehensive plans and land-use regulations, pursuant toCthe 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 (CATS) area, and LOS D elsewhere. c. Performance standardsfrom the OHP shall be applied on state facilities in the Eugene-Springfield metropolitan area. In some cases, the level of service may be sl~bstandard. The local government jurisdiction may find that transportation system improvements to bring performance up to- standard within the planning horizon may not be feasible, and safety will not be compromised, and broader community goals would be better served by allowing a substandard level of service. The limitation on the feasibility of a transportation system improvement may arise from severe constraints, including but not limited to environmental conditions, lack of public agency financial resources, or land use constraint factors. It is not the intent of ISI Raodway Policy #2: i\-'fotor 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 develop an alternative mi.'C of strategies (such as: land use measures, TDi\-'l, short-term safety improvementJ) to address the problem. Subsection a.(2) in the above policy requires an evaluation of the proposal pursuant to the state Transportation PlatU1ing Rule (TPR). The accompanying Traffic Impact Analysis 5-60 Metro PlanlEMRP Diagram Amendment PeaceHealth Oregon Region March 15.2007 Page 16 provides the factual basis to determine that the proposed redesignation would not result in a "significant effect" as defined under the TPR (OAR 660-012-0060(1)). Specifically, the proposal does not change the functional classification of Main Street or any other nearby roadway, and it does not change the standards for implementing the City's functional classification system of roadways, as identified in the Regional Transportation Plan. As demonstrated in the TIA, the proposal also does -not: . Result in types or levels of traffi c or access that are inconsistent with the functional classification 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 zonmg. Specific TPR findings are further located in the TIA, see pp. 31-32. Because the proposal does not result in a "significant effect" as established by applicable OARs, no further TPR analysis is required. The request is therefore consistent with the above policy. 8. Public Facilities and Service Element G.] 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 II-B, relevant policies in this chapter and other N! etro Plan policies. The subject property is located in SpringfielCl'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 on Tax Lot 400. Therefore, the proposal is consistent with the above policy. >" 9. Parks and Recreation Facilities Element Policies Policies in this element of the Metro Plan are not relevant to the requested 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 PlanlEMRP Diagram Amendment PeaceHealth Oregon Region March 1 5.2007 Page 17 11. Energy Element Policies Policies in this element of the Metro Plan are not relevant to the requested diagram amendment. 8.0 East Main Refinement Plan Consistency The following demonstrates how the proposal is consistent with applicable policies in the East Main Refinement Plan (EMRP). 1. Mixed-Use Element Policy 2) Area #2 A) The following land uses are allowed under 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 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 (or Commercial Refinement Plan Desif!nlltion . 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 Metro PlanlEMRP Diagram Amendment PeaceHealth Oregon Region March IS, 2007 Page 18 B) where it does not increase conflict between Low Density Residential and Coirlmercial; 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 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 11r!edium 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 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. F) where designated Commercial on the Nfetro 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 refinement plan designations to clearly define the limits of new commercial uses where there is not an existing, legally established, and beneficial mix:ing 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. Itwould also enable commercial uses to be established on Tax Lot 400, thereby defining the limits of new commercial uses between the pre-existing commercial uses on Tax Lot 402 and others to the west, and the developed industrial business park to the east. Tax Lot 400 does not have an existing or beneficial mix of uses, but has historically housed industrial yard-type operations. Therefore, approval of 5-63 Metro PlarVEMRP Diagram Amendment PeaceHealth Oregon Region March 15.2007 Page 19 the proposal would define the limits of new commercia] 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 iv!ain Street, through the Site Plan Review process and in public improvement projects. The proposal would result in reducing the number of existing access points as required above. Through the Site Plan Review process, future development on Tax Lot 400 will have a single driveway access onto Main Street, eliJIlinating one of the two existing curb cuts on this site. Sidewalks and street trees are already located along its Main Street frontage, consistent with the above policy. Policy 4) Provide buffering between commercial and residential uses through Article 31 of the 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 and retain existing jobs and businesses. . Imvlementatiol1 The City shall maintain a current inventory of vacant commercial and industrial land and structures within the East N!ain 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 02 32 2 4 /3S/. 02 " 77..9,"",.. S/~. /4~ SOO. .e J4 9.8~" 401 501 1 . f , I ~ I ~ ,2 J , I I , J ~ It) ,,- I - ir\' t'\ ~ , I ~ t.. J 9:l " " ' , ~~I ,8 ~ 11'\ " . .~ ~~ ~ ~. lq' ~ ~ T')~ ~I en ~ 5M ITH EXISTING (~. / . 9.9fJdJ t . NE COOR./ -.&93 "I. . TD EDWARDS NW COR. ~ AWHAMM v D.L.C. 55 D.LC. 36 100 ~ ~ , ~ ~~, 'ti ~ .. ~ ~ ' ~ ~ " 00 to C\J d z o I~ cr ". .,.... f_ ~.,:!,..;.:..;.:.,: ',::. \:l~: ~:.:' >- }- z ::> /8 . ::.......'...- ..j.':..~::<::t. ......:.'..,'.,.,. .. Community Commercial Light Medium Industrial i""'" M d" D "t . !irki e lum ensl y Residential 02 32 2 4 /-S'S/, 02 77.9C>~" S/4./4' SOD. 2 , I "';>49.8'<' J 401 501 J f , , I I(l ~ I I .2 I I , J Ir) I ~ frI' ~ I , ~ , ~ t-- I :t " '~I ~ , " ' It\ t... , ,8 ~ " . . ~ 'tl ~. ~~ ~ ~. ~ ~I ~ 1)<); fIi t-= ~ '\ UJ --- /35/. 3SCr 5M ITH PROPOSED NE C~R./ ~z~~;.-",~ TD EDWARDS AW HAMM ~ D.L.C. 55 D.Le. 36 100 , 00 ~ J'<) , ~ N .~~ ~ d ~ ~ z l ~ ..... "- ~ CJ -.-.. \. c:r 0 cr >- }- z ::> 0 (,) II Community Commercial Light Medium Industrial Medium Density Residential Metro Plan / 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 :.9'4 OI_.',_ll~ _lMi"'IIlllll._I'C"'-- ~._':'::"':;:'::;' t,Jq......__J~_ ~O..;l,_ . .. ~~,:,,~.~~ 1 5-67 ., ~~:-\.....--_-.....~~(CIQ -~.."= ,~;~_d__ . ,--- --.-... 5-68 2 3 5-69 Questions? 4 5-70 "'- Propelc/Planning & Development 11 Pea(:eHealth March 28, 2007 David Reesor, Planner IT City of Springfield Development Services Department 225 Fifth Street Springfield, OR 97477 Re: Plan Amendment (LRP2007-00013), Zone Change (ZON2007-00012) Mr. Reesor, The following and attached is supplemental information for the ~~ove-referenced applications for proposed Metro Plan diagram amendment and zone change in east Springfield. The proposal seeks to redesignate and rezone approximately 5.24 acres on two parcels from Light-Medium Industrial (LMI) to Commercial. As noted in the application findings submitted last week, the Springfield Commercial Lands Study demonstrates that the City has a deficiency in needed commercially designated and zoned land, so approving the proposal would help reduce 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 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 constraint-free industrial acres.. ..This supply exceedsthe projected demand over the next twenty years, which is behveen 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-term industrial demand. This portion of the supply also exceeds the twenty year demand projection." The City performed subsequent analysis of industrial land supply as part of periodic review requirements to demonstrate compliance with statewide planning Goal 5 (Natural Resources). As shown in Attachment A, that analysis indicated that even removing the possible industrial acreage affected by 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. Staff s GoalS work also calculated the changes in industrial land supp lies 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, DedicCI{edro E\Cepliol7C1j j\.k:dicinr? - and CompClssiol7u{r? Core Phone (541) 3:35-2593 F:lX: (541) 335-2595 River8end Annex 123 International Way Springfield.. OR.. 97477 www.peacehealthorgloregon 5-71 suggesting that there is still anample supply of available industrial lands to meet existino ... 0 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 ofLMI zoned and designated land due to City Council approval in April 1997 for land east of the th - t 28 /315 Street connector and north of Mar cola Road (Ordinance No. 5851). Insofar as the City and metropolitan area continue to enjoy a surplus of needed Industrial land, and specifically Heavy Industrial zoned and designated land, the above-referenced change added more than enough acreage to the inventory of LMI _designated and zoned land to off-set the proposal to remove only about 5 acres from the LMI inventory. We therefore respectfully submit that the proposed Metro Plan diagram amendment and zone change will not materially affect the inventory of needed Industrial land and will not alter the City's continued compliance with Goal 9.. ' With acceptance of the above findings and earlier findings and narrative in the prior submitted applications, we believe the applications are complete and ready to be set for Planning Commission hearing. Please notify me when the hearing is set, and send me a copy of the required hearing notice to DLCD for my files. Thanks for your consideration of the above. If you need additional information, please contact me at your convenience. . Re~j'_ h_~ p~;r~t.