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HomeMy WebLinkAboutMiscellaneous APPLICANT 4/21/2004 . . FINDINGS OF FACT IN SUPPORT OF APPROVAL JP HAMMER INDUSTRIAL PARK METRO PLAN AMENDMENT CITY FILE NO. DATE: ,2005 Following are Findings of Fact Supporting Approval of JP Hammer's Request to Re- Designate on the Metro Plan General Diagram 6.2 Acres of Land from Heavy Industrial (HI) to Commercial (C): DECISION CRITERIA SDC Section 7.070(3) provides the criteria for approval of a plan amendment as follows: "(3) CRITERIA FOPR APPROVAL OF PLAN AMENDMENT Thefollowing 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. " Following is a discussion ofthe above decision criteria for a Metro Plan Amendment: "(a) The amendment must be consistent with the relevant statewide planning goals adopted by the Land Conservation and Development Commission; " Each applicable Statewide Planning Goal is addressed below: GOAL ]- CITIZEN INVOLVEMENT Section 7.080 of the SDC describes that plan amendments are subject to public hearings before the planning commission and City Council. This established City program ensures citizen involvement in land use related decisions in a manner which is consistent with state statutes and regulations and this Statewide Planning Goal. GOAL 2 - LAND USE PLANNING The City of Springfield's land use planning process is spelled out in the SDC and ensures consistency with the provisions of this goal in effecting any changes to a land use plan or implementing ordinance. This process is mandated in Section 7.080 of the SDC and is an integral component of the decision making process to which this application is subject. GOAL 3 -AGRICULTURAL LANDS This goal is not applicable to this application, as no agricultural lands as defined by state statute and rule are involved in the request. GOAL 4 - FOREST LANDS This goal is not applicable to this application, as no forest lands as defined by state statute and rule are involved in the request. . . ti / If ~oL{ _ Data RecelVetL ~ ,," Planner. -J D [ 0 fjJJ~~ . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 2 GOAL 5 - OPEN SPACES, SCENIC AND HISTORIC AREAS AND NATURAL RESOURCES Upon a review of the Eugene / Springfield Metro Plan; the Mid-Springfield Refinement Plan; the Draft Natural Resources Special Study; the US Fish and Wildlife Service's National Wetlands Inventory Map; the Draft Springfield Wetlands Inventory Map;and the list of Historic Landmarks, the consultant has discerned that there apparently are no inventoried natural resources or historic features on this site. Wetlands indicated on the National Wetlands Inventory were former log ponds which have been filled in compliance with local, state and federal regulations. This Statewide Planning Goal is not applicable to this request because none of the types of resources contemplated by the goal would be effected by the proposal. GOAL 6 - AIR, WATER AND LAND RESOURCES QUALITY This goal speaks primarily to responsibilities of local governments in adopting plans which facilitate the protection and monitoring of air and water resources. Among other provisions, the goal suggests physically separating land uses with conflicting or different impacts upon air and water quality. The specific wording of this part of the pertinent goal reads: "3. Plans should buffer and separate those land uses which create or lead to conflicting requirements and impacts upon the air, water and land resources." The plan diagram changes proposed herein are part of a larger, holistic master planning concept for the industrial park. Described in whole, that ultimate vision is for: A) Re-designation and re-zoning, from Heavy Industrial to (Community) Commercial, of about 6.2 acres of the subject property; B) Implementation of a car sales lot on the re-zoned parcels fronting on 42nd Street; and C) Re-zoning the smaller, westerly lots (5-8) from Heavy Industrial (HI) to Mixed Use Employment (MUE). The MUE Zone is consistent with the "Heavy Industrial" Metro Plan designation, so no plan amendment is necessary to accommodate this particular aspect of the proposal. The objective of Goal 6 to "buffer and separate those land uses which create or lead to conflicting requirements and impacts" would be promoted by the ultimate re-zoning of lots 5-8 from Heavy Industrial (HI) to Mixed Use Employment (MUE), a change which would decrease the interface between industrial-zoned lands in the existing park and adjacent residential uses to the immediate west (Adams Plat, First Addition). While this Metro.Plan Amendment does not directly affect Lots 5-8, approval of this application, and the subsequent re-zoning requests, would ultimately facilitate implementation of the applicant's master plan vision for the site. This would result in the removal of 5.31 acres of current industrial zoning from an area adjacent to residentially zoned property to the west. . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 3 The Mid Springfield Refinement Plan is rife with references to the incompatibility of industrial with residential uses, pointing specifically to past conflicts which have arisen in this portion of the City. Obviously, residential, commercial and industrial land uses are respectively on an uphill gradient with respect to demands for and impacts upon air, water and land resources. Speaking generally, industrial uses require greater land bases and more substantial commitment of other natural resources as compared with commercial uses, which in turn generally have more needs than single family residential uses. Likewise, impacts upon air and water quality can be seen to rise progressing from single family residential to commercial and through industrial types of development. Residences typically only affect air quality through either wood burning stoves or automobile trips associated with dwellings. Commercial developments can often have a.more significant adverse impact upon air quality due to the greater number of vehicles trips generally associated with those as compared with a residence, and increased emissions tied with those additional trips. Industrial development, however, can involve processing, burning and other activities which can more often result in externalities such as smoke, odor, noise, and ground and surface water contamination or pollution. Locating development with heightened environmental impacts, such as can be associated with many industrial land use types, adjacent to an established neighborhood increases the risk of adverse impacts upon the existing residential uses. The creation of