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<br />We find that the proposed use of the expansion area will provide a continued stable and long- <br />term source of sand and gravel aggregate material proximate to the Metro area market it serves. <br />From an energy conservation perspective, an aggregate mining site located within the Metro area <br />is highly preferable to a supply site located outside the Metro area which requires the <br />transporting of the material, processed or otherwise, to the Metro area for use. Approval of the <br />application would result in the establishment of a stable and long-term source of aggregate <br />material without an increase in energy consumption. <br /> <br />Therefore, we find that approval of the application would be consistent with the intent and <br />purpose of Goal 13. <br /> <br />Statewide Planning Goal 14 <br />To provide for an orderly and efficient transition from rural to <br />urban land use. <br /> <br />Only resource use is proposed for the site and no urban facilities or services, other than those <br />currently provided, are required to support that use. <br /> <br />To the extent that Goal 14 is applicable to this application, we find that approval of the <br />application would be consistent with its purpose and intent. <br /> <br />Statewide Planning Goal 15 <br />To protect, conserve, enhance and maintain the natural, scenic, <br />historical, agricultural, economic and recreational qualities of <br />lands along the Willamette River as the Willamette River <br />Greenway. <br /> <br />The subject property is not located within the Willamette River Greenway. Accordingly, <br />Goal 15 is not applicable. <br /> <br />Statewide Planning Goal 16, 17, 18, 19 <br />(Estuarine Resources, Coastal Shorelines, Beaches and Dunes, and Ocean Resources) <br /> <br />The subj ect property contains no estuarine resources, shorelines, beaches, dunes, or ocean <br />resources. Accordingly, Goals 16, 17, 18, and 19 are not applicable. <br /> <br />Adoption of the amendment must not make the Metro Plan <br />internally Inconsistent. <br />Neither the Eugene Code nor the Metro Plan has been amended to adopt procedures and <br />requirements consistent with the Goal 5 Rule for the consideration of PAPAs regarding the <br />designation of significant aggregate sites or specific criteria regarding the consideration of a <br />PAPA proposing to add a site to the Metro Plan's acknowledged list of significant aggregate <br />sites. Therefore, only the provisions of the Goal 5 Rule are directly applicable to Eugene's <br />consideration of this application. Metro Plan goals and policies and land use regulations of Lane <br />County and the City of Eugene are not applicable to this application. <br /> <br />The Land Use Board of Appeals has recently discussed OAR 660-023-0180's comprehensive <br />regulatory scheme that is intended to supersede local land use laws and policies. Based on <br />LUBA's decision in Eugene Sand and Gravel Inc. v. Lane County, 44 Or LUBA 50, rev 'd in <br />part on other grounds, 189 Or App 21, 74 P3d 1085 (2003), it appears that LUBA believes the <br />City is prohibited from considering or applying Metro plan policies that go beyond OAR 660- <br /> <br />Exhibit A to Ordinance 20413 - 31 <br />