~- r- Director, Land Use Planning & Development PeaceHealth Oregon Region : Attachments 5-72 A TT ACHMENT A 11.0 Impact of the Proposed Protections on Buildable Umd Inventories This section estimates the impact of the recommended pro gram for protecting Springfield's resource areas on the inventory of buildable residential, commercial and industrial land. The administrative mle quoted above is somewhat vague about how to compute the impact. Some cqntend 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 surplus of buildable land that was determined at the adoption of the inventory. Case law supports subtracting the protected acreage from the surplus of buildable land. Tables ll-l, 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 Residential Land Supply Acres Eugene-Springfield Metropolitan Area Residential Lands and Housing Study Surplus Acres Low Demand Assumption 1862.00 or or High Demand Assumption 790.00 Acres Removed from Residential Designation by Previous Plan Amendments* Eugene -84.90 Springfield -52.03 Total - -136.93 Maximum Possible Residential Acres Iri1pacted by -445.77 Eugene GoalS Protection Measures Maximum Possible Residential Acres Impacted by Sprin!!field GoalS Protection Measures -14.18 Remaining Surplus 1265.12 or 193.12 5-73 Table 11-2. Analysis of Maximum Possible Impact on Supply of Commercial Lands within the Springfield Urban Growth Boundary Commercial Land Supply Acres Springfield Commercial Lands Study (2000) projects a deficit of -158 acres commercial land. Acres Removed from Commercial Designation by Previous Plan -2.8 acres Amendments* Maximum Possible Commercial Acres Impacted by Springfield's -11.56 acres GoalS Protection Measures Remaining Surplus (Deficit) (-172.36 acres) Table 11-3. Analysis of Maximum Possible Impact on Supply of Industrial Lands within the Eugene-Springfield Metropolitan Area Industrial Land SupplY Acres Metropolitan Industrial Lands Inventory Report Surplus Acres Low Demand Assumption 2954.28 or or High Demand Assumption 2432.28 Acres Removed from Industrial Designation by Previous Plan Amendments* Eugene -642.30 Springfield -90.80 Total -732.80 Maximum possible Industrial Acres Impacted by Eugene GoalS Protection Measures -44.73 Maximum Possible Industrial Acres Impacted by Springfield Goal 5 Protection Measures -54.43 Remaining Surplus 2122.01 or 1600.01 * 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 Puea Residential Land and Housing Study (Residential Lands Study) estimated the amount of vacant buildable residential land in the area. In Springfield, a total of 3,087 acres of buildable lands were identified. The Study classified wetlands listed on the Springfield Local Wetland Inventory as unbuildable and'were not included in the estimated supply 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 of 230 KV power lines; . Land within 75 feet ora Class A stream or pond; . Land within 50 feet of a Class B stream or pond; and . Small irregularly shaped lots. Since the Residential Lands Study did not include wetlands listed on the Local Wetlands Inventory in the buildable lands inventory, 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 Table11-4 below, about 9.95 acres oflow-density residential (LDR) and .59 acres of medium density residential (1'lDR) land will be removed 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 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 removed 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 stormwater quality protection policies. The combined impact of the proposed 25-foot setbacks for wetlands and riparian areas is 14.18 acres. This represents .45% of the 3,087 acres of buildable residential land described in the 1999 Residential Lands Study. In May 2004, a Residential Lands Study Monitoring Report was published, updating the residential lands inventory to reflect development through 2003. The report estimated that at the end of 2003 there was 1,361 acres of remaining buildable residential land in Springfield. The amount of land removed from the buildable inventory by the 25-foot wetland and riparian setbacks proposed by this report represents about 1 % of remaining 1,361 acres. 5-75 Table 11-4. Vacant Residential Land within Proposed Protection Setbacks Setback Distance V acan t Vacant Total Acres LDR lVID R Acres Acres- 'rVetland Setbacks 25 foot 9.95 .59 10.54 50 foot 9.4 2.73 12.13 75 foot 4.97 4.15 9.12 Total 24.32 7.47 31.79 Riparian Setbacks 25 foot 3.42 .22 3.64 50 foot 6.06 2.73 8.79 75 foot 4.97 4.15 9.12 Total 14.45 ~ 7.1 21.55 Grand Total 38.77 14.57 53.34 11.2 Impact on the Commercial Lands Inventory The Springfield Commercial Lands Study (2000) listed several types of development constraints that affected commercial properties. These development constraints included: Major transmission lines; Hazardous waste sites; Slopes greater than 15%; Lots less than 6,000 square feet in size; Lots with poor visibility; Lots with inadequate access; Hydric soils; . Unstable soils' , Willamette Greenway and Greenway setbacks; Floodway and floodway fringe; Wellhead zone of influence; Wetlands listed on the Springfield Local 'rVetland 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, since they were part of the draft Springfield Inventory of Natural Resource Sites at the time Commercial Lands Study was conducted. 5- 76 - Since the Springfield Commercial Lands Study did not remove wetlands and riparian. sites, protection measures proposed by this study willhave an impacton the inventoried acreage of vacant commercial lands. The development setbacks recommended for significant wetland and riparian sites will further reduce the inventoried acreage of vacant buildable commercial land adjacent to these resource sites. The extent of this impact is discussed below. The Commercial Lands Study concluded that there was about 85'acres of vacant buildable commercial land in 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 was 255 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 commercial land 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 stonnwater facilities or required landscaping within the recommended setbacks, thus reducing or eliminating lost development area. The total impact on the Commercial Lands Inventory would be a reduction of 1.54 acres if wetland 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 Stonnwater Quality Management program. Therefore, no commercial acreage is removed from the Commercial Lands Inventory by the implementation of proposed protections in this study. As noted in Table 11-5, no vacant commercial land will 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 Larld within Proposed Protection Setbacks Zoning District Site 25 ft. 50 ft. 75ft. Total Acreage Setback Setback Setback Acres Wetlands Community .071 1.47 .11 0 1.65 5-77 . Zoning District Site 25 ft. 50 ft. 75 ft. Total I Setback Acreage Setback Setback Acres Commercial Neighborhood 0 0 0 0 0 Commercial General Office 0' 0 0 0 0 Major Retail 0 0 0 0 0 Commercial' 'Wetland Total 0.07 1.47 0.11 0 1.65 Riparian Areas ComIIlUnity 2.78 0 0 2.6 5.38 Commercial Neighborhood 0 0 0' 0 0 0 Commercial General Office 0 0 0 0' 0 0 Major Retail 0 0 .24 0 .24 Commercial Riparian Total 2.78 0 0.24 2.6 5.62 Grand Total 2.85 1.47 .35 2.6 7.27 11.3 Impact on the Industrial Lands Inventory The 1992 Metro Area Industrial Lands Study assessed the supply and demand for industrial land in the greater Eugene-Springfield area. The Shldy 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 Stonnwater 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 GIS analysis shows that 13.70 acres of vacant industrial land are affected by riparian areas are that not already protected by the Springfield Stonnwater Quality Management (SQM)program. These riparian areas are recommended for protection by a 25-foot ' development.setback under the Springfield Natural Resources Study. These setbacks add another 3.27 acres to the amount o'findustrial zoned landthat 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 16.97 acres. Table 11-6 shows the total acreage for land affected by riparian corridors and the acreage protected by setbacks from both this program and the existing SQM program. Total Impact Th~ 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 and their 25~ft setbacks were fully . protected. This represents less than 1 % ofthe 709 acres of buildable industrial land for Springfield in the Industrial Lands Study. Table 11-6. Vacant Industrial Land within p~oposed Protection Setbacks Zoning Total Site 25 ft. 50 ft. 75ft. Total District Wetland Acres not Setback Setback Setback Acres Site Protected Acreage by SQM 'Wetlands Light- 28.20 (27;76) 4.81 .82 0 33.83 Medium Industrial Heavy 13.16 (2.88) 2.01 19.15 0 34.32 Industrial Campus .35 0 0 1.28 0 1.63 Industrial Special 0 0 0 0 0 0 Heavy . Industrial Quarry 0 0 0 0 0 0 Mining Booth Kelly .13 0 0 .47 0 0.60 MU 'Wetland 41.84 (30.64) I 6.82 21.72 0 70.38 Total Riparian Total Site 25 ft. 50 ft. 75 ft. Total Areas Riparian Acres not Setback Setback Setback Acres Site Protected Acreage by SQM 5-79 Zoning Total Site 25 ft. 50 ft. 75 ft. Total District Wetland Acres not Setback Setback Setback Acres Site Protected Acreage o by SQM Light- 16.48 (19.89) 2.05 4.72 1.26 24.51 Medium Industrial Heavy 68.31 (2.81) 1.22 8.93 0 78.46 Industrial Campus 3.22 0 0 2.83 .03 6.08 Industrial .. , Special 0 0 0 0 0 0 Heavy " Industrial Quarry ., 0 0 0 0; 0 0 Mining . ' Booth Kelly. .21 0 0 .82 0 1.03 MU ~parian 88.22 (13.70) 3;27 17.3 1.29 110.08 Total , Grand Total 130.06 (44.34) 10.09 39.02 1.29 180.46 .. 5-80 I Metro Plan Diagram Changes Affecting the Su 01 I co ~ Local File Number LOR 90-04-058 90-12-201 92-04-77 5,3 93-01-330,5 93-01-12 3.7 93-06-087 94-10-0194 95 02-036 95 02-036 95-02 036 95-02-036 95 02-036 95-08-0157 97-05-101 99-02-038 99-02-041 99-09-230 02-03-0062 02-03-0063 02-07 -200 02-08~243 LRP-2002-12431 LRP-2004-00031 LRP-2005-00015 Res id ~Htla f:t,ofals;sin~~\~~9 $.;:M1iiii~' MOR cc -0.1 35.0 -5.3 0,0 0,0 -3.0 -0.9 :~':::3 8i'7 (0 I of Residential, Commercial and Industrial Land Changes in Metro Plan Designations NC CI LMI HI POS G&E NR AG MU 0.1 5.0 0,0 0.0 0.0 3,0 0,9 -3.7 9.2 72.0 16.5 -34,5 0.4 33.0 LOR Low Density Residential MOR Medium Density Residential CC Commercial Center NC Neighborhood Commercial CI Campus Industrial LMI Light Medium Industrial HI Heavy Industrial POS Public Open Space G&E Government and Education NR Natural Resource AG Agriculture MU Mixed Use ):> -4 -4 ):> C1 I ~ m z -4 rn m. PeaceHealth , . March 15, 2007 Zone Change Application Written Explanation of the Proposal Applicant: peaceHealth Oregon Region 770 E. 11 th Avenue P.O. Box 1479 Eugene, Oregon 97440 i ' I Property Owners: Hyland Business Park, LLC (Tax Lot 400) 1941-A Laura Street Springfield, OR 97477 Attn: Shaun Hyland (541) 726-8081 Andrew Head (Tax Lot 402) 1616 Ardendale Ln. Eugene, OR 97405 (541) 521-3403 Applicant's Representati ve: Philip Farrington, A.ICP Director, Land Use Planning & Development PeaceHealth Oregon Region 123 International Way , Springfield, Oregon 97477 (541) 686-3828 * Fax (541) 335-2595 pfarringto n@peacehealth.org 1.0 Land Use Request PeaceHealth Oregon Region (the "Applicant") requests approval to change the zoning classification on the City's zoning map from Light Medium Industrial ("LMI") to " Community Commercial ("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 LMI to CC, as allowed in Springfield Development Code ("SDC") 12.020 (1)(a)l, 5-82 Zone Change Application PeaceHealth :Oregon Region 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 Applicant seeks to rezone (and through concurrent application, redesignate) the subject properties to CC so they may be developed for commercial uses (i.e" Tax Lot 400), including a possible future medical clinic which could serve residents in the growing east Springfield area, and to be allowed to continue long-standing commercial operations (i.e., Tax Lot 402). Approval of this land use request would preserve employment and existing viable commercial operations on Tax Lot 402, and create stable family-wage employment opportunities on Tax Lot 400 - a vacant and underused industrial site. The proposal would also help beautif'j this portion of Main Street from its _ traditional industrial yard uses, and future development would provide a superior buffer - for residential uses to the west than currently exists. As described in later sections of this narrative the proposal is consistent with East Main Refinement Plan (EMRP) and the Metro Plan as required by approval criteria in SDC 12.030. ill 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 aliow for a broader, more beneficial range of commercial and employment-generating uses on the subject properties. It would also improve the area and better distinguish and buffer adjacent residential and industrial business park uses. 3.0 Site Context The subject properties include a currently vacant, flat parcel (Tax Lot 400) and existing commercial development (Tax Lot 402) east of 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 cabi-net 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). 'vVhile 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 fonn plywood. Tax Lot 402 has had various commercial services on site since the 1950s. 5-83 Page 3 Zone Change .