a new MUE Zone in this location of the existing industrial park would be consistent with the above discussed objective of Goal 5 to "buffer and separate those land uses which create or lead to conflicting requirements and impacts upon the air, water and land resources" by eliminating the direct interface of industrial and residential lands and buffering these conflicting types of activities with intermittent office and other lesser-impacting commercial uses. GOAL 7 - AREAS SUBJECT TO NA TURAL DISEASTERS AND HAZARDS This property is not subject to any known or inventoried natural hazards which are site specific and do not apply region-wide. This proposal is consistent with this goal. GOAL 8 - RECREA TIONAL NEEDS In Springfield, the Willamalane Park and Recreation District manages recreation areas or facilities. This property is located in the city limits and is part of this recreation district. This proposed change would not affect recreation needs or facilities pertinent to the Mid-Springfield area. GOAL 9 - ECONOMIC DEVELOPMENT This proposal is in compliance with Goal 9 - Economic Development. Goal 9 requires that an adequate amount of commercial and industrial land be provided to meet projected needs through the planning period. . . Findings ofF act JP Hammer Metro Plan Amendment City of Springfield, June,2005 Page 4 In this case, industrial and commercial land needs anal yses identified the respective acreages of these lands needed to accommodate area growth projected through the years 2010 and 2015, respective I y. Upon a review of the 2000 Springfield Commercial Lands Study, SCLS and portions of Eugene Springfield Metro Area Industrial Lands Study (ILS), the following was discerned: . The ILS found a huge surplus of industrial-zoned land (between 2,432-2,954 acres of surplus) in the Metro area. This study concludes that about 650 to 1,172 acres of industrial land would be needed to accommodate market demands in the entire Metro area through the year 2010, but that the Springfield UGB alone at the time of that writing had over 700 acres (708.8 acres in '92) of developable industrial land. . In addition to the above, based on projected employment estimates, the SCLS states the ILS found that there was no future need or demand whatsoever for "Heavy Industrial" Zoned land in the Eugene Springfield metro area. . By comparison, the City has a substantial deficit of commercial land relative to its projected need. At an annual absorption rate of seventeen (17) acres per year, the SCLS found that 255 acres of commercial land will be needed to meet the City's demands through 2015. The SCLS indicates that at the time of that writing the City had just 97 acres of developable commercial land, including 12 acres of land which was considered as "redevelopable". This represents a very substantial deficit as compared with an identified need for 255 acres of viable and vacant commercial land. . The SCLS indicates that the associated Citizen Advisory Committee (CAe) noted that 255 acres was likely a conservative estimate of commercial land needs through 2015, based upon a "more recent" annual absorption rate, from 1995 1999, of 36 acres per year. Due to these observed increased rates of commercial growth, actual demands for developable commercially-zoned land in the Springfield UGB could easily surpass the 255 acre mark between the years 1995 and 2015 (the original planning period utilized in the SCLS). This means that the already very substantial deficit of vacant commercial land demonstrated in the preceding paragraph in reality could be significantly larger. . Not only did the SCLS conclude that the existing supply of vacant industrially-zoned land was adequate to meet projected needs through the planning period, the inventory did not even include the subject site as part of this vacant industrial land supply, since it was already committed to log ponds associated with a mill site. In short, the acreage proposed for re-designation from an industrial to a commercial plan designation was never intended or planned for use in meeting future industrial development needs of the City. . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 5 . Rezoning and re-designation were identified in the SCLS as desired methods for increasing the commercial land supply in Springfield's UGB. Any such actions must be appropriately supported by the necessary findings of a traffic analysis; an analysis of impacts on existing neighborhoods; and an analysis of other associated constraints. Impacts upon traffic of the proposed change are discussed in the applicant's Traffic Impact Study and under Goal 12, Transportation. As stated previously, this proposal represents one component of a larger master plan for this site involving re-zoning of just over six acres (Lots 9,11-13,15 & 16) from Heavy Industrial to Community Commercial, which change requires prior approval of a Metro Plan diagram amendment. An additional component of the plan involves applying to re- zone Lots 5-8 from Heavy Industrial to Mixed Use Employment (MUE), a designation which is consistent with the Heavy Industrial plan designation. This change would be proposed in conjunction with the future application for re-zoning Lots 9,11-13,15 & 16 to Community Commercial, in event of approval of the current request. This desired removal of about five acres of industrially-zoned land from an area adjacent to an established residential neighborhood would accrue positive impacts for the nearby residents. The conclusion that this would benefit the residential uses is sllPported by findings in this document discussing the subject refinement plan's policies concerning conflicts between industrial and residential zones in this area of town, specifically. Please see subsequent discussions of this applicant's narrative for additional details in this respect. . The SCLS also raised concern about the quality of developable parcels in commercial zoning, and concluded that the City has a lack of readily developable commercial lands to meet future demands. Parcels proposed for re-designation on the Metro and Refinement Plans, in order to facilitate subsequent application for re-zoning to Community Commercial, range in size from .38 to 1.68 acres in area. Approval would increase the diversity of commerciaIly-zoned parcel sizes in the UGB, in addition to adding much needed total acreage to the commercial lands inventory. . There is potential for future businesses at the J.P. Hammer Industrial Park to provide services to employees of adjacent and nearby businesses (e.g., Weyerhaeuser). Presently, no services or conveniences are available in this immediate area. Any such inter- connection of utility among land uses within or in proximity to the proposed industrial and business park would have the added benefit of reducing demand for automobile trips. . The parcels proposed for plan diagram amendment from Heavy Industrial to Commercial range from .38 acres to 1.68 acres in size. As such, they are more suited to a wide range of commercial uses than industrial uses, most of which generally will require or prefer much larger lot areas. . