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<br />designation to any other use designation, pursuant to a post acknowledgment plan amendment, it <br />must address all applicable planning requirements and (a) demonstrate that the proposed <br />amendment is consistent with the parts of its acknowledged comprehensive plan which address the <br />requirements of OAR 660 Division 9; or (b) amend its comprehensive plan to explain the proposed <br />amendment pursuant to OAR 660 Division 9; or (c) adopt a combination of (a) and (b) consistent <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 from the commercial land supply. The 1.3 acre portion of the <br />subject site south of Green Lane is an "other employment use designation" of Commercial in the <br />context of this requirement; however it is less than 2 acres, therefore subsection (4) is not <br />applicable. Further analysis of the Eugene Commercial Lands Study (ECLS) is provided under EC <br />9.7730(b) and is incorporated herein by reference. <br /> <br />Based on these findings, the proposal is consistent \vith Statewide Planning Goal 9. <br /> <br />Goal 10 - Housing: To provide for the housing needs of the citizens (~fthe state. <br /> <br />Goal 10 requires that communities plan for and maintain an inventory of buildable residential land <br />for needed housing units. The Administrative Rule for Statewide Planning Goal 10 (OAR 660 <br />Division 8) states that "the mix and density of needed housing is determined in the housing needs <br />projection. Sufficient buildable land shall be designated on the comprehensive plan map to satisfy <br />housing needs by type and density range as determined in the housing needs projection. The local <br />buildable lands inventory must document the amount of buildable land in each residential plan <br />designation." The comprehensive plan map for the City is the Metro Plan land use diagram. The <br />1999 Eugene-Springfield Metropolitan Area Residential Lands and Housing Study (RLS) is <br />acknowledged for compliance with the requirements of Goal 10 and its Administrative Rule. <br /> <br />There is not sufficient evidence to show that any p01tion of the subject property was included in the <br />RLS supply analysis. Regarding the portion of the property to the n01th of Green Lane, page 50 of <br />the RLS states that it was assumed that 32 percent of residential land would be used for all non- <br />residential uses, and that land used for non-residential uses, such as schools, were subtracted from <br />the available amount of buildable land. The site north of Green Lane has been up until recently <br />developed with the Santa Clara Elementary School, so it would have been subtracted from the <br />available buildable land supply. Regarding the portion of the site south of Green Lane, although <br />zoned as R-I, it is designated as Commercial and developed with a single-family residence and thus <br />not part of the inventory. As such, it is determined that the proposed amendments do not am~ct the <br />residential land supply because the subject property was not included in the RLS and therefore the <br />proposal is consistent with Goal 10. However, the applicant's responses (pages 13-15) are <br />incorporated herein by reference as demonstrating compliance with Goal lOin the event that it is <br />determined that the residential land supply is affected by the amendments because the subject <br />property was included in the RLS. <br /> <br />Should it be determined that Goal 10 analysis is needed, the following is noted. The portion of the <br />property north of Green Lane is designated as Low Density Residential on the Metro Plan. The <br />portion of the subject property south of Green Lane is designated as Commercial on the Metro Plan. <br /> <br />Findings- November 19.2007 <br />Page 5 <br />