~pp lication PeaceHealth Oregon Region March 15.2007 The properties have no jurisdictiomil wetlands or inventoried Goal 5 naJural 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 Light/Medium Industrial in the EMRP diagram and zoned LMI. The areas immediately to the west and south of the site fronting Main Street are identified as being within Mixed-Use Area #2 in the EMRP, and are all zoned Community Corrunercial. 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 of 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 development. 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 with l\'1etro Plan Text and Diagram Consistent with SDC 12.030 (3)(a), this narrative only addresses those policies that apply to the proposal, and does not discuss those portions of the Metro Plan that: (1) apply only to rural or other lands outside of the urban growth boundary, (2) apply to land uses other than the current or proposed designations for the site and will not be affected by the proposed Plan diagram and text amendments, or (3) clearly apply only to specific development applications (e,g, site plan review submittals or subdivisions). In many. instances the goals, policies and implementation measures apply to specific development proposals that will be addressed through complia~ce with applicable City regulations during site plan review of a given future development proposal. Except for the Growth Management Goals, which are addressed below, each of the Metro Plan policies are addressed in the order in which they appear in the Plan Element section of the Metro Plan, 5-84 Page 4 Zone Change Application PeaceHealth 'Oregon Region March 15, 2007 4.1.1 Metro Plan Elements 1. Growth Management Policies 1. The urban growth boundary and sequential development shall continue to be implemented as an essential means to achieve compact urban growth. Provision of all urban services shall be concentrated inside the urban growth boundary. The proposal satisfies 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 resulting approval of from this application. The City's site plan review processes ensure that the appropriate level of services is available to serve future development. 2. ResidentiulLand Use and Housing Element Policies A.ll Generally locate higher density residential development near employment or commercial services, in proximity to major transportation systems or within transportation-efficient nodes. The proposed redesignation does not affect the inventory or availability of residentially designated or zoned land; including the single-family residential area abutting Tax Lot 400 that is zoned and designated for Medium Density Residential, or higher density residential developm~nts located east of the site along Main Street. ' However, approval of the requested redesignation to Community Commercial would allow for residential areas proximate to the subject area to have close and efficient access to existing commercial serviceson Tax Lot 402 and to future medical facilities proposed for 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 transportation system that can support the needs of nearby residential development. - A.22 Expand opportunities for a mi.l: of Llses in newly developing areas and existing neighborhoods through local zoning and development regulations. 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 be developed to serve this rapidly growing area of the community. Approving the request would expand commercial opportunities to serve these neighborhoods consistent with the above policy. 5-85 Page 5 Zone Change b-pplication PeaceHealth Oregon Region March 15.2007 3. Economic Element Policies B.l Demonstrate a positive interest in existing and new industries, especially those providing above-above wage and salary levels, and increased variety of jOb opportunities, a rise in the standard of living, and utilization of our existing comparative advantage in the level of education and skill of the resident labor force. . The 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 arid 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 economic development which utilizes local and imported capital, entrepreneurial skills, and the resident labor force. 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 zoned for light industry and commercialllses correlating the effective supply in terms of suitability and availability with the projections of demand. The proposal will add approximately 5.24 acres ofComtnunity Commercial land, consistent with recommendations to increase the commercial lands inventory made in the Springfield 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. Approvalofthe 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 adoptedSCLS. B.ll Encourage economic activities which strengthen the metropolitan area's position as a regional distribution, trade, health, and service center. The amendment will facilitate the development of medical uses that will serve the needs of the growing residential areas in east, south and southeast Springfield, and strengthen the metropolitan area's position as a premier locale for healthcare services, consistent with this policy objective. 5-86 Page 6 Zone Change Application PeaceHealth Oregon 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, and recreational land uses shall be encouraged' when consistent with other planning policies. Approval of the proposed map amendments will add just over 5 acres into the City's inventory of commercially designated and zoned land, thereby allowing for a variety of needed commercial uses to occur on the subj ect 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 llse patterns and development, including higher intensity, transit-oriented development along major transit corridors alid near transit stations; medium- and high-density residential development within one-quarter mile of transit stations, major transit corridors, employment centers, and downtown areas; and development and redevelopment in designated areas that are or could be well served by existing or 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 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 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 NIotor vehicle level of service policy: a. Use motor vehicle level of service standards to maintain acceptable and reliable performance on the roadway system. These standards shall be used for: (1) Identifying capacity deficiencies on the roadway system. (2) Evaluating the impacts on roadways of amendments to , transportation plans, acknowledged comprehensive plans and 5-87 Page 7 Zone Change_Application PeaceHealth Oregon Region March 15,2007 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. Performance standardsfrom 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 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 financial resources, or land use cOllstraint factors. It is not the intent ofrSI Raodway Policy #2: ~;Jotor 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 develop an alternative mi."I: of strategies (such as: land use measures, TDi'vI, 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 accompariyingTraffic 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 inconsistent with the functional classification of Main Street or any other nearby roadway; . Reduce perfonnance of traffic on Main Street or other affected intersections to a level that is below acceptable established performance standards; or 5-88 Page 8 Zone Change Application PeaceHealth Greg'on Region March 15, 2007 . Make perfo~ance 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 findings 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.] Extend the minimum level.andfull r{Lnge of key urban facilities and services in an orderly and efficient manner consistent with the growth management policies in Chapter II-B, relevant policies in this chapter and 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 on Tax Lot 400. Therefore, the proposal is consistent with the above policy. 9. Parks and Recreation Facilities Element policies Policies in this element of the Metro Plan are not relevant to the requested zone change. 10. Historic Preservation Element policies Policies in this element of the Metro Plan are not relevant to the requested zone change. 11. Energy Element policies Policies in this element of the Metro Plan are not relevant to the requested zone change, . 5-89 . Page 9 Zone Change -{\pplication PeaceHealth Oregon Region March 15.2007 4.2 Consistency with East lYlain 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 unc!er Community Commercial zoning: All Community Commercial uses 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 cOjJ1IIlercial 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 or Commercial Re l11ement Plan Desianation 1. Generally) the Community Commercial refinement plan designation shall be applied under the following ~ircu,mstances: A) where it is not anintmsioll into well-maintained residential neighborhoods; The area proposed for rezoning does not intrude into the existing residential area west of the subject site along 44th Street, and is therefore consistent with the above criterion, B) where it does /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. Approval of the proposed rezoning of the subj ect sites would actually result in a decrease of conflicts between abutting residential and non-residential land uses by allowing future infin 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 €lregon Region March 15.2007 C) where criteria for designating l'11edlum 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 were legally created prior to development of the Metro Plan or EMRP. Tax Lot 400 has had a variety of commercial services located on-site over the years. E) where adequate customer and ser'f,'ice access to an arterial . street can be provided; ... and The subject site has adequate legal access onto Main Street, which is classified as an arterial street. F) where designated Commercial on the Metro Plan Diagram. Approval of the concurrently 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-specific Commercial refinement plan designations to clearLy defin~ the limits of new commercial uses where there is not an existing} legally established, and beneficial mi..--dng of uses. Approval of the concurrently requested redesignation would apply Commercial plan designations to the subject properties, allowing the existing, legally established commercial uses on Tax Lot 402 to continue. It would also enable commercial uses to. be established on Tax Lot 400, thereby defining the limits of new commercial uses between the pre-existing commercial uses on Tax Lot 402 and others to the west, and the developed industrial business park to the east. Tax Lot 400 does not have an existing or beneficial mix of uses, but has historically housed industrial yard-type operations. Therefore, approval of the proposal would define the limits of new commercial uses as called for in the above policy, and also provide the ability to make superior buffering and other improvements associated with future development on Tax Lot 400 through the site plan review process. Policy 3) Reduce the number of vehicular accesspoints and require the rebuilding of curbs and installation of sidewalks and street trees along lVlain Street, through the Site Plan Review process and in pubLic improvement projects. 