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 6 This plan amendment is consistent with the applicable economic development and diversity objectives of Goal 9. This proposal will provide much needed commercial land in a jurisdiction that has identified a substantial and severe deficit in their commercial lands inventory, and will simultaneously balance the City's land supply by removing from the inventory unneeded industrial land. As discussed above, this proposal would not have an adverse impact upon the City's ability to meet projected needs for industrial development because: A) A significant surplus of industrial zoned land exists in the Springfield UGB and greater metro area; B) The subject parcels are too small to generally be of utility as industrial zoned parcels; C) It has been determined that no Heavy Industrial zoned land is necessary for meeting the City's projected demands; and D) This proposal would not remove land from the supply which was considered by the ILS as vacant industrial land, since it was excluded from the inventory as either significantly constrained or developed, and was never anticipated to accommodate future industrial growth. GOAL 10-HOUSING This proposal will not impact the housing inventory, as no residential property or designations are applicable to this request. GOAL 11 - PUBLIC FACILITIES AND SERVICES This property is located within the city limits and is fully served with public facilities and services. As discussed, industrial uses typically have greater demands for, among other resources and facilities, water. Significant amounts of industrial development can place a burden on municipal water supplies and systems. Aside from the likelihood that less water intensive uses will typically locate in commercial and office related developments than in l)1any strictly industrial areas, suggesting that future water consumption may be decreased by the proposal, this proposal would have little or no impact upon other public facilities and services. GOAL 12 - TRANSPORTATION This plan amendment is consistent with Goal 12 - Transportation, and Oregon Administrative Rules (OAR) 660-0]2. Specifically: Conformance of any development on the site with the specific requirements of OAR 660-0]2- 0045(3)-(5) will appropriately be ensured at site plan review or prior to making application for building permit(s). Following is a discussion of aspects of this rule most pertinent to the current Plan Amendment request. . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 7 "660-012-0060 Plan and Land Use Regulation Amendments (1) Where an amendment to afunctional plan, an acknowledged comprehensive plan, or a land use regulation would significantly affect 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 with the identifiedfunction, capacity, and performance standards (e.g. level of service, volume to capacity ratio, etc.) of the facility. A plan or land use regulation amendment significantly affects a transportation facility if it would: (a) Change the functional classification of an existing or planned transportation facility (exclusive of correction of map errors in an adopted plan); (b) Change standards implementing afunctional classification system; or (c) As measured at the end of the planning period identified in the adopted transportation system plan: (A) Allow land uses or levels of development that would result in types or levels of travel or access that are inconsistent with the functional classification of an existing or planned transportation facility; (B) Reduce the performance of an existing or planned transportationfacility below the minimum acceptable performance standard identified in the TSP or comprehensive plan; or (C) Worsen the performance of an existing or planned transportation facility that is otherwise projected to perform below the minimum acceptable performance standard identified in the TSP or comprehensive plan. Access Engineering has prepared a detailed Traffic Impact Study (TIS) in support of this application, and that document is attached to this written statement. The TIS describes the foreseeable change in traffic impacts and patterns which would likely be associated with this change, and describes specific mitigation measures appropriate to address those. This proposal would not result in the types or degrees of impacts described in OAR 660-012- 0060(I)(c)(A)-(C), above. With implementation of the applicant's proposed mitigation plan, described in the attached Traffic Impact Study (TIS), this proposed plan amendment would maintain consistency with the functional classification of existing and planned transportation facilities in the vicinity and would not reduce the performance of any existing or planned transportation facility below the minimum acceptable performance standard identified in the Springfield TSP. . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 8 Finally, no existing or planned transportation facility which is currently projected to function below any identified minimum acceptable performance standard would be worsened under this proposal. Pages I and 2 of the TIS contain the following excerpted paragraphs describing the method for arriving at the applicant's proposed mitigation plan. That portion of the attached TIS reads: "An operational analysis of the study area for the PM peak hour in the horizon year 2020 was conducted assuming the TransPlan programmed projects are in place; 42nd Street improved to a three-lane urban standard, signalization of 42nd Street at Marcola Road, and signalization of 42nd Street at the Eugene-Springfield Hwy. Westbound Ramp intersection. The results of the analysis show that all study area intersections will operate . within the mobility standards of ODOT and the City of Springfield through 2020. A mitigation plan has been presented which would relieve the queuing problems at the closely spaced Olympic Street and E-S Hwy. EB Ramps intersections along 42nd Street. The mitigation plan would be required under the