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<br />OAR 660-009-0010(4) does not apply in this situation because the changes proposed by this <br />application will remove less than two acres from the supply of land designated for commercial <br />use. <br /> <br />GoallO - Housing: To provide for the housing needs of citizens of the state. <br /> <br />Response: <br />Goal 10 requires buildable lands for residential use to be inventoried and requires plans to <br />encourage the availability of adequate numbers of needed housing units at price ranges and rent <br />levels commensurate with the financial capabilities of Oregon households. Oregon <br />Administrative Rule 660, Division 8 defines standards for compliance 'with Goal 10. OAR 660- <br />008-0010 requires that: <br /> <br />"Sufficient buildable land shall be designated on the comprehensive plan map to sali,~fY <br />housing needs by type and density range as determined in the housing needs projection. <br />The local buildable lands inventory must document the amount of buildable land in each <br />residential plan designation. '.' <br /> <br />The comprehensive plan map for the City of Eugene is the Metro Plan Diagram. Approval of the <br />applicant's proposed amendments changing approximately 7.3 acres irom Low Density <br />Residential to Commercial and 1.3 acres from Commercial to Medium Density Residential on <br />the Metro Plan Diagram requires compliance with statewide planning Goal 10, Housing (OAR <br />660, Division 8). (The change will have a net effect of adding 6.0 acres to the commercial <br />designation while removing 7.3 acres of Low Density Residential and adding 1.3 acres of <br />Medium Density Residential.) The Post Acknowledgement Plan Amendment (PAPA) is <br />consistent with the parts of the Metro Plan which address the requirements of Goal 10, as will be <br />shown below. Using Metro area average densities of developed properties the table below shows <br />that the proposed impact of the amendments will be insignificant when considering a comparison <br />of the total number of likely dwelling units for the plan designation and! or zoning type. <br /> <br />Table 2: Proposal Impact on Potential Dwelling Unit Totals <br /> <br />Development - Average <br />Designation Density. <br />SFR . LOR 4.4 <br />MFR - MOR 23.2 <br />'" Metropolitan area du/ac on developed tax lots <br /> <br />Area Change <br />-7.3 <br />1.3 <br /> <br />Total Units <br />-32.1 <br />30.1 <br /> <br />The Eugene-Springfield Afetropolitan Area Residential Lands Study (RLS) was completed in <br />1999 as a technical document informing policy changes to the Metro Plan as part of the area's <br />periodic review requirements. The RLS was acknowledged by the state Land Conservation and <br />Development Commission as being consistent with Goal 10. The purpose of the RLS Vlas to <br />compare residential land needs with available land supply. The analysis does not require buildout <br />of particular densities or numbers of units on specific sites or within the metro area as a whole. <br />Information regarding the supply of residential land is supplemented by the adopted Goal 5 <br />inventory. rt includes an analysis of the new Goal 5 protections' impact on residential lands. It <br /> <br />Santa Clara - Metro Plan Amendment Application <br />Written Statement - August 2, 2007 <br /> <br />Page 13 of32 <br />