5-91 Page 11 Zone Change.Application PeaceHealth Oregon Region March 15,2007 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 streeUrees are already located along its Main Street frontage, consistent with the above policy. Policy 4) Provide buffering between commercial and residential uses through Article 31 of the 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 whh the above policy, 3. Industrial Element Policy 1) The City shall encourage efforts of various agencies to attract new and retain e.:-dsting jobs and businesses. Implementation The City shall maintain a current inventory of vacant commercial and indllstrialland and structures within the East lY1ain area. Consistent with the above policy, approval of the requested. zone change and redesignation will enable existing, long-standing jobs and businesses on Tax Lot 402 to remain as legal, conforming land uses, and allow future development of new employment on Tax Lot 400 with higher than average wages and employment densities than the current designation and zoning allows. 5-92 Page 12 Zone Change Application PeaceHealth 0regon Region March 15. 2007 4.3 'Provision of Adequate Public Facilities The subject properties were annexed into the Springfield corporate limits in 1960, and therefore are provided with City police, fire, and other government services. Other basic infrastructure is in place to serve existing development on Tax Lot 402 and any future development on Tax Lot 400; Specifically, sanitary sewer, stormwater, and water lines are all located along the site's Main Street frontage - all of which are adequate to serve the needs of existing and/or future development on the subject site. Transportation 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 Traffic Impact Analysis accompanying the concurrently submitted zone change and Metro Plan diagram amendment, approval of the proposal would not result in a "significant effect" to the transportation sy~tem, 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 a:ndefficient access and circulation for vehicles, and also will benefit from the sidewalks, bike lanes, 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 SDe 12.030 (3). . 4.4 Consistency with Approval Criteria inSDC Article 7 The proposed zone change is submitted concurrently with an application to amend the Metro Plan diagram. The following findings are contained in the Plan diagram amendment application, and also demonstrate that this proposal complies with Metro Plan policies as required inSDC 7.070 (3) and with zone change approval criteria in SDC 12.030. Both the findings below relative to Goal 12 and those above pursuant to Metro Plan Transportation Element policies address consistency with the state TPR, as called for in SDe 12.030. It should also be noted that approval of a Metro Plan diagram amendment also correspondingly changes the applicable refinement plan (East Main Refinement Plan) diagram, as established in SDC 7.110 (4), Goall - Citizen Involvement Goal 1 addresses the need to develop a citizen involvement program to ensure citizen involvement in all phases of the ,land use planning process. The Planning Commission and the City Council will hold public hearings and accept testimony on the proposal. Through the procedures established by the city, citizens will receive notice of hearings in generally published local papers and have the opportunity to be heard regarding the proposed diagram amendment and zone change. Notice of the public hearings will also be given in accordance with SDC requirements to nearby property owners, interested parties requesting notice, and any established neighborhood organization. Since the process complies with the City's citizen involvement program and citizens have 5-93 Zone Change...fI.pplication PeaceHealth Oregon Region March 15 , 2007 Page 13 opportunities to be involved in the procedure, the proposed plan and zone map amendments are consistent with Goal I. Goal 2 - Land Use Planning Goal 2 requires that local comprehensive plans be consistent with the Goals, that local comprehensive plans be internally consistent, and that implementing ordinances be consistent with acknowledged comprehensive plans. Goal 2 also requires that land use decisions be coordinated with affected jurisdictions and that they be supported by an adequate factual base. As required in SDC 7.050, the City is required to give referral , notice of the proposed Type II Metro Plan diagram amendment to the City of Eugene and Lane County so they may determine if there are grounds to participate as parties to the hearing. The 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 confonnity 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 cbmpliance, the proposal satisfies the consistency element of Goal 2. ' .' .' Goal 3 - Agricultural Lands This goal is inapplicable because as provided in OAR 660-15-000(3), Goal 3 applies oqly . 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. ' Goal 4 - Forest Lands Goal 4 does not apply within urban growth boundaries, per OAR 660-06-0020, and the areas affected by the Plan amendments are inside Springfield's acknowledged UGB. Goal 5 - Natural Resources , GoalS requires local goverrunents 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 apart of periodic review, to (1) identify such resources; (2) determine their quality, quantity, and location; (3) ideI1tify conflicting uses; 5~94 Page 14 Zone Change Application PeaceHealth Oregon Region March 15, 2007 (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 inventoried resources are located on the site. The National Wetland Inventory and Springfield Local Wetland Inventory maps have been , consulted and there are no jurisdictional wetlands located on the site. Therefore, the proposal does not alter the City's compliance with GoalS. Goal 6 -Air, Water, and Land Resources Quality The purpose of Goal 6 is to maintain and improve the quality of th~ air, water and land resources ofthe 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 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 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/histOlic 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 through the site plan review process, thereby complying with applicable state and federal environmental quality standards. Goa17 - Areas Subject to Natural 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 of natural disaster and hazards, such as areas prone to landslides, flooding, etc.' The site is flat and not subject to landslide hazards, and is located well outside of any established FEMA flood hazard area, Therefore, approval of the proposal will not alter the City's acknowledged compliance with Goal 7 through its adopted plans, codes and procedures. 5-95 Zone Change.Application PeaceHealth 6~egon Region March 15. 2007 Page 15 Goal 8 - Recreational Needs Goal 8 requires local governments to plan and provide for the siting of necessary recreational facilities to "satisfy the recreational needs of the citizens of the state and visitors," and where appropriate, provide for the siting of recreational facilities including destination resorts. The subject site is not included in an inventory ofrecreational sites, and the proposal will not have an impact on the community's recreational facilities or needs; therefore, the proposal does not implicate Goal 8. 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 of CC designatedlzonea land in place of the existing industrial designation and zoning. Pennitting the construction of future clinic facilities on Tax Lot 400 and allo\ving long-standing commercial uses on TaX. Lot 402 to continue and become confonning uses consistent with commercial zoning through approval of the proposed Plan diagram amendment and zone change is consistent with numerous policies in the City's adopted plan for compliance with Goal 9, the Springfield Commercial Lands Srudy (SCLS). ' Specifically, the following SCLS policies are applicable to the proposal: Policy I-A: "Maintain a mixed supply of large and small commercial sites through strategies such as rezoning or annexation to serve Springfield's future population." . The proposal fulfills this policy objective by rezoning (and redesignating) land from industrial to commercial use, for two tax lots of varying sizes and commercial uses, thereby maintaining existing employment and commercial use inTaxLot 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 ofcornmercial1and 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 epg, 33) a need to support "employment in population-dependent sectors such as retail sales and health services" to meet Springfield's growing community. The SCLS also noted (pp. 27-29) state and local 5-96 Page 16 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 result in a deficit of needed industrially designated and zoned land, but it would help reduce the commercial lands deficit identified in the SCLS. Th,erefore, approving the proposal would be consistent with SLCS Implementation Strategy 3-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 proposal in fact consistent with inventories for commercial ahd 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 designations "in excess oftwo acres within an existing urban growth boundary from an industrial land use designation to a non~ industrial use designation" to have to address applicable planning requirements - such as consistency with the Metro Plan and other local plan policies (i.e., SCLS) or be consistent with an economic opportunities analysis. The City can find that the proposal complies with relevant local plan policies by converting one form or emp~oyment-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 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 amendment without the need for an economic opportunities analysis apart from the SCLS, which DLCD acknowledged as fulfilling the City's obligations under Goal 9. Because the requested redesignation and zone change implements SCLS policies and does not result in a deficiency of needed industrial lands, and is otherwise demonstrated to be consistent with relevant Metro Plan policies, approval of the proposal is consistent with the City's compliance with Goal 9 and applicable administrative rules regarding Goal 9 implementation, ConlIO -Housing LCDC's Housing goal requires cities to maintain adequate supplies of buildable lands for needed housing, based on an acknowledged inventory of buildable lands. The proposal does not affect the City's inventory of residential lands, In fact, approval of the requested redesignation for Tax Lot 400 would enable redevelopment of an industrial site abutting existing residential development. Through 5-97 Zone Chang~..Application PeaceHealth Oregon Region March 15. 2007 Page 17 the site plan review process, fu.tun:: development on that property can provide a superior buffer and a higher use that will benefit the adjoining residential properties. Because the proposal does not involve directly any change in the amount of residentially designated or zoned land, 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 Springfield UGB and city limits, and is already designated for urban levels of use. The proposed amendment to the Plan map designations 'lnd zone map classifications 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 commercial uses on the subject site. ) ":.. , Goall2 _Transportation . 