current plan and zoning, and would not require widening of 42nd Street beyond what is planned in TransPlan. The mitigation plan includes: Q) 42nd Street from 250 feet south of Olympic Street the E-S Hwy. WB Ramps - Utilizing the programmed 3-lane section, change the center-turn-lane to a northbound through lane and allow left-turns from this lane at Olympic Street and the E-S Hwy. EB Ramps intersections. Q) Provide protected-permitted left-turn phasing at those intersections, leading at Olympic and lagging at E-S Hwy. EB Ramps. North of the E-S Hwy. EB Ramps, the center lane would become a left-turn only lane approaching the E-S Hwy. WB Ramps intersection. Q) At 42nd and the E-S Hwy. EB Ramps - Provide an overlap phase on the existing single right-turn lane. Q) At 42nd and Olympic - Change the striping on the eastbound approach to a left-turn lane and a left+right-turn lane. Q) At 42nd and Industrial - Provide a traffic signal when warranted. These improvements provide additional capacity and storage at the study area intersections which would accommodate the development traffic from both the Current and Proposed Plans." . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 9 The applicant's TIS notes that the proposed mitigation plan is not primarily intended to address ODOT mobility standards (i.e., volume to capacity ratios) associated with existing or planned facilities in the area, but rather corrects an existing queuing problem based on the insufficient physical separation between Olympic Street and the freeway interchange to the north. (2) Where a local government determines that there would be a significant effect, compliance with section (1) shall be accomplished through one or a combination of the following: (a) Adopting measures that demonstrate allowed land uses are consistent with the planned function, capacity, and performance standards of the transportation facility. (b) Amending the TSP or comprehensive plan to provide transportation facilities, improvements or services adequate to support the proposed land uses consistent with the requirements of this division; such amendments shall include a funding plan or mechanism consistent with section (4) or include an amendment to the transportation finance plan so that the facility, improvement, or service will be provided by the end of the planning period. (c) Altering land use designations, densities, or design requirements to reduce demand for automobile travel and meet travel needs through other modes. (d) Amending the TSP to modify the plannedfunction, capacity or performance standards of the transportation facility. (e) Providing other measures as a condition of development or through a development agreement or similar funding method, including transportation system management measures, demand management or minor transportation improvements. Local governments shall as part of the amendment specify when measures or improvements provided pursuant to this subsection will be provided. This section is not applicable based on the information provided in response to subsection (l), above, that with implementation of the proposed mitigation plan, which consists of almost exclusively prior programmed public improvements, no significant effect on any existing or planned transportation facility is anticipated. (3) Notwithstanding sections (1) and (2) of this rule, a local government may approve an amendment that would significantly affect an existing transportation facility without assuring that the allowed land uses are consistent with the function, capacity and performance standards of the facility where: . . Findings of Fact , JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 10 (a) The facility is already performing below the minimum acceptable performance standard identified in the TSP or comprehensive plan on the date the amendment application is submitted; (b) In the absence of the amendment, planned transportation facilities, improvements and services as setforth in section (4) of this rule would not be adequate to achieve consistency with the identifiedfunction, capacity or performance standardfor that facility by the end of the planning period identified in the adopted TSP; (c) Development resulting from the amendment will, at a minimum, mitigate the impacts of the amendment in a manner that avoids further degradation to the performance of the facility by the time of the development through one or a combination oftrimsportation improvements or measures; (d) The amendment does not involve property located in an interchange area as defined in paragraph (4)(d)(C); and (e) For affected state highways, ODOT provides a written statement that the proposed funding and timing for the identified mitigation improvements or measures are, at a minimum, sufficient to avoidfurther degradation to the performance of the affected state highway However, if a local government provides the appropriate ODOT regional office with written notice of a proposed amendment in a manner that provides ODOT reasonable opportunity to submit a written statement into the record of the local government proceeding, and ODOT does not provide a written statement, then the local government may proceed with applying subsections (a) through (d) of this section The applicant's proposed mitigation plan would avoid significantly affecting any existing transportation facility, as described by this rule, so this subsection is not applicable. (4) Determinations under sections (1)-(3) of this rule shall be coordinated with affected transportation facility and service providers and other affected local governments, (a) In determining whether an amendment has a significant effect on an existing or planned transportation facility under subsection (l)(c) of this rule, local governments shall rely on existing transportation facilities and services and on the planned transportation facilities, improvements and services set forth in subsections (b) and (c) below. (b) Outside of interstate interchange a;eas, the following are considered planned facilities, improvements and services; . