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<br />with the requirements of Division 9. <br /> <br />The applicant states that OAR 660-009-0010(4) does not apply because the proposed amendment <br />will remove less than two acres trom the commercial land supply. As stated above, subsection (4) <br />applies to removal or adding two or more acres and the proposed change in commercial designation <br />is in excess of two acres. Specifically, the amendment will re-designate approximately 7.3 acres to <br />Commercial and re-designate 1.3 acres of land from Commercial to Medium Density Residential. <br />Thereh)fe, the net amendments will increase the supply of available commercial land by 6.0 acres <br />for the purpose of facilitating the development ofa "mixed use center," therefore subsection (4) is <br />applicable. <br /> <br />In the context of OAR 660-009-001 0(4), the proposed change is not consistent with all parts of the <br />Metro Plan that address the requirements of OAR 660 Division 9 (option (a), above) as discussed <br />below. The Eugene Commercial Lands Study (ECLS) is acknowledged for compliance \-vith the <br />requirements of Goal 9 and its Administrative Rule. The EeLS constitutes the City's obligation <br />under OAR 660 Division 9. Currently, the City of Eugene has a surplus of commercial land. The <br />portion of the subject site south of Green Lane was part of the ECLS because it is designated <br />Commercial. Approximately 2 acres of the portion ofthe site north of Green Lane were also <br />included in the ECLS because those tax lots (300 and 400) \vere zoned for commercial use. The <br />remainder of the subject property (5.3 acres) was not included in the ECLS because it was neither <br />zoned nor designated as commercial. Below, the findings address consistency w-ith relevant policies <br />in the fCLS. <br /> <br />Promote redevelopment of existing commercial areas and compact, dense growth by <br />encouraging businesses to revitalize and reuse existing commercial sites. (Policy 6.0) <br /> <br />By its express terms, this policy does not constitute a mandatory approval criterion. However, as <br />addressed in context of Policies 8 and 22, the proposal would add new commercial on a vacant site <br />in an area that has already been determined to have adequate commercial land supply, rather than <br />redevelopment of an existing commercial site as encouraged. <br /> <br />Recognize the dtflering needs of residential areas in the various parts of the community. and <br />determine the need to create additional commercial sites in light ofopportunities/or <br />redevelopment. (Policy 8.0) <br /> <br />This policy does constitute a mandatory approval criterion to be addressed by an applicant. As <br />discussed below, the River-Road Santa Clara Subarea Policy 22 specifically states: "Recognize that <br />the commercial sites designated in the River Road/Santa Clara Urban Facilities Plan provide <br />adequate commercial supply for the area." <br /> <br />Concentrate development in existing commercial areas to minimize traffic impacts on the <br />rest of the city. (Policy 12.0) <br /> <br />Reduce congestion on commercially developed streets (strip commercial areas). (Po/i",y <br />13.0) <br /> <br />Staff Findings - O<::tober 8. 2007 <br />Page 5 <br />