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 property, though existing and long-standing commercial uses occur on Tax Lot 402 such that approval of the proposal will not result in any changes to the type or intensity of uses on the site, and will not increase the trip generation for that fully developed parcel. As the attached Traffic Impact Analysis (TIA) demonstrates, future development of medical office facilities on TL 400 will not degrade mobility standards below acceptable levels and allow for adequate queuing lengths at applicable intersections. Therefore, tpe proposal will not have a "significant effect" on transportation facilities as defined in the Transportation Planning Rule (OAR 660-012- 060). Existing development at Tax Lot 402 is not affected by the proposal, and is assumed to retain its current access points off Main Street. It is further assumed that future development on Tax Lot 400 will result in some access changes as ,vill be reviewed through the site plan review process, thereby consolidating two existing curb cuts located on Tax Lot 400 into a single access point located approximately inthe 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 zone change, Furthermore, reducing the number of access points for future development on Tax Lot 400 is consistent with policy objectives found in East Main Refinement Plan (EMRP) Access, Circulation & Parking Element policy 1 B (pg. 17) and Commercial Element policy 3 (pg. 12). Because the proposal, as demonstrated in the TIA, is consistent with the requirements of the TPR and with applicable policies in the EMRP, it is consistent with Goal 12 and applicable local implementing policies, 5-98 Page 18 Zone Change Application PeaceHealth Oregon Region March 15, 2007 Goall3 - Energy Conservation The Energy goal is a general planning goal and provides limited guidance for site-specific map amendments. The proposal has no direct impact on energy conservation, though it would in fact will promote greater energy efficiency by enabling needed clinical services available to growing residential areas in east Springfield. Therefore, the proposal is consistent with, and does not alter the City's continued compliance with Goal 13. Goal 14 - Urbanization Goal 14 requires local jurisdictions to provide for an "orderly and efficient transition from rural to urban land use." The subject property is within the UGB and the city limits of Springfield, and within an existing urbanized area of the community. Therefore, Goal 14 is not applicable to this application. Goal 15 - Willamette River Greenway This goal is inapplicable because the subject property is not within the boundaries of the Willamette River Greenway. Goals 16-19 - Coastal Goals The coastal goals are not applicable to this application. 5-99 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 specified deadlines as noted in the Planning Commission public hearing on June 5t\ 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 t}Vo letters in their entirety are attached for reference and review in addition to the excerpts and Staff responses in this report. Ms. SC2el's Subrrtittal- Issue #1: "Applicant Relies heavily on the acknowledged 2000 Springfield Commercial Lands Study (SCLS), 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 established for the entire Metro UGB area, but rather only for the Springfield portion of the UGB area... " Applicant's Rebuttal: "The cities of Eugene and Springfield have separately adopted and acknowledged commerciallands studies fulfilling the requirements of Goal 9. As such, the SCLS senes 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 analysis of commercial lands in order to adopt findings satisfying compliance with Metro Plan policies and Goal 9... " ST 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. The SCLS was not adopted as a specific amendment to the Metro Plan. The City undertook a supply and demand analysis to detennine if there was adequate commercial 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 or TransPlan; are a recommendation to amend the Code; or are suggestions to improve business practices. The City and DLCD concluded 5-100 it was not 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 findings, reasons and conclusions for those PAPA actions. Best available data was' used in the analysis of these applications, which included the SCLS. There are no comprehensive studies (i.e. commercial lands inventory) available for the entire UGB related to commercial lands within one specific time period. Rather, there is a conglomeration of various studies that are reviewed. For example, the 1992 Industrial Lands study is UGB-wide, The Residential Lands Inventory which is used by the City is not UGB-wide. Likewise, the SCLS is not Metro-wide. Ms. Se2el's Submittal- Issue #2: "The ad@pted Springfield Natural Resource Study (adopted by Ordinance #6150) shows little or no impact on the commercial lands inventolY from Goal protection measures, and pro'v~idelittle if any analyses of land availability within the entire Metro UGB area, ratherthanjust 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, " Applicant'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 than 61 acres of needed commercial land. Approving the requested Plan amendmentlzone change would still leave a deficit of approximately 55 acres of needed commercial land... Therefore, even considering impacts to commercial lands inventories from other adopted and acknowledged plans (i.e. the City's plan for Goal 5 compliance) and acknowledged Plan amendments / zone changes, approval of the proposal will not result in there being an excess of needed commercially zoned and designated land. To the contrary, this analysis demonstrates that there will remain a deficit of approximately 66 acres after approval of the requested redesignation / rezoning, " STAFF RESPONSE: The Springfield Natural Resource Study (SNRS) is referenced by the applIcant and staff as related to this PAP A because it provides a more updated view of the city's comrriercial & industrial lands inventory, It is not meant 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 infonnation possible given all the available data at this time. Again, the applicant's report and staffs analysis reference the most recently adopted documents! inventories available. The City currently does not have an ongoing database' 5-101 that keeps track of inventories bas,ed upon Plan Amendm~nts and/or 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 commercial land within Springfield's city limits. Ms. Se2e!'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 !vIetro UGB. even though the Metro Plan (comprehensive plan) Economic Element policy #12 establishes that the cities are to 'discourage fitture Metropolitan Area Gelzeral Plan amendments that would change development ready industrial lands (sites defined as short-term in the metropolitan Industaal Lands Special Study, 1991) to nOh-industrial designations. . The applicant and staff findings do not address how the loss oj these 5.24 acres impacts the short-term supply of LMI designated land... " , Applicant's Rebuttal: "Ms. Segel's citation of Economic Element Policy 12 ignores the fact that the subject site was not included among the sites "defined as short~term in the metropolitan Industrial Lands Special Study. 1991). "... 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 oJan 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 surplus ofnearly 50 acres of LA,'iJ designated land even after approval of the requested Plan amendment. This does not account Jar th,e 11.5 acres' of land added to the inventory oj LMI zoned and designated land referenced in my March 28. 2007 supplemental information. .., Therefore. the removal of 5.24 acres oj LMI zoned and designated land wi/! 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 counterv-ailing policies in the !vIetro Plan (i.e" Economic Element Policy 6) and SCLS (i.e., policies I-A and 1~ C) that are directive to providing an adequate supply of needed commercial lands ," " STAFF RESPONSE: Staff concurs with the applicant's rebuttal to the issue raised, The applicant has cited numerouS acreage calculations based off of adopted inventories which support the proposal. As noted by the applicant, the subject site was not included among the sites defined 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 deficit of cornmercialland 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. Se!!el's Submittal - Issue #4: "The Applicant's analysis of the proposals' consistency with comprehensive plan Economic Element policies found in the Metropolitan General Plan, Chapter III, B-1 - B-7 is insufficient and does not address the most significant policies that must be considered. " Applicant's Rebuttal: "...there are countervailing policies in the Metro Plan (i.e.. Economic Element Policy 6) and SCLS (i.e" policies I-A and I-C) that are directive to providing an adequate supply of needed commercial lands, The Metro Plan recognizes such conflicts: "The respective jurisdictions recognize thatthere are apparent conflicts and inconsistencies betrveen and among some goals, objectives. and policies. When making decisions based on the Plan, not all the goals, objectives. and policies can be met to the same degree in every instance. Use of the Plan requires a 'balancing' of its various components on a case-by- case basis. as well as a selection of those goals, objectives, and policies most pertinent to the issue at hand. .. (pg, 1-4, Metro 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 the 32 Metro Plan Economic Element policies are relevant to the proposal. Many are aspirational in nature and not directive to 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 I -4 of the Metro Plan, "The respective jurisdictions recognize that there are apparent conflicts and inconsistencies between and among some goals, objectives, and policies. When making decisions based on the Plan, not all the goals, objectives, and policies can be met to the same degree in every instance. Use of the Plan requires a 'balancing' of its various components on a case-by-case basis, as well as a selection of those goals, objectives, and policies most pertinent to the issue at hand." The applicant submitted written statements relative 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 commercial and industrial adopted inventories. IVls. Se~el's Submittal - Issue #5: "The applicant is not specific about what Llses wi II be cited should the proposal be approved, and there is no way to know if in fact above wagejobs and salaries... there is no way to establish if the applicant will in fact utilize local and imported capital. skills etc, as no commitment to a use has been established... .. Applican t' s Rebuttal: ".. .Ms, Segel'sassertion that the application was unspecific as to the future uses on Tax Lot 400 is inaccurate. The application narrative clearly states the intended purpose of the redesignation/rezoning is to 5-103 allow for a future medical clinic on Tax Lot 400 and to allow the long-standinu " 0 commercial operations on Tax Lot 402 to continue (pg. 2, pg. 4-2 in the Commission's June 4 hearing packet), Such clinical uses are not permitted in any industrial zoning district, thus promopting the need to rezone (and Redesignate) Tax lot 400 to allow a medical clinic. Average wages and benefits for medical workers tends to be higher than average local wages, and further substantiating data can be entered into the record at the City Council level... ST AFF RESPONSE: The applicant has noted the intent of the Plan Amendment and concurrent zone change is for the eventual development of a medical office building. This is mentioned not only in the applicant's narrative, but also in the applicant's Traffic Impact Analysis. In fact, the referenced table in the TIA (Table 7, pg. 19) specifically calculates trip generation for the proposed medical office building. However, as noted by Ms. Segel, there is no certainty as to what the salaries will be, if it will utilize local capital, etc. With that said, there is no such assurance for any new use that might go on the property with the existing zoning and Plan designation either> Given the fact that the applicant is a medical service provider (i.e. Peace Health); that they are pursuing these applications; and that they have indicat.ed on their application that the purpose of these applications is to develop a future medical office clinic, it is highly likely (in Staff's opinion) that they will pursue the medical office use as they've specified. As noted in the ,applicant's