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page II (A) Transportation facilities, improvements or services that are funded for construction or implementation in the Statewide Transportation Improvement Program or a locally or regionally adopted transportation improvement program or capital improvement plan or program of a transportation service provider. (B) Transportation facilities, improvements or services that are authorized in a local transportation system plan and for which afunding plan or mechanism is in place or approved. These include, but are not limited to, transportation facilities, improvements or services for which: transportation systems development charge revenues are being collected; a local improvement district or reimbursement district has been established or will be established prior to development; a development agreement has been adopted; or conditions of approval to fund the improvement have been adopted. (C) Transportation facilities, improvements or services in a metropolitan planning organization (MPO) area that are part of the area'sfederally-approved, financially . constrained regional transportation system plan. (D) Improvements to state highways that are included as planned improvements in a regional or local transportation system plan or comprehensive plan whenODOT provides a written statement that the improvements are reasonably likely to be provided by the end of the planning period. (E) Improvements to regional and local roads, streets or other transportation facilities or services that are included as planned improvements in a regional or local transportation system plan or comprehensive plan when the local government(s) or transportation service provider(s) responsible for the facility, improvement or service provides a written statement that the facility, improvement or service is reasonably likely to be provided by the end of the planning period. (c) Within interstate interchange areas, the improvements included in (b)(A)-(C) are considered plannedfacilities, improvements and services, except where: (A) ODOT provides a written statement that the proposed funding and timing of mitigation measures are sufficient to avoid a significant adverse impact on the Interstate Highway system, then local governments may also rely on the improvements identified in paragraphs (b)(D) and (E) of this section; or (B) There is an adopted interchange area management plan, then local governments may also rely on the improvements identified in that plan and which are also identified in paragraphs (b)(D) and (E) of this section. The subject site is within an interstate interchange area but would not result, as stated, in a significant effect on an existing or planned transportation facility under subsection (l)( c) of this rule. There is no adopted interchange area management plan in effect for this area. . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June,2005 Page 12 (5) The presence of a transportation facility or improvement shall not be a basisfor an exception to allow residential, commercial, institutional or industrial development on rural lands under this division or OAR 660-004-0022 and 660-004-0028. This proposal does not involve any rural lands, and as such, this subsection is not applicable to the current request. (6) In determining whether proposed land uses would affect or be consistent with planned transportationfaGilities as provided in 0060(1) and (2), local governments shall give full credit for potential reduction in vehicle tripsfor uses located in mixed-use, pedestrian-friendly centers, and neighborhoods as provided in (a)-(d) below; (a) :4bsent adopted local standards or detailed information about the vehicle trip reduction benefits of mixed-use, pedestrian-friendly development, local governments shall assume that uses located within a mixed-use, pedestrian-friendly center, or neighborhood, will generate 10% fewer daily and peak hour trips than are specified in available published estimates, such as those provided by the Institute of Transportation Engineers (ITE) Trip Generation Manual that do not specifically account for the effects of mixed-use, pedestrian-friendly development. The 10% reduction allowed for by this section shall be available only if uses which rely solely on auto trips, such as gas stations, car washes, storagefacilities, and motels are prohibited, (b) Local governments shall use detailed or local information about the trip reduction benefits of mixed-use, pedestrian-friendly development where such iriformation is available and presented to the local government. Local governments may, based on such information, allow reductions greater than the 10% reduction required in (a); , (c) Where a local government assumes or estimates lower vehicle trip generation as provided in (a) or (b) above, it shall assure through conditions of approval, site plans, or approval standards that subsequent development approvals support the development of a mixed-use, pedestrian- friendly center or neighborhood and provide for on-site bike and pedestrian connectivity and access to transit as providedfor in 0045(3) and (4). The provision of on-site bike and pedestrian connectivity and access to transit may be acc'pmplished through application of acknowledged ordinance provisions which comply with 0045(3) and (4) or through conditions of approval or findings adopted with the plan amendment that assure compliance with these rule requirements at the time of development approval; and (d) The purpose of this section is to provide an incentive for the designation and implementation of pedestrian-friendly, mixed-use centers and neighborhoods by lowering the regulatory barriers to plan amendments which accomplish this type of development. The actual trip reduction benefits of mixed-use, pedestrian~friendly development will vary from case to case and may be somewhat higher or lower than presumed pursuant to (a) above. . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 13 The' Commission concludes that this assumption is warranted given general information about the expected effects of mixed-use, pedestrianfriendly development and its intent to encourage changes to plans and development patterns, Nothing in this section is intended to affixt the application (if provisions in local plans or ordinances which provide for the calculation or assessment of systems development charges or in preparing conformity determinations required , ' under the federal Clean Air Act Page 10 of the applicant's TIS begins with the following sentence: "Even though the proposed pial) amendments and zone change would result in a mixed-use development site, no adjustments are :madefor internal trips." In fact, although the proposal is for a controlled mix of commercial and.industrial uses, this does not appear to qualify as "mixed use" development under the transportation planning rule (OAR 660-012- 0060(8)), This section is not applicable to this proposaL (7) Amendments to acknowledged comprehensive plans and land use regulations which meet all