rebuttal, average wages and benefits for medical workers tends to be higher than average local wages. Staff concurs with the applicant's rebuttal statement and affinns the original Staff Report findings indicating that the proposal is in compliance with applicable Metro Plan policies. Ms. Se2;el's Submittal - Issue #6: "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. (map 17-02-32); however, the 2000 SCLC. at AppendLI. C. "Sites with Plan/Zone Conflicts" does not include the subject property. It 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." , Ap-plicant's Rebuttal: "The applicant does not allege that there is a Plan/zone conflict on Tax Lot 402; clearly the existing Plan designations and zoning are UvfI. Rather. the point made in our application narrative is that commercial uses , have existed for decades. pre-existing the establishment of the Metro Plan and the application of the LivfJ designation on the subject properties. Ms. Segel provides no evidence to back up her accusation that the City wittingly allowed commercial uses on Tax Lot 402 after adoption of the SCLS. The applicant and owner of Tax Lot 402 will provide additional evidence and testimony at the City Council hearing on July 2 which will further demonstrate factually that commercial uses and employment have been in the building on Tax Lot 402 for nearly 50 years.., " 5-104 ST AFF RESPONSE: The existing zoning for TL #402 is Light Medium Industrial (LMI). The existing Plan Designation for TL #402 is Light Medium Industrial (LMI). Therefore, there is no Plan/zone conflict as alleged by Ms. Segel. A non-confonning use is not the same as a plan/zone conflict. Ms. Segel alleges that the City pennitted 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 provisions to allow existing non-confonning uses to modify or expand based upon specific criteria. A "non-conforming use" is a use that was legally created when first established but would not be allowed as a "new use" under the existing zoning, The existing commercial uses on TL #402 are most likely considered non-confonning uses (i.e. commercial uses on industrial zoned property). The 2000 SCLS does not list TL #402 as a Plan/Zone conflict because it is not a plan zone conflict. Ms. Segel'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, including goals 2,6,9.1 0.12 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... Staff has failed to address the impact that this proposal will have on the dwindling supply of shovel ready industrial land inside the Springfield city limits, including prior actions approving land use code amendments to the campus industrial zone that established more flexibility' for what uses are allowed in the city's campus industrial zones. .. Applicant's Rebuttal: "It shouldfirst be noted that the application does not involve or in any way affect the 'metro area's supply of campus industrial land. ' Moreover, the application has no effect upon Goal 10 (Housing), and has elsewhere demonstrated compliance with Goal]2 and other applicable statewide planning goals. My guess is that Ms. Segel and Nancy Falk, who appeared at the June 4 hearing and requested the written record be left open for a week, both vigorously appose the Plan amendment/zone change proposedfor the Marcola Meadows project, and are borrowing arguments to also object to this modest request before the City... The contention that the proposal would not result in a 'logical and harmonious' land use pattern is without substance or basis in fact, and is not an approval criterion. As noted above and elsewhere in the record, this proposal is consistent with policies and provisions in the iyfetro Plan, its Economic Element, supporting refinement plans (i.e" the SCLS and MILS) to the }yJetro 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 Light Medium Industrial, not Campus Industrial. As noted in the applicant's rebuttal, the statement submitted by Ms. Segel indicating that the".. . proposed change is 5-105 not 'logical and hannonious...' isnot a criterion of approval for these applications, Staff have reviewed the proposal based upon the applicable criteria of approval, and found that' it meets the criteria (with conditions) as written in the StaJfReport. The inventories of commercial and industrial land have been evaluated and balanced with the relevant Metro Plan policies to formulate the recommendation for approval with conditions. Specific findings related to the Statewide Planning Goals have also been included in the original Staff Report. ".'.-' 5-106 :-'. GOAL ONE COALITION ~ , Goal One is Citizen Involvement: City of Springfield Planning Commission David Reesor . City of Springfield 225 Fifth Street Springfield, OR 97444 June 12,2007 '1>:L~,'~':~"'" . ~ ...-- ..... .,~ e ,-::, ' H '... '". ",-'l_!"'.....,/ :.:".OH. '-l .~,iU) .1UN 1 2 2007 BY:..."..J-~ RE: ZON 2007~00121LRP 2007~0013, Plan Amendment & Zone Change Dear Members of the Commission: The Goal One Coalition (Goal One) is a nonprofit organization whose mission is to provide assistance and support to Oregonians in matters affecting their communities. Goal One is participating in these proceedings at the request of and on behalf of its membership residing in Lane County. This testimony is presented on behalf of Goal One and its membership, including Nancy Falk, 2567 Marcola Road, Springfield Oregon 97477, as an individual. 1. Introduction This proposal is for a site-specific Metro Plan Amendment / Refinement Plan Amendment and a concurrent Zoning Map Amendment from Light Medium Industrial (UvIT) to Community Commercial (CC) within the Springfield dty limits. The subject site is located near 44th and Main Street (Highway 126). The site consists of two parcels under separate ownerships, and is located on approximately 5.24 acres identified as TCL,,( 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 structures. The smaller of the two subject lots, TL 402 (.24 acres), has an existing commercial development on-site, although the plan designation and zone are LMI. Properties located to the north (Weyerhauser) are zoned and designated heavy industrial. Parcels located west of the subject site are designated mixed- use on the East Main Refinement Plan. Property located east and adjacent to TL #402 is built out as a business park, and designated LMI. Properties located south of the subject site, across Main Street, are zoned and designated Community Commercial.. II. Criteria applicable to the request Local approval criteria are found in the following documents: Springfield Development Code, Metro General Plan, and East tv'lain Refinement 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 Goal 12, Transportation. The Eugene office: 642 Charneleon Suiee 100 ' Eugene OR 9740 I ' 541-431-7059 ' Fax 541-431.7078 Lebanon office: 39625 Almen Drive' Lebanon OR 97355 ' 541.258-6074 . Fax 541-258.6810 'H'HW .goal1.org 5-107 GOAL ONE COAUTION proposed plan amendment must also comply with administrative rules implementing applicable statewide planning goals. Ill. Analysis COMPREHENSIVE PLAN CONSISTENCY AND COMPLIANCE WITH STATE\VIDE GOALS All comprehensive plan amendments are reviewable for compliance with the statewide planning goals. Residents of Rosemont v. Metro. 173 Or App 321 (2001); 1000 Fnends of Oregon v. Jackson County, 79 Or App 93, 97, 718 P2d 753 (1986), rev den 301 Or 445 (1987); Opus Development Corp. v. City oj 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 decisions and actions~" Specifically, local land use actions "shall be consistent with the comprehensive plans." Goal 2, Part L Furtfler, the infonnation upon which land use decisions are made "shall be contained in the plan document or supporting documents." Goal 1, Part 1. In this case, the applicant relies heavily on the acknowledged 2000 Springfield Commercial Lands Study (SCLS), which does not address the entire Metro UGB area, and is not a refinement 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 proposed findings 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 material includes data used to justify findings of compliance with goal 9. Any decision relying on such findings would not comply with Goal 2. GoalS Concerning applicability of landinventories pursuant to Ordinance #6150 that adopted the Springfield Natural Resource Study, staffs position is that inventories established pursuant to GoalS are relevant considerations in considering availability of commercial and industrial land. However, that analysis (applicant's Attachment "A" _ tables 11-1, 11-2 and 11-3) actually show little or no impact on the commercial lands inventory from Goal 5 protection measures, and provide little if any analyses of land availability within the entire Metro UGB area, rather than just the Springtleld UGB area. Table 1 i -2, Arlalysis of Maximum possible Impact on Supply of Commercial Lands within the Springfield Urban Growth Boundary shows an impact of 11.56 acres on Springfield's (not the urban growth boundary area in it's entirety) cOrnrrlercialland 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 #6150 fails to account for lands ADDED TO the commercial inventory since 2000, including but not limited to the Gateway MDR site's 100 acres, providing a skewed pic~re of the actual commercial land inventory. To skew the picture even further, the analysis of max.imum possible impact from Goal 5 protection measures on supply of industrial lands (Ordinance #6150, table 11-1) considers ALL industrial lands within ,the entire Metro UGB area, rather than just the Springfieldportion of the UGB, and does not provide a breakdown of number of industrially zoned acres in Springfield vs. Eugene. The 2000 SCLS, however (Table 3-2) shows that the number oflight medium industrial (LMI) acres by plan desigmition in the Springfield UGB area is 198.77, while the number of LMI 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 only about 16% of the Metro area ugb industrial land supply is within the Springfield city limits. - ::.;;:t:~.,:: Goal 9 _ Economic Development is: '"To provide adequate opportunities throughout the state for a variety of economic activities vital to the health, welfare, cfud prosperity of Oregon's citizens. " The Staff Report's Goal 9 findings are based upon the 1992 Industrial Land Study and the 20QO Commercial Land Study. Goal 2 requires that information upon which land use decisions are made be contained in the plan document or supporting documents. OAR 660-015-0000(2), Part I Planning establishes that city, county, state and federal agency and special district plans and actions related to land use shall be consistent with the comprehensi ve plans of cities and counties and regional plans adopted under ORS Chapter 268. Goal 9 _ 660~009-0010 (4) establishes that for a post-acknowledgement plan amendment' under OAR chapter 660, division 18, that changes the plan designation ofland in 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 designation to any other use designation, a city or county must address all applicable planning requirements, and: (emphasis added) (a) Demonstrate that the proposed amendment is consistent withits most recent economic opportunities analysis and (emphasis added) the parts of its acknowledged comprehensive plan which address the requirements of this di vision; The applicant appears to rely heavily on inventory and policy statements established bY the 2.000 SCLS in establishing that the proposal is consistent with the Goal 9 rule. However, the. applicant's analysis of the proposals' consistency with comprehensive plan Economic Element policies found in the Metropolitan General Plan, Chapter 1lI, B-1 - B-7 is insufficient and does not :lddress the most significant policies that must be considered. The proposal would decrease the City's campus industrial