of the criteria listed in (a)-(c) below shall include an amendment to the comprehensive plan, transportation system plan the adoption of a local street plan, access management plan, future street plan or other binding local transportation plan to provide for on-site alignment of streets or accessways with existing and planned arterial, collector, and local streets surrounding the site'as necessary to implement the requirements in Section 0020(2)(b) and Section 0045(3) (if this division: (a) The plan or land use regulation amendment results in designation of two or more acres of landfor commercial use; (b) The local government has not adopted a TSP or local street plan which complies with Section 0020(2)(b) or, in the Portland Metropolitan Area, has not complied with Metros requirement for street connectivity as contained in Title 6, Section 3 of the Urban Growth Management Functional Plan; and (c) The proposed amendment would significantly affict a transportation facility as provided in 0060(1). Although the proposed amendment would result in the designation of more than two acres of commercially-zoned land, the following two necessary criteria from this section (items (b) and (c), above) are not met. More specifically, the City of Springfield does have an adopted Transportation System Plan (TSP) and, as discussed above, the proposal would not significantly affect a transportation facility as provided in Subsection 0060(1), Based upon the above findings of fact, this proposal is considered as consistent with Oregon's Statewide Planning Goal 12. . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 14 GOAL 13 - ENERGY CONSERVATION The ultimate development of this property will rely on energy efficient building codes, fixtures and appliances. The configuration of access and internal streets, lot layout, and parcel orientation in this industrial and business park make the most efficient use of the existing transportation network, and facilitate substantial southerly exposure for maximum solar benefit, reducing heating and lighting costs for future and existing uses. GOAL 14 - URBANIZATION This property is existing urban land and is not subject to urbanization policies and procedures. GOAL 15 - WILLAMETTE RIVER GREENWAY The subject site is not located on or near the Willamette River. This Statewide Planning Goal is not applicable to this application. GOAL 16 - ESTUARINE RESOURCES This Goal is not applicable to this application. GOAL 17 - COASTAL SHORELANDS This Goal is not applicable to this application. GOAL 18-BEACHESANDDUNES This Goal is not applicable to this application. GOAL 19 - OCEAN RESOURCES This Goal is not applicable to this application. "(b) Adoption of the amendment must not make the Metro Plan internally inconsistent. " This section of the applicant's narrative discusses the applicable provisions of the Eugene / Springfield Metro Area General Plan, and is followed by a discussion ofthe Mid:Springfield Refinement Plan policies. CONSISTENCY WITH METRO PLAN This proposal is consistent with the Metro Plan. The Metro Plan's Economic Element finds that maintaining an adequate supply of vacant, buildable commercial and industrial lands is essential. The document, along with the Springfield Commercial Lands Study, also recognizes that the Eugene-Springfield metropolitan area must take advantage of and encourage further diversification of the area's economic activities and base. This metro plan amendment and zone challge would convert lands from Heavy Industrial, a classification whose supply is in significant overabundance and with no need for any land in that designation projected on the planning horizon, to Community Commercial, a classification whose supply in the Springfield UGB is in a state of significant deficit as compared with expected demands. Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 15 This change would bring more economic diversification, a compatible and efficient mix of land uses within a combined business and industrial park, and help the City move toward a better balance between land base needs and the available supply of land in the Springfield UGB. . . The following Policies and other components of the Eugene Springfield Metro Area General Plan appear most pertinent to this request: The discussion under Section III-B, Economic Element, is not a Finding, Objective, Goal or Policy, but an introductory statement which includes the following: "In striving toward LCDC's Statewide Economic Goal, "to diversifY and improve the economy of the State, " the Eugene-Springfield metropolitan area must take advantage of and encourage the further diversification of this area's economic activities and role as a regional center. " This change would facilitate subsequent application for zone changes as described herein, to effect a mixed business I industrial park, incorporating primarily office uses abutting the existing single family residential neighborhood; various industrial uses internally, consistent with the current plan for the park; and car sales along the site's frontage on 42nd Street. ECONOMIC FINDINGS Finding Number 1 of Section II-B reads: "1. The structure of the Eugene-Springfield metropolitan area economy is undergoing a shift away ji-om lumber and wood products manufacturing (and other heavy industrial activities) and towards a more diverse economic base characterized by growth in light manufacturing activities and non-manufacturing activities of trade, commercial and professional services, finance, insurance, and real estate. " In addition to supporting the above finding by facilitating more land area zoned to accommodate the economic growth sectors listed above, this proposal is consistent with the economic element of the refinement plan because it will increase the amount of commercial property in Springfield which is in short supply. Further, the Industrial Lands Study (ILS) found a 2,432-2,954 acre surplus of buildable industrial land. Based on projected employment estimates, the ILS found no need for Heavy Industrial land in the future. The ILS found that, "This supply exceeds the projected demand" (SCLS, 23). Further, City planning staff have indicated that the subject property was not counted as part of the ILS' metro-wide inventory of vacant industrial land since it was committed to log ponds at the time of that study's writing. According to the Springfield Commercial Land Study (SCLS), ".. .there will be a continuing need to provide commercial opportunities to serve the needs of Springfield's residents. ,. Finding 12 of this section notes that there are currently inefficient uses of the City's land resource base, and this proposal would address and improve on that situation by removing from industrial zoning six acres of land consisting of six narrowly-configured, small parcels with commercial-appropriate frontage on 42nd Street and Kathryn I 40th Street. . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 16 INDUSTRIAL AND COMMERCIAL FINDINGS Industrial Finding 4 ofthe Mid-Springfield Refinement Plan states "The lots in the Adams Plat are often too small to accommodate the needs of new industrial development." This also applies in particular to existing Lots 9, 11-13, 15 & 16 of the JP Hammer Industrial Park, which parcels are the subject ofthis plan amendment request, as well as Lots 5-8, which will be proposed for MUE zoning in the event of approval of the current application. These lots range in area between .38 and 1.68 acres. Also in the subject refinement plan is language under the heading "Criteria for Designating Commercial Land', item I, which reads: "Recognize the predominance of commercial strip development along Main Street and North 42nd by designating these areas for commercial use." Since these subject parcels are too small to be of realistic utility for most types of heavy industrial uses, as called for by the current plan, and because frontage on 42nd Street is considered to be an appropriate and desirable location for providing commercial services and uses, this proposal represents a more efficient use of the subject land resource. Objective II of this section supports the applicant's approach in this regard. Consistent with the intent of Finding 15 of this section, this proposal represents a thoughtfully designed and controlled mixing of commercial and industrial uses in such a manner as to remove an existing incompatible condition, in heavy industrial zoning west of 40th Street abutting single family residential zoning and uses across 39tll Street. This proposal would accommodate a future request on the part of the owner of the park to re- zone that sector of the site to Mixed Use Employment, which is consistent with the current Metro plan designation and would permit a wider variety of office and other lighter and non-industrial uses. This is considered as an appropriate graduation of intensity of uses, and the MUE district would thus constitute an effective and attractive buffer between Lot I O's future, heavy industrial activities, and the existing neighborhood to the west. Please refer to the attached Plan Amendment diagram for a graJ;hic illustration ofthis proposed protective measure for the existing residences west of 39 Street. ECONOMIC OBJECTIVES The above discussion is also intended to demonstrate this proposal's consistency with Objectives 7 and 12 of this section. ECONOMIC POLICIES Policy 6 states: "Increase the amount of undeveloped land zoned for light industrial and commercial uses correlating the effective supply in terms of"suitability and availability with the projections of" demand." As stated, this proposal would facilitate a subsequent increase in the amount of undeveloped land zoned for a wide range of lighter industrial and various commercial types of uses, commensurate with projected needs of the City of Springfield. . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 17 Please see also the attached correspondence from Mr. Jack Roberts, Executive Director of Lane Metro Partnership, stating his expectation of the high marketability and appropriateness of this proposal. Policy 12 reads: "Discourage future Metro 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," This proposal would not conflict with Policy 12 because the subject site was not identified as development ready or even vacant industrial land in the ILS, since it was simultaneously committed to industrial mill use and severely constrained to development by virtue of being in standing water cover at the time of the ILS' writing. Policy 16 states: "Utilize processes and localcontwls, which encourage retention of large parcels or consolidation of small parcels of industrially or commercially zoned land to facilitate their use or reuse in a comprehensive rather than piecemealfashion." This proposal would retain the largest existing heavy industrial parcels in their current zoning while simultaneously consolidating uses among five smalier lots currently zoned Heavy Industrial but ultimately proposed for commercial zoning. This achieves both of the ends identified in the above policy. This proposal retains those existing parcels which front on the Southern Pacific Railroad in an industrial designation, consistent with Policy 17. Approval of this action would help to address the present and future commercial development needs of the City, and is consistent with the stated economic elements and findings in the Metro Plan. ENVIRONMENTAL OBJECTIVES Section III-E, Environmental Design Element, includes an objective that states that the Community Commercial zone is appropriate next to mediinn and high density residential uses, and in fact that these may be "integrated into a single overall complex, local regulations permitting". This suggests that the proposed commercial designations are generally more compatible with residential uses which already occur in the vicinity than is the current plan of industrial, considering very differing statements which appear in the subject refinement plan concerning the interface of industrial with residential uses. TRANSPORTATION POLICIES Policy F.9, Transportation Element, reads as follows: . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, Z005 Page 18 "F9 Adopt by reference, as part of the Metro Plan, the 20-Year Capital Investment Actions project lists contained in TransPlan. Project timing and estimated costs are not adopted as policy. " This policy encourages the City to fully fund and realize those projects identified in the TransPlan, The identified TransPlan projects pertaining to this area would be necessary, as discussed in the attached TIS, under either the current or proposed plan for the subject site, Policy F, 15 states: "F 15 Motor vehicle level of service policy: 1. Use motor vehicle level of service standards to maintain acceptable and reliable performance on the roa~way system. These standards shall be usedfor: (a) Identifying capacity deficiencies on the roadway system. (b) Evaluating the impacts on roadways of amendments to transportation plans, acknowledged comprehensive plans and land-use regulations, pursuant to the TPR (OAR 660-012-0060). (c) Evaluating development applications for consistency with the land-use regulations of the applicable local government jurisdiction. " 2. 