land inventory by yet another 5.2.4 acres, The applicant has not justified the conversion of scarce, shovel ready industrial land, Metro Plan/East Main Refinement Plan. ZON 2007 -00012 - LRP 2007-00013 5-109 3 GOAL ONE COALITION :, especially land designated and zoned light medium industrial inside the Metro UGB, even though Metro Plan (comprehensive plan) Economic Element policy # 12 establishes that the cities are to "discourage future M~tropolitan Area General Plan amendments that would change development ready industilallands (sites defined as short - term in the metropolitan Industrial Lands Special Study, 1991) to non-industrial designations." The applicant and staff fmdings do not address how the loss of these 5.24 acres impacts the short-term supply of LMI designated land. The applicant makes the argument that the proposed plan amendment and zone change would have the effect of correcting existing no~-confonning uses on TL #402. (map 17-02-32); however, the 2000 SCLC, at Appendix C, "Sites with Plan/Zone Conflicts" does not include the subject property. It 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 Comrf1ercial Lands Study (2000 SCLS), the applicant appears to try to separate the Metro Area by jurisdictional boundary. However, Eugene and Springfield have a shared and adopted UGB, Comprehensive Plan, and Industrial Lands study. The jurisdictionally focused SCLS does not 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 660-009-001 0 (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 complian<;e 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 Springfield commercial lands inventory was the 2003 plan amendment and zone change (LRP 2003-0013 and ZON 2003-0019) at the 100-acre Gateway Medium Density Residential site that had the effect of rezoning and redesignating 100 acres 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 between 1991 and the present, but has failed to account for or otherwise address the addition of corrunercialland to the SCLS, even though it is clear that more than 100 acres 0 f comm,ercialland 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 accountina for additions to and subtractions from the various land inventories. ~ The applicant also relies in part on inventories established in conjunction with adoption of Springfield's Natural Resource (NR) Study, by Ordinance #6150 on November 28, 2005, \Vh.ile those inventories may be relevant to this proposal in that possible 'impacts' resulting from Goal 5 protection measures were considered for all zoning classifications, the analysis of maximum possible impact on supply of commercial lands pursuant to the study is limited to the area within the Springfield portion of the Metro UGH (table 11-2). Again, because Eugene and Springfield share a UGB and a comprehensive plan, an analysis of the entire UGB area is necessary to establish an accurate picture of the supply of commercial lands. Metro Plan/East Main Refinement Plan, ZON 2007 -00012 - LRP 2007-00013 5-110 4 ,,' GOAL ONE COAUTION In any case, the NR Study foundthat the maximum possible impact of Goal 5 protection measures on the Springfield Commercial Lands Inventory would be the loss of 11.56 "commercial acres." LOSS OF INDUSTRIAL LAND The proposed plan amendments and zone changes would remove 5.24 acres of shovel ready light medium industrial 1 arid from the Metro UGB area industrial lands inventory. This is in addition to an additional 56 acre conversion of campus industrial to community commercial land less than 2 miles away which is currently pending approval by the Springfield city council. The applicant is vague about the purpose of the proposed plan amendment and zone change, noting that, with approval of the plan amendment and zone change, the uses could include a possible future medical clinic, and the provision of family wage jobs. The applicant has said nothing about the existence of their other 100 acre medical campus located within about, 5 miles of the subject properties proposed for plan and zone changes. Given this fact, the applicant has not justified the removal of shovel ready light medium industrial land for commercial uses. This area within the Springfield city limits, is already inundated with commercial zoning and commercial uses, and approval of this proposal would contribute even further to over commercialization within the city of Springfield. The applicant cites 4 of the 32 Economic Element policies pursuant to the comprehensive plan (Metro Plan) (Chapter III, Section B) of the Plan as relevant to the proposed PAPA. The four Plan policies considered by the applicant as relevant to the supply of industrial land are policies 1,2,6, and 11 Policy I is to Demonstrate a positive interest in existing and new industries, especially those providing above wage job and salary levels, and increased variety of job opportunities, a rise in the standard of living, and utilization of our existing comparative advantage in the level of education and skill of the resident labor force. However, the applicant is not specific about what uses will be cited should the proposal be approved, and there is no way to know if in fact above 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 applicant will in fact utilize local and imported capital, skills etc. as no commitment to a use has been established. Policy 6 merely states: "Increase the amount of undeveloped land :oned (emphasis added) for light industrial and commercial uses correlating the effective supply in terms of suitability and availability with the projections of demand." Tnis policy addresses zoning only, not plan designation, and concerns the necessity of having adequate supplies of land of both commercial and industrial designations. It says nothing concerning the applicability of favoring one plan designation over the other. Metro Plan/East Main Refinement Plan, ZON 2007 -00012 - LRP 2007-00013 :'-111 5 GOAL ONE COALITION " 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) will facilitate the development of medical uses that will serve the needs of the growing residential areas in east, south and southeast Springfield, and strengthen the metropolitan area's position as a premier locale for healthcare services, consistent with this policy objective. Considering that their 2003 zone change and plan amendments were based on the assertions that provision of medical care pursuant to campus style 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 another 5.24 acres will somehow strengthen Springfield's position as a premier locale for healthcare servIces. The PAPA proposal mustbe consistent with the Economic Element of the Comprehensive plan in it's entirety. A major omission found in the application and staff report is an analysis of all the Metro Plan Economic Element policies other than the four addressed by the applicant. The remaining 28 policies should be addressed in some manner. More specifically, the following policies are 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 location requirements; prefer alternative sites to choose from, and usually benefit from location of other special light industrial firms within the community and within the same industrial development." The subject site is located adjacent to an existing light medium industrial site. 9 _ Encourage the expansion of existing and the location of new manufacturing activities which are characterized by low levels of pollution and efficient energy use, Staffhas not discussed efforts to attract and/or 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. l5 _ Encourage compatibility between industrially zoned lands and adjacent areas in local planning program. Metro Plan/East Main Refinement Plan. ZON 2007-00012 - LRP 2007 -00013 5-112 6 " GOAL ONE COALITION 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 land to facilitate their use or reuse in a comprehensive rather than pie~emeal fashion. The subject properties are adjacent to a large parcel which is zoned and designated 11v11. 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 ofLMI land within 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, includiJ1g prior actions approving land use code amendments to the campuS indU;;trial 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 explained why rieighborhood cO!11IDercial zoning is being ignored for higher intensity uses in this existing neighborhood. All the Metro Plan Economic Element policies are applicable to this application, and should have been addressed by the applicant. III. Conclusion The proposed plan amendment is not logical and harmonious with the hmd use pattern for the greater are:l. Tbe proposed change is not "logical and harmonious" because it is not consistent with the development pattern envisioned in the Metro Plan, As explained above, the proposed amendment is inconsistent with the intent of the Economic Element of the Metro Plan, and does not comply with Metro Plan policies. Therefore it cannot be found to be compatible with these Plans, Compliance with statewide planning goals, including goals 2, 6, 9, lO, 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 PAP A and zone change proposal. Metro Plan/East Main Refinement Plan, ZON 2007-00012 - LRP 2007-00013 5""'113 7 GOAL ONE COALITION " " 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 .~,.. Metro Plan/East Main Refinement Plan, ZON 2007-00012 - LRP 2007-00013 5-114 8 .' ~ PeaceHealth June 13,2007 Springfield Planning Commission Attn: David Reesor, Planner City of Springfield Development Services Department 225 Fifth Street Springfield, OR 97477 l:...:..:...>.~ -. ;.", t.,:.: f-.:'J:::.:-;:..... -il ' " ,.,~.'/:(:;;~~.. .JAV' \", .:-->~>. I.) <. r--,.:'., .~l<~'L.'>-' ,] (UI)/_: -.J.'i' -:-<~~ '/ '-'-~ JI . -.....-..- . .... "., , ~~':;-... Re: ZON 2007-00012, LRP 2007-00013 - Plan Amendment/Zone Change Dear Chairman Cross and'Commissioners, The Commission considered the above-referenced applications on June 5 at a duly noticed work session and public hearing. The following rebuts written testimony submitted by Lauri Segel of the Goal One Coalition at the close ofthe extended record yesterday. Ms, Segel suggests that the applications do not comply with statewide planning Goal 9 (Economic Development) - and by extension with Goal 2 (Land Use Planning) - because the 2000 Springfield Commercial Lands Study (SCLS) "does not address the entire Metro UGB area, and is not a refinement plan of the Metro Plan." (pg. 2; June 12,2007 Segel letter) She further states that "Eugene and Springfield have a shared and adopted UGB, Comprehensive Plan, and Industrial Lands study. The jurisdictionally focused SCLS does not analyze supply and demand for the entire Metro UGB area and cannot be relied upon on it's (sic] own to establish consistency with the requirements of OAR 660-009-0010 (4), which establishes that the proposed PAPA [Plan amendment] be consistent with both (emphasis added) the most recent economic opportunities analysis (i.e., the 2000 SCLS) ~J1d the comprehensive plan," (pg. 4, Segel letter) Applicant's Response: The SCLS was developed by the City and adopted by the Springfield City Council (Resolution No. 00-13 and included in the end pages of the SCLS) to comply with Goal 9 and applicable OARs pursuant to periodic review requirements established by the Oregon Land Conservation and Development Commission, Prior to the SCLS, the City of Eugene had an acknowledged plan for complying with Goal 9, the 1992 Eugene Commercial Lands Study (ECLS). The ECLS states: "The study includes solely the Eugene portion of the metropolitan urban growth boundary." (pg. 1-3, ECLS) Phone (541) 636.3660 Fa.: (541) 686.3699 PO Box 1479 Eugene OR 97440.1479 www,peacehealth,org Dedicated 10 Exceptional /vJedicine and C o/llpassionure Care 5-115 Re: ZON 2007-00012, LRP 2007-00013 - Plan Amendment/Zone Change Applicant's Rebuttal - June 13.2007 Page 2 '. Although there is in fact an ackno\vledged study covering both communities' industrial lands (the 1993 Metropolitan Industrial Lands Policy Report, and companion Inventory Report), the cities of Eugene and Springfield have separately adopted and acknowledged commercial lands studies fulftlling the requirements of Goal 9, As such, the SCLS serves as the City of Springfield's "most recent economic opportunities analysis," as Ms. Segel notes above by her own admission. The SCLS also .complies with Metro Plan Policy 31 which called for the City to conduct a commercial lands study, and fulfills the City's _ Goal 9 requirements pursuant to the periodic review work order, now accepted as . complete by DLCD. There is no requirement that the Applicant or the City perform a metro~wide analysis of commercial lands in order to adopt findings satisfying compliance with Metro Plan policies and Goal 9. Ms. Segel states that the analysis provided does not account for additions to the inventory of commercial lands, notably "the GateWqy MDR site's 100 acres." (pg. 4, Segel letter) , Applicant's Response: The City previously adopted amendments to the Gateway Refinement Plan (Jo. No. 2002-08-244), including GRP, 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 Medical 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 commercial land. Approving the requested Plan amendment/zone change would still leave a deficit of approximately 55 acres of needed commercial land. The supplemental information submitted into the record by the Applicant included the City's analysis of impacts to the commercial lands inventory pursuant to the City's acknowledged compliance with Goal 5 periodic review requirements. Table 11-2 of this analysis (see pg, 3-25 in the Commission's June 4, 2007 hearing packet) identifies that as a consequence of the City's 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 impacts to commercial lands inventories from other adopted and acknowledged plans (i.e., the City's plan for Goal 5 compliance) and acknowledged Plan amendments/zone changes, approval of the proposal will not result in there being an excess of needed commercially zoned and designated land. To the contrary, this analysis demonstrates that there will remain a deficit of approximately 66 acres after approval of the requested redesignationJrezoning. 5-116 , " Re: ZON 2Q07-00012, LRP 2007-00013 - Plan Amendment/Zone Change Applicant's Rebuttal ' June 13,2007 Page 3 Ms. Segel states that the application relies "heavily on inventory and policy statements established by the 2000 SCLS in establishing that the proposal is consistent with the Goal 9 rule. However, the applicant's analysis of the proposals' consistency with comprehensive plan Economic Element policies found in the Metropolitan General Plan, Chapter III, B-1 _ B-7 is insufficient and does not address the most significant policies that must be considered." (pg, 3, Segel letter) She further alleges that the application hasn't "justified the conversion of scarce, shovel ready industrial land, especially land designated and zoned light medium industrial inside the Metro UGB, even though the Metro Plan (comprehensive plan) Economic Elemt;nt policy #12 establishes that the cities are to 'discourage future Metropohtan 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.' The applicant and staff findings do not address how the loss of these 5 .24 acres impacts the short-term supply of LMI designated land." Applicant's Response: The Applicant's original March 15, 2007 sub~ittal included findings addressing relevant Metro Plan policies (see pg. 5 of the submittal, pg. 4-5 of the Commission's June 4,2007 hearing packet), Clearly not all of the 32 Metro P,lan Economic Element policies are relevant to the proposal. Many are aspirational in nature and not directive to a specific quasi-judicial application, for example Policy 28: "Recognize the vital role of neighborhood commercial facilities in providing services and goods to a particular neighborhood." (pg, III-B-6, Metro Plan) Others are directed to actions that the public sector jurisdictions are to undertake, such as Policy 31, which Springfield did in conducting in the SCLS: "Conduct a Commercial Lands Study prior to the next major plan update." (pg. III-B-7, ibid) Nonetheless, to demonstrate that all policies were considered irrespective of their applicability, the Applicant will provide supplemental findings and enter them into the record prior to the City Council hearing 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 on point. Ms, Segel's citation of Economic Element Policy 12 ignores the fact that the subject site was not included among the sites "defined as short-term in the metropolitan Industrial Lands Special Swdy, 1991)," The adopted and acknow ledged Metropo litan 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 MIL Policy Report) do not identify the subject site among the "short-term sites" in the industrial lands study, presumably because both were considered developed, The abutting property now developed with the Hyland Business Park was, however, identified in the study as site #7 in this subregion. While the Hyland property was included in the matrix of "short-tenn sites," it was also identified as being a "developed" site, The j'vHL Policy Report states that "sites developed during the study 5-117 Re: ZON 2907-00012. LRP 2007-00013 -Plan Amendment/Zone Change App lie ant' s Rebuttal June 13,2007 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-Springfield during the previous two year period, a time of economic growth. This short tenn 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-teITl.1industrial 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 considering it in the context of industrial and commercial land inventories. As stated above and established in the record, there is a demonstrated need for additional commercial land .;; , which the proposal helps address." 'The record also includes evidence demonstrating that there is a sdrplus of needed industrial land. The acknowledged metro industrial lands study identified a surplus of buildable light medium industrial acreage, and overall industrial acreage, in Eugene, Springfield, and combined in the metro UGB. Table 5 in the MIL Inventory Report (pg. 47) identifies supplies of buildable industrial land as follows: Eugene Springfield Metro UGB LMI Acres 1,230.78 198.77 1,429,55 Total Industrial Acres 2,895.49 708.80 3,604.29 The report further states that the study "identifies about 1,688 constraint-free industrial acres.... This supply exceeds the projected demand over the next twenty years, which is between 650 to 1,172 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 of the Commission's June 4 hearing packet). The analysis also found that there were 90,80 acres removed from the industrial designation by prior Plan amendments in Springfield. Therefore, even if all of the industrial acreage impacted by GoalS and all of the acreage redesignated in Springfield were from the LMI designation _ which is no doubt not the case - there would still be a surplus of nearly 50 acres of LMI designated land even after approval of the requested Plan amendment. This does not account 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 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 te07 -00012, LRP 2007 -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 policies, When making decisions based on the Plan, not all the goals, objectives, and policies can be met to the same degree in every instance. Use of the Plan requires a 'balancing' of its various components on a case-by-case basis, as well as a selection of those goals, objectives, and policies most pertinent to the issue at hand." (pg. 1-4, Metro Plan) The Applicant contends that findings and evidence in the record from adopted "and acknowledged sources demonstrate that approval of the requested 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 specific.about what uses will be cited should the proposal be approved, and there is no way to know if in fact [sic] above wage jobs and salaries." (pg. 5, Segel letter) She also states that while "the applicant argues that the proposal would have the effect of correcting existing non-conforming uses on TL #402" that the property is not included in the "Sites with Plan/Zone Conflicts" in the SCLS. She goes on to state that "it appears that the existing nonconfom1ing uses were actually established AFTER adoption of the 2000 SCLS, indicating that the existing uses were actually pennitted by the City with the knowledge that these uses would create plan/zone conflicts," (pg. 4, Segel letter) . Applicant's Response: The Applicant does not allege that there is a Plan/zone conflict on Tax Lot 402; clearly the existing Plan designations and zoning are LMI. Rather, the point made in our application narrative is that commercial uses have existed for decades, pre-existing the establishment of the Metro Plan and the application of the LMI designation on the subject properties, Ms. Segel provides no evidence to back up her accusation that the City wittingly allowed commercial uses on Tax Lot 402 after adoption of the SCLS, The Applicant and owner of Tax Lot 402 will provide additional evidence and testimony at the City Council hearing on July 2 which will further 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 application narrati ve clearly states the intended purpose of the redesignation/rezoning is to allow for a future medical clinic on Tax Lot 400 and to allow the long-standing commercial operations on Tax Lot 402 to continue (pg, 2, pg, 4-2 in the Commission'slune 4 hearing packet). Such clinical uses are not permitted in any industrial zoning district, thus prompting the need to rezone (and redesignate) Tax Lot 400 to allow a medical clinic, Average \vages and benetits for medical workers tends to 5-119 . 0 to Re: ZON 2007-00012, LRP 2007-00013 - Plan Amendment/Zone Change Applicant's Rebuttal June 13,2007 Page 6 be higher than average local wages, and further substantiating data can be entered into the record at the City Council level. Ms. Segel contends that the proposal is not "logical and harmonious" with land use 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 proposal." Applicant's Response: It should first be noted that the application does not involve or in any way affect the "metro area's supply of campus industrial land." Moreover, the app lication has no effect upon Goal 10 (Housing), and has elsewhere demonstrated compliance with Goal 12 and other applicable statewide planning goals. My guess is that Ms. Segel and Nancy Falk, who appeared at the June 4 hearing and requested the written record be left open for a week, both vigorously oppose the Plan amendment/zone change proposed for the Marcola Meadows project, and are borrowing arguments to also object to this modest request before the City. The contention that the proposal would not result in a "logical and hannonious".land use pattern is without substance or basis in fact, and is not an approval criterion, As noted above and elsewhere in the record, this proposal is consistent with policies and provisions in the Metro Plan, its Economic Element, supporting refinement plans (i.e., the SCLS and MILS) to the Metro Plan, and Goal 9 and, other applicable statewide planning goals. On the basis of the record and arguments before you, we urge you to support the Staff recommendation and forward to the City Council your recommendation approving the pending applications. ... JiliP ~ arring~ n, reF Director, Land Use Planning & Development PeaceHealth Oregon Region cc: Jim Werfelmann Andrew Head Shaun Hyland 5-120