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. 3. Performance standards from the OHP shall be applied on state facilities in the Eugene- Springfield metropolitan area. " As stated, the TIS finds no conflicts or deficiencies in the current or proposed plans with respect to mobility or similar standards on the existing transportation network, the City's TSP, the TPR or applicable land use regulations. The mitigation plan proposed in the TIS primarily addresses an existing problem with cuing between Olympic and the 'interstate interchange area. All of the facilities in the area presently operate at or above level of service (LOS) D except the eastbound movements at the 4Znd Street and Eugene Springfield Hi~hway westbound (E-S Hwy. WB) ramps, which operates at LOS F; northbound left turns on 4Zn Street @ Marcola Road which operate at LOS E; and eastbound left turns at 4Znd Street and Industrial Avenue, LOS F. The tables on pages IZ and 13 of the TIS provide two pertinent pieces of information: a) That the LOS problems identified above will all be corrected by implementation of the subject TransPlan projects included as the applicant's mitigation plan; and b) That this proposed change would not impact or increase the severity ofthese existing conditions relative to the LOS of the transportation facilities in the area. . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 19 This proposal is consistent with this policy. Policies F .22 through F .24 state: "F 22 Construct and improve the region's bikeway system and provide bicycle system support facilities for both new development and redevelopment/expansion. F23 Require bikeways along new and reconstructed arterial and major collector streets. F24 Require bikeways to connect new development with nearby neighborhood activity centers and major destinations. " These policies encourage the City to complete bicycle oriented transportation improvement projects under the TransPlan and to require new development to likewise provide those amenities. During the subdivision phase for this industrial park, easements through the subject site were reserved to provide linkage with bicycle and pedestrian facilities to the east and northwest. Specifically, there is a bike path on the east side of 42nd Street and a bike lane in Olympic Street with which the proposed interior bicycle facilities will tie, to provide an integrated and interconnected system in this part of Mid-Springfield. Sidewalks also exist within and abutting the subject site. CONSISTENCY WITH THE MID SPRINGFIELD REFINEMENT PLAN The following findings and conclusions from the Mid-Springfield Refinement Plan appear most pertinent to this application: RESIDENTIAL FINDINGS Residential Finding 15 identifies that there are "conflicts between the residential uses in Mid- Springfield and Industrial and Commercial uses." , INDUSTRIAL FINDINGS Industrial Finding I states: "The mix of industrial and residential uses in the Adams Plat has resulted in conflicts between the uses". This proposal would work to remove the interface of four existing industrial parcels with the residential neighborhood to the west by supporting the applicant's master plan for this site, which ultimately calls for rezoning the subject lots from Heavy Industrial to Mixed Use Employment (MUE). That re-zoning request would follow shortly after approval of this plan designation amendment request. As discussed previously, Industrial Finding 4 states "The lots in the Adams Plat are often too small to accommodate the needs of new industrial development." . . Findings of Fact JP Hammer Metro Plan Amendment City of Springfield, June, 2005 Page 20 This applies in particular to existing Lots 9, II-B, 15 & 16 of the JP Hammer Industrial Park, which parcels are the subject ofthis plan amendment request, as well as Lots 5-8, which will be proposed for MUE zoning in the event of approval of the current application. All of the above parcels range in area between .38 and 1.68 acres each. INDUSTRIAL POLICIES Based upon the above facts and findings, this proposed action would provide clear and substantial support for Industrial Policy 7, which notes: "There is a need to reduce the conflicts which arise when Heavy Industrial uses locate adjacent to Residential uses." The plan's "Criteria for Designating Industrial Lane!' immediately follow the Industrial Policies in the plan, and reinforce the appropriateness and need for larger lots for industrial zoning, as opposed to those currently proposed for re-designation to commercial on the Metro Plan diagram. This section also directs the City to "Minimize areas where Industrial and Residential designations abut'.. The plan's "Criteria for Designating Commercial Lane!', immediately following the refinement plan's Commercial Policies, includes item 1, which reads: "Recognize the predominance of commercial strip development along Main Street and North 42nd by designating these areas for commercial use." This recognizes the appropriateness of commercial zoning specifically along North 42nd Street, the location of the proposed plan amendments from Heavy Industrial to Commercial. TRANSPORTATION POLICIES Transportation Policy 2 would be supported since transportation facilities have been previously approved and constructed specifically to serve the industrial and business park, and no corrimercial or industrial traffic will be routed onto any local or residential street(s). Transportation Policy 4 would be supported by the existence of sidewalks and an adequate right of ~ay adequate width on 40th Street / Industrial A venue for bicycle lanes within the park. CONCLUSION The ' applicant's written statements and supporting materials (graphic illustrations, attached excerpts of applicable City codes and plan language, and the Traffic Impact Study), demonstrate that.the subject proposal to amend the Metro plan diagram for 6.2 acres of existing Heavy Industrial designated land, to Commercial, is consistent with the applicable decision criteria. Specifically, it is consistent with Statewide Planning Goals 9, 12, and others which are applicable, and would not make the Metro Plan internally inconsistent. In fact, the proposal would make the diagram more consistent with the document by supporting enhanced oppgrtunities for commercial development and by removing unneeded industrial land